NCD980602163_19971007_Warren County PCB Landfill_SERB C_PCB Working Group - Meeting Minutes-OCR

Joint Warren County/State PCB Landfill Working Group
draft October 7, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to order
at 6:45 P.M. Tuesday, October 7, 1997 by co-chair Dollie Burwell. The meeting was held at the office of
the Working Group. ·' .:~J
NEW BUSINESS
:::-\.: \jj.,s~:,r,7
\ ,\~~ 11 ;cQ~I
'' :" Ms. Burwell advised that the main purpose of this meeting was to discuss the public meeting schecll!l~cktc,1
November 1, 1997 and to discuss the noncompliance order issued against the State. She then'~sk~d if
anyone else had other items to be discussed. Ken Ferruccio stated that he thought we would get a review
of the comparative analysis report. It was agreed that the comparative analysis report would be given first,
followed by the response to the noncompliance order and then the discussion of the public meeting.
Comparative Analysis
Joel Hirschhorn reported on the comparative analysis. He advised that the report used the selection criteria
specified in the RFP. The RFP selection criteria are as follows:
1) The ability to meet Phase I performance criteria as demonstrated through Phase I test
data. For post-treatment solids the principal preliminary remediation goals were 20
ppb for total PCBs and 1 ppt for dioxin TEQ. The air emission performance goals
were 8x10·4 micrograms per cubic meter (ug/cm) for PCBs and 5xl0·8 ug/cm for
dioxin TEQ.
2) The quality of the Phase I test report.
3) The ability of the vendor to provide full-scale equipment at the Warren County PCB
Landfill site.
4) The ability of the vendor to provide a safe, reliable and cost-effective full scale application
of the selected technology at the Warren County Landfill. The RFP further clarified the
goals and objectives of the test. In addition to the meeting the performance criteria,
feasibility would also be determined by considering the safety of the technology, the rate of
detoxification, the cost per unit of detoxification and the reduction in long term potential for
environmental releases from residual of tl)_e-treatment process.
5) The quality and cost of the proposal for providing Phase II services.
Mr. Hirschhorn said that based on these criteria ETG Environmental, Inc. (ETG) comes out on top. In
almost all areas of the selection criteria ETG was judged superior to EcoLogic. He added that ETG has
a less complicated process that is less vulnerable to human error and therefore safer for the community.
Mr. Hirschhorn acfvised that EcoLogic has probably not met the stringent dioxin cleanup criteria used in
this project in previous projects. Adding that in an EPA report the thermal desorption unit "did not perform
to design specification" and the company "experienced material handling problems" and the company does
not seem to have been able to perform commercial projects at a profit, so may be experiencing uncertain
financial conditions. Based on this and other information the Science Advisors agree that ETG is the best
draft October 7, 1997 Meeting Minutes
Page 2
qualified company for receiving the Phase II contract.
Jim Warren said that this report is very helpful and includes the technical reasons for why ETG was chosen.
Deborah Ferruccio asked if the Working Group is at a point where a formal recommendation can be made
to the State. Mr. Hirschhorn replied yes.
Ken F erruccio said that in the report it was stated that the EcoLogic process was not as safe as ET G's
p(ocess .. When hydrogen is used there is greater vulnerability than when it is not used, said Mr. Hirschhorn.
The ETG process does not use hydrogen.
Mr. Warren made the motion to accept the recommendation by the Science Advisors. Ms. Burwell
amended the motion to include having the members polled due to the lack of a quorum and if any member
has questions that they are authorized to contact Mr. Hirschhorn. The motion was second with the
amendment.
Order of Noncompliance
Bill Meyer reported on the noncompliance order issued by EPA. He advised that a response is due to EPA
by November 28, 1997 and that the State would have one year to begin implementation of the actions
included in the response. Mr. Meyer said that the State will propose to EPA that they would like to do
some extensive monitoring so that would have constant water measurements. Patrick Barnes asked if the
water measurements will have a readout tape. Mr. Meyer responded that the weather station does have a
readout tape and ifit shows no increase in the water level there should be no problem with tying dewatering
with detoxification. ·
Ms. Burwell asked does the ETG process work better in wet or dry soil. Mr. Hirschhorn said that ETG
has addressed the water issue and concluded that it did not pose a problem. Mr. Barnes asked why would
not the water be pumped. If you don't pump the water it must be monitored intensively, said Mr. Meyer.
Mr. Barnes said that he feels that water in moving in and out and that no pumping it is an environmental
health risk. He added that from a technical prospective, the water should be removed. Mr. Hirschhorn
added that the question is not whether to remove the water, but when. The landfill should not be dewatered
until the legislature has given funding for the detoxification because dewatering will decrease the chances
of getting the funding said Mr. Hirschhorn. Mr. Meyer agreed that the question is when to dewater and
added that later will increase the option of detoxification. He continued by saying that it will take about
one (1) year to get the water in the landfill to a one foot level. Mr. Barnes agreed adding that the soil will
not yield the water that quickly, but hopefully the water can be removed faster than it is coming in.
Mr. Hirschhorn asked the State if they have thought about putting in a temporary liner? That is an option
said Mr. Meyer. He, Mr. Meyer, went on to say that we need to decide to pump or not to pump because
we must submit a plan to EPA. Mr. Meyer suggested that there is about six months before the General
Assembly convenes. In that time we can roll out a plastic liner, submit a full scale plan/design, implement
a RFP that will take three to four months and submit a design for a reconstructive top. Mr. Meyer said that
EPA may say that everything the State is doing is contingent upon getting funding for detoxification and
suppose the State does not supply the funding. This plan will be put in place if the funding is not obtained
said Mr. Meyer. He added to satisfy EPA requirements the State will purchase a pumping system to
determine the rate of release to the leachate collection system.
draft October 7, 1997 Meeting Minutes
Page 3
Ms. Burwell added that she believes that there will be detoxification, but that nothing is guaranteed. To
have a contingency plan will not hurt our efforts for detoxification. We must be responsible, but not closed
minded because we have a good case to submit to the legislature she said. Ms. Ferruccio said that the
responsibility factor is important; there was not pumping before because of the State's plan to spray the
water back over the landfill. She added that monitoring is going to show that the landfill is not a threat and
the $20 million will not come ifthere is no risk. Ms. Burwell said that it is better to go to EPA with a plan
than for EPA to tell the State what must be done. Mr. Warren agreed and stated that this discussion should
continue when more of the members are present to express their opinions.
Mr. Hirschhorn then made a point about the health risks. He noted that water is leaving the landfill but
there is no evidence that it poses a health risk. He added that the real health risk is from PCB air emissions.
If we do not get funding for detoxification then the landfill must come into compliance he said.
Ms. Burwell recommended that Bill Meyer put his response to the noncompliance order in writing so that
the Working Group can review it before it is submitted.
Mr. Barnes added that because we did not detect sufficient discharges does not mean they are not present.
To not make an immediate move to dewater the landfill would be irresponsible and the actual removal will
take some time. Mr. Barnes continued by saying that the water that is leaving the landfill is taking
contaminates with it and we do not know what the resulting health risks are. He said as Advisor to the
Working Group he suggests that we move quickly toward dewatering; the RFP process will buy some time,
but should not be used as a delay.
Mr. Hirschhorn added that even with detoxification the water will have to be pumped. However, there is
no immediate rush to dewater the landfill he said .
Mr. Warren said that we want to be responsible and we must make sure that the timing will not jeopardize
the bigger picture of detoxification.
After additional discussion the Working Group agreed with asuggestion made by Mr. Warren, that the
State should prepare a proposal in time to be reviewed by the Science Advisors before being submitted to
EPA. Afterwhich additional discussion can continue if needed.
Public Meeting
The Working Group agreed that the public meeting would be held Saturday, November 1, 1997 at the
Warren County Courthouse at I p.m.. Ms. Burwell asked Mr. Barnes to fax some ideas to the office. It
was agreed that letters of invitation would be sent to local and surrounding counties elected officials and
would include questions that will be answered at the public meeting. The Science Advisors, the co-chair(s),
the State, and the representative(s) from ETG will make presentations. Mr. Hirschhorn advised that he
would be working with ETG on their presentation. Ms. Burwell appointed Ms. Holcomb to be on the
committee for the public meeting. Holcomb advised that she and the secretary would get assistance from
other members or the Working Group.
ADJOURNMENT
The meeting was adjourned at 9 p.m. and the next meeting was scheduled for November 12, 1997 at 6:30
p.m ..
FROl1 91971~360~ SOLID WASTE DIU
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Jam Els B: Hunt, Jr,, Governor
Wayr\e · cDevltt, S cret8ry
WIiiiam · . Meyer; D ector
DUM:
TO: WA
FROM:
SUB)EC:
Npvember 3, 1997
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·i
OUP, SCIENCE ADVISORS
you are aw e, the Division of ~'aste Management is required by the EPA a!I a
fthe permit or the PCB landfill to conduct semt-aruiu~ mo~itoring of the landfill.
The first art of the tes ng for this year W$s done during the Site Investigation Work which
started (o site) in Feb l!U'}',
ng a crew out to tl)e landfill within the next two to three weeks to do the
I
second ro nd of sampli g. I em enclosing' tho sampling locations we plan to use, and you v,.ill
note that e have adde additional polnts, :specifically six of the monitoring wells installed this • I
sprlng'Wh·ch are clo•es to the Jandflll. '
Th testine req1 r-ement caJls for P~B's, specific conductance, pH and temperature. ,
Copy: 'Bil Meyer
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Rose
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November S, 1997
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MEMORANDUM:
TO: JOEL rilRSCHHORN
PATRICK BARNE
FROIY1: MIKE KELLY
SUBJECT: MEETING WITH ETO
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FAX FAX
' I have spoken with Steve Detwiller wit~ ETG in reaard to: a meeti g with
them on Phase II. We tentatively agreed to Nqvember 1'4 th at lOrOO am lre in
Raleigh. Since there is a Working Group Mee1ting that night 6j30, I fel this
would be a good time since you all would be ip town for that e♦ting. T e l Oam
time should give everyone time to arrive that porning.
. Steve indicated that he would contact l<fF Kaiser and l tbem kno}. They
need to visit the landfill, and could do that Tutsday afternoon and Wedn9sday,
although Steve indicated that if they go up on,1Wednesday, w wpuld not really be
needed. . · .,,-I
Please \et me know if this is OK with y~u. I
Thanks. .
COPY: WORKING GROUP
BILL MEYER
HENRY LANCASTER
91;: 11 i. E-61 · ,;;0 · 11 ,. 010 31S~M OllOS 1;09£~1L6l6 WO~j
t~O1J-12-97 20: 41 NC WflRN TEL:[phone]
2009 Chapel Hill Roect
P.O. Bo• 61051
Oumam. NC 27715-t0SI
1''10119: (1119) 490•0747 faJC: (919) 4!!;3-6614
E•Mail ·.o,adress: NC•WAANOPOSOX.COM
. '
MEMO
November n, 1997
To: Wurkiug Group & Science Advisors
From: Jim Warren
Subject:. Pleate read prior lo meeting
A few thoughts and request for 1t 1,;uuple of things on the agenda for Tue~tlay.
First, I want to thank all of you for R successful community meeting. I also suggest ,vo send a
formal thanks to Dr. Purcell for doing an excellent job with guou spirit; she's a strong ally
For the upcoming Working Group meeting, I ask that we allow sufficient time to discus8 the
future roles of Patrick and Joel. In particular, l 'm not clear on whether we have decided whether
Joel's contract continues in 1998. We heard from Mike Kelly that we have $25 ,000 saved from
hiring ETG for Phase Tl so we need to look at how to budget our finite resourc.;e~ a!! we pursue
continued
0
funding for the Working Group itself along with Doris and the facilities.
(At this point in particular, I think the WG should be closely apprised of our resources; to that
end, 1 request that DWM bring a current accounting of WG finances .)
I do not yet know what are all the -scientific duties 1md support we' 11 need in the near and
intennediate future, although I have several thoughts on this. I hope we can discuss this fu !ly on
Tuesday so we can best plan and coordinate our t\Ctivities on various fronts. I suggest we l!iy out
!l writlen. evulvin~ (imdine for lhe next ~ighL monlhs; T for one would appreciate a visual image
as we discuss our approach and activities.
I feel that ~e would be making a grave mistake to not continue utilizing both scientists to the
degree neu:ssary to emmre our btst shot to obtain funding for detoxification. They have both
done an excellent Job for us and are. a vital part of the team. You don't unhitch one of your two
hones just shy of the mountain top.
Pat has the lead on the community building aspect; J think Joel could be helpful in supp01i of that
task. A bigger questio.n for me is getting the funding from the state. Although I'm no expert on
the legislature, I do know we will have to make a very strong case to-some committees and
probably.some individuals ---wilh Stn. Ballance's guidance and assistance I hope. ·
We wiU need both Pat and Joel for this work in order to fully support the senator's efforts. We
already know there are state· challenges about the failure of the dump. Since we have consistently
P :02
Advisory Boan!: Dr. F'aul Connen • !:nan Connett• Fat Cos1ner •Dr.Gerald Drake • Bi lie Elmore • Atv. Isaiah >.h'3ison • Wiaiam San1our • Ptt\lr Macbowet:
llOU--1C:-97 20 : ,41 t4C WARt~ TEL: [phone]
chosen to de-emphasize failure and focus on feasibility, it makes sense to gird ourselves as
strongly as possible for the feasibility seliing points, especially since the technology, our choosing
ofit, and its price tag will certainly be crucial elements of interest and likely chalknge fl-om
le~islstors, oLher delo~ companies 11ml other.s. Jud is uur te<;hnulogy ex.p~rt and it would seem
unwise to proceed without him.
Folks, getting $25 million from the state of North Carolina will be a monumental effort. We must
have every resource available to have a reasonable chance of succeeding. We heard Sen. Ballance
-·· nothing'~ certain in the political world. We mu:st do everything we can to support his efforts.
Sad as it is, there are many in the state government who continue to undervalue the good pe.op1e
of Warren County.
Although I haven't yet talked with any of you about this, I feel very strongly that these are
important ---even vital ---decisions for the success of our project and for helping this
community.
I look forward tu maximizing our efforts h1unch~d 11t the community meeting
* Can the citizeru llll<l iscience 1ttlvi~ors please meet I hour prior tu the main meeting at trus veiy
important time and discuss upcoming community strategies? Or have a conference call earlier
Monday? (not as good economically)
F':03
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~ MEETING REMINDER
The Joint Warren County/State PCB
Landfill Working Group will meet
· Tuesday, October 7, 1997
at 6:30 p.m.
at the Warren County Office.
Joint Warren County/State PCB Landfill Working Group
draft September 22, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:30 P.M. Monday, September 22, 1997 by co-chair Henry Lancaster. The meeting was held
at the office of the Working Group.
NEW BUSINESS
Triangle Environme11tal, Inc. Letter
Mr. Lancaster called for discussion on the letter sent to the Working Group by Triangle
Environmental, Inc. (Triangle). Joel Hirschhorn began the discussion by saying that he sent a letter
to Triangle (See Attachment) and phoned them. He added that he was not impressed with what he
learned and that he did not see any bases for honoring their request. Mr. Hirschhorn said that he feels
sure that the Triangle's technology has not been tested full scale.
Deborah Ferruccio added that material for testing cannot be requested under the Freedom of
Information Act. She concluded by saying that what would keep other companies from requesting
material to sample. She recommended that a letter be sent to Triangle to advise them that the process
is closed.
Daria Holcomb asked what could be requested under the Freedom oflnformation Act. Mr. Lancaster
responded information only.
Tommy Cline suggested that a letter be sent to Triangle saying that you did not respond to the RFP
within the time allotted, however if the process is reopened then we will contact them. This statement
became a motion and was seconded by Jim Warren and carried.
UNFINISHED BUSINESS
Site Investigation Report
The site investigation report was given by Patrick Barnes with assistance from Mr. Hirschhorn.
Mr. Lancaster noted that the report was marked draft and asked what is needed to make this report
final . Mr. Barnes said if something is not clear in the report or if something has been left out, these
things would be corrected. That would make the report final. Mr. Lancaster asked Mr. Barnes to
summarize the document and then there would be time for questions. He, Mr. Barnes began my
explaining the goal of the investigation, which was included in the executive summary, the first
section of the report. The second section dealt with reviewing the files and learning what was in the
files and what was not. Section three dealt with the. procedure followed. He explained that the
sampling plan was followed with a few modifications. Section four dealt with the analysis of the
field-testing results. This section discusses the regional geology, site strata distribution, soil
permeability and groundwater flow. It continues with landfill soils/wastes, leachate, offsite
groundwater, offsite surface water, offsite soils and sediments. It concludes with air testing for
PCBs, landfill_integrity, _top liner, water in the landfill, the bottom liner, and the Richardson report.
draft September 22, 1997 Meeting Minutes
Page 2
During this discussion, Mr. Hirschhorn noted that there are different concentrations of wastes in the
landfill. He added that during cleanup this could cause some engineering problems. Mr. Barnes said
that there are some variations in concentrations but they are not extreme. Next discussed was the
presence of a dioxin not usually found in PCBs, 2,3,7,8 dioxin. This may indicate that there is
something in the landfill other than ordinary PCB said Mr. Hirschhorn. He added that 2,3 , 7,8 was
also found in a sample that Eco-Logic tested. Ms. Ferruccio added that she remembers newspaper
articles that said that a higher form of PCB came from Fort Bragg. She asked the state if there are
any records of what came from Fort Bragg. There is no information in the files on what came from
Fort Bragg said Mr. Hirschhorn. The Working Group has requested this information from Fort
Bragg, but at this time they have not responded to that request.
Air emission was discussed next. Mr. Hirschhorn stated that air testing takes several weeks. He
added that most of the air releases have already occurred. However, there was one sample close to
the main vent that had a very high concentration of PCBs. Dollie Burwell said if most air emissions
have already occurred, is there no way to make a correlation to what is happening now. Mr.
Hirschhorn said there is not enough data to make a correlation. He added that the air emissions now
are "bulging and burping," not a steady flow. Ms. Ferruccio said that years ago EPA found air
emissions and recommended that air monitoring be done. Why did the State not follow that
recommendation? Mike Kelly advised that the State did some testing over a period and found no
emissions, so it was decided not to continue the testing. The air emission was high enough to require
regular monitoring and will be add to the recommendations said Mr. Barnes. Dennis Retzlaff asked
the Science Advisors if they could give a worse case scenario of the health effects of PCB air
emissions. Mr. Hirschhorn responded that there are so many perimeters to consider and there are
standard ways to quantify. He added that a health study should include the people who lived closest
to landfill at the time it was installed, they would be most impacted.
During the discussion of the landfill integrity, Mr. Kelly said that there needs to be more discussion
included on the top liner. Mr. Warren added that information on the clay liner should be included as
well. Mr. Barnes agreed to include additional information about the top liner and the clay liner.
Section five, of the' report, is the conclusion section; Mr. Barnes and Mr. Hirschhorn conclude that:
1) There are significant levels of PCBs and dioxins/furans in the landfill and the
concentrations vary.
2) There is no evidence of off-site contamination in surface waters, sediments,
groundwater or soil.
3) There is evidence suggesting some limited impact of the landfill on subsurface
materials immediately outside the landfill.
4) Contamination was found in two (2) groundwater wells, which indicates some failure
of the containment system.
5) _Water is entering and leaving the landfill and taking some contaminates with it.
6) There is loss of containment efficiency in the landfill's top liner.
7) There have been releases of PCBs into the air.
draft September 22, 1997 Meeting Minutes
Page 3
The last section of the report is the recommendations; the Science Advisors recommend the
following:
1) Additional testing, especially of material beneath the landfill. This would determine
the full extent of contamination outside the landfill that may need detoxification.
2) The Phase II contractor should use a contingency figure of an additional 25% of
material that may need to be detoxified.
3) The Phase II contractor should consider different cleanup standards for PCBs and
dioxins.
4) The Phase II contractor should be made aware of the varying chemical composition
of materials in the landfill. This could require blending of materials or a design
to handle maximum possible concentrations of contaminates.
5) In response to EPA requirements for regulatory compliance, the State should
determine if actions they take are effective in removing water trapped in the landfill.
6) Volumes of water extracted from the landfill should be analyzed to determine the
extent to which the leachate collection system needs repair.
After the report was complete it was agreed to give the members two (2) weeks to comment. The
Science Advisors should receive comments by October 6, 1997 and a final report produced by
October 20, 1997.
Technology Assessment and Selection Criteria
Mr. Hirschhorn began by saying that the criteria for selection were developed in the RFP. Mr. Barnes
added that he put together a scoring system based on those criteria. Ms. Burwell said that this is not
the detailed criteria. It is the legal criteria said Mr. Hirschhorn. After discussion it was decided to
wait to make the final recommendation after all the questions submitted to both companies have
received a response. Mr. Hirschhorn agreed to take the lead on a final report which will include a
narrative and a comparative analysis. A draft will be prepared by October 3, 1997 if all information
is received by Wednesday, September 24, 1997.
Legislative Session
Mr. Lancaster advised that they were not successful in getting the additional funds ($125,000.00) to
meet the Science Advisors needs. He will be meeting witQ Secretary McDevitt to see if the funds are
available to come from within the Department if Environment, Health and Natural Resources.
Other Business
First, Mr. Hirschhorn raised the issue of a request from Mike Kelly to shorten the time given for the
Phase II report.-He advised that originally the company was given seventy-five (75) days to produce
the report and now it has been reduced to thirty (30) days. Mr. Kelly responded saying that when
draft September 22, 1997 Meeting Minutes
Page 4
the contract is awarded, the company will be asked if they can produce the report in thirty (30) days.
They are not being told that they must produce the report in thirty (30) days. If the company does
not agreed, then the State would adjust accordingly. He explained that this is an effort to expedite
the process since the State has been accused of delaying the process. After discussion it was agreed
that Mr. Kelly could discuss this with the company.
Next, the Working Group was advised of a letter received from Eco -Logic announcing an open
house they have planned for October 2, 1997. After discussion Mr. Cline made a motion to send a
letter to Eco-Logic to encourage them to come when the Working Group holds it public meeting, if
they are the company chosen for the detoxification. The motion was seconded and carried. Mr. Kelly
agreed to send the letter from the State and the Working Group.
Ms. Ferruccio asked when is the Working Group going to be reconstituted. It was motioned by Ms.
Ferruccio and second by Mr. Retzlaff to send a letter to Secretary McDevitt asking him to
reconstitute the Working Group as soon as possible. The motion carried.
The last item discussed was a date for a public meeting. After discussion it was decided to have the
public meeting on November 1, 1997 with an alternative date of November 8, 1997. Details of the
public meeting will be discussed at the next Working Group meeting.
ADJOURNMENT
The next meeting is scheduled for Tuesday, October 7, 1997 at 6:30 P.M .. Ms. Burwell asked Mr.
Kelly to see if Bill Meyer can attend the next meeting to address the issue of noncompliance. The
meeting was adjourned at 9:45 P.M ..
HIRSCHHORN
@,d?JASSOCIATES ~ A Division of Hygienetics Environmental Services, Inc.
ATTACHMENT
Suite 411
21101 Bluericlge Avenue
Wheaton, MD 20902
September 22, 1997 ............................................................................... by FAX
To: C. Thomas Hendrickson
From: Joel Hirschhorn
Phone: [phone]
f.,x: [phone]
Re: Request by Triangle Environmental to test materials from Warren County PCB Landfill
I am writing to you in my capacity as a Science Advisor for the Joint Warren Cow1ty/State PCB
Landfill Working Group, and because I have just received a copy of your 15 September letter to
Ms. Burwell and Mr. Lancaster.
I have played a major role in the work on cleanup technology assessment and activities for our
project. I would very much appreciate it if you would fax me as much material as you possibly
can that would provide information on the following points:
( 1. At the pre-bid meeting in Raleigh on February 17, 1997 for the bench-scale detoxification
'----technology testing RFP a Lyle Hunnicutt attended. Did that person have some relationship to
your company and the two technologies mentioned in your letter?
2. Can you provide any detailed technical data for the two technologies mentioned in your letter
on their effectiveness in removing and destroying both PCBs and dioxins/furans from soil
matrices?
3. Can you provide any infonnation on exactly where both technologies have been used full-scale
for actual remediation projects and, particularly, whether any of those projects included work on
PCBs and dioxins/furans? If there are such projects, would you be able to supply detailed reports
on how both technologies performed?
4. Notliing in your letter indicates that you would follow the exact protocol and requirements
established in the RFP for the bench-scale testing, which two other companies have complied
with. Are you suggesting that you are familiar with the RFP and would follow the protocol and
requirements, even though your company would bear all costs?
The \Vorking Group is having a meeting this evening and, therefore, I request that you fax
the requested materials to my attention at the \Vorking Group's office in Warrenton as
soon as possible and hopefully before the close of business today; the fax number there is
919 257-1000. I expect to be in the Warrenton office by about 4:00 PM and the phone
number there is 919 257-1948,
3-01-1997 10 .02PM FROt.1
COI\1PARATIVE EVALUATION OF THE TWO PHASE I
REPORTS ON DETOXIFICATION TECHNOLOGY TESTING
OF MATERIALS FROM THE WARREN COUNTY, NORTH
CAROLINA PCB LANDFILL
Prepared by:
Joel S. Hirschhorn, Ph.D ., Hirschhorn & Associates
in association with
Patrick A Barnes, P.G., BFA Environmental, Inc.
October 1, 1997
1.0 Introduction
In response to a Request for Proposals to evaluate treatment technologies on soils
extracted from the PCB Landfill. Warren County, North Carolina, i&SUed by the Division of Waste
Management ofDENR on January 31, 1997, two proposals were selected for funding. The Rfp
had clearly identified two detoxification technologies as meeting the requirements established by
the Joint State/Warren County Working Group; these were Base Catalyzed Dechlorination (BCD)
and Gas Phase Chemical Reduction. The RFP notified potential proposers that the project was
divided into two phases and that nmltiple companies might be chosen for Phase I, but that only
oue company would be awarded a contract for Phase II.
Section 2. 1.4 of the RFP specified the following selection c1iteria for choosing one
company for the Phase Il part of the RFP:
a. The ability to meet Phase I performance criteria as demonstrated through Phase I
test data. The performance criteria were presented in Section 2.5 oftbe RFP. For post-
treatment solids the Principal Preliminary Remediation Goals were 20 ppb for total PCBs
and l ppt for Dioxin TEQ. The Air Emission Performance Goals were 8x:l 0--1 micrograms
per cubic meter (ugicm) for PCB& and 5x10•K ug/cm for Dioxin TEQ.
b. The quality of the Phase I test repon.
c. -The ability of the vendor to provide full-scale equipment at the Wanen County
PCB Landfill site.
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d. The ability of the vendor to provide a safe, reliable and cost-effective full scale
application of the selected technology at the Wa1Ten Cowity Landfill. Section 2.2 of the
RFP further clarified the goals and objectives of the testing, particularly in teIDIS of
determining feasibility for full-scale detoxification and that, in addition to the meeting the
perfonm.uce criteria, feasibility would also be determined by considering the safety of the
technology, the rate of detoxification, the cost per unit of detoxification, the reduction in
long term potential for enviroD.Dlental releases from residuals of the treatment prnce.ss.
e. The quality and cost of the proposal for providing Phase ll services.
This report by the two Science Advi~ors for the Working Group is the comJ>arative
evaluation of the two Phase I reports submitted in this project and is provided to the Working
Group aud the Division of Waste Management for the pwpose of assisting with the selection of
the Phase ll contractor. All reports and responses to questions submitted by the two compllllies,
ETG Environmental, Inc. (ETG) and ELI Eco Logic Inte:mational Inc. (EL), have been
considered in preparing this report. The format is to present a discussion of the relative pros and
c.ous, or advantages and disadvantages, of each company's proposed technology for each of the
above selection criteria. Finally, a summary comparison and recommendation is preserited in the
last section.
2.0 .1\leeting the performance criteria
2. I Post-treatment solids -total PCBs
ETG conducted four test runs and in all four cases the total PCBs were reduced to levels
Je~ than 20 ppb. The average of the four runs was 0.8 ppb. A consideration is the variatiou in
PCB levels in the iuput (raw feedstock) materials, which u1 this case averaged 506 ppm. Because
nondetects (NDs) are often reported, detection limits are also a factor jn evaluating results. In
comparing two the companies the isrue that arises is ifNDs are reported but the detection limits
(DLs) are diffexe.nt, then the NDs are not exactly the same. With higher DLs the NDs RJe less
impressive, because the potential level of undetected PCBs is higher. Another way oflooking at
this issue is to realize th.at with lower DLs it is possible to have positive hits or findings of PC.8
isomers while if higher DLs were used, then those findings .would not be present.
EL conducted three tes.t runs and reported NDs for all three results; however, the DLs
were significantly higher than in the ETG testing, primarily because smaller size samples were
used in the EL testing (i.e., 0.010 kg versus 0.030 kg.for ETG). The only scientific way to h~ter
compare the two sets oftest data, therefore. is to recalculate the total PCB levels by using the
worst possible case in which it is assumed that the NDs are actually equal to the DLs. This has
been done and the recalculated levels for both companies' data are given in the foUo,ving table by
using tbe data given in the respective reports. It can be seen that by following this procedure, that
the recalculated average for ETG increases to 1.84 ppb and for EL the average changes from
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what might be interpreted as zero to 3.63 ppb. Thus, while it is correct to say that both
companies were able to meet the pe.rfonnaoce criterion, it is also correct to conclude that ETG
performed better than EL, particulady because ETG conducted four runs while EL presented data
for three rans. Additionally, the average PCB level in the raw materials tested \\'as 237 ppm for
EL but 385 ppm for ETG, ·which makes the ETG resuJts even more significant, because a higher
fraction of PCBs were removed.
Company/sample Original total PCBs (ppb) Recalculated total PCBs (pph)
ETG WCl-3 .74 1.33
ETGWCl-4 1.55 3.06
ETGWC2-3 O(ND) 1.80
ETGWC2-4 o (ND) 1.18
ETG average 0.8 1.84
EL 1 0 (ND) 4.10
EL2 O(ND) 3.40
EL3 o (ND) 3.40
EL average 0 (ND) 3.63
2.2 Post-treatment solids -dioxin TEQ
ETG reported data for four runs, with an average dioxin TEQ of 0. 91 ppt, however one of
the runs bad a ·value of 2. 96 ppt, but this ·was for the sample '"'"ith the highest level of PCDs. fo
fact, ETG had optimized its process based on a much lower level of chemical treatment (BCD)
admtive, which would explain why in this one run both the PCB and dioxin TEQ J._,vels were the
highest in the residual treated solids. In fact , the TEQs for the other three runs were exceptionally
low, with an average of about .23 ppt, which is insignificimt. It should also be noted that even the
2. 96 ppt level is very low and that EPA and most states have not approached this level for dioxin
cleanups. For examp.1e, for the Koppers Superfund site cleanup in Morrisville, North Carolina the
dioxin cleanup level was 7,000 ppt.
EL reported data for three runs. However, the dioxin analy~e~ we.re rerlouc for nius l aud
3, but not run 2, because of overly high detection limits in the original testing. Also, some dioxins
were originally found in run 2 mat~ despite high detection levels, because of bjgh dio,cin levels
that resulted from run 2 representing a process failure due to too low a tempeTature ;n the TR.1\,1
desorption unit.that did not allow removal of dioxins for chemical reduc6on in the second hig.h
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temperature stage. This is discussed in length later in this report. The original TEQ values for
IUUs l and 3, based on using detection limit values was reported by EL as 15 ppt SJ1d. 32 ppt,
respectively. If the value for nm 2 is included, then the average for all three runs in the original
data is very high at 142 ppt, and with the data from the retesting it is 127 ppt. The data are
summarized in the follo,ving table.
It is shown how comparable data can be used from both companies, iu te.rms of either data
from all runs or onJy the best runs, and for EL for original and revised data. For ex:ample, the
average for the two best EL runs can be compared to the average of the three runs of ETG that
represented their best process perfonnance. In other words, if all test data are considered for
both companies. theo. EL clearly fails to meet the performance criterion~ and if only the best runs.
are considered for both companies, then EL meets the c-riterion but ETG has superior
performance. From a community perspective, it is valid to judge the companies on the basis of all
their data, because they are responsible for suboptimal nms.
Average Dioxin TEO Levels (pot)
TF.ST RUNS ETG ECOLOGIC ECOLOGIC
original data re\ ised data
·-
All runs .91 142 127
Best runs .23 24 .50
It should be noted that the average dioxin TEQ level in the raw materials for EL runs 1
and 3 (the best runs) was 186 ppt, and 175 ppt for the three best runs ofETG. Proportionally,
ETG had slightly better perfomwice (i.e., 99.89% versus 99. 73% removal).
2.3 Air releases -total PCBs
ETG reported data for three runs in terms of both stack discharges and modeling results
for a property liue assumed to be 200 feet from the equipment, which is a proper procedure for
adchess.ing an exposure concentration (and that had been deemed appropriate at the pre-bid
conference for the RFP). In f.act, the performance criteria bad been established on the basis of
exposure concentrations for a very low ,isk level. The average of the ETG data was .S7xl0·4
ug/cm, or about one-tenth the perfomllllce criterion of 8x1o·'ug!cm.
EL reported data for three runs in terms of stack gas concentrations only, for which the
average was l.26xl0·• ug/cm, which is below the performance criterion at the stack, and which
automatically makes it below the criterion at any distance to an exposure point.
The ETG data for the stack concentrations were significantly higher than for tl1e EL data.
However, air sampling methods and equipment were not identical and, therefore, a direct
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comparison of stack data alone is not necessarily complete. The main problem is that an air
sampling procedure that is more efficient and effective in removing material and obta.ining low
detection levels will have a higher probability of detecting contaminants. for example, sampling a
larger volume of gas will increase the probability of detecting contaminants. .For example, the
stack gas flow rate in th.e ETG tests were about three times wger than in the EL testing,
suggesting a higher sensitivity in the ETG air testing. It must be emphasized that the performance
level set for this testing was ek"treme]y low and stringent and that the data from both cowpanies
indicate; that no health hazard would be caused by PCB air emissions from the detoxincat.ion
process. Indeed, in all probability there may be greater concern about potential PCB air releases
from site excavation and matelial handling prior to treatment in equipm.ent, but this issue should
be adchessed in the Phase II work.
Based on available information it can be said that both companies are comparable on this
sub-criterion.
2.4 Air releases -diox:in TEQ
ETG reported stack and model data for t.bJ ee ru11s. The model data had an avenge of
.52xto•ic ug/cm, about a tenth of the petfonnance criterion.
EL reported that no diox:ins/furans we.ce found above detection limits, but t11at the highest
possible level was I. 7xto·~ ug/cm, which is higher than the performance criterion. Thtrefore, EL
said that ''Due to these sampling and analytical constraints, it is not possible to demonstrate the
ability of the ECO LOGIC Process to meet the dioxin TEQ performance goal..'' The highest
possible EL level is some 1000 times greater than the perfonnance goal. However, if EL would
have modeled its data to address levels at some reason.3ble exposure point, then it ,vould have
been able to show compliance, because its stack level was similar to that found by ETG.
The Science Advisors conclude that ETG has the advantage on this sub-criterion.
3.0 Quality of the Phase I report
Making a professional judgment about the quality of a technical .report can involve many
considerations. Certainly. the reports should present the inforruatjon 1·equired in the RFP in a
user-friendly format. Additionally, however, the quality of the report can be considered to be
higher when there is considerable attention to particu.Lirly important issue> and when additio.nal
information is provided to usist the understanding and evaluation oftbe testing. It must also be
noted that EL submitted a draft report which was then modified in response to v~rions questions
and comments to produce a final report, • .. vhile ETG submitted only one initial final report.
Therefore, to some extent the one submission by ETG is comparable to the second submission by
EL that correGted deficiencies in the original draft report.
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As an important example of a difference in presentation quality, consider the Tab.Jes 4-5
and 4-6 in the ETG report, which presented in easily understood tabular form the primary data 01\
treatmeDt effectiveness for PCBs and dioxins/furans for aU the test runs, and for all the individual
i~omers or congener& in each category. A reader could immediately see how the post-treatment
levels compared to the original raw material levels, and when nondects were reported the
detection limits were also presented. In contrast, the EL report presented the analogous data in
two separate tables (Tables 8 and 9), and the contractor had to be instructed to provide detection
limits in the final report, and neither table presented the data for all the individual isomers or
congeners in the useful way employed by ETG.
Another factor was that ETG presented more information than was strictly required. For
example, ETG presented the results of testing to show that their process had actually destroyed
PCBs and also obtained data on particulate levels in emissions and water content in raw feed
materials.
It must also be noted that the quality of the report is merely a surrogate for the quality of
the bench-scale testing. In this sense, it is important to note that EL conducted three nms versus
four for ETG, and that one of the EL runs (run 2) was essentially a failure because of an operator
on-or that caused the initial TRl\1 desorption part of the process to function poorly due to a low
temperature that did not separate dioxins/furans for chemical reduction in the seco.od part of the
process. A major aspect of any type of technology testing is to see how well a company conducts
itself and operates its o\\-n equipment to demonstrate a very high level of competence that
provides confidenc•e to potential clients that the very best performance will be obtained in full-
sc.ale usage. The main guestion tha! mrots attention for this aspect of the EL test_ing is why the
senior persons in charge of the test did not identify the low leuweurtur"~roblem du.ting the lffl
period and r~eat the test run, This was especially important because only three runs were used.
Also, in discussing this event EL has referred to a minimum temperat1ue in the TRM unit
of 5 50°C, but the unit is supposed to operate at 600°C according to the information in the EL
report. EL did .not provide detailed data for nm 2 on exactly what temperature was used or for
how long a suboptimal temperature existed during the run, except that the temperature dropped
to 500"C. However, it reported average mill temperatures of 595°C, 572°C, and 628('C for test
nms 1, 2, and 3 respectively. It is interesting that two of the runs did not have average
temperatutes of 600.,C. The fact that the average temperature in run 2 was above the 5 SO''C
minimum that EL has mentioned also raises a question of uncertainty about what actually
occurred in run 2 to so thoroughly cause no treatmentof the dioxin contamination. The
fofonnation suggests that out of the total of 15 minutes. in the TRM unit even a mull amount of
time at suboptimal temperature is sufficient to cause a·complete failure to remove dioxiu
contaminants from the feed materiaJ, which is a serious sensitivity to low temperattue excursions.
EL also had a problem with an important part of its dioxin testing, which it blamed ou the
testing laboratory. However, much of what has been said by EL simply does not hold up under
close scrutiny.,__ Part of 1;he competence of a company in the remediation technology business is
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expertise for obtairung the best analytical services. If a company provides incomplete or
misleading information to a chemical analysis laboratory, then the laboratory may perform poorly.
In the EL testing, some of the most critical dioxin testing was inferior because of high detection
limits that resulted from unusually small sample sizes for the testing. EL dai...'llS that this resulted
from its telling the laboratory that there were high PCB levels, and that this caused the laboratory
to use lower than normal sample quantities. There are two problems, however. First, tl,e overall
PCB levels in the .raw materials (information given .in the RFP) were not exceptionally hlgb for
PCBs. Second, certainly there would be no rational reason why EL would want the laboratory to
believe that PCB levels were high in their treated materials. EL also said so.mething that any
experienced professional who deals with dio,dn testing of solids knows is inconect, namely that a
target value of 1 ppt dioxm TEQ is impossible to obtain or verify for method 8290. 1nis is plain
wrong; as any examination oftest results foT this met.hod cleitrly shows, including the dioxin test
data obtained for the project's site investigation work. as well .1s the dioxin testing for ETG .from
the same laboratory used by EL. In the opinion of one of the Science Advisors, who does
considerable work with dioxin contamination and cleanup and who discussed this issue with both
companies, EL did not exhibit a high degree of knowledge and experience in tlJjs area. ETG
verified that at no time did it change its instructions to the analytical laboratory that both
companies used, .nor is their any logical basis for believing that actions taken for EL samples
would have affected ETG work in the very large laboratory. The one key fact th.at seems to
explain the cause of the dioxin testing problems faced by EL was the infonnatiou it provided to
the laboratory which caused them to use irregular, low sample volumes for testing.
Another issue is that EL did not clearly represent what material~ it tested relaO\,e to the
materials it had received. EL said th!t it received three 5-gallon buckets but that only two were
used. But no information was provided to indicate exactly what materials were teS1ed in EL's
three runs. In contTast, ETG clearly indicated what materials had been received and teskd in each
of their four ruus ..
The professional judgment of the Science Advisors is that the ETG repo1t followed the
requested format of the RFP more closely than the EL report, and that the ETG repo1t was in
general easier to follow and presented key information in a more concise manner than the EL
Teport . As the above discussion indicates, the conclusion is that the quality of the ETG report i\lld
its testing was better than the EL report and its testing.
4.0 Ability to provide full-scale equipment
Both companies are in the positiou of roos't technology vendors, namely that ejtber an
existing piece of equipment could be transported to the site and used, or n.ew equipmeu.t would be
constructed for the particular job. Both companies have indicated that they would need up to six
months to provide necessary equipment, which is consistent with industry practice for large
cleanup projects. But there is more to consider for this evaluation criterion. The ability to
provide full-SC!fo equip~ent is legitimately related to the stability and viability of the compauy,
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because some significant investment is necessary for a large project, which this one would be
potentially. ETG is actually part of a business that is well established commercially and quite
substantial financially, and it has performed in similar remediation appJicatious for U.S. clients
over some years.
Interestingly, in the BCD treatment technology arena, wh.ich is based on companies
obtaining licenses from EPA, ETG has outlasted other companies. In contrast, EL is more of a
sta11-up technology developer that has had few clients (and none in the U.S. for actual full scale
work) and is not the same level of a stable, financially successful company '\-vith a long coIT.UUercial
track record as ETG. There may also be some significance to the fact that ETG is a U.S.
company located nruch closer to North Carolina, while EL is a more distant Canadian company.
It is also of some relevance that a very recent study for a major federal Superfund site at which
dioxin is a major contaminant (the Escambia Treating Company site in Pensacola, Florida)
examined potential treatment technologies, and the EPA contractor doing the Remedial
lnvestigation/Feasibility Study screened out EL and its techn.ology at the earliest stage of
technology evaluation. but inclllded BCD treatment and cited ETG as the source of the BCD
technology. While EL has performed treatability and demonstration tests in the U.S. it has not yet
secured any actual remediation project. In contrast, ETG is the vendor cleaning up the Southern
Maryland Wood Treatment Superfund site, where it will treat some 145,000 tons of material.
This job is closer to the Warren County project than any work that EL has perfonued.
Toe Science Advisors conclude that overall the ability to provide necessary full-scale
equipment for the Warren County project is better for ETG than for EL.
5.0 Safety, reliability, cost, and long term releases
5..1 Safety
There are two major ways to look at the safety issue. First, the intrinsic nature of tJ,e
technology can be assessed in tenns ofinherent hazards. For example, any process that utmzcs
hazardous materials is fundamentally .more hazardous than one that does not use aoy hazardous
materials, and one that operates at either higher pressure or temperature than another on.e poses
more potential for u.nsaf e situations.
The second approach is to consider how vulnerable a process is to human error~ because
most unsafe conditions and accidents relate to human error. Some technologies are inherently
safer because they are much simpler than other technologies, for example. As for treafa.bility 01
demonstration testing, it is presumed that a company will logically use its best trained aod
qualified personnel. Hhuman errors occur in testing, it does not portend well for full-~cale
company operations.
ETG technology operates at a lower temperature than the EL process, 10ughly about
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onehalflower temperature. The ETG process also operates under vacuum conditions, while the
EL process operates at ambient pressure, and this reduces the potential for system leaks and
discharges of contaminants into the environment. The EL technology uses hydrogen gas, which is
intrinsically hazardous, while the ETG technology uses no hazardous materials, vi.1th the exc•.!ption
of sodium hydroxide which is corrosive but not combustible or toxic. The EL process also
utilizes a bath of mohen tin, which raises a safety concern.
Although EL has made a good argument that industrial processes have used hydrogen
very successfully, there is still an inherent haz.a.rd that cannot he entirely dismissed, especially
when one recognizes that safety issues generally are centered on unusual, unintended and
unforseen incidents or accidents .. While process control instrumentation and monitoring
eqwpment may be u&ed, the problem in the real-world are low probability events that consist of
several things going wrong to create an actual problem For example, for everyone of the nine
factors that EL has cited to assure the safety of using hydrogen it is possible to ideutif)· a
condition that nulli.6.es the factor_ Fo.r example, EL says that no open flames or smoking are
permitted onsite, but any experienced professional has probably seen just such human beh.avior oo
actual industrial sties where the prohibitions exist. Similarly, leak proof proc.ess vesse1; in the
field can be rendered unsafe by, for example, a bullet piercing a piece of onsite equipment The
use of nitrogen purging to avoid mixing with oxygen can &il when som<:one uses a wroog gas
tank or makes a wrong connection_
On the issue of human error, it is also relevant that in the bench-sc.ale testing for this
project, there was a clear, admitted case of human error in the EL test, when a temperature was
not properly controlled in run 2 in the TRM unit. EL also acknowledged a .second '1operator
error'' when the excess gas burner that was supposed to be operated at 800°C was actually
operated between 300 to 400°C, apparently for all the runs. The company also had -problems ,\.ith
equipment, including a mic.ro-GC instrument that was supposed to be used but was not
operatio~ and a broken mill shaft which happened twice and caused delays_
Another safety issue is the potential for the air pollution control system to function
effectively to prevent unacceptable discharges of hazardous substanc.es. In this regard, the ETG
report paid considerable attention to this issue and provided extensive discu~~ion of how the
company would employ the most sophisticated technology to collect and treat dust.
The Science Advisors conclude that, asswning that either company would empt oy the best
industrial safety practices in design and operation of th cir equipment, the ETG technology has ai1
advantage over the EL process_ ·
5. 2 Reliability
ReliabHity can mean many different things, but one key engineering concept is whether a
process technology will offer the best performance under varying field and raw material
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conditions. In other words, some technologies are more sensitive or vulnerable to variations in
key conditions or parameters and become Jess reliable because there are upsets created. Some
technologies are very complex with multiple steps or stages and the need for very complex
process control and monitoring equipment. All of these issues can reduce reliability. The use of
computers and sophisticated equipment has not eliminated major problems in industrial processes.
An issue of concern in the current project is the degree to which the detoxiflcatiou technology
may become unreliable because of high water content in feed materials, for example. To some
degree it seems as if the EL process would be less sensitive to water content, but in fact a dose
examination of discussions of this topic by the contractors reveals essentially the same p.roblem.
That is, both processes can handle higher moisture levels, but both would be negatively impacted
in terms of throughput, efficiency and processing time. Moreover, ETG actually measured water
content and concluded that no dewatering of nLtterials will be required.
An important feature of the ETG process js that there is solid phase BCD tre:.ttment of
PCBs and dioxins in the thermal desorption part of the process and then more BCD liquid phase
treatment of oily condensate, if necessary. Their test resuhs showed that the solid phase
detoxification was successful. In contrast, in the EL process there is no detoxification of PCBs
and dioxins in the first stage thermal desorption unit, and detoxification is dependent on first
separating the c-ontaminants into a vapor phase that then undergoes high temperature reduction.
As the testing showed, the EL process was vuhierable to poor performance when the thermal
desorption stage was not operated at optimal conditions and, therefore, dioxins we1e not
detoxified.
It is the opii1ion of the Science Advisors that the ETG process is intrinsically simpler and
less prone to problems created during full-scale use that would reduce reliability.
5.3 Cost
EL has said that it foresees a cost of $300 to $350 per ton, based on processing 100 to
200 tons per day v.-ith a 70 to 80% availability, leading to a project duration of 90 to 123 weeks.
The availability rauge used by EL is not impressive and may indicate its experience in actual
projects where there has been significant down time. This cost does NOT include cenain
acti\-ities, such as excavation, performance testing or disposal of processed .solids, but it DOES
include system mobilization and commissioning, all waste preparation. and processing, lab costs
for process outputs anaJysis and system demobilization.
ETG has said that its estimate of $390 per ton pertains to a processing rate of 300 to 400
tons per day with 100% availability. ETG's cost is all inclusive and includes excavation and
backfilling of soil, which the EL esti.mate did not. ETG has also indicated that if less stringent
cleanup performance standards were used, then the cost could be decreased by some 35% if more
typical criteria ~ere used for PCBs and dioxins. In fact, it is highly probable that the state would
use its normal c1eanup criteria and that the ETG cost would likely be less than $300 per tou. It
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should be n.oted that there is less intrinsic capability to reduce operating costs in th~ EL proces3,
as compared to the ETG process~ and that EL did not offer a similar obseivation. Note that the
processing rate for ETG is about twice as high as the EL figure, meaning that total project
duration might well be reduced by 50% and require about one year , ather than two years.
The Science Advisors conclude that for cost and cost-effectiveness the ETG process is
superior to .that of EL.
S. 4. Long term releases from residuals
Any detoxification technology will create certain t)pes of residuals. byproducts or waste
effluents that might pose longer term risks because of releases. Both companies hav~i paid
sufficient attention to this issue and provided similar discussions about the safe and effective
handling of all process residuals and wastestreams. and neither has an advantage. Tile ro.ore
confidence there is in the company's ability to reduce residua] levels of PCBs and dioxins to the
lowest possible levels, then there is minimal concern about long term releases from post-treatment
residuals replaced on the landfill site.
6.0 Quality and cost of Phase II proposal
The initial proposals that re.sponded to the RFP included a proposal for the Phase II work
For the most part, both companies submitted comparabJ.e proposals that addressed the
requirements of the RFP. Both companies teamed with large, experienced environmental
engineering firms for the Phase II ,vo1k. However, the cost of the ETG Phase TI work wa~
significantly less at $89,000, while EL proposed a cost of Sl 15,000.
The Science Ad,isors conclude that ETG offers a significant cost advantage for the Pha~c
II work, especially in light of currently limited funding for all aspects of the current pr~ject. TI1at
is, the saving of $25,000 offers the potential of being able to accomplish other fimctions and ne-eds
prior to the state legislature authorizing funds for the full detoxification of the land.fill.
7.0 Summary comparison and recommendation
The following table presents a simplified swnmary of the conclusions reached for the
individual evaluation criteria. Rather than using an artificial and subjective numerical rating
system, the Science Advisors have indicated a net advantage in terms of a + sigu for the company
"'ith the best capability. When both companies were comparable, both received a +.
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SELECTION CRITERION ETG ECOLOGIC
Performance
solids -PCBs +
solids -dioxin TEQ +
air-PCBs + +
air -dioxin TEQ +
Quality of Phase I report +
Ability to provide full-scale equipment +
Safety, reliability, cost, long term effects ++++ +
Phase II proposal, quality and cost +
As can be seen from the table, in most categories ETG was judged to have an advantage.
lbis is not to say or imply that Eco Logic and its technology was inferior, poor or completely
unacceptable, but only tl1at, in this particular tewng and for this specific application~ ETG has a
number of advantages, as presented in the previous discussions. On the basis of visiting the te.;t
sites, having discussions with company personneL and examining the reports, the Science
Advisors agreed that ETG seems a more engineering oriented company, while EL seems more
R&D or science oriented, with less of a practical, engineering construction focus.
Also, a close examination of all documents provided by EL indicated the follov-.':ing ( 1) the
c,ompany probably has not met the stringent dioxin cleanup criteria used in this project in prev:ious
projects~ (2) the September 1994 EPA report on the thermal desorption unit found that it "did uot
perform to design specifications" and that the company "experienced material handling problems:"
and (3) tJ1e company does not seem to .have been able to perfotm commercial projects at a profit
and may be experiencing uncertain financial conditions. On the latter point, the last two annual
reports from EL indicate th.at the company has continued to be unprofitable, despite rising
revenues, while the information supplied by ETG indicates a medium size euvironmental senices
company that .is profitable. For example, the highest revenue stream for EL in 1996 was less than
$5 million annually (for which the annual Joss was nearly $12 million), while the complllly that
ETG is a division of grosses about $50 million and is profitable.
lu conclusion, the Science Advisors agree that .ETG is the best. qualified companl
for receiving the Phase Il contract and advise the Working Group to accept this selection
and to formally communicate its recommendation to the Division of Waste Management.
12
P 13
~(,,_ 7/,,._
C:µ5
Joint Warren County/State PCB Landfill Working Group
draft July 23, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:45 P.M. Wednesday, July 23, 1997. The meeting was held at the office of the Working
Group and was called to order by co-chair Henry Lancaster.
UNFINISHED BUSINESS
Discuss implications of new Secretary for DEHNR
Mr. Lancaster informed the Working Group that he met with the new Secretary, Wayne McDevitt,
who will be sworn in on August 1; Secretary McDevitt(the Secretary) said that he wishes to do no
departm~nt business until that time. Mr. Lancaster advised that he believes that the Secretary ts
going to favor citizen involvement and that he is committed to detoxification.
Jim Warren made a motion to ask the Secretary to endorse the process that the Working Group has
already established. The motion was seconded and carried. A letter is to be sent to the Secretary
asking for his endorsement of the process previously agreed upon for the reconstitution of the
Working Group.
Reports and Recommendations regarding sampling and testing
Patrick Barnes presented a draft table of contents for the site investigation report. (See Attachment)
He said that the reason for the site investigation was to lend support to the process and to find out
what is in the landfill. Because of this investigation, we have found that:
1) dioxins are outside the landfill,
2) water is entering the landfill, and
3) PCBs have been released into the air.
Mr. Barnes added that a formal report is at least a month away and that it must be very
comprehensive.
Ken Ferruccio said that dioxin was found in two of the monitoring wells. Mr. Barnes said that well
5D has the most toxic form of dioxin; he added that the well was put at this location because if there
were any leakage, that well 5D would be the most logical place for it to occur.
Joel Hirschhorn added that the dioxin found in well 5D is not characteristic of dioxins found in PCBs,
what is in well 5D is very unusual. Mr. Lancaster asked if it matched anything found in the landfill.
Both Science Advisors replied no.
'•
draft July 23, 1997 Meeting Minutes
Page2
Mr. Ferruccio asked the Science Advisors if they were satisfied with the chain of custody for the soil
delivered to Eco Logic and ETG for the bench-scale study. Mr. Hirschhorn advised that Eco Logic
had infonned him that the seals were broken on the materials they received and that they believed it
happened during transportation.
Mr. Barnes adde~ that the companies may not be sure they could pen down the cost going from
bench-scale to full-scale detoxification. Deborah Ferruccio asked when the companies are looking
at cost, will they have to look at the characteristics of the materials to be detoxified. The
characteristics of the material are important, but the volume of the material that needs to be detoxified
is the most critical information they will need, said Mr. Hirschhorn.
Ms. Ferruccio asked ifwe know the chemical makeup of the material brought from Fort Bragg. Mike
Kelly advised that the State did not sample the soils from Fort Bragg. Discussion followed, it was
agreed by consensus that the Science Advisors and the Working Group would request information
on the composition of the soils sent from Fort Bragg. Mr. Hirschhorn agreed to draft this letter.
Air testing was discussed next. Mr. Hirschhorn advised that there were only a few positive results,
but with an aged landfill you would not expect to have a lot of positive air tests, but bursts of PCB
emissions. He added that we have a lot of information fitting the position that the landfill lacks
integrity. Bobbie Riley added that the testing was done during cold weather and one would expect
the burst of PCB emissions to be more prevalent during hot weather. Ms. Ferruccio said PCB air
emissions over the years is a serious health threat. Mr. Hirschhorn added that emissions would be
expected to be higher in the past and declining over the years.
Next, Mr. Hirschhorn questioned the integrity of the report from Soil and Materials Engineering
(S&ME}, saying that there are serious deficiencies in the report. S&ME was contacted by Mr.
Hirschhorn and was advised that there were drafts of the report. He asked the State to provide
copies of the draft and of their comments made to S&ME. Discussion followed. After which, Mr.
Kelly agreed to provide copies of the draft report and copies of the comments made by the State.
Report from the Technical Committee
Mr. Warren advised that the Technical Committee recommends that the Working Group formally
requests a copy of any compliance order issued to the State. The motion was seconded and carried.
Mr. Kelly advised that he contacted the Science Advisors, provided them with a list of tasks that need
to be completed and asked how much would each task cost. After comment from the Science
Advisors it was decided, by the State Office of Purchasing and Contracts, to divide the remaining
funding between the Science Advisors for specific tasks. Ms. Burwell added that any issues that
involve funding should be directed to the executive committee.
draft July 23, 1997 Meeting Minutes
Page 3
Pilot Studies
Mr. Hirschhorn advised that the pilot studies are complete and that we are waiting for the analytical
data. He· suggested that we should have the completed reports by mid to late August. Mr. Kelly
advised that he has spoken with both companies. Eco Logic said their report would be complete in
about two weeks and ETG has already started to send some data and their report should be complete
by August 8.
Next, said Mr. Hirschhorn, will be selecting one company for phase two. Mr. Lancaster asked if the
criteria for making this decision has been decided. Discussion followed . It was agreed that the
Science Advisors will develop the criteria, present it to the Working Group and then they, the State
and the Science Advisors, will make the decision. It was decided by consensus that if there is no
agreement, the Science Advisors are to contact the office to schedule a conference call with the
Technical Committee, Science Advisors and the State.
Mr. Kelly advised that a technology company, Taylor, Inc., has asked if they could have some
material to test their process. They advised Mr. Kelly that they would do all of the testing free of
charge. Mr. Kelly advised that they have a patented process that leaves ammonia and chloride as
residuals. After discussion the Working Group authorized Mr. Kelly to advise any companies that
contact him that the process is closed. ·
ADJOURNMENT
The meeting was adjourned at 9:20 p.m.. The next meeting will be dependent upon the completion
of the final reports from the Science Advisors.
rcn LANDFILL
SITE INVESTIGATION REPORT
1.0 DACKGROUND
1.1 Introduction
1.2 Goals and Objective
1.3 Investigation Approach
2.0 FILE REVIEW .
2.1 Monitoring and Reporting Compliance
2.1. l Past Analytical Results
2.2 Landfill Design
2.2.1 Liner System
2.2.2 Leachate Collection System
2.2.3 Site Hydrology
4.0 FIELD INVESTIGATION PLAN l'ROCEDURES
95-017
70C.doc
3.1 Off-site Activities
3.1. l Monitoring Well Placement
3.1.2 Monitoring Well Design and Construction
3.1.3 Surface Water Sampling
3.1.4 Sediment Sampling
3.1.5 Surface Soil Sampling
3.1.6 Air Monitoring
3.2 Facility Testing Activities
3.2. l Landfill Content
3.2.2 Leachate Samples
3.2.3 Sediment Basin and Substrate Samples
3 .2.4 Sand and Carbon Filtration Bed
3.3 Top Liner Integrity
3.4 Landfill Waler Extraction Wells
3.5 Quality Assurance/Control Procedures
3.6 Analytes and Analytical Methods
-i-
V
PCB LANDFILL
SITE INVESTIGATION REPORT
(Continued)
4.0 ANALYSIS OF FIELD TESTING RESULTS
4.1 Site Geologic Setting
4.1.1 Strata Distribution
4.1.2 Soil Permeability and Groundwater Flow
4.2 Water Quality Characteristics
4.2. 1 Groundwater
4.2.2 Surface Water
4.3 • Surface Soil and Stream Sediment Characteristics
4.3. I Surface Soil Adjacent to Facility
4.3.2 Stream Sediment
4.4 Air Quality Analysis
4.4.1 On-site
4.4.2 Off-site
4.5 Landfill Facility
4.5. I Leachate
4.5 .2 Contents
4.5.3 Treatment System ·
4.5.4 Physical Characteristics of Wastes
4.5.5 Entrined Water Quantity
5.0 CONCLUSIONS
5.1 Discharge Potential
5.2 Off-Site Environmental Impacts
5.3 Waste Characteristics and Site Setting
6.0 RECOMMENDATIONS
6. I Immediate Measures (60 -90 Days)
6.2 Long Term (I to 2 Years)
95-017 -11-
roc.doc
PCB LANDFILL
SITE INVESTIGATION REPORT
(Continued)
TABLES
2.1 Past Analytical Results Summary
3. l New Sample Location and Analysis
4. l Summary of Field Permeabilities
4.2 Summary of Field Parameters
4.3 Analytical PCB Results Summary
4.4 Analytical Dioxin Results Summary
4.5 Analytical BN/AE Results Summary
4.6 Analytical Metals Results Summary
l. l
1.2
1.3
2.1
2.2
2.3
3.1
3.2
3.3
( ~.4
~.5
3.6
4.1
4.2
4.3
4.4
Location Map
Site Map
Master Plan Flow Chart
Facility Map (Prior to Field Work)
Facility Design
Hydrograph
Major Flow Paths
New Sample Network
Air Monitoring Network
Off-Site (Background) Wells~
Generic Monitoring Well Design
Extraction Wells
FIGURES
Lithologic Cross Sections A-A', ~
Lithologic Cross Sections ~•, B-B'
Water Table Contour Map ~
Depth to Rock Contour Map
APPENDICES
l. PCB, BNAE and VOC Analytical Results
2. Dioxin/Furon
3. Liner Evaluation R~port
4. Air Monitoring Analysis
5. Monitoring Well Installation Report
95-017 -111-
TOC.doc
Joint Warren County/State PCB Landfill Working Group
May 8, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:55 P .M. Thursday, May 9, 1997. The meeting was held at the office of the Working
Group and was called to order by co-chair Dollie Burwell.
APPROVAL OF MINUTES
There was one correction made to the January 21, 1997 meeting minutes. Minutes from the
December 17, 1996; January 3, 1997; February 6, 1997; and March 13, 1997 meetings were approved.
OLD BUSINESS
Ms. Burwell infonned the Working Group that Mike Kelly has asked the Science Advisors to release
the codes for the sampling event. Mr. Kelly was informed that the Working Group had agreed in a
previous meeting not to release the codes until all data has been received. After discussion the
Working Group again agreed not to release the codes until all the data is received.
Science Ad,1isors Concerns
Pat Barnes asked where do we stand with the rest of the data? Mr. Kelly advised that the State has
received the data for the PCBs and herbicides. However, he said, there is data to be received for four
background soil samples and for the twenty-four samples that were run for BNAs.
Joel Hirschhorn asked if all the dioxin data had been received. Mr. Kelly said yes. Mr. Hirschhorn
said that he expected to see TDQ values and added that they were to be included in the data. He
explained that TDQ values take a lot of complicated data and condenses it to simple terms and
compares that data to a standard. Mr. Kelly said that he thought that information was included. He
was asked to obtain the information from the State labs.
Mr. Hirschhorn asked if a report had been received from EPA on the split samples. Mr. Kelly replied
that he had not spoken with EPA Next, Mr. Hirschhorn asked if S&ME had sent their report on the
liner. Mr. Kelly advised that the report was received yesterday (May 7, 1997) and would be made
available to the Science Advisors. Continuing, Mr. Hirschhorn asked it the data had been received
on the air sampling. The results for the lower volume sampling has been received, said Mr. Kelly,
but not for the high volume testing. He presented a report prepared by Southern Testing & Research
Laboratories, Inc. (See attachment # 1)
Next, Mr. Hirschhorn asked if the State lab could give more details on the testing procedure for PCBs
because if appears, from the report received by the Science Advisors, that they tested for only one
arochlor of PCB. Mr. Barnes voice concern that the report on the PCB was done manually.
Discussion followed, after which Mr. Kelly agreed to ask the State lab to provide information on their
testing procedure for PCBs.
Mr. Burwell asked the Science Advisors to write down what would make a complete report to be
presented to the State.
draft May 8, 1997 Meeting Minutes
Page2
Deborah Ferruccio asked if the detection limit being used is what is legal or what the EP A's standard
is today. Mr. Kelly responded, it is the EPA standard.
Mr. Hirschhorn said there is hard evidence that material inside the landfill has migrated outside the
landfill. This conclusion was the result of the dioxin data. He added that the material that has
migrated is very close to the landfill and not all around the landfill. He said the containment system
lacks integrity and has failed.
Mr. Barnes said that he is more cautious. He added that he knows water is coming in and going out
and presented the Working Group with a graph of water level contours. (See attachment# 2) He said
that he would like to see one or two confirmation samples.
To reinforce his position, Mr. Hirschhorn added that dioxins have a "fingerprint" and that there is
dioxin in this area that is not consistent with dioxin in the landfill, but consistent with burning. He
advised that there is one sample with a very high level of the most toxic kind of dioxin; it is outside
the landfill and it is not in the landfill .
Ms. Burwell asked the Science Advisors how they would recommend handling this.
Mr. Barnes suggested re-sampling.
Dennis Retzlaff said that this information is interesting and helpful and asked what is the time frame
for the Science Advisors and the State to prepare a summary of all the information.
Mr. Hirschhorn said about a month. He added that if additional sampling is done that he would
recommend using an independent lab that has a more sophisticated reporting system.
Ms. Ferruccio asked if enough samples were taken form inside the landfill to definitely say that this
most toxic dioxin is not present inside the landfill. Mr. Hirschhorn said that this dioxin, 2,3,7,8 OTT
is not characteristic of dioxins found in PCBs. He added that this is a very odd finding.
Tommy Cline asked if additional testing is to be done, at what point should it be done. Mr.
Hirschhorn said that additional testing should only be done if there is resistance, from the State, to
what is in the reports.
Jim Warren asked how would this fit with the compliance issue. Mr. Hirschhorn said EPA has a
strong enforcement with the State. That they have also found an 1981 document which shows the
landfill without the perforated pipe. Therefore, they have concluded that they approved the change.
Ms. Burwell suggested that the Working Group respond to the letter requesting supporting
documents, i.e. construction change orders and who signed it. She added that they should be given
a time limit to respond. The Working Group agreed by consensus.
Mr. Warren asked the time frame for detoxification and what are the options at this point. Mr.
Hirschhorn responded that the Working Group has a case for going to the State. He added that the
clock is ticking on the technology companies.
draft May 8, 1997 Meeting Minutes
Page 3
Ms. Burwell reminded the Working Group of Bill Meyer's optimism with linking detoxification to
compliance. She asked Pat Williamson if she was aware of whether Mr. Meyer had spoken to EPA
about this issue. Ms. Williamson said that she did not know whether Mr. Meyer has contacted EPA.
Ms. Burwell suggested that a letter is sent to Mr. Meyer to remind him of his commitment to contact
EPA.
Referring to the question asked earlier by Mr. Warren, Mr. Hirschhorn said by September what is
being done now will be complete and the Working Group will be out of money, what will happen
then? Ms. Burwell said by that point we should have enough information for the Working Group to
approach Senator Ballance in the short session for continued funding .
Ms. Ferruccio said that the Working Group is still talking about sampling and no company has been
out to test and see if the landfill can be detoxified. She added that the only way, she feels, to get
money from Senator Ballance is to prove that the landfill is leaking.
Disagreeing, Ms. Burwell said that the first million dollars was not given because the landfill was
leaking. It was given to test to see if a technology can detoxify the landfill and this is what we need
to show.
Report from the State
Mr. Kelly advised the Working Group that the contracts for the technology companies have been
sent; Eco Logic has a draft approval from EPA and wants to be sure before they proceed; and ETG
Environmental, Inc. has asked for phased delivering. He added that the material will be shipped the
week of May 19, 1997 and both companies will begin testing on May 27, 1997.
Mr. Kelly advised that the waste material for the sampling is ready to be shipped to Utah. S&ME's
cost went over budget, due to the additional wells, however there was no charge for the
redevelopment of the wells he said. He said that approval has been given for the invoice from
Southwest Labs and the contract for the fencing has not be issued.
Mr. Barnes asked if the weather station has been installed. He also asked if all the wells will be used
when water levels are taken. (In the previous meeting Bill Meyer advised that the State would be
installing a weather station which would use two water detection processes that would be down
loaded into a computer for constant water levels.) Mr. Kelly said the weather station has not been
installed due to a hold up with the computer program. He added that on April 30 water levels were
taken, however, not from all of the wells.
UNFINISHED BUSINESS
Ms. Ferruccio asked if the remaining data would be received in time to go the Senator Ballance on
the short session.
Ms. Burwell suggested that the Science Advisors draft a letter to Senator Ballance concerning
continued funding.
OTHER BUSINESS
draft May 8, 1997 Meeting Minutes
Page4
Mr. Barnes asked if the State is considering pumping the water out of the landfill. Mr. Kelly said yes,
that State has and will continue to consider pumping the water our of the landfill. However, he said,
if EPA tells us to pump it out, we will. The State is also considering doing a risk assessment said Mr.
Kelly. Discussion followed. After which Mr. Warren made a motion to ask the State not to use tax
payer money to create a risk assessment. The motion was seconded and carried. There was one
abstaining and one opposing the motion. Nan Freeland was selected to draft the letter.
ADJOURNMENT
The meeting was adjourned at 9:30 p.m.. No date was set for the next meeting.
NT#l
i9 ... ,~~ s~_,;/
~ ('\
0 "' Southern Testing Research Laboratories, Inc.
':, '4,
,A <.,
"f ~'
,t-,4 I~ \l
3809 Airport Drive
April 9, 1997
Mr. Pierre Lauffer
North Carolina DEHNR
P.O. Box 27687
Raleigh, NC 27611
Dear i'vlr. Lauffer:
[phone] • Fax: [phone]J.il Wilson, ~C 27896
Attached are the results for the analysis of 25 organic versatile sampler (OVS) tubes
for ArocWors 1242, 1254, and 1260. We recei ed 25 samples from you on February 21,
1997 and 6 samples on February 25, 1997. Th samples were analyzed using NIOSH Method
No. 5503 with a few modifications.
The fust modification was the separate alysis of the filter and the front sorbent
sections. This was done at your request to allo v differentiation of the particulate and vapor
phases. We also made a series of modification for the purpose of improving the detection
limits of the method. They include: the use of capillary chromatography for separation
(Alltech SE 54, 30 m x 0.32 mm x 0.25 µm), d concentration of the extracts from 2 mL to
100 µL. We also added dibutyl chlorendate as an internal standard to normalize the
concentration step.
For quantitation of the chromatograms, e chose eight major peaks for each of the
three arochlors. The sample results are listed i Tables 1 and 2. In Table 1, we have listed
the results as total ng found and in Table 2, as air concentrations based on the volumes you
provided . We only detected arochlors in ones pie. W-13017 (STRL No. 6618F2). The
amount shown for the sorbent includes both th front and back sections, even though they
were analyzed separately. The back section co tained 845 ng of Arochlor 1242, 82. 7 ng of
Arochlor 1254, and Arochlor 7.3 ng 1260. It i apparent that there was significant
breakthrough of some of the 1242 components for this sample.
Our limit of quantitation is about I ng or Arochlors 1254 and 1260, and 5 ng for
Arochlor 1242. These were verified by succes ful recovery of laboratory spikes at these
levels.
We appreciate the opportuinity to work with you on this project. Call me if you have
any questions.
s;?:,.}J
i'r:i ~. Baughrn
Ch1emico1I and '.\1icrobiolORic.al Analy~s: Em-ironmenl.il • I uslrial Hygiene • A1trochemical • Foods • Pharmaceuricals .
May-06-97 03:28P Southern Testing Labs 919 237 9341 P .. 03
' -
Table I. Sample Resu ts as Total Nanograms
Arochlor 1242 (ng ) Arochlor 1254 (ng) Arochlor 1260 (ng)
STRL DENHR I.D . I.D. Filter Sorber~ Filter Sorbent Filter Sorbent
W-13011 6618Fl < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < l.0
l W-13017 6618F2 3.2 2,630 3.1 738 2.8 712
W-15400 6618F3 < 5.0 < 5.0 < l.0 < 1.0 < l.0 < 1.0
W-15277 6618F4 < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < 1.0
W-15395 6618F5 < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < l.0
W-13013 6618F6 < 5.0 < 5.0 < l.0 < l.0 <·l.0 < 1.0
W-15142 6618F7 < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < 1.0
W-15142-per 6618F8 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
W-15396 6618F9 < 5 .0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
W-15398 6618Fl 0 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
W-11706 6618Fl 1 < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < 1.0
Lab Blank 6618Fl2 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
Field Blank 6618Fl3 < 5.0 < 5.0 < l.0 < l.0 < 1.0 < 1.0
Fence South 6618Fl4 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
Cone South 6618Fl5 < 5.0 < 5.0 < 1.0 < l.0 < 1.0 < 1.0
Center Vent 6618Fl6 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
Vent 6618Fl 7 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
116' from 6618F18 < 5.0 < 5.0 < 1.0 < l.0 < 1.0 < 1.0
Fence
Fence 6618Fl9 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
15398 6692FI < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
13017 6692F2 < 5.0 < 5.0 < 1.0 < l.0 < 1.0 < l.0
15394 6692F3 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
15401 6692F4 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
13013 6692F5 < 5.0 < 5.0 < 1.0 < 1.0 < 1.0 < 1.0
15400 6692F6 < 5.0 < 5.0 < l.0 < 1.0 < 1.0 < 1.0 ,,
-~
,.,c1_y-uo -~, .
.. _ ,,. 1
u~:£9~ ~ou~nern resting Labs 919 23/ 9:.:S4.l
Table 2. Results as Air Concentrations
DENHR l.D.
W-13017
\V-15400
W-15277
W-15395
W-13013
W-15142
W-15396
W-11706
15398
STRL
I.D.
6618F2
6618F3
6618F4
6618F5
66 l 8F6
6618F7
6618F9
6618Fll
6692Fl
Arochlor 1242
(ng/m3)
Filter
2.5
< 3.6
< 5.3
< 5.4
< 3.9
< 4.5
< 3.2
< 5.4
< 3.8
Sorber t
2090
< 3.t
< 5.3
< .., C J.
< 3.:
< 3.!
Arochlor 1254
(ng/m3)
Filter Sorb~nt
2.5 588
< 0.8 < 0.8
< I. 1 < I.I
< I. I < I. I
< 0.8 < 0.8
< 0.9 < 0.9
< 0.7 < 0.7
< I.I < I.I
< 0.8 < 0.8
Arochlor 1260
(ng/m3)
Filter Sorbent
2.2 567
< 0.8 < 0.8
<I.I < I.I
< 1.1 < I.I
< 0.8 < 0.8
< 0.9 < 0.9
< 0.7 < 0.7
< I. I < I. I
< 0 .8 < 0.8
Note : Concentrations are calculated based on : ir volumes supplied by DENHR.
3
P-04
ATTACHMENT# 2 ~&,Environmental Con■uttant■ /lameo, Feriand and iitu-latao, ino. LEGEND 0 SURFACE WATER SAMPLE (SW) ~ SURFACE SOIL (SurS) D,, SEOII.AENT SAMPLE (SEO) EX!S11NC SURFACE WATER STATIONS _ EXISTING WELL (I.AW) .A. HYDRO PUNCH SAMPL.ES @ NEW WEU. (OR CLUSTER) (I.AW) WARREN COUNTY PCB LANDFILL WATER LEVEL CONTOURS FIGURE 1
I Joint Warren County/State PCB Landfill Working Group
January 21 , 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 4:32 P.M. Friday, January 21, 1997. The meeting was held at the Warren County Office
of the Working Group and was called to order by Jim Warren. Co-chairs Henry Lancaster and
Dollie Burwell joined the meeting later.
OLD BUSINESS
Issue of Recommendations to the State
The Screening Committee received nine letters of interest and the nine letters were sent to
Secretary Howes (Secretary). Rev. Leon White asked that his name be added to the list sent to
the Secretary.
RFPs Update
Joel Hirschhorn began by inquiring if the three previous RFP contracts had been awarded. Next,
he listed several concerns with the fourth RFP. 1) Time frame, it appears that this RFP could be
stretched out over a year and could be done in several months; 2) The RPF is too complicated, it
is written as if it were for the total cleanup and 3) The RFP should clearly state that only Base
Catalyzed Dechlorination (BCD) and Gas Phase Chemical Reduction (Gas Phase Reduction) will
be used.
Responding to the inquiry by Mr. Hirschhorn, Mike Kelly advised that the contracts have been
mailed to two of the three companies. However, only two of the three companies recommended
by the Working Group were awarded the contracts. State Contracts did not award the contract
to Engineering Tectonics (Tectonics) for the monitoring wells installation. Mr. Kelly explained
that State Contracts said if a company cannot be disqualified, then we must go with the lowest bid
and that would be Environmental Investigations (Environmental).
Patrick Barnes said that the primary reason that Tectonics was chosen was because they had their
own drilling capabilities and Environmental will subcontract the drilling. Another major reason
Tectonics was chosen was because they had more landfill experience, Mr. Hirschhorn said. He
asked why was Soil &Materials Engineering (S&ME) chosen for the bore hole/excavation wells
when their price is over $10,000.00 more than the lowest bid, Triangle Labs. State Contracts
agreed that S&ME's upper liner capabilities were much better than the lowest bid, said Mr. Kelly.
There must be a procedure for appeal, said Mr. Hirschhorn. Mr. Lancaster asked if the contract
had been sent out. Mr. Kelly said that Environmental has been told they have the contract. Ken
Ferruccio asked if the Science Advisors had been contacted before the contracts were sent out.
They had not, responded Mr. Kelly. Trying to find a legal standpoint for which the contract could
be reconsidered, Mr. Lancaster asked if there was anything that could be altered in the Scope of
Work (SOW). The State and Science Advisors agreed that there was nothing that should be
I
draft January 21, 1997 Meeting Minutes
Page 2
changed in the SOW. After discussion it was agreed that the Science Advisors will be notified of
those contracts not awarded as recommended by the Working Group.
Mr. Kelly advised the Working Group that State Contracts has already seen the fourth RFP and
have asked if there are other technologies that can detoxify the landfill. Discussion followed. The
Working Group agreed that the RFP should go out with language to state that only BCD and Gas
Phase Reduction will be considered. If asked to defend it's choice, the Working Group would.
Mr. Hirschhorn voiced concern about the schedule, siting that EPA may delay the certification of
the technologies chosen. He advised that EPA has up to three months to grant approval.
Therefore, he asked for authorization to work directly with EPA. After discussion, it was decided
that the Science Advisors and the State would get together and decide who would be responsible
for speaking with EPA.
Air Sampling Event
Mr. Hirschhorn advised that he has submitted a copy of a 1989 scientific paper and suggested that
the State use the method of air sampling described in this paper. He said when full scale
detoxification begins, we should be concerned about PCB air emissions as a safety issue and the
preliminary design should take this in consideration. Mr. Kelly advised that the State has a copy
of the same scientific paper and there are only two differences in what they did and what the State
plans to do: 1) They used high velocity air samplers and we planned to use low velocity; 2)
They used a prepared polyurethane filter and we planned to use a combination of filters. The
State suggested the following changes: 1) We will use a prepared filter; 2) testing will be done by
an outside lab in Wilson, N. C.; 3) High velocity air samplers will be used and 4) Pat Barnes
suggested some sediment samples, which we will get together and choose and add to the sampling
plan. Ms. Burwell asked if what the State has put together includes the suggestions made by the
Science Advisors, because they should not move forward without the Science Advisors approval.
Deborah Ferruccio asked what protocol will be used to assure that the samples are independently
tested. Mr. Lancaster replied that the Science Advisors will be present when the State takes the
samples and will oversee the chain of custody.
Next, Mr. Kelly informed the Working Group of the States plan for methane gas monitoring. The
purpose of this project is to do methane monitoring for determining surficial liner integrity. He
said that if the liner system is functioning as designed, then gas should only be venting through the
existing air vent. In addition a weather station will be installed. The weather station will record
and provide real time data. These two projects will be done exclusively by the Division of Waste
Management (Division) personnel and with Division funds.
...•
I
NEW BUSINESS
EPA visit I Hankinson Letter
draft January 21, 1997 Meeting Minutes
Page 3
A draft letter to Mr. Hankinson was presented. Ms. Riley made a motion to sent the draft letter.
The motion was seconded and carried. The letter is to include the following:
I) A reminder of the issues in the original letter;
2) Ask EPA to keep the Working Group informed of its activities and
3) The Working Group would like to have the Science Advisors present during any sampling,
providing oversight.
Mr. Kelly advised that Craig Brown from EPA was in his office and said that EPA is planning to
do some sampling. Mr. Kelly informed Mr. Brown of the State's schedule for sampling and asked
EPA to take part in it. It was agreed that simultaneous sampling would be best, but there was not
commitment from Mr. Brown.
ADJOURNMENT
The meeting was adjourned at 8:20 p.m .. The next meeting was set for February 6, 1997 at 5:00
p.m ..
..
Joint Warren County/State PCB Landfill Working Group
draft November 18, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 4:08 p.m. Monday, November 18, 1996 by Mr. Ken Ferruccio. The meeting was held at
the Warren County Office and was co-chaired by Ms. Dollie Burwell. The agenda was
distributed.
READING AND APPROVAL OF MINUTES
By consensus of the Working Group the minutes from the October 23, 1996 meeting were approved
with two corrections. ·
UNFINISHED BUSINESS
Proper and Inappropriate Lines of Communication
There was not much discussion on this topic. As a result one member of the Working Group asked
how was the agenda prepared. Ms. Burwell advised that the agenda is usually prepared by the co-
chairs or the Technical Committee. However, since the co-chairs nor the Technical Committee met
before this meeting, the secretary called or faxed members seeking agenda items.
Press Conference
Ms. Burwell said that she understood that the co-chairs would have a conference call before .the press
conference to draft a statement from the Working Group. Then she was informed that Ms. Ferruccio
was planning to be on the conference call and to speak at the press conference. Ms. Burwell said,
"ifwe open the conference call and the press conference to one member of the Working Group, then
we must do so for all members." She added that she did not get the information about the conference
call until after the time of the call.
Mr. Ferruccio said that he thought there were to be two conference calls, one with the co-chairs and
one with the co-chairs and the Science Advisors. He contacted Mr. Barnes and Mr. Hirschhorn and
then contacted the secretary. After which a conference call was scheduled for Friday,
November 8 at 4:30 p.m.. Later, the time was changed to 6:00 p.m. and I assumed it was to
accommodate Henry's schedule, said Mr. Ferruccio. After dailing in for the conference call and
waiting several minutes, Mr. Ferruccio went ahead with the conference call without Mr. Lancaster
and Ms. Burwell. After the conference call, Mr. Ferruccio called Mr. Meyer's office to suggest that
someone be at the press conference to represent the State. Mr. Ferruccio agreed that the co-chairs
should have prepared a press statement. However, without participation from the other co-chairs he
thought that the Working Group should go ahead with the statements from the Science Advisors.
Mr. Mike Kelly advised that Mr. Lancaster was out of town and did not get back until 4:00 p.m. that
Friday and was not aware of a conference call until then.
...
draft November 18, 1996 Meeting Minutes
Page 2
Ms. Burwell said that after the last meeting she understood that both the Science Advisors would
make their own declarations. A draft declaration was prepared by Mr. Hirschhorn, which was
approved by the Working Group. Mr. Barnes did not have his declaration written, but was to have
his own statement as well. The co-chairs were to prepare a statement from the Working Group and
that did not happen.
Suggesting that we "chalk up" this one, Mr. Warren said we needed to have had a discussion and
assigned people to do certain things. He expressed concern that one co-chair felt he/she could not
attend the press conference. He added that we needed a coordinated effort, which we did not have,
but we did get some good points out at the press conference. Mr. Cooper added that the structure
of this organization does not lead to workability.
Saying that the media moves with him because they move with facts, Mr. Ferruccio added that facts
are what the media was given. He said the state papers spun their story toward the state and the
other papers/news stations spun their stories toward that citizens and the community. Ms. Burwell
said it is not about how the stories were spun, we are in an environmental justice arena. We have
to be careful what picture we send out. She stated, "why was the landfill put here? It was put here
because this is a poor African-American community. People of color should speak for people of
color. The Working Group should not have gone to a press conference without any people speaking
that represent the majority of the people in this community."
Mr. Warren suggested whenever there is a statement from the Working Group, all members
participate or delegate it to the co-chairs.
Ms. Bobbie Riley wanted to clear up the misconception that there was a statement from the Working
Group. She said that Ms. Ferruccio introduced the Science Advisors and they made their statements.
She added that she felt that they did a wonderful job.
Ms. Burwell said that she feels if the Working Group calls a press conference, they should have a
statement. Mr. Ferruccio agreed with Ms. Burwell and said since there was not participation from
all co-chairs no statement was prepared from the Working Group. Mr. Warren made a motion to
move on to the next agenda item. The motion was seconded and carried.
Policies for co-chairs and Science Advisors
Ms. Ferruccio motioned that this discussion be tabled. The motion was seconded and carried.
This discussion was tabled so that all co-chairs could participate.
Reappointment of Working Group Members
Mr. Warren motioned that this discussion be tabled. This motion was seconded and carried.
This agenda item was tabled so that all co-chairs could participate.
Status of Project Officer
draft November 18, 1996 Meeting Minutes
Page 3
Advising that he talked with Mr. Lancaster and Ms. Linda Rimer, Mr. Kelly said they liked the idea
that the Department would find a project officer or suggest one. Mr. Kelly added that he and Mr.
Patrick Waters have been working together. Their goal is to keep the project on target. He said that
Mr. Meyer has tried and that this is more than he can do . Mr. Kelly advised that Mr. Waters used
to work with the Superfund section, but is now pursuing his master's degree. He has come back to
the Division on a part-time basis, on this project.
Ms. Burwell said Mr. Lancaster reported that he would make a proposal to appoint someone from
within the Division of Solid Waste Management (Division). She said that we should table this
discussion and wait to hear from him. By consensus, further discussion was tabled, awaiting a report
from Mr. Lancaster.
Strategy for Funding
1) PCB Landfill Detoxification Project
Mr. Hirschhorn said that he is against going after federal dollars. Saying that there would be so many
hurdles to overcome and that could take three (3) to five ( 5) additional years. He said that we would
have to be in desperate need to pursue this option. If three (3) years from now the landfill is not
cleaned, then we might want to look at pursuing federal dollars.
Mr. Warren asked two questions about pursuing federal dollars. First was, "does not pursuing federal
dollars mean that we do not want assistance from the federal government and second, will sending
a letter to Mr. Laws, Assistant Administrator Solid Waste and Emergency Response of the U. S.
EPA, give the impression that we want the landfill to become a Superfund site?"
Mr. Hirschhorn said that if we show that there is an uncontrollable release of materials. Then the
State would be forced to act and if they did not, then the federal government would step in.
Ms. Riley said at the Technical Committee it was explained that if the EPA gets involved they will
not take in consideration the wishes of the Working Group. They would use the most cost-effective
remedy. If that remedy is incineration, then they would use incineration.
Ms. Burwell said that when we are talking about assistance for the EPA, we are not talking about
becoming a Superfund site. The EPA has some responsibility for the landfill being here and since they
have some responsibility, when we ask for assistance we expect it. Ms. Burwell said that she is a
citizen of this community and a person with political background. She asks that her position in this
community be respected.
Mr. Hirschhorn said the other part of the strategy is to compel the federal government and the EPA
to fulfill their legal obligations. These obligations are to hold the State to its responsibilities. He said
that it is not easy to compel the EPA to act; there is not one document in the State's files that show
draft November 18, 1996 Meeting Minutes
Page 4
EPA oversight since the completion of the landfill. Mr. Hirschhorn added that the EPA has not met
their requirements and assumed that the State would stay in compliance. The State has been out of
compliance since day one stated Mr. Hirschhorn. He said that the first thing to do is to get the EPA
involved. Mr. Hirschhorn said Mr. Meyer told newspapers that the EPA approved a leachate
collection system without the perforated pipe. There is no paperwork in the files to prove this.
The Division does not know how the plan got changed, Mr. Kelly said. He added that the
Department of Administration may have the document in their files; the State is trying to locate the
paperwork.
Ms. Elmore said the EPA should have a copy in their files.
Mr. Kelly advised that the State is sending a person to Atlanta Thursday (November 21, 1966) and
would have that person check this.
Mr. Hirschhorn said that before going public with this issue he spoke with Mr. Meyer. There is a
diagram that the EPA gave approval for and, a final plan that does not have the perforated pipe in the
leachate collection system said Mr. Hirschhorn. In January and February of 1983 the EPA was at the
landfill and published a diagram that had the perforated pipe in the leachate collection system. He
added that he has not written anything that says that the Division of Solid Waste Management is
responsible. He has always said the State is the responsible party, adding that it is not important
which division approved or changed the leachate collection system. What is important is that Mr.
Meyer said that the State would not have approved a landfill without a leachate collection system.
Mr. Barnes added that he does not believe that the leachate collection system that was to be installed
would have worked. It has not worked, said Mr. Hirschhorn. Jim Warren said that the State should
have tried that leachate collection system before the landfill was filled. Mr. Hirschhorn said that they
should have operated the system while the landfill was being filled. He said that you cannot have a
landfill without a functioning leachate collection system.
Ms. Daria Holcomb asked what are the ramifications if the EPA did approve the landfill without this
leachate collection system. If the EPA gave approval for a landfill without a leachate collection
system then someone could go to jail was the response from Mr. Hirschhorn. He added, "the State
is fundamentally responsible" and that he would be amazed if the EPA approved the landfill without
a leachate collection system.
Mr. Hirschhorn said that in 1982 everyone seemed to have thought that the landfill and incineration
were the only two options; they were not. They may have been the most cost-efficient, but there
were other options. Ms. Burwell said that Warren County was blamed for the lost oflives, because
the Highway Patrol was here and not on the highways. When the lost of lives are taken in
consideration, trucking the PCB contaminated soil to Alabama or incinerating it would have been less
expensive.
Next, Mr. Hirschhorn advised that EPA scientist measured some release of PCBs into the air. He said
in January and February of 1983, before the pumps were turned on in March, PCBs were measured
draft November 18, 1996 Meeting Minutes
Page 5
in the air. The PCBs were measured at two pipes, at the sumps, and in the lower and upper leachate
from the vents. However, no report was written which included this information.
Mr. Ferruccio said that it was reported that only methane gas was coming from the vents. Therefore,
there was no need for filters to be installed.
Mr. Kelly suggested that air sampling for PCBs be added to the sampling plan.
Mr. Barnes said that he is beginning to believe a statement made previously by Mr. Ferruccio that
Warren County was used as a sacrifice zone.
Status of Letters
The secretary was asked to contact the offices of Mr. John Hankinson, Mr. Elliott Laws, and
Secretary Howes to make sure that they had received the letters that the Working Group voted to
send them. She could confirm by this meeting that the letters had been received by Mr. Laws and
Secretary Howes, but had not heard from Mr. Hankinson. Ms. Burwell said that she does not see the
need to contact these offices for confinnation. We have given these offices sixty days to respond and
after that time if we do not hear from them, then we should contact them for confirmation. After
some additional discussion, Mr. Ferruccio motioned that the secretary seeks confirmation from Mr.
Hankinson's office. The motion was seconded and carried.
Ms. Monica Porter said that the meetings are beginning to get longer and when a meeting gets over
two hours we are not being productive. She said that we are not being considerate of the members
that have to travel; she suggested that the co-chairs get together and "clean house." Ms. Porter said
that a lot of time is spent with the co-chairs bickering and not taking care of business; adding that the
co-chairs should have met and had these discussions before the Working Group meeting.
At this meeting were several visitors, who live next to the landfill. One visitor, Mr. Massenburg
Kearney, said that he lives very close to the landfill. He said that living so close to the landfill, he is
very concerned about possible leakage. Adding that he had heard about the possibility of a
monitoring well being put on his property. He wanted to let the Working Group know that he has a
well on his property. It is not being used and he would allow it to be used as a monitoring well, if
it meets the needs of the Working Group. He said that the adjacent property owners are very
interested in what is happening and would like to get more information.
Mr. Patrick Barnes said that we should have a community forum, adding that it probably should have
been held before the press conference to inform the community. Ms. Burwell said that since the
press conference has occurred, we should not have a forum until the questions raised at the press
conference have been answered. Mr. Hirschhorn said that we should let the community know they
can come to this office and pick up documents, adding that he thinks a community forum is long
overdue. Mr. Copper added that the co-chairs are overworked. He said the co-chair should divide
and each work with other members of the Working Group, so they would not have such a heavy load.
There was concern expressed about whether the community members can understand the technical
draft November 18, 1996 Meeting Minutes
Page 6
information. Ms. Riley said that both Science Advisors could explain the information so that anyone
can understand. Reiterating the importance of a community forum, Mr. Hirschhorn advised that he
has had forums where people have come and asked questions and can understand the information.
It was suggested by Mr. Warren that a couple of people from the community get together and appoint
a committee to plan a community forum. Mr. Cooper said that the co-chairs should appoint and
structure a committee. It was the consensus of the Working Group that the co-chairs would appoint
a committee to plan a community forum.
Status of the RFPs
The report of the status of the RFPs was given by Mr. Kelly. He first informed the Working Group
of the RFP for soil removal, which will involve the integrity of the top liner. Mr. Kelly advised that
four companies responded to the RFP. The EPA advised that it will require thirty (30) days to issue
a permit for the removal of soil. Mr. Kelly said that once the company is selected that he would
pursue the permit from EPA.
The next report was given on the dioxin/furan testing. Mr. Kelly advised that•he has visited Triangle
Labs (Triangle) and toured the facility. He asked Triangle if they could lower their price, due to the
quantity of samples. They agreed and gave a considerably lower price. After which, Mr. Kelly called
other labs to check their prices. He got some prices that were about the same and some less. The
RFP for dioxin/furan testing was mailed November 6, 1996 and was originally due back two weeks
later. However, that date was changed because some additional information had to be included. The
new date for the respondents is November 27, 1996. Mr. Kelly advised that he asked the companies
to bid separately on having a scientist come and take samples verses having them sent Federal
Express. He advised that the standard turnaround time, for results, is 21 -30 days. Triangle was
asked to estimate the charge if the testing was completed in seven days.
The last report was on the monitoring wells. This RFP went out on November 6, 1996 and was sent
to twenty-two (22) companies. Nineteen (19) of those companies responded and were present at
today's (November 18, 1996) pre-bid conference. These companies were brought to the site and
showed where the twelve (12) additional wells would be placed. The response is due December 2,
1996. Mr. Kelly advised that he put out an addendum to this RFP for the three (3) off-site wells. He
advised that Mr. Larry Rose came to Warrenton and visited some sites and all three (3) sites could
be used. Mr. Kelly advised that all wells will be fenced and will be lOxlO. The fence will be 6 feet
high with 3 feet of barbed wire. There will be a 3 1/2 foot personnel gate. The estimated cost is
$6,000.00.
Mr. Kelly added that Mr. Barnes has been sent a copy of the Sampling Plan on disk so that he can
make the changes agreed upon at the last Working Group meeting. Mr. Kelly feels that the Sampling
Plan is at a point where it can be finalized.
Status of Landfill
draft November 18, 1996 Meeting Minutes
Page 7
Mr. Barnes estimates that the landfill is talcing on 1/2 inch of water per year. He advised that 26,000
gallons of water is leaving the landfill yearly, adding that this does not mean that the water is
contaminated. Mr. Barnes said he does not agree with the State's position that the fluctuation in the
water level is caused by gas production. If gas production was the cause of the fluctuation then we
would not see a steady rise in the water level. He added that the more rain there is, the more water
there is in the landfill. Mr. Hirschhorn stated that his latest report will cast some doubt on the State's
position as well . His opinion is that if there is that much water in the landfill, the State estimates 1. 5
million gallons, then you would expect to have some water passing through the lower leachate
collection system. He added that he doubts that the lower leachate collection system is functioning.
NEW BUSINESS
Mr. Hirschhorn asked about the status of the RFP for the technology company. At the last meeting
he proposed a 2 phase RFP for the technology company. Mr. Meyer was to put him in contact with
Ms. Doris Strickland to check the legality of the 2 phase RFP.
Next, Mr. Hirschhorn asked who would make the decision of which technology company would be
used; how will this decision involve the Working Group, the State, and the Science advisors?
Mr. Kelly said the Science Advisors and the State would work that out, adding that the Division of
Contracts awards the vendor. Mr. Cline said that the Working Group could make a recommendation
and if it is a good reasonable decision, then the State would agree and award that vendor. Ms.
Burwell said that the Working Group, by consensus, agreed that unless there is a disagreement with
the Science Advisors and the State that they would choose the vendor.
Other new business was the resignation of a Working Group member. Ms. Billie Elmore gave her
resignation. She cited the time involved to properly prepare for these meetings, the approaching
inclement weather, and the distance and time that she has to travel as factors in her decision. Ms.
Burwell motioned to accept her resignation and to forward a copy to Secretary Howes. The motion
was seconded and carried.
OTHER BUSINESS
None.
ADJOURNMENT
. The meeting was adjourned at 6:55 p.m .. The date of the next meeting was not decided.
AGENDA
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DATE: October 23, 1996
I. Welcome
II. Approval of Minutes .......................................................................... April 25, 1996
July 10, 1996
August 27, 1996
III. Unfinished Business
1) Report of Executive Meeting with the Science Advisors ............. Henry Lancaster
a) Update on Proposal
2) Six Point Plan For Actions ........................................................ Joel Hirschhorn
a) Decision making process and other issues
b) Federal and State Strategy
c) RFP and Technology Vendor
d) Detoxification Cleanup Goals
e) Water in the Landfill
f) Bioremediation
2.1) Recommendation from Technical Committee ..................... Deborah Ferruccio
3) Science Advisor's Pay ................................................................ Dollie Burwell
Ken F erruccio
3.1) Recommendation from Technical Committee ...................... Deborah Ferruccio
4) Sampling Plan ............................................................................ Patrick Barnes
4.1) Recommendation from Technical Committee ...................... Deborah Ferruccio
5) Report, Status, and Recommendation ofRFPs ........................... Patrick Barnes
Joel Hirschhorn
IV. New Business
1) Press Conference ....................................................................... Joel Hirschhorn
Patrick Barnes
Deborah Ferruccio
V. Other Business
VI. Adjourn
~ JOINT WARREN COUNTY/STATE PCB LANDFILL WORKING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Fax Cover Sheet
DATE:
TO:
FROM:
October 31 , 1996
Bill Meyer
DSWM
Doris Fleetwood
'l t);f
TTh'IE: _4;.0011, M.
RE: Minutes for October 23 , 1996 meeting
Number of pages including cover sheet: )i / Z
Message:
Mr. Meyer:
Here is a copy of the minutes that you requested I have not made my fine tunings yet. I ususally go
through the minutes several. I have one more read through before I am complete. So please forgive
any mistakes not yet corrected.
TO ·.:J CT :9T 96 , T£ lJO OOOT-lSC-6T6 :XE~
Joint Warren County/Sate PCB Landfill Working Group
draft October 23, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 4 :30 P . M. Wednesday, October 23, 1996 by Ms. Dollie Burwell. The meeting was held
at the Warren County Office and was co-chaired by Mr. Ken Ferruccio and Mr. Herny Lancaster.
The generic agenda was distributed.
READING AND APPROVAL OF MINUTES
There were three sets of minutes for approval. Ms. Deborah Ferruccio, in separate motions, moved
that the minutes from the April 25, 1996 meeting and the July 10, 1996 meetings be approved. The
motions were seconded and carried. Ms. Billie Elmore moved that the minutes from the August 27,
1996 meeting be approved. The motion was seconded and carried.
UNFINISHED BUSINESS
Report of the E.r.ecutfre Lommittee Jl,/eeting
The report of the executive committee meeting was given by Mr. Henry Lancaster. Mr. Lancaster
advised that present at the meeting were Ms. Dollie Burwell, Mr. Ken Ferruccio, Mr. Patrick Barnes,
Mr. Joel Hirschhorn, and Mr. Bill Meyer. :Mr. Lancaster said that discussed at the meeting was the
manpower and Mr. Meyer's ability to handle this project with all his other responsibilities. He advised
that a proposal will be made to designate a project officer from within the Division of Solid Waste
Management (Division) who would be paid by the Division through the remainder of this fiscal year.
After that period, funds to continue through the end of the project would be sought from the General
Assembly.
Mr. Lancaster also advised that membership to the Working Group ends for all members on
December 1, 1996. He said that there is consistent attendance to meetings by nine to ten members
and that the Working Group may want to take action on that issue. Ms. Burwell said that the
Executive Committee may want to meet and discuss the issue of membership before the next Working
Group meeting. It was the consensus of the Working Group to send a letter to the Governor before
December l, 1996 to advise that the Working Group would like to continue.
Six Point Plan for Actions
1) Decision Making Process
Mr. Hirschhorn recommended that the Working Group create a system to speed up the
decision making process; saying that if a process is defined then the Technical Committee
could get things done.
DJ .d CT :9T 96, T£ lJO OOOT -lSC-616 :XE~
2
2) Federal and State Strategy
Mr. Hirschhorn said that his analysis revealed that the Working Group should pursue a
Federal strategy. He suggested asking the State to perfonn a compliance audit of all EPA
permits for the landfill. In addition he recommended that the Working Group submit a written
request for EPA to perfonn an audit of the State.
Ms. Deborah Ferruccio, reporting for the Technical Committee, advised that Mr. Hirschhorn
has been asked to draft a letters to John Hankinson, Regional Administrator of EPA Region
IV and to Elliott Laws, Assistant Administrator Solid Waste and Emergency Management,
on behalf of the Working Group. She advised that the Technical Committee recommends that
theWorking Group approve these letters with copies sent to Congresswoman Eva Clayton,
Senator Frank Ballance, and to the National Environmental Justice Advisory Council
(NEJAC).
Ms. Burwell sugges.ted that the members take time now to read the letters and then they will
be discussed. After reading the letter to Mr. Hankinson, :Mr. Lancaster asked Mr. Hirschhorn
in what area( s) is the State not in compliance. Mr. Hirschhorn responded that he does not
believe that the State has never been in compliance, but that it is not now. He said that the
State has not done semiannual testing since the fall of 1994; the leachate collection has not
been done because the system is dysfi.mctional; and that water has remained in the landfill.
Mr. Lancaster asked how long the leachate collection system had been dysfunctional. Mr.
Meyer advised it was discovered in the fall of 1989. Mr. Lancaster asked Mr. Hirschhorn to
be prepared to document the areas of noncompliance.
Mr. Dennis Retzlaff voiced concern that the letter said that the State "failed to act or plan
to remove large amounts of water inside the landfill. 11 He said that the State came to pump
out the water and some members of the Worlcing Group were opposed to this action. The
State listened to their concerns and did not pump the water out. Ms. Burwell said the reason
some members opposed pumping, was because they were advised that the water would be
sprayed back over the landfill. Mr. Hirschhorn said that the State has a legal responsibility
for the landfill and if the State agreed to respect the wishes of some members of the Working
Group then they should have gone to EPA and asked for a waiver or approval.
Mr. Retzlaff suggested toning down the language of the letter. Ms. Burwell said that if
someone does not agree with the verbiage of the letter then they should suggest changes. :Mr.
Hirschhorn said that the EPA will do serious oversight only when it is pushed to do so. Ms.
Ferruccio said that the tone is necessary because the EPA has known about the
noncompliance and has done nothing.
Mr. Lancaster said that he would like to make three suggestions.
1) In any statement of lack of regulatory compliance, state specific technical
£0'd CT :9T 96 , T£ lJO OOO T-LSC-6T6 : <~'..:l
3
support.
2) Remove unconscionable and leave dangerous and unacceptable.
3) Remind Mr. Hankinson of his commitment to assist the Working Group.
Ms. Billie Elmore made a motion to accept paragraph five as written. The motion was
seconded with five (5) in favor and five (5) opposed. The motion failed . Mr. Retzlaff
suggested starting paragraph five by saying, .. The State should be held to the same
standards of industry," and suggested removing the present sentence. Ms. Elmore
made a motion to rephrase as stated above. The motion was seconded and carried. Ms.
Burwell added that it is the consensus of the Working Group to remove unconscionable It
was suggested to take out the following sentence: "The Working Group believes it very
important that EPA complete its compliance audit soon, because the full extent and impact
of the State's noncompliance should and will play an important role in the State's decisions
in coming months and public support for the detoxification project." This sentence should
be replaced with, "Consistent with your comnutment to facilitate the efforts of the Working
Group, we expect that this matter will be expedited." After more discussion it was decided
that this paragraph should start with the above mentioned replacement sentence. Ms. Elmore
motioned that the letters be forwarded as rewritten and signed by the co-chairs. Copies of
these letters are to be sent to Congresswoman Eva Clayton, Senator Frank Ballance and to
NEJAC. The motion was seconded and carried. Two members abstained from voting.
The second letter prepared by Mr. Hirschhorn was to Elliott Laws. Mr. Jim Warren
motioned that the letter be approved as written. The motion was seconded and
carried.
Mr. L. C. Cooper motioned that a letter be sent to the State for a compliance audit This
letter will be sent to Secretary Howes. The motion was seconded and carried. Mr. Meyer
recommended that the letter included specifics of what is to be included in the audit. Ms.
Ferruccio motion that the letter include specifics for the audit. The motion was seconded and
carried. One member abstained from voting.
3) RFP and Technology Vendor
Mr. Hirschhorn suggested that one RFP go out with two (2) parts.
I) The companies will bid on the bench-scale test at their facility, on materials
sent to them. The companies will be limited to two (2) technologies.
2) After the completion of the bench-scale test one (1) company will be selected
to participate in the design and remedy with the Science Advisors.
Ms. Ferruccio motioned to approve the two (2) phase RFP. The motion was seconded and
carried. One member abstained from voting
t'C1 'd OOOT-lSZ-6T6:XE~
4
Mr. Bames said that the first part of the RFP is the competition on how the company
can meet the goals of the Working Group. The other part is to select one company
to participate in the design of the remedy. The design will be a collaborative effort.
Mr. Meyer suggested that the Science Advisors check with Ms. Doris Strickland to
make sure it is legal to buy a certain amount of hours. Mr. Meyer advised that Ms.
Strickland is Chief Purchase and Contracts, Division of Administration for the Department
of Environment, Health and Natural Resources. He said that he would facilitate getting Mr.
Hirschhorn in contact with Ms. Strickland.
4) Detoxification Cleanup Goals
Mr. Hirschhorn advised that the Working Group must decide what concentration levels are
acceptable and how it relates to health risks. He advised a range of cleanup goals for PCBs
and dioxins and noted that the Federal standard is the least stringent. The least stringent level
is one or two parts per million (ppm) for PCBs and one part per billion (ppb) for dioxins. This
level of PCBs and dioxins equates to lin 10,000 health risks. He advised that companies
have only been asked to reach this level and this is where they have their experience. He also
advised that the level asked for in the RFP would be the preliminary cleanup goal. Ms.
Ferruccio advised that the Technical Committee discussed this issue and decided to
recommend to the Working Group that extremely stringent be used for the preliminary
cleanup goal and so motioned. The motion was seconded. Questions were asked about the
implications and cost estimate. :Mr. Hirschhorn advised that since no company had been asked
to reach this level that there is no information on how much this would cost. He did
advise that the co~1 would increase, but how much could not be detennined. Mr. Meyer said
that the extremely stringent level will be pushing technology to the edge and if materials have
to be treated twice, who pays for that. Mr. Barnes said that is why it is important to advise
companies in advance of the cleanup goals, so that this can be factored in before the bid is
made. The motion carried. One member abstained from voting.
5) Water in Landfill
This topic was tabled until Mr. Barnes gives hls report.
6) Bioremediation
Mr. Hirschhorn advised the Working Group to make it clear to the State that it wants
them to stop pursuing bioremediation. It was motioned that a letter be sent to the
Division of Solid Waste Management, with a copy sent to Secretary Howes, to formally
request that bioremediation be ruled out as a feasible remedy and to encourage the State to
stop using its limited resources to pursue bioremediation. The motion was seconded and
carried. One member abstained from voting.
9J"d 0CO l-LSZ-616:XEj dn□d9 9NI~d0~ 8Jd
5
Science Advisors' Pay
Ms. Burwell said that the Working Group needs to establish some policy concerning the Science
Advisors' pay. The Technical Committee recommends that all invoices be paid upon submittal to the
State. If a question arises on validity of invoices that should be turned over to the Technical
Committee for a recommendation. Mr. Warren made the motion to accept the recommendation from
the Technical committee. The motion was second and carried. Mr. Meyer added that invoices will
be paid according to State Administrative Payment Process. Mr. Lancaster said that he feels any
situation that deals with monies for payment should be handled by the Executive Committee. After
receipt of the invoice if the Executive Committee needs additional infomlation they will refer to the
Technical Committee. A motion was made that any situations dealing with monies for payment of
invoices be directed to the Executive Committee, within three days of submittal to the State. If any
additional infonnation is need the Executive Committee should refer to Technical Committee, within
three days of receipt. Recommendations will be made by the Executive Conuuittee. The motion was
seconded and carried. One member abstained from voting.
Sampling Plan
Mr. Barnes advised that he and the State had discussed amendments to the Sampling Plan, but they
had not been included in the draft Sampling Plan. (Please review ·the memo with subject
"Amendments to the Draft Sampling Plan Dated, October 2, 1996"). Mr. Barnes would like to
iuclude his amendments as an appendix to the sampling plan. It was advised that there will be no
split-sampling Ms. Ferruccio said that if there in no split-sampling, how will the Working Group
know that the community is protected. Mr. Barnes advised that he will be on the site and that he will
be in charge of the labeling. He said that the companies will not know what they have other than that
it is a soil or a water sample Mr. Barnes added that dedicated samplers should be used for each
well. Therefore, there would be no problem with whether the equipment was decontaminated.
Mr. Barnes stated that the supplemental Sampling Plan mentioned collecting samples at each boring,
He said that there are a few items that he would like to see added and they are as follows:
1) Amend the Sampling Plan to include two ~oil samples in each of the three wells close to the
landfill and in the background wells, for PCBs and dioxins.
2) No other sample needs to be taken at the confluence ofRichneck Creek and the Unnamed
Tributary. Leakage will show best at the delta, where the two bodies of water meet.
3) Sediment and surface water samples are to be field selected by Mr. Barnes, with the consensus
that the Working Group approves the amendments to the Sampling Plan.
4) And the the Working Group should establish a process for further amendments
Report, Status, and Recommemk1tio11s of RFPs
There are three (3) RFPs to deal with. First a contractor needs to be selected to perform extraction
of materials. The Science Advisors and the State have ranked the four proposals they received. By
90 'd OJOT-LSC-616:XE~
6
consensus the State and Science Advisors, Patterson Exploration Services will not be considered.
They received that lowest ranking from each party. Mr. Hirschhorn ranked Triangle Environmental,
Inc. (Triangle) first, however after discussing their bid with Mr. Barnes, he feels that their bid may
not have included all factors. The Science Advisors, both have put three calls in to Triangle to verify
what is included in the bid; there has been no response to their calls. Therefore, Triangle is being
ruled out. Mr. Hirschhorn proposed that we enter into negotiations with Camp Dresser & McKee
(CDM), since they were ranked first with the State and second with both the Science Advisors. The
negotiations will include the price) schedule and scope of work.
Mr. Mike Kelly submitted to the Science Advisors and Mr. Meyer a draft RFP for dioxin/furan
analysis. Mr. Barnes advised that there would be fifty to sixty samples taken and that the Working
Group approves this RFP. Ms. Ferruccio motioned that the Workjng Group accepts the draft RFP
for dioxin/furan testing. The motion was seconded and carried. Mr. Meyer advised that six
companies will be selected for the dioxin/furan testing. He advised that the RFP should be out by
the end of next week (November 1, 1996) and will give the companies two weeks to respond.
The RFP for well installation, Mr. Barnes felt was very important. He suggested five amendments
and they are as follows:
1) The diameter of the proposed wells will be four inches in diameter'.
2) The proposed wells will be constructed of type 316L stainless steel.
3) The depths used for bidding purposes shall be 45 teet for the shallow wells and 90 feet
for the deep wells.
4) If necessary the contractor will attempt to drill past potential shallow obstructions a
minimum of three times.
5) The supplemental sampling plan be included as a working plan for the RFP.
Water in the Landfill
Mr. Barnes has ploned the water in the wells and in the landfill on the same graph. He advised that
a few conclusions can be drawn from this graph. One important conclusion is that there stands a
sutlicient chance that the landfill is tak~ng on water and water is leaving. Mr. Meyer said that he
disagrees and believes that it results from gas production. Mr. Barnes said that he does not ab'Tee
with the gas production theory. He stated that with gas production you would expect to see highs
and lows and not a steady increase. Mr. Meyer then asked Mr. Lancaster, "do you hear what Patrick
is saying, that the top and bottom liners are leaking." Then, Mr. Meyer said that since the system is
monitored through a one inch pipe that there may be an alternate explanation. Mr. Hirschhorn said
that he wanted it on record that he agrees with Mr. Barnes explanation. Mr. Meyer advised that he
would send out his infonnation for a peer recommendation. Mr. Hirschhorn suggested that Mr.
Barnes infonnation be sent to the same company for peer review.
Ms. Burwell said if the Science Advisors or the State wants a peer review then the Working Group
should know what is being peer reviewed and should agree on who will conduct the peer review, so
7
that there is no conflict of interest. After a peer review is done, it should be reviewed by the Working
Group first. Ms. Elmore motioned that the Working Group accepts the recommendation for a peer
review. The motion was seconded and catTied.
Mr. Meyer advised that next week the State will be putting a two-inch pipe with a tape that will give
a daily read out. Ms. Burwell asked why the State was just doing this. Mr. Meyer responded that
he has always believed that pressure is the cause of the water fluctuation in the landfill, but could not
prove it. Ms. Burwell said if the State felt that the water fluctuation was the result of pressure and
could not prove it, why did they wait until now to take action to prove it. She also said that the
Working Group should have been advised before hand that the State was planning to take this action.
Mr. Ferruccio asked if a well would be put in and Mr. Meyer advised that would be putting in a four-
inch hole with a two-inch pipe.
Mr. Lancaster asked how long the State would need to prepare a report in response to Mr. Barnes'
report. He also asked if more accurate infomiation was needed before the peer review was done and
if the peer review would include recommendations as to the next step. Mr. Warren said if the peer
review can be done without holding up the process, let's do it . He believes the people who say that
the landfill is not leaking will always believe that it is not leaking no matter how many peer reviews
say otherwise. Ms. Burwell said that we don not want getting the landfill detoxified tied to whether
it is leaking. Mr. Hirschhorn said that saying the landfill is leaking should only be important because
it is not secure and therefore not safe. It is the consensus of the Working Group to give Mr. Meyer
a week to get his report ready and he will be given a chance to defend it. When the reports are
complete, they should be sent to the Working Group office to be forwarded to the Technical
Committee for review. After reviewing the reports, the Technical Committee will make a
recommendation.
NEW BUSINESS
Press Conference
Mr. Hirschhorn advised that at the Technical Committee meeting he presented a draft declaration of
feasible technology and that he now has a final version available. He also presented a statement that
he prepared as Science Advisor to the Working Group. Mr. Lancaster said that he liked the
declaration, but that the statement was inflammatory. Ms. Fem1ccio said that she wants the public
to know that everything had not gone smoothly and that the process has been delayed by the State.
Ms. Burwell advised that the Technical Committee is recommending to the Working Group to hold
a press conference. The date suggested by the Technical Committee was October 31, 1996 at 10:00
in the morning. Mr. Hawkins said that he agrees that the Working Group should not inflame the
State. There was agreement with several Working Group members that a few days before election
was not a good time for this release. They sited that a press conference would not get the media
attention that it deserves due to the elections. Mr. Hirschhorn said that he feels that the time to get
a politician to make a promise is during an election. Ms. F em1ccio agreed, saying that once t~e
Governor is in office, he's there and it will not matter to him because he cannot run for office agam.
SO 'd
8
Mr. Lancaster said that the focus should be on the declaration oftechnolof,ry. The media would be
shocked to hear that the Working Group and the State are releasing the same document. After
additional discussion, a motion was made to hold a press conference a week after the election. The
motion was seconded and carried. A press release will go out on November 11, 1996 to advise that
a press conference will be held the following day. At the press conference the declaration of feasible
technology will be released with the concurrence of the State. Also, released will be the request
made to the EPA and the State to perform compliance audits. The press conference will be held at
the State Capitol Building, Tuesday, November 12, 1996 at I I ;00 A M ..
ADJOURNMENT
The meeting was adjourned at 8:55 P. M .. The next meeting is scheduled for Monday, November
18, 1996 at 3 :30 P. M.. There will be a Technical Committee held on November 12, I 996 after the
press conference.
60 'd 0001-2.S,3-616: X'E'.:1
ORIGINAL COPY OF MEETING
MINUTES IS KEPT IN PRISCILLA
TYREE'S OFFICE. CONTACT
PRISCILLA TYREE OR PAT
WILLIAMSON FOR COPY/REVIEW OF
FILES.
TO: WORKING GROUP MEMBERS
FROM: DORIS FLEETWOOD
DATE: SEPTEMBER 24, 1996
RE: SEPTEMBER 26, 1996 MEETING
DEAR MEMBERS:
I HA VE BEEN ASKED TO TAKE A POLL OF THE WORKING GROUP MEMBERS TO
GET YOUR OPINION ON THE SCHEDULED MEETING FOR THURSDAY, SEPTEMBER
26, 1996. I HA VE SPOKEN WITH MS. BURWELL, MS. HOLCOMB, MR. FERRUCCIO,
MS. FERRUCCIO, AND OTHERS WHO FEEL THAT TIIB MEETING SCHEDULED FOR
THURSDAY WOULD NOT BE PRODUCTIVE. WE ARE STILL WAITING FOR SOME
INFORMATION REQUESTED AT Tim LAST MEETING. MR. MEYER HAS A DRAFT
RFP FOR SOIL REMOVAL. HE ALSO ADVISES THAT HE WILL HA VE A DRAFT
SAMPLING PLAN AVAILABLE FOR THURSDAY'S MEETING. HOWEVER, TI-IE
TECHNICAL COMMITIEE HAS NOT MET AND DISCUSSED TIIE DRAFT RFP NOR
THE DRAFT SAMPLING PLAN. PLEASE CALL WITII YOUR OPINION OR FAX TIIlS
MEMO BACK TO ME WITH YOUR OPINION.
THANK YOU.
rY\ ~ . ffi o ll I c Q.., 7 6 (ch~ r <.
m R 1-i 0,.1 e~ lei-µ ca~ -4.~ (<..
lclu e.o.. ~,A,-\-\ t:, e
IC>(Y\ (f\~ C, \I~ e...,
'3, I 1i·~ E..1 rho<?-c.
1°\ \"Y'. \\f O--Kl'Z. t.Al
Y'J l \ \ i !l. Y'Y\ ff\ '--~ ~ (l_
······-··· ........... _________ _
80 :tl 96, vl das OOOt-LSl-6t6:XP~ drl0d9 9~lDklm 8Jd
~ MEETING REMINDER
The Joint Warren County/State PCB
Working Group will meet on
Thursday, September 26, 1996
at 4:30 pm in conference room of the
Warren County Office
To: Mr. Hemy Lancaster
Ms. Laura Butler
Mr. Tommy Cline
Ms. Billie Elmore
Mr. William Meyer
From: Ms. Doris Fleetwood
PCB Working Group
Secretary
Total Pages 14
TO"d £0:vT 96, £C das OOOT-lSG-61 6:X~~
August 29, 1996
To : Technical Committee
From: Joel Hi.rsc.hhom
Subject: Recommendations on decision making process and several actions
en rr0sw
A) My advice is that the TC and WG use a more formal means of comm\lnicating requests
to the state. Thcte is a need to prepare carefully written memos or Jetten from the WG to either
Bill Meyer or a higher state official. Verbal requests or motions at meetings, such as what
happened this week on the issue .J raised about EPA permits for ramoving materials from the
landfill, are inadequate, unless they are followed up immediately by a wrlttea document that
precisely spells out the details of the request. Details and creating a documented record of
requests and responses are very important in these matters.
B) My advice is that the TC adopt a &tandard procedure for .ma.king decisions about
actions recommended by the Science Advisou. I am referring to action memos, not inf ormatfona.l
memo,, nor submission of work products. My rccoimnended proceu is:
1. The SA faxes an action memo for the TC to the WG office for immediate distribution
by &x to TC members and the other SA.
2. The office arranges for a phone conference eall 'Within 24-48 hou.r:s for the TC r.o
discuss and make decisions on recommended actions.
3. During that call with the S~ the TC asks questions and cliseussei action
recommendations and either makes decision(s) on action ite.m(s), allowing followup activities by
SA(s), or some other decision is made. SCGrctuy maintain, minutes of such calls.
4. Within 24-48 hours:
a) As appropriate, the SA(s) f.axes a work product to office for distribution to TC
(unless instructed to take sotne other action directly, such as sending a memo or makin.a a call to
son1e party on behalf of the TC or WG) to facilitate the TC or WO irnplemcoting the decision.
OR
b) The TC o.-WG takes final action. Secretary .keeps record of exactly what is
done.
1
000 1-LS?-616:Xe~
q) fdsnl str1'F1Y
My advice is that the TC con.sider and the WG adopt the following strategy to initiate
steps to build a case for fedetal intervention and actions tb•t support the goal of dotoxi.fication of
the landfill. My analysis of the histoiy of this situation lead, me to conclude that the en.tire
strategy oftbe community has been to dq,end on eventually obtaining the desired decisions aJJd
funding from the state. this stxategy has several dit.advantages, not the: least of which are: a
fundamental conflict of intetest the state has between being the owner and operator of the land.fill
as wen as the protector of public health, and all of the difficulties m building a technical
environmental, and economic case sufficient to obtain substantial state funding. My
recommmdation i~ that it is in the community's interest to develop a parallel strategy that i~ based
on the plausibility of forcing fede,a.I intere~, answers to request.t, and various .interventions or
official positions that provide either pressure on the state to take certam actions, or supply
irnportint support for what the WG recommeu.d$ to the state.
There are three immediate action reoommaulations:
a) The WG should submit a writtCll request to the state for a compliance audit and
summary report giveu to the WG within 30 days. The WG would ask very specific, carefully
ctafted questions, based largely on various federal requirements that the state wa, required to
satisfy,
b) The WO would submit a written request to the EPA Region 4 Administrator to conduct
an official EPA compliance investigation under TSCA for the landfill, based on EPA extmiruttio.a
of its records~ state roe-0JdS., at1d a f.tcility inspection, if necessary. The .ueed for very C"Jledient
implementation would be made. Specific concerns would be identified.
c) The WG would submit a written request to Assistant Administrator Elliott Laws at
EPA ffcadquutcrs for his office to examine specific policy issue, under CERCLA/National
Contingency Plan by asking key questions affecting potential cleanup of the landfill. The Jette,
wowd cite the details of the agreement betweeu the EPA and the state, in the form of a
.;(;;"Op!lfll~•:gi:~-iliat was funded uude:r CERCLA/Superfund. Specific policy
determinations would be requc.s,ed Oil specjfic isyucs, such as whether the current fonD of the ·:,, .
NCP applies to the landfill, ud whether the statutory requirement for review of the remedy evecy
.five years applies.
l3) §trtSSIY (or 1ft (pc gizyipipg I tesh.gqlggy ygpdqr
The issue is .how to mo$i efficiently follow state requirements for obtam.wg detox,fication
techo.ology COWJlanies for co.nduetin.g bench-scale tests and for one selected company to assist the
SAi and WO in preparing a conceptual design of the desirod remedy fo.r inchision in the pr(;posal
to the state le;is1-tw-e. My idea is to use one RFP to cover both activities to save considerable
2
OOOT-lSc-616:Xe~
time. My recommendation is that the WG consider my proposal and fonnally submit st to the
state and ,eek a dcd~ion on whether it can be implemented in its present fonn or how it can be
modified to meet state legal r~uitements.
The key components of the proposal ale~
•· The RFP would be described as the 90licitation of a contractor that after completing a
successful bench or pilot scale test of detoxification technology will provide professional seivici:s
in developing • conceptual engineering design of the full remedial action at the landfilL including
an onsite deoJ.onstration test prior to full !.Cale use of the selected detoxification technology.
-· The RFP would de.tine the following step, for iutereaed parties;
a) Based on information given in the .RFP (in.eluding site background, aud scope of work
for test) 1 to 3 vmdots will be selected on the basis ofAubmiUcd proposals to conduct a bench or
pilot scale test at their own facility on lan.dfill materials provided to them.
b) After th.e selected companies submit the required repons on test results and provide any
additjonal information required, one company shall be selected to provid~ tbe con.cepwal design
services, bas.ed on bot.b. the test results; other information provided, and the bids m the compauy's
proposal.
•-The RFP would ask for proposals that must contain ocnain types of information,
including !,ids for the initial testing and. if selected, for the design services, ba&ed on scopes of
work for the two phases given in the kFP Teclmology ccmpanie$ would be urged i11 tht RFP to
select a ,ubcontractor ( such as an environmental design and eogio.eering firm) that has the
capabilities to contribute to the conceptual design of the total remedial action based on but nett
limited to the detoxification technology.
--The state would enter into an. initial contract with tho c-oropmies selected for the bench
or pilot tests. This contract would ctn1taiD. a provision stipulating that the company is being pi:e-·
qualified or short-listed by virtue of being selected to conduc1 the test fo.r final selection as the
provider of the design service1 and that no other RFP will be .Issued by the state. Subsequently,
after ooc comp&ny is selected, the state woulcl enter into the &al contract for !he pro,ui.011 of the
design ser.ioes.
Hl Pct2!:WS1MPP slseove c0ek
In order to obtain useful bench scale tests1 it will be necessary to iDform potential v~ndors
in the llfP what the numerical goals of the detoxifioati11n are for key contamh,.ants. In other
word~ we mu.st apecify what leve.1 of PCBa md dioxms are acceptable in. residual treated
materiab that would, ptesumably, be backfilled into the exca\·ated landfill. These levels would be
3
!70'd vo: VT 96, ~z das OOO T-lSc-6T6:Xe~
the prolirnmary cleanup goals (PCGs) or pmonnance requ.irerwmts fur waste ueatment. They
would be given as preliminary ones, mainly because they might be changed after all the test results
are obtained ( either increased or decreased).
The technical problem is deciding on what basis to use for the PCGs. There are two
principal approaches. A regulatory cleanup level may already exist that either must be used or
may be used. For example, certain file docuxnents indicate that EPA would require treatroent to
achieve a level less than 2 ppm for PCBs, but the state may typically tequire less than J ppm
(parts per million). Whenever a state has a more stringent requirement than. EPA. the state one
prevails.
The second approach is to use health risk based cleanup standards. Some risk based
concentrations aheady exist in the fonn of EPA generic Supe:rfund Soil Screening Levehi. These.
however, are based on certain specific exposure and riSk assumptions that may not be complete))
applicable at specific sites. When they are not, only a site specific risk assessment can generate
othtr numbers. There •re DWIY tough issues for such risk as~essments.
Consider PCBs, EPA data rcweal a 10·6 can~er risk level for residential soil ingenion
exposure of?0 ppb (puts per billion). However, EPA uses a value of 1 ppm (1 ,000 ppb) as an
SSL and under its PCB clcmup guidance. This means that l ppm equals a risk of I. 4 ~ 1 o-~ ( a
tenfold higher risk).
But if dioxins a.re al,o present, they must be considered. H dioxins: only are cc;msjdered,
the11 tbe 10·" cancer risk level is 2 ppt (parts per trilllo.o) for cumulative ingestion, inhalation, and
dermal exposure to swface soil or 4 ppt if only ingestion is considered. EPA often attempts to
U$e a very higb .level of l ppb for soil cleanup deci$ions, which is blatantly unacceptable. [I do not
now have a risk based concentration for PCBs based on three e,cpo&"Urc pathways, which would
be less than 70 ppb, possibly around 40 ppb.J
If both PCBs and di.oxins are present, however, then c:unmlative risk must be considered,
meaning that levels BELOW the I 0-6 levels obtaitted for them individually would correlate with
Jo-' cumulative risk.
The problem is whether detmcificatio.n tecluiologies can achieve very Jo,,. 1esidu31
c;ontaminut levels corresponding to to·' risk le\:els. Therefore, while PCG5 cm be set very
strlogently, actual tea data may show that no feasible detoxification tc:chn.ologJ can meet them
reliably aa.d consistently ( eq,ecially with varying wute inputs., in terms of contaminant ll>.d water
levels, for example). In other words, the teclutical feasibility of detoxification tecllnology for th.is
application will depeud on exactly what cleanup perfonnanee requirements ate demanded. The
woJe protective the WG wants to be, the greater the probability that no fcuible technology cm be
shown to exist. One of the more subtle i5$UCS that must be con$idered is wheth~r typica.l e,<posure
pathways are relevant for the site after post•treatment residuals are backfilled into the hildiill. Ill
other word$, if treated residues are buried in. the ground and rovc:red with olean soil. tb.eo there
4
SO "d SO :u1 96, £G das 0001-lSc-616 :Xe~
may be uo plausible exposure pathways ( as long as the containment 1emain~ e.ff ective ), because
people will not il.gest the materiaL or inhale airbome particles1 or have direct dennal contact ""ith
the material. The.re might be some concern about leaching of the contaminants over time into
groundwater, but because both PCB, and dioxins have low water solubility and high soil
adsozption, such leaching an.d migration will normally result iu much higher acceptable levels than
those obtained on the basis of cancer risk.
EPA often uses this reasoning to _justify higher acceptable clean:u.p levels. In the extreme,
it justilic1 NO treatmmt because hazardous chemicals are buried in some type of containroi;ut
system.
The WG must decide what cleanup goah to u.se. Here are some alternatives:
--Least stringent l or 2 ppm for PCBs and 1 ppb fo, dioxins (max 5 x 10·• risk)
··Stringent: 70 ppb for PCBs and 4 ppt for dioxins (4 x 1o•ei)
--Very stringent: 40 ppb for PCBs and 2 ppt for dioxins (2 x 10·6)
--Extremely stringent: 20 ppb for PCBs and 1 ppt for dioms (max l x 10.r, risk)
(All of these risk figures ignore synergistic effects.]
Note that consideration of noo•caocer health effects gm er ally results in higher
contaminant leveli th.an those obtained on the basis of cancer risk assessment.
A practical problem is that if the RFP cites very low cleanup levels for PCBs a.o.d dioxins
in residues., SOJM companies may .not be interested in pursuing the work.. Or, companies may
pursue the work, but have to increase the intensity of th.eir treatment, or plan on retreating some
residues, that would in.crease costs substantially. The mcreni.ental treatment cost in.creases for
incremental risk redllctlons can be very large.
My recommcnd•tion i$ that the WG use the Stringent alternative above as PCGs,
recognizing that the RfP will .wake clear that the lowest possible residual contaminant levels are
desired, cvnsisteot with obtainin.1 a oost-effect.ive cleanup, an.cl that the test results from tl1e
several vmdors selected for tb.e testing phase and other information they provide will be-used to
select final cleanup goals. Aflo.--the WG mues a decision, I recommend that the $1.ate be
informed in writing of that decision and ask~ for it, concw-rence.
A major complication fot detoxification .is the presence of water m the landfill, because it
affects technology perfurmao.ce and cost. There is a need for more coxnpltte and reliable
infonn.ttion from the state to assw-e that the RFP and design of the bench scale test is 1dcquate.
My -recommendation is that the WO sub.Dlit a written request for infomiatioa to tho stat~. 111e
request would be for a technical summary of all ley information on water iu the landfill. and
5
90'd 90:vr 96, £c das OOOT-LSZ-616:Xe..:J
. ,
answers to specific technical questions. Note the interest is NOT on what caused the water, but
rather o.n the details deaoribing the nature of the current water.
(6} Biorsmsdiafio,a
I have seen evidence that the state is still puuui11g biorcmcdiation as a means of
detoxifying the lmdfill . .I have concluded that no form ofbioremediation is a candidate for
selection as a feasible technology for this applieation. Three other evaluations over the years also
reached that 1:ooclusion. Therefore, I recommend that the WG formally request the It.ate to stop
all aetivities re.lated to bioremed.iation use for the Jan~ because their resovces ue far toll
limited and are needed for many other more important activities .
6
90 :vT 96, £l das OOOT-lSc-616 :X2j dr)Ocl9 9N Dl~□r~ 8Jd
Joint Warren County/State PCB Landfill Working Group
draft April 25, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called
to order at 4:28 P.M. Thursday, April 25, 1996. The meeting was held at the Warren County
Office of the Working Group and was called to order by Mr. Ken Ferruccio and co-chaired by
Ms. Daria Holcombt Mr. Ken Ferruccio, and Mr. Tommy Cline. A generic agenda was
distributed.
READING AND APPROVAL OF MINUTES
It was suggested by Ms. Priscilla Tyree that minutes from February 22, March 7, and March 28
meetings be approved. Co-chair Mr. Ken F erruccio disregarded the suggestion to approve the
minutes from the last three meetings.
UNFINISHED BUSINESS
None.
NEW BUSINESS
Mr. Joel Hirschhorn introduced the Master Planning Project. He began by discussing the
Important Reasons for Changing Current Strategy. They are as follows:
1) Field testing of small amounts of site waste will not provide infonnation
that is more useful then bench-scale testing;
2) Costs of two field tests would be extremely high;
3) It is necessary to examine other detoxification technologies;
4) Current approach would not provide sufficient detailed information; and
5) A much stronger case for funding can be made by spending money on
more thorough site investigation and remedy design.
Next, Mr. Hirschhorn discussed the Key Steps of Recommended Alternative Strategy. They are
swnmarized below:
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
11)
12)
so·d
Detailed evaluation of detoxification technologies and vendors~
Initiate site investigation;
Design soil/waste removal plan/select vendor;
Issue feasibility study report~
Invite vendors to conduct bench-scale treatability tests;
Science advisors evaluate test results and select/rank vendors;
Finalize site investigation report;
Working group meeting with highest ranked vendors;
Best technology vendor selected/pre-qualified for actual clean-up;
Selected vendor is hired as design contractor (under curren.: funding);
Remedy selection and remedial design report; and
Report used as the basis for Working Group/DEHNR formally_
proposing the landfill detoxification project to the State Legislature
to obtain funding.
lO :vT 96, £G das OOOT -lSG-616 :X~~ dn□cl9 9N DklOfll 8Jd
draft April 25, 1996 Working Group Minutes
Pagel
Mr. Hirschhorn advised that after all infonnation has been gathered this approach will provide
the state with the information needed to provide funding of the detoxification project without
needing additional tests preformed. Mr. Hirschhorn then asked for questions, then the meeting
was turned over to Science Advisor, Patrick Barnes. Mr. Barnes continued with the Master
Planning Project, starting with Site Investigation Goals, the reasons for additional testing and
they are as follows :
1) Establish conditions of liner;
2) Bedrock condition and topography;
3) Transmissivity of weathered rock zone;
4) Direction of ground water flow;
5) Identification of contaminant plume; and
6) Types and amounts of contaminated media requiring clean-up .
Next, Mr. Barnes discussed Site Investigation Activities) what steps would be necessary and
they are summarized below:
I) Collection of samples to conform with permit requirements~
2) Analyze existing data;
3) Develop and implement field sampling and testing plan;
4) Non-intrusive testing (Geophysics);
5) Soil borings~
6) Installation of additional monitoring wells; and
7) Collection of additional surface water and sediment samples.
Lastly, Mr. Barnes introduced the Master Plan: its purpose, its contents, and its implementation
schedule.
The purpose of the Master Plan is to serve as a:
l) Guidance document;
2) Road map;
3) Operation document; and
4) Stand alone document.
The Master Plan contents are outlined below:
PRELIMINARY TABLE OF CONTENTS
1.0 INTRODUCTION AND BACKGROUND
1. I Site History
1.2 The Working Group
I . 3 The Role of the State
LO :v1 96, £c das OOO T-LSc-616:Xe~ dn□cl9 9t·ff>kl□rl 8Jd
draft April 25, 1996 Working Group Minutes
Page 3
L 4 The Role of the Science Advisors
2.0 PROJECT GOALS AND OBJECTIVES
2. l Mission Statement
2.1 .1 Impact Assessment
2.1.2 Detoxification
2.1.3 Community Involvement
2.1.4 Responsibility of the Working Group
3.0 DEVELOPMENT OF FEASIBILITY AND REMEDY SELECTION REPORT
3 .1 Detoxification Technology and Vendor Evaluation
3.1. l Review of Past and Current Approach
3. 1. 2 Comparative Analysis
3.1.3 Recommendations
3.1.4 Work Plan for Treatability Testing
3.2 Landfill Soil/Waste Removal Plan
3.2.1 Review of Current Approach
3.2.2 Soil/Waste Removal and Vendor Selection Procedure
3.2.3 Testing Requirements
3.3 Treatability Testing
3.3.1 Bench Scale Testing Results
3.3.2 Analysis of Data
3.3.3 Recommendations
3. 4 Remedy Selection
3. 4. l Effectiveness/Performance
3.4.2 Safety/Environmental Impacts
3.4.3 Cost
3. 4. 4 Comparative Analysis and Recommendations
3.4.5 Role and Responsibility of the Working Group
3.5 Procedure for Establishment of Remedial Goals
3.5. I Evaluation of Test Results
3.5.2 Ranking Procedure
3.5.3 Performance Standards
3.5.4 Responsibility ofWorking Group
3.6 Procedure for Selecting and Awarding Detoxification Design
Contract
3.6.1 Role of Science Advisors
3.6.2 Role of Working Group
3.6.3 Role of State
4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
4.1 Site Investigation
OT 'd 0001 -LSG-616:XPJ
draft April 25, 1996 Working Group Minutes
Page4
4.1.1 Review of Past Sampling and Analysis
4.1.2 Field Sampling and Testing Plan
4 .2 Landfill Integrity
4.2.1 Leachate Collection System
4.2.2 Liner Condition
4.2.3 Water in Landfill
4.3 Scope of Off-Site Impact
4.3.1 Soil
4.3.2 Groundwater
4.3.3 Surface Water
4. 3 .4 Sediment
4.3.5 Air
4.4 Conta.rnitwlt/Waste Releases
4.4.1 Fate and Transport
4.5 Estimates of Volumes Requiring Remediation
5.0 REMEDIAL DESIGN
5.1 Roles of Technology Vendors, Science Advisors/State
5.2 Site Layout and Logistics
S .3 Construction Phasing
5 .4 Health and Safety Concerns
S .S Impact Monitoring
5.6 Detoxification Field Pilot Test
5. 1 Preliminary Design and Operation Plan
5.8 Clean•up Cost Estimates
6.0 LEGISLATIVE FUNDING
6.1 Briefing Document
6.2 Presentation Procedure and Materials
6.2.1 Role of Working Group
6.2.2 Role of Science Advisors
6.2.3 Role of State
7.0 PROJECT SCHEDULE
Below is listed the Master Plan Implementation Schedule.
ACTIVITIBS
1 ) Master Plan development
n ·c1 so:v1 96 , £c d8S
TARGET DATE
May 15
&)Od9 9Nn::J□rl 8Jd
draft April 25, 1996 Working Group Minutes
Page 5
2) Detoxification TechnologyNendor Evaluation June 15
3 ) Site Investigation August 15
4 ) Soil/Waste Removal June 15
s) Treatability Testing August 15
6) Feasibility Study September 15
7) Remedial Goals October 15
8) Vendor Screening & Awarding of
Detoxification Contract November 30
9) Site Investigation December 15
10) Remedial Design/Remedy Selection Report December 31
11) Legislative Funding April 30
Questions were asked by Messrs. L. C. Cooper and Ken Ferruccio, and Misses Deborah
Ferruccio and Daria Holcomb. The questions concerned whether the Working Group, if they
approved the entire Master Plan, would have the opportunity to give their opinions and approval
on each phase of the Master Plan before it is carried out After these concerns were voiced and
after much discussion. co-chair Mr. Ferruccio restated the motion to accept the Master Plan
with the understanding that the Working Group would approve each phase of the Master Plan
before implementation. Mr. Cooper, who had earlier made the motion to accept the Master
Plan, reminded Mr. Ferruccio that a motion was already on the table. The original motion was
seconded and carried. Ms . Daria Holcomb opposed the motion.
Mr. Joel Hirschhorn asked ifit were possible that a smaller number of people could be contacted
when they were in need of a quick response. After discussion, it was moved and seconded that
the Technology Group would be responsible for working directly with the Science Advisors
when time is short. It was moved and passed that the Technology Group.
ADJOURNMENT
The meeting was adjourned by Co-Chair, Mr. Ken Ferruccio at 5:55 P.M. The date of the next
meeting is Thursday, June 20, 1996 at 4:30 P.M ..
Doris R. Fleetwood
Warren Cowity/State PCB
Working Group Secretary
OOO T-lSc-616 :Xe.:J dn□d9 9NDlijOfll 8Jd
Sept. 10, 1996
To: Technical Coromittcc ................................. _, ...................... by FAX (5 pages)
From; Joel Hir-sdlhoni
Attached is • copy of .a newly published article "A Needle in I lbystack1' that I think can be
educational, because it illustute, how explaiah1g why positive findings of dioxin have been found
in a study poses importan.t toch.nioal cballeGges that can, however, be resolved .
In the cue described, some logical and thorough tcclmical wo(.k demonstrated convincingly to a
government agency that the dioxin contamination came from a noo•sito 50urcc. In this case aerial
deposition of dioxins logically explained why .some low level, of dioxins had been found in
wastewater efllncnt at a site with a landfill The concept of am)ymg specific distributions of
dioxin isomers to address the origin. of diom.s is importan.t.
Some of the other data in the paper are also ofiuterest, Such as TEQ dio,cm fom>.d ill pw-e
laboratory water and the amount deposited from the m.
There are many ubiquitous sources of dioxin in air.
60 :vT 96, £c das 1,lr"I\.I.J L~I •OIi ~l-~-?:;
0001 -lSc-616: xe.:1 dn□::J9 9~lDkJOrl 8Jd
cover story
A Needle in a Hay:stack
Tracking down tht ,lu.s~ve dioxin source proved to bt
a cha/knge at a California Air Foru base.
ud, Air Force Base, near
Ar-tier in California'$ Ccnual
Vallq, hu been in ul,tence
•ina: 1941 . Until twCI yeau
sgo. when ir became l e,.ndichte for do.
sure, it 1ni tht tnini.og center for 11.II B•
52 b,nnbet ind KC-135 ranker C(e"f•
rncmlxrj. 0vff the yw-t, fud-malt!.ly
JP,'4, JP·8 and gasoline-was handled,
wich in~1:1blc: iew ind o«uien:&.I 1pilh.
Oth~r p~1,1 pnfunned 011 the bl.,t
included airctaft and pa.m deaning. usln«
uichlorocthy!ene (TCE) ud methyl
ethyl ktlone (M£K). paincing and sikt
recmt'.ry. Suff1c1~nt TC£ entered tbe
puundw.ter for the bast to l;,e ded,~ a
Natioi,.J Prloricics Liit (NPL) site, and
ch¢ TCE plume ii ~trendy being •~c:d
duousft a pun,p◄nd•ucat progi:am.
Catdc's Watn.rater, afttt undergoing
primary an<l tee.0nda,y CfUl"'ent, h:.d
hi,11,rica.lly bttn spn.}"C'd ov-et it leach•
field, 1 potcion of i.:hich ~Lt aver a
clo~d l,ndftll.
Castk's fl(>tffl water Wa) colle(:ted by a
atric, or C&Nll and rliKhttg!d into a
Marhy creek. Tht coiutrut:don of the
c:anak 1Uowt about one foot of ,-,at¢r :o
collea In the borrom bcfinc i, swti to
flo~ off hue. If rhc c•nal5 •re empty
when r,Jn begin•. it would ake abo1,1i
0.25 inch o( rain to prqvide 1ufficil!nt
Water t1' start I ftow off bu¢.
Col'lc:una abour thr pouibillry of the
sp~rcd W2Stt"Wttcr leaching haurdcus
s1.1lm.1ncc.s from tilt h!ldnU ,~ (O a
change in the wutewurr ditch•~ lo-
It t frr,il'C1flll"tt111J PROTICTION
By Russell A. Stowe
cation. It wu decidtd to dischar~ the
l!mu~nt in[Q tht same ctetk IS the!
norm w1ter.
Thjs required • modif ,acion to the
Nation.I Pollution Oischarge FJimi,u .•
uon Syscl!m (NPOES) pcrmii. ln gttnt•
inr; the permit, rhe C.Cntr:al Valley
Regional Water Quality Control Bo-ard
(RWQCB) dir«D!d ttsdng for I wide
ranse of conttfflin1nu licred in th=
Inland Su.rhcr W.~t Plai\ (IS"WP), in•
d11ding dioxin.
Dioxin letting
The dioxin t~niftJ on the wanewace1 cf•
flucm vqs done 1n Ocrober 1993. The
reauhs were po•itive for two congener
g,oupt, 130 puts per quad,illion for
OCDO, and 100 pg/L fut ro,al TCOD.
No 2,3,7,8 chlorinated 1'C:OD .,.,u
If dioxin were
actually precipitotin9
from the air,
then it should
be falling over
c large area,
not jvst on base.
,
found. On ,he recommendation of the
RWQ.CB, the dilutnt ~ ccstcd 2pi11
in J1nu11.ty. This time, the ltve)s wue
about half tho.e in ~«iber for the wne
two conscncn.
Br thi1 time, the court !,,ad tef uide
the ISWP •nd. iu m.nda.rds. However,
the RWQCB found I viol1.tio11 of
Ptt>p<»ition 65 (du: Call~rnia S:1.fe
Drinking Warer and Toxlca El\forcc~nt
Act), which lim1ts dtoxin to 1 ~pg/L,
This ff(lUircd a norlfbtion of che health
board, which im1ed, warning sming
the v.-atcr in ,he rccelvinJ crrck w:as a
heahh h~urd. The RWQCB directed
furthe< ompling and analysis through-
01&t th@ wast~tc,r 111tem. the Pttd..,ing
wtteta and che scormwuer 1yttcm to
find. the Mptcted c&xi11 ,ourcc.
A careful readin~ o( Prop 6S lndic.ar-
cd it applied only to 2,3,7,8-TCDO,
whidt ,i,as not fowad. The R.WQCJ3 in-
tcrptctetf Prop 6, to mean to:clciry
~uivalcnu (T£Qs). The diollin le'ffl.J
e1tpre.ued i" 2,3,7.8-TCDO equtvtltnn
were wdl below the Prop cs, limit,
However, by this titne, rhc rc,ulu of
;edimenr tuting i• lhc: storm wacet
ditd\et llnd rcceivlAg creek yielded diox-
ll\f. The RWQCB fth thil proved there
111as a dioxin tour~ sorn«whcrc on but
•11d dircctcc:I furthet svnplirig and cle-
velopmcnf of a rtmediadoft pltn.
labn-Anlktton In~. (LA) ..,,..s con-
trac.-d to dtt-dop 2nd irnplem1mt a Mn\•
piing pla.n re And the ;ourcc. Du.e tC die
c;irpenH of analyzing for <fioxin-SlJOO ,.,,.,,,1,9'
VOM.d Wd£ l · 0 l 966 1-60-C: 0001-l SC:-616 : xe .:J dn□<:19 SJr,J I >lcJOffl 8Jd
Joint Warren County/State PCB Landfill Technical Committee
draft September 12, 1996 Meeting Minutes
The September 12, 1996 Technical Committee Meeting was facilitated by Ms. Deborah Ferruccio.
The meeting began at 1:25 P. M. In attendance were Ms. Daria Holcomb; Mr. Patrick Barnes,
Science Advisor; Mr. Joel Hirschhorn, Science Advisors; Ms. Bobbie Riley and Ms. Nan
Freeland.
The discussion was based on, Recommendations for Decision Making Process and Several
Actions, The Estimated Budget, and The Detoxification Technology and Vendor Evaluation all
of which were prepared by Mr. Joel Hirschhorn.
Ms. Ferruccio asked if the Federal Government could put pressure on the State to get them to
clean up the landfill. Mr. Hirschhorn said that the grievance aspect is that the State does not meet
TSCA requirements. The State was given permits that impose legal requirements on it as the
owner operator and those requirements have not been met. Mr. Hirschhorn said that this would
not have happened if the State had some reasonable enforcement. Mr. Barnes said that there is
no excuse for not doing the compliance testing. Ms. Riley asked if the blame for the State not
being in compliance could somehow fall in the lap of the Working Group. The Science Advisors
agreed that may happen, but it would have no validity.
Mr. Barnes asked if the landfill had been inspected since the hurricane. He advised the Technical
Committee to contact Mr. Meyer to have the landfill inspected and to have ground-water levels
taken. He advised that he would fax Mr. Meyer with his concerns.
RECOMMENDATIONS
PROCESS
Mr. Hirschhorn advised the Technical Committee and the Working Group to use a formal means
of communication with the State. He suggested written communication; verbal requests are not
adequate unless followed with a written document. He advised the Working' Group to adopt a
standard procedure for making decisions. Mr. Hirschhorn's recommended process is:
1) One of the Science Advisors fax an action memo for the Technical Committee to the
Working Group office for immediate distribution by fax to Technical Committee members
and the other Science Advisor.
2) The office arranges for a phone conference call within 24-48 hours for the Technical
Committee to discuss and make decisions on recommended actions.
3) During that call with the Science Advisors, the Technical Committee asks questions and
discusses action recommendations and make decision(s) on action item(s), allowing
follow-up activities by Science Advisor(s), or some other action. Secretary will maintain
minutes of all calls.
4) Within 24-48 hours:
September 12, 1996 Meeting Minutes
Page 2
A) As appropriate, the Science Advisor(s) will fax a work product to office for
distribution to the Technical Committee (unless instructed to take other action
directly, such as sending a memo or making a call to some party on behalf of the
Technical Committee or Working Group) to facilitate the Technical Committee or
Working Group implementing the decision.
Or,
B) The Technical Committee or Working Group takes final action. Secretary will
keep a record of exactly what action is taken.
FEDERAL STRATEGY
Mr. Hirschhorn advised that the State is in legal violation of EPA permits since Federal dollars
were used for constructing the landfill facility. He said that if the Community had correct
political advice before the landfill was built, that the landfill could have been stopped because it
did not comply with what is in the statue. Mr. Hirschhorn advised that whe~ TSCA has a
Superfund Site no permits are required. Since the landfill was not done as a superfund site, a
permit should have been required. Mr. Hirschhorn advised the Technical Committee to "initiate
steps to build a case for federal intervention and actions that support the goal of detoxification of
the landfill." His three recommendations are:
1) The Working Group should submit a written request to the state for a compliance
audit and summary report given to the Working Group within 30 days. The Working
Group would ask very specific, carefully crafted questions, based largely on various
federal requirements that the state was required to satisfy;
2) The Working Group could submit a written request to the EPA Region IV
Administrator to conduct an official EPA compliance investigation under TSCA for the
landfill, based on EPA examination of its records, and a facility inspection if necessary.
The need for very expedient implementation would be made. Specific concerns would be
identified, and
3) The Working Group would submit a written request to the Assistant Administrator
Elliott Laws at EPA Headquarters for his office to examine specific policy issues under
CERCLNNational Contingency Plan (NCP) by asking key question affecting the potential
cleanup of the landfill. The letter would cite the details of the agreement between the
EPA and the State in the form of a cooperative agreement that was funded under
CERCLA/Superfund. Specific policy determinations would be requested on specific
issues, such as whether the current form of the NCP applies to the landfill, and
whether the statutory requirement for review of the remedy every five years applies.
September 12, 1996 Meeting Minutes
Page 3
Mr. Hirschhorn advised that when this is presented to the full Working Group that there may be
some opposition, because this will force the State to become compliant.
STRATEGY FOR RFP FOR OBTAINING A TECHNOLOGY VENDOR
Mr. Hirschhorn advised that to streamline the process the compliance testing and site
investigation should be handled in one RFP. He explained that his idea is that the first set of
activities would be:
1) to choose companies that will conduct the bench-scale test and that these companies
would be pre-qualified for the preliminary design depending on the results of the bench-
scale test and
2) the selection of one company to work on the preliminary design of the full-scale
detoxification.
Mr. Barnes said that before any company can be chosen for the bench-scale test that it must show
that it can do both the bench-scale and the design. Mr. Hirschhorn advised that what the
Technical Committee needs to do is to get the Working Group to approve these actions. Next,
write a letter to Mr. Meyer and advise that this is how the Working Group would like to proceed.
Mr. Meyer should be asked ifhe concurs and to respond in five (5) to ten (10) days. The letter
should be ready for the Working Group to sign at the next meeting.
DETOXIFICATION CLEANUP GOALS
Mr. Hirschhorn advised that he has put together a budget (See Appendix 1) which shows realistic
cost projections. He advised that there will be three companies to do the bench-scale test and
they would give two cost estimates, one cost estimate will be for the bench-scale test and one cost
estimate will be to participate in the remedial design. The companies responding to the RFP for
the bench-scale test must provide a target level of detoxification they can realistically perform.
The possible cleanup levels, presented to the Technical Committee for discussion were:
Least Stringent: 1 or 2 parts per million (ppm) for PCBs and 1 part per billion (ppb) for
dioxins.
Stringent: 70 ppb for PCBs and 4 parts per trillion (ppt) for dioxins.
Very Stringent: 40 ppb for PCBs and 2 ppt for dioxins.
Extremely Stringent: 20 ppb for PCBs and 1 ppt for dioxins.
The least stringent level is the typical number and the health risk assessment level. Mr.
Hirschhorn said this is the best done anywhere for over a decade. The stringent level cannot be
obtained by all treatments. It is however, the level recommended by Mr. Hirschhorn for the
September 12, 1996 Meeting Minutes
Page 4
preliminary cleanup goals. The very stringent level is questionable regarding whether companies
can reach it or not. The technology is available, but this level is not economically feasible
because it requires repeated treatment of the same material. Mr. Hirschhorn said that the
extremely stringent level is very questionable and has not been done on any site at this time. Ms.
Ferruccio asked when the bench-scale test are completed will there be enough information to get
money for the clean up or will the State say that a pilot study is needed. Mr. Hirschhorn advised
that many issues depend on if the landfill has maintained its integrity and has not contaminated the
environment or if it is leaking and has contaminated the environment. He advised if the later is
true, it will be easier to get funding for a cleanup. Next, the source of funding was discussed.
Mr. Hirschhorn said that this Community has relied on the State for funding a cleanup and that
Federal intervention is an alternative. He advised that with CERCLA the Working Group would
have to go through a different process. He also advised not to seriously consider TSCA or
Superfund. Mr. Hirschhorn advised that the State could be sited by Superfund as the responsible
party and that would result in a mandatory cleanup paid for by the State.
INFORMATION ON WATER IN LANDFILL
Mr. Hirschhorn advised that the presence of water in the landfill complicates detoxification,
because if effects technology and cost. Ms. Holcomb asked if the Eco Logic process has any by-
products. Mr. Hirschhorn said that the Eco Logic has fewer by-products than the BCD process.
He advised that the Eco Logic Process is very good with water and that is the only technology
viable with water. He advised that this process was designed to deal with wet sediment.
However, this process has not been tested with dioxins.
Mr. Barnes advised that he is looking at the water in the landfill from a hydrological standpoint; is
the landfill leaking, either from the top or from the bottom? He advised that the reports he was
given from the State concerning the water levels in the landfill only contained the depth that the
levels were taken from; not the elevation the samples were taken from. Mr. Barnes also voiced
concern that the water levels were not taken, or the reports not given to him, after October 1994.
He added that the chart he was given showed more fluctuation than is normal due to temperature,
decomposition, pressure, etc. (See Appendix 2)
BIOREMEDIATION
Mr. Hirschhorn recommended that the Working Group formally request that the State stop all
activities related to bioremediation, since the Working Group has ruled it out. He feels that no
form ofbioremediation would be successful with this landfill. He also advised that there is a
political problem because there are two (2) bioremediation companies in North Carolina who
want this clean up. Mr. Hirschhorn said that he believes that the State is pursuing bioremediation
because they feel that it is unlikely that the Working Group will get $25,000,000.00 to
$50,000,000.00 for this cleanup. He feels that the Working Group may have to look at opinions
ruled out ie. , off-site disposal or treatment, containment, separation technologies, and
incineration.
BUDGET
September 12, 1996 Meeting Minutes
Page 5
Mr. Hirschhorn prepared a budget of anticipated costs of each activity. He advised the Technical
Committee to present the budget to the Working Group and ask Mr. Meyer for his opinion. (See
Appendix 1)
ACTION ITEMS
The Technology Committee will write a letter to Mr. Meyer to advise his office to proceed with
the sampling plan without the off-site wells, if they are holding up the process, to advise the status
of the Project Director, and to send someone to inspect the landfill, if that has not been done.
The Technology Committee will recommend to the Working Group at their next meeting:
1) To implement the strategy that Mr. Hirschhorn has recommended,
2) That the Working Group write to the US EPA Region IV to ask about permits
needed for the extraction of soil from the landfill,
3) That letters are sent to Secretary Howes and to Governor Hunt to see if their offices
can help facilitate the process,
4) Ms. Holcomb is to contact Congressperson Eva Clayton about at~ending a meeting,
when the Science Advisors are present, to see what help she can provide toward the goal
of detoxification,
5) To contact Mr. Lancaster and ask that a copy of the by laws of the Working Group be
sent to the Working Group office, and
6) Mr. Hirschhorn is to write a letter to Assistant Administrator Elliott Laws at US EPA
Headquarters, on behalf of the Working Group, for his office to examine policy issues
under CERCLNNational Contingency Plan.
OTHER INFORMATION
Mr. Barnes advised the Technical Committee of an alternative to drilling wells. He advised the
Technical Committee of a method that would push the wells in using a piping wire with a screen.
Materials would be removed by going into the casing and taking out what is needed. He advised
that with this method there would be no problem with storage. The Technical Committee
suggested that this method be presented to the State for consideration.
Mr. Hirschhorn advised that he has looked at all of the possibilities, even those currently ruled out
by the Working Group. He has decided that there are two (2) feasible detoxification
technologies; BCD technology and the Eco Logic process. He advised that he is talking with two
(2) BCD companies, Eco Logic, and possibly three (3) or four ( 4) other BCD companies. He
feels that this time that Eco Logic is the process that would be most beneficial for this landfill.
Appendix 1
ESTIMATED BUDGET
Prepared by Joel Hirschhorn
Presented to The Technical Committee, September 12, 1996
Science Advisors ................................................................................. $200,000.00
Extraction............................................................................................ 100,000.00
Site Investigation................................................................................. 250,000.00
Bench Scale Tests (3) .......................................................................... 225,000.00
Design................................................................................................. 100,000.00
Office, Miscellaneous.......................................................................... 50,000.00
Contingency........................................................................................ 75,000.00
$1,000,000.00
-0 Ql co CD {~ \ I ft\ ~J· (~ ~ 0 1-tt ~; 'c; ~~ i~~cif s., r ~ ~ E Ii:~ i i-11t1i ~ ; ~-('-... vi r , ) ; 1~ r .J ~ ~ ~ ('-'tt ~ _. _. _. r--..,_.w_.~_. Jan-(]'I w (]'I ~ (]'I (.]1 93 ■--,---, Feb- , : / 93 I ,■ Mar-f 93 I • Apr-: f: , 93 : ·1· : May-, , , 93 I I! I Jun-, j, I ' I 93 I .. I I I J I-I ,'\. I I I LJ I "\ 1 I I 93 : ~\ I : Aug-, , I. I 93 I I \'. I Sep-' , 93 I : 1.· : Oct-' : /, ' 93 : : : ■; ~ Nov-, , \ , l> I I I/ I -t 93 I I I ''I m Dec-' ' ' ::o I t I r 93 I I • I m I I ' I < Jan-, , . m 94 : ~ : : r Feb-, ;> , 94 I I , ~, Mar-: ; : 94 I I • I I '/' I Apr-, , , 94 : • : I I May-, ~ , , , l :~ I I I 94 I I I J I\• I un-I I I l I 94 I : ■ I Jut-I I 94 : ; Aug-' ' 94 I II : S I I '\' ep-I I I I 94 : I : Oct-, 94 I l"-l f~ t "-'-t:i. '~ '->.i I ~ 'R, ~ t ? r ~ ~ ~ , ~ ~ I ( ~ ~ ~ r m )> ~ ~ "O X G r ::, CJ) e: (') ~ :J" Ql N ~ w
Joint Warren County/State PCB Landfill Technical Committee
draft September 12, 1996 Meeting Minutes
b
The September 12, 1996 Technical Committee Meeting was facilitated by Ms. Deborah Ferruccio.
The meeting began at 1 :25 ~-. M. In _,.ttendance were Ms. Daria Holcoml)f)"1r. Patrick Bames, Sc,<,UUl. A-iv1s--z-1 ./~~~~l~~~(\ ~
Mr. Joel Hirschhorn, ~✓l.S. Bobbie Ril.eC7M~nd Ms. Nan Freeland, ,
Ms. Ferruccio begai1 the discussior,/aying that the State is liable for this landfill and nsked if th¢
'
Feden,1 Govemmeut could put p;essure on the State to get th:m to clean up the lnndfiU. lVlr.
HirsctiJ,orn :::aid that the grievance aspect is that the Sti~te cloen not meet TSCA requirements.
The State was given permits that impo:,c le_g~l requirements 011 the State :i.s the owner operator of
;,t
the landflH and:th~y:-ha;,ve uot met those requirements. This is not i:i. matter of th8 EPA coming to
the re1i~.;ue to this co1111,1unity. Mr. Hirschhom said that this would not h.ave happened if the State
I-:-1/ ,~ ___ --n t,('.7 i _ ... ,
lw.d so:i:ne reasonab!e enforcement. Mr. Barnes said that there j5 any excuse for not doing the .!~ ':':i:'.l 11tA((c..:
compliance t~sting. 1v1s. Riley asked if the blame for the State not being in r,omplinnce could
somehow fall in the lap of the Working Group. The Science Advisors agreed that may happen,
hut would have no validity. Mr. Ban1es asked if anyone had inspected the PCB landfill since the
hurricane and advised it not that W1r. Meyer should send someone as soon as possible and hl\Y~
them truce ground-water level samples. He advised that the Technical Committee contact lvfr.
Meyer and request that the landfill be inspected and advised that ho would fox Mr. Meyer with his
concerns.
RECOMf.\fENDATIONS
TO'd
Post-It~ Fax Note 7671
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(JT;.-t[<,,
Mr. Hirschhorn ~~~,sJH'e advised that the Technical Committee and the _
{tti. ~Gdkuu'.) .
Working Group use more fonnal means of communication with the State. He suggested that .J,e-e1 r..f'4°J / .
-r: I n d .c?I ,/ 1e•~r -prepare written communication; Saymg:.that Verbal requests are not adequate unless they are t • ( yr1r
followed with a written document. He advised)< the Working Group was to adopt e standard
procedure for making decisions. His recommended process is:
, ,rt'LV
t~ r./,• 0t t)l ,:.--
1) _in'e Science Adviso&ax an action memo for the Technical Committee to the Working Group
office for immediate distribution by fax to the members and the other Science Advisor.
2) The office arranges for a phone conference call with.in 24--48 hours for the Technical
Committee to discuss and make decisions on recommended action.s.
3) During that call with the Science Advisors, the Technical Committee as'?( questions r.nd
discussy{ action recommenda ti ons and ?.J-t-P~ make decision (s) on action item(s), allowing follow-
ct o f-i 011 .. -Vv' i It
up activities by Science Advisor(s), or some other d.0eision..is-rnade. Secretar/-hlaintain$ minutes
{LlL-
of yuch calls.
4) Within 24-48 hours:
./ LV id
a) As appropiiate, the Sci~nce Advisor(~ fax~/ a work product to office for distribution
to Technical Committee (unless instructed to take other action directly, such as sending a
memo or making a call to some party on behalf of the Technical Committee or Working
OClO T-t!.Sc-6T6:Xl'.::J dn□cJ9 9MI>lcl0/ll HJd
Group) to facilitate the Technical Committee or Working Group implementing the
decision. tr,
11vi1i
b) The Technical Committee or Worldng Group takes final action. Secrcw/4cep, a
recordofexactlywhatisd~ne: etCt(c)n ,.,;··~ni::.e.n •
FEDERAL STP.ATEGY
Mr. Hirschhorn advised that the State is in legal violation of EPA pennits since Federal dollars
were used for constructing the landfill facility_ He said that it is not normal to construct a new
permrnent facility just for clean up waste and that this probably had never happened before.
Mr. Hirschhorn said that if the Working Group had correct political advice before the landfill wns
built, that the landfill coul~ ruwe been stopped because it did not comply with what is in the
-1 .,i.-L C :f["(Ll\ e_. -.:statue. Therefore, the Worldng Group could have tried to stop the Federal funding. He advised
that when TSCA has a superfund site no permits are require~~~ince the landfill was not done as a
superfund sit;:/1 permit should have been required. Mr. Hirschhorn, as described in his
recommendations to the Technical Committee, advised to "initiate steps to build a case for federal
intervention and actions that suppon/ the goal of detoxification of the landfill." These action
recomnwndations are:
1) The Woricing Group should submit a written request to the state for a_compliance
audit and summary report given to the Working Group within 30 days. The Working
Group would ask very specific, carefully crafted questions, based largely on various
federal requirements that the state was required to satisfy;
2) The Working Group could submit a written request to the EPA Region IV
Administrator to conduct an official EPA compliance investigation under TSCA for the
landfill, based on EPA examination of its records, and a facility inspection ifn~;essary.
The need for ye( expedient implementation would be made. Sp.;t.;;i.fii;; concerns would be
identified; and
_j_,., ) {rj(!) 1 / J''-·1 {~1·
3) The Wodcing Group would submit a written request i Assistant Administrnt5Elliott
Lz.ws at EPA Headq1.1<•.rters.: for his office tc:i exmnine specillc policy issues under
<t.(,I')
CERCLAJNational Contingency Plan by asking key question affecting potenti2J cleanup of
the landfill. The letter would cite the details of the agreement betv;een the EPA nnd the
Stat~in the form 9f a cooperative agreement that was funded under CERCLA/Superfund.
Specific policy determinations would be requested on specific issues, such as whether the
r~rrent fonn of the NCP applies to the landfill., and wheth~r the st~tut.ory requirement v;:
for review of the remedy every five years applies.
i1Y.U .. /
Mr. Hirschhorn advised that when this is presented to the full Working Grnup that there weuk!-.lbe
some opposition, because thi9 will force the State to become compliant.
STK.4.TBGY FOR PJ'P FOR OBTAINING A TEl1.fNOLOGY VENDOR
l70'd
:Mr. Hirschhorn advised that to streamline the process the compliance testing and site
investigation should be handled in one RFP. He explained that his idea is that the first :set of
activities would be:
cl ,otoe~
1) to·-ehom-e companies that will condu~t the bench-scale test and depending-en-the~resuru--
; d-epewlt'ri.1-?\' Ctr, +Ctc/ ,
that these companies would be prequalified of preliminary desigrl~nd U ( tSLLl rs c).f-
2) the selection of one company to work on the preliminary design of the fi45cate
detoxification.
i·b
Mr. Barnes ~d that before any company can be chosen for the bench-scale test that trj{ must
it .
show that ~ can do bo* the bench-scale and the design.
Mr. Hirschl1orn's key components to the proposal are:
1) The RFP would be described as the solicitation of a contractor that after completing a
c:rp,L--d-_
successful hen€~~ scale test of detoxific;(l,tion technology vlill provide professional
services in developing a conceptual engineering design of the full remedial action at the
landfill, including an onsite demonstration l~rior to fu8cale use of the selected
detoxification technology,
2) The RFP would define the following steps for interested parties:
SO 'd Vl :Ol 96 , 0£ das OODT.-c'.'.SC:-6T6:XP.-J
·-/-(L.£,-
h ,7' 'l·l11~.::;(,·t v U ·L . -.
·tf5t
A) Based on information given in the RFP (including site background, and scope
of work for test) one (1) to three (3) vendors will be selected on the basis of
submitted proposals to conduct a bencJ8,r pil~cale test at their own facility on
landfill materials provided to them.J,1.,~ ~
B) After the selected companies submit the required reports on test results and \
I
provide any additional information required, one company shall be selected to )
provide the conceptual design services, based on both the test results, :ther \ i1Ls1 {4/? I
infonnation provided. and the bids in the company's proposal. / C [J\f\ (
-----------------------------~-------·✓----
3) The RFP would ask for proposals that must contain certain types of infonnation,, induding bids
for the initial testing and,c.d,f0rthe--ees-ig~~~ of work for the two
phases given in the RFP~,Zechnology companies would be urge~~-~to select a
subcontractor {such as an environmental design and engineering firm) that has the capabilities to
contribute to the conceptual design of the total remedial action based on but not limited to the
detoxification technology.
4) The state would enter into an initial contract with the companies selected for the benc~r pilt)
tests. This contract would contain a provision stipulating thut the company is being pre-qualified
or short-listed by vu tue of being selected to conduct the test for final selection as the provider to
the design services and that not other RFP will be issued by the state. Subsequently, after one;
c,ompany is selected, the state would enter into the final contract for the provision of the design
90'd vc::01 96, 0£ das OOOI-.'.'.'.SC:-616:XP~
services.
J\1r. Hirschhorn advised that what the Technical Committee needs to do now is get the Working
Group to approve these actions. Ne>..-t, write a letter to Mr. Meyer and advise that this is how the
Working Group would like to proceed; tell us if this is feasible and give him five (5) to ten (10)
days to respond. The letter should be ready for the Working Group to sign at the next meeting.
DEWXIFICAllON CLEANUP GOALS
t-✓ir. Hirschhorn advised thnt he has put together a budget (s¢¢ appendix l) which shows realistic
cost projections. He advised that thl.'lre will be three companies to do b~nch-scclo t,zst and they
would give t'No prices. One price will be for the bench.scale test o.nd one price ·will be to
pc.rtidpate in remedial design. Then the State would enter into an agreement \vith these
companie~. lvrr. Hirschhorn said that must tell the companies interested in bench-scale. that they
must give a target level of detoxification they can perform. He advised that for PCB Wld dioxins
th~ typical number is one (1) or two (2) parts per million. Ms. Ferruccio asked if ofter the bench-
scale test will have enough infotmation to get money for the clean up or will the State say that a
pilot study is needed. Mr. Barnes said that the three (3) technologies selected will factor in full
scale operation, before they are selected. Ms. Ferruccio asked if at some point an on-site study to
Bet enough infotmation to get funding for the clean up. Mr. Hirschhorn replied only if som~ne
wants to delay the project and it depends on what results are gonen from the bench-sea.le tern.
Mr. Hirschhorn said that a lot depends on if the landfill still has integrity and has not 5eriously
contaminated the environment or whether it is leaking and has seriously contaminated the
uc:01 96 , 0£ das
environment. He advised that ifwe get involved with CERCLA will go thrcugh another process.
and all of the work done, would be useless. He also advised not to seriously consider TSCA Md
Superfund. Mr. Barnes advised that since this is a site investigation at the facility that it could be
Superfund site. Mr. Hirschhorn advised that it is unlikely that the landfill would be a superfund
site.
INFORMATION ON WATER IN U...NDFJU
lvfr. Bames said that he does not have the el~vation form of where measurement where taken
from. He was given a depth to, but needs the elevation of Mr. Barnes advised that he is looking
s.t the water in the land;,-<iU from a hydrological standpoint; is there a leak or not, either from the
top or bottom? He said trui.t the chart he was given shows much fluctuation and there should not
be that much fluctuation. #e noted that the water levels have an upward trend (see chart
numbered 3).
Mr. Hrrschhorn advised that the Eco Logic Process is very good with water and that is the only
tochnology viable with water. He advised that this process was designed t~~deal with wet
sediment, however, this process has not had to deal with diox:ins. The BCD process produce~ by
products and Eco Logic has less by products and is better for nir emission:;. Mr. Hirschhorn
advised that talking with 2 BCD companies, Eco Logic and possibly three or four other BCD
comparues.
BJOP~EDIATION
\. I
80'd
Mr. Hirschhorn recommended that the Working Group formally request that the Sw.te stop all
activities related to bioremediation, since the Working Group has ruled it out. He feels that no
fonn ofbioremediation would be successful with this landfill. He also advised that there is a
political problem because there are two (2) bioremediation companies in North Carolina who
want this clean up. !\1r. Hirschhorn said that he believes that the State is pursuing bioremediation
because they feel that it is unlikely that the Working Group will get $25,ooo;ooo.oo to
$50,000,000.00 for th.is cleanup. He feels that the Worldng Group may have to look at opinions
that they have ruled out like: offwsite disposal or treatment~ containment, sepv.ration technologies,
and incineration.
BUDGET
Mr. Hirschhorn prepared ia budget of what each activity should cost. He advised the Technology
/~~A-1 r n'l..f u:J
Commiuee present it to Working Group and ask W.lI'. Meyer if he feel s it is adequate. (See il[."'W'e""
j1-j_,.cic, d > -..,.1,) }
AC110N ITEA1S
The Technology Committee will write a letter to Mr. Meyer to advise his office to proceed with
the sampling plan ·without the off-site wells, if they are holding up the process; to advise the status
of the Project Direct~r; and to send someone to inspect the landfill> if that has not been done.
The Technology Committee will recommend to the Working Group at their next meeting:
60'd nocn-)c:?-hTF.: xP ..J
1) to implement the strategy that Mr. Hirschhorn has recommended,
2) that the Working Group write to the EPA to inquire about pennits needed for the
extraction of soil from the landfill. and
3) that a letter be sent to Secretary Howes and to Governor Hunt to see if their offices can
help facilitate the process.
OTHER llvFORMAllON
1\1:r. Barnes advised that instead of drilling, that we might want to consider the push method of
well installntion. With this method one would use a piping wire ·with a s.creen, you would go into
the ee.sting l!.Ild remove just what material is needed and would not have the prob!em of storage.
Ths Technolgy Committee advised that this method should be suggested to the State.
' t)·\ ,u: ➔ ( ,1J :r
Sc:OT 96, 0£ das
..
L . (,-· I ). I ' , '
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1 ·,.
i
OOOh'.'.Sc-616: XP.:J
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-... ;.,t ,f'. -~
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ESTIMATED BUDGET
Science Advisors ................................................................................. $200.000.00
Extraction............................................................................................ 100,000.00
Site Investigation................................................................................. 250,000.00
Bench Scale Tests (3) .......................................................................... 225,000.00
Design................................................................................................. 100,000.00
Office, :tvliscellaneous .......................................................................... 50,000.00
Contingency........................................................................................ 75.000.00
$1,000$000,00
9c:OT 96, 0£ das dnm:1~1 9N I>l~OI~ 8Jd
Joint Warren County/Sate PCB Landfill Working Group
draft August 27, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 4:45 P. M. Thursday, August 27, 1996 by Ms. Dollie Burwell. The meeting was held at
the Warren County Office and was co-chaired by Ms. Dollie B. Burwell and Mr. Ken Ferruccio.
A generic agenda was distributed.
READING AND APPROVAL OF MINUTES
Two corrections were made to the April 25, 1996 meeting minutes. The approval of these minutes
were tabled pending those corrections.
Ms. Bobbie Riley moved the the minutes from the June 20, 1996 meeting be aproved with the
amendment that the April 25, 1996 meeting was tabled pending corrections. The motion was
seconded and carried.
UNFINISHED BUSINESS
Status of Sampling Plan
A report from the State was deliverd by Bill Meyer. Mr. Meyer reported that there are several
matters requiring agreement before the sampling plan can be completed. The three main issues
are: 1) increasing the number of monitoring wells, 2) the location of these new monitoring wells,
and 3) the parameters to analyze for. Mr. Meyer provided a document illustrating the locations of
proposed new ground-water monitoring wells, surface and sediment sampling locations, and one
area that will be hydropunched. (See figure 1.) This is the base of what the sampling plan
consists of and if the Working Group can agree on this, the project can move forward. Mr.
Meyer said that he has a draft sampling plan that can be put in place, then a lab can be selected
and sampling can begin.
Ms. Ferruccio said that the Technical Committee was expecting a meeting with the State and the
Science Advisors. At this meeting the State and the Science Advisors were to iron out all their
differences. After which, the Technical Committee was to receive a plan that they had all agreed
upon. She then asked if this was just the work of Mr. Meyer and the State. Mr. Meyer
responded that this is a consensus document that locates, new sampling points and existing
sampling points. A combination of the two plans will consist of what the sampling plan will
address. In addition we have consensus or. the location of new and existing points and what they
will be analyzed for. (See figures 2 and 3.) He explained that this is the object of the sampling
plan. How it is to be carried out is to be ar-dressed in another document. Tilat document will
discuss all issues of quality control, quality assurance, decontamination, and personnel protection.
Mr. Meyer said that when he spoke with some members of Working Group, he heard some
disagreement about doing additional sampling. With this in mind, he thought that the first step
would be to get the Working Group to approve these issues and the sequence of how things
would go, then a full sampling plan would be developed. Mr. Ferruccio asked Mr. Meyer if what
draft August 27, 1996 Meeting Minutes
Page 2
he was saying was that he wants input from the full group in the formulation of the full sampling
plan. Mr. Meyer said that what we need from the Working Group is approval of the sampling
locations, the number of new wells, and the parameters to test for. Once we have that, we will
know what the market is and how to draft documents needed to get a lab to assist in
implementing the sampling plan.
Ms. Burwell then said that the Technical Committee was set up for a purpose and that purpose
was to be a liaison between the Science Advisors and the State. The Technical Committee is to
review, inform, and bring recommendations to the full Working Group. They are to share with
the full Working Group the discussions that they had with the Science Advisors as justification for
their recommendations. On the matter of a disagreement with additional sampling, there was no
disagreement because the Technical Committee knew nothing about additional sampling. They
had not received information that the State and the Science Advisors had agreed on a plan. If the
process had been followed that Technical Committee would have had time to discuss this plan
with the Science Advisors and bring a recommendation to the Working Group. Then the
Working Group could vote on the plan. Ms. Holcomb asked how much of the Science Advisors
input went into this plan. Mr. Meyer advised that meetings were held and a consensus was met.
Ms. Ferruccio said that the Technical Committee had a conference call with the Science Advisors.
What she understood from that call was that they had given their portions of the plan to Mr.
Meyer and was waiting on him. The Technical Committee did not realize that a consensus had
been met and all that they wanted was to see what that consensus was. Mr. Hirschhorn stated
that the Science Advisors had a meeting with the State on July 3, 1996. At that meeting a
consensus was met on many basic key issues. Those issues included a general frame of work,
security system to be used rather than split samples, procedures and protocols that are important,
and division of work. All of this was done to create a document that would be brought to the
Working Group for approval. Mr. Barnes advised that this portion of the work was to be to Mr.
Meyer by the 17 July and was faxed to Mr. Meyer on the 18 July. A few weeks later Mr. Barnes
got a response from Mr. Meyer advising that more work was needed on his portion. The results
of this were given to Mr. Meyer this morning. Mr. Barnes said that he feels that was his final
input and that the final document would come from Mr. Meyer. From the conference call with
the Technical Committee, Mr. Barnes said, there were concerns that the Technical Committee
was being left out of the loop of communication. Therefore, Mr. Barnes has put together what he
has done and will give to the Technical Committee along with the State. Ms. Ferruccio voiced
concern that we are not sticking to the schedule of the Master Plan. Because of this she feels that
things are not moving forward. The Technical Committee thought that things would move along
concurrently. Ms. Burwell said that we need to come back to this because nothing is being
resolved. She went on the say that this was the focus of the conference calls. Reports were
promised and not delivered and no explanation was given about why the reports were not
available. Ms. Riley said that the whole purpose of this meeting was to vote on the sampling plan.
She said it is true that the Technical Committee was to have this report ahead of time. Since the
plan does not look complicated and since the Science Advisors are here, the Working Group
should hear their input and advise. Ms. Riley asked if this is what we are to look at to say yes or
no to and then the full document is done. As explained by Mr. Barnes, this is the base for the
plan. Then Mr. Meyer added that the other part is process. Ms. Holcomb asked Mr. Meyer if
•'
draft August 27, 1996 Meeting Minutes
Page 3
the locations of the new wells were on the document that he had provided. He responded yes and
explained that monitoring wells 16, 17, and 18 are off-site background wells. He also said that
we have to negotiate with the property owners to allow us to put wells on private property. Next,
Ms. Burwell asked to hear from the Science Advisors. Mr. Hirschhorn recommended that the
Working Group approve the plan so that the Working Group can move forward. Ms. Riley asked
the Science Advisors if the plan looked like what they had agreed to and Mr. Barnes said yes.
Also discussed was the fact that the Working Group is continually being asked to approve things
that have just been presented to them. Then they are made to feel guilty if they do not. Mr.
Barnes said that he understands the concerns. He did get that impression from the last conference
call, so he has put together three (3) notebooks on the project. These notebooks include his part
of the sampling plan and are for information only. He advised that the Technical Committee can
use the notebooks to gain information the Working Group needs to help them make decisions, so
the next time they can feel that they are making an informed decision. Mr. Barnes noted that the
only thing that had not been mentioned was the Master Plan. He advised that he and Mr.
Hirschhorn spoke and decided to work on the Master Plan. Mr. Barnes said this is a draft, but it
would give an idea of how they recommend the project proceed. These notebooks will include
rationale why the monitoring wells were placed in specific locations. Mr. Hirschhorn added that
the Master Plan was discussed, presented, and given approval. He said that then the Science
Advisors were told to fill in the details and that is what happened at the meeting with Mr. Meyer
and his staff. So what the Working Group is getting is consistent with the strategy presented.
Mr. Barnes said the schedule has changed, but goals, objectives, and intent of the project had not
changed. ,
Ms. Riley asked if PCBs, dioxins, and furans are being analyzed at the same levels that the State
labs uses. Responding, Mr. Hirschhorn said that we are using the most sensitive test, EPA
method 8290. Another issue was that the EPA has developed new guidelines for drilling wells to
test for low level organics. Mr. Meyer, advised that the last time each sample cost $1150.00 and
that total was $30, 000.00. With the addition of twelve (12) more samples, the cost would be
approximately $150,000.00. Mr. Meyer said the issue here is that the test are expensive and costs .
are an important consideration. So the State may have to come to the Working Group and say
that we need to do ten (10) wells instead of twelve (12). When the Science Advisors presented
the alternate technology, part of what they explained was that it did not make economic sense to
spend money on onsite pilot technology testing. Because monies would need to be spent in ways
that would get the results that the Working Group wanted. Ms. Burwell said that when the State
and the Science Advisors came up with twelve (12) wells, cost should have been considered. She
also said that the Working Group did have some concerns with semiannual testing and the voted
to include dioxin testing. Where the money came from for this dioxin testing, she was not sure.
If all testing done to keep the landfill in compliance comes from Mr. Meyer's operating budget,
then if this was a problem, he should have said so. Mr. Meyer advised that most of the money for
the past twelve (12) years has come out of his operating budget. Money for dioxin testing came
from his department's budget. Ms. Burwell asked Mr. Meyer ifthere was money in his budget for
compliance testing. When he developed these new wells, did he see a problem with paying for
them. The response was that money has to come out of the million dollars appropriations. Ms.
Burwell asked why the PCB fund would be paying for semiannual testing and Mr. Meyer
draft August 27, 1996 Meeting Minutes
Page 4
responded that this is not semiannual testing. He said that this is a site investigation to determine
three (3) things: 1) the medium contaminated inside and outside the landfill, 2) the form of the
medium, whether it is liquid or sold, and 3) the volume of that medium. Again, Mr. Meyer
advised that the only part that the State does not pay for is the cost of dioxin testing. The
members of the Working Group then advised Mr. Meyer that when they told that dioxins were
present, he also told them that there was money in his department for dioxin testing. Mr. Meyer
said there was money in his budget for a one time sampling event. Ms. Holcomb then read from a
letter dated August 24, 1995. (See figure 4) Mr. Meyer advised that was ~,statement of what
things cost, but no commitment for State funds to be used. After more discussion on whether
dioxin testing was to be added to compliance testing and therefore paid for by the State, Mr.
Cooper moved that the scope of the sampling plan be approved. The motion was seconded and
carried. Abstaining from voting was Mr. Ferruccio. Opposing the motion was Ms. Burwell.
NEW BUSINESS
Extraction of Material
Mr. Hirschhorn asked the status of the extraction of materials for bench-scale testing. Mr. Meyer
said that last February, eleven (11) companies showed up with specific designs based on taking
material out of the landfill. That RFP is still valid and he hopes to use the same companies. We
need approximately 2,000 pounds of sample for the bench-scale test. We can have seven six-inch
wells in landfill at twenty-four feet deep or two twelve-inch wells at twenty-four feet deep. Mr.
Hirschhorn asked if an EPA permit would be needed for this removal. Mr. Meyer said as long as
PCBs do not leave the site and that all storage requirements for toxins are met, that he has been
assured verbally that no EPA permit would be needed. However, he is not sure if there is a time
frame associated with this storage. "The breaching of the integrity of the landfill is a major factor
and I doubt that the EPA would give approval so quickly for this," said Mr. Hirschhorn. "The
RFP had a safety measure built into it," said Mr. Meyer. Companies would have to submit a
design so that the State and the Science Advisors would be assured of no violation to protection
of the cap. Continuing, Mr. Meyer said what Mr. Hirschhorn is talking about is a regulatory issue
that may prohibit this. Ms. Burwell said that when the Working Group had a meeting with the
EPA she thought that Mr. Meyer got that approval in writing shortly after that meeting. After
more discussion on the matter of the permit, it was clear that the Working Gro11p thought Mr.
Meyer had received written approval from the EPA. Mr. Cooper said that the concerns being
voiced are legitimate and the problem is that we do not have a director, who would see that things
are done. We need a paid individual who will work with the Science Advisors and is responsible
to this committee. Mr. Hirschhorn advised that with other community group, he has had the
authority to speak for them and negotiate with government officials; however strategic issues
came for the community group. Ifwe had a director, the director would tell the Science Advisors
and the State what needs to be done. He would be speaking for the Working Group and would
be held accountable when things are not done. Ms. Burwell said that she feds if Mr. Meyer felt
that this project was more than he could handle, with his other responsibilities, than he should
have come to the Working Group or the Technical Committee and said so. Mr. Meyer stated, as
of August 20, 1996, I have a part-time person working twenty hours a week on this project. I
recognized that I do not have the time and that is why this person was hired. Questions were
draft August 27, 1996 Meeting Minutes
Page 5
asked and it was discovered that this person will work his full twenty hours on this project, that
the Science Advisors can go directly to this person and not to Mr. Meyer, that this person will be
attending the meetings along with Mr. Meyer, and that this person is now the Project Director and
will have authority to make decisions. Ms. Burwell called for a motion for a Project Director
whose purpose would be working with the Science Advisors and making decisions. Mr. Meyer
wanted it to be clear that he will not be spending less time on this project. He feels that this
project will take his time and the Project Director's time. He also wanted it clear that this person
will be the lead person and will do any leg work that needs to be done. And he, Mr. Meyer, will
be available for any assistance he can provide the Project Director. Mr. Cooper asked if the
Project Officer would be responsible to the Working Group or to the State imd therefore where
will his loyalties lie. The Project Director will be working for the State, said Mr. Meyer. Mr.
Hirschhorn said that we still have a problem, will Science Advisors have authority to tell this
Project Director what to do. After additional discussion it was apparent that the Science
Advisors are not decision makers. The Working Group will make decisions based on the advice
and recommendations of the Science Advisors. Mr. Hirschhorn voiced concern that the Working
Group wants to make every decision. He said that the people who hire him do so because they do
, not have the qualifications to make decisions that need to be made, where technology is
concerned. Ms. Burwell said, when the Science Advisors were hired they knew the process by
which this work was to be done. The Science Advisors understood that the Working Group had
the power and authority to make decisions and recommendations to the State. That their role was
to help the Working Group make decisions, not to make decisions for them. Ms. Holcomb asked
Mr. Meyer if the Project Director will be paid from his department. He replied no, from the PCB
fund. There was more discussion on the source of funding for the Project Director, and to whom
he will be responsible. The Working Group feels that if they pay for the services of a Project
Director that they should have say so about who is hired. Mr. Lancaster explained that the State
has to play a role in terms of the State's property interest and liability for th~ project. So we, the
State, must have someone directly involved and right now that is Mr. Meyer. He is trying to
transfer that to someone else and requesting that you allow the money to come from the million
dollars. The State does not have the funds for a Project Director, therefore if the funds do not
come from the million dollars then this falls back in Mr. Meyer's lap. Next, the motion was made
to table the Project Director until the next meeting. Meanwhile we will get an update on what has
been spent and a projected budget. This budget will include the amount for: the Project Director,
analysis, wells, vendors, etc. The motion was seconded and carried.
Next, Ms. Elmore made a motion that we get in writing from the department the roles,
responsibilities, and decision making authorities of the Working Group, Mr. Meyer's department,
and the Science Advisors. This should be made available at the next meeting. The motion was
seconded and carried.
Mr. Hirschhorn said that there is another area that needs a motion. That is who is to approach the
EPA about what permits or authorities are going to be necessary to take material from the landfill.
It was motioned that Mr. Meyer's office gets in writing the EP A's requirements for excavating
material from the landfill. The motion was seconded and carried.
Vendor Technology
draft August 27, 1996 Meeting Minutes
Page 6
Ms. Ferruccio bought up the subject of vendor technology. She asked Mr. Hirschhorn what
information is needed from the sampling to continue his work with vendors. Mr. Hirschhorn
advised that there are two viable technologies with several vendors. He also advised that there
are tougher issues that need to be addressed. One issue is how to structure the RFP and that
cannot go on until Mr. Meyer works out two aspects. First, he has to get a contractor lined up to
do the extraction and second, he has to deal with regulatory issues. These are barriers for going
forward. Ms. Freeland suggested a meeting with the Science Advisors to work that out. Mr.
Meyer advised that he will contact the EPA and send correspondence to the Technical
Committee. At which time the Technical Committee can decide a date to meet based on progress
with the EPA. Mr. Hirschhorn advised that he would be sending a memo addressing some issues
and would have it available to the Technical Committee next week.
ADJOURNMENT
The meeting was adjourned by co-chair Ms. Burwell at 7:30 P. M. The date for the next meeting
is Thursday, September 26, 1996 at 4:30 P. M, A Technical Committee meeting was scheduled
for Thursday, September 12, 1996.
Doris R. Fleetwood
Warren County/State PCB
Working Group Secretary
0 EB A 0 0 0 A ) . ,····Vr ____ , ~ , ,, • I ,,, t __ ,,.. ,,, . _ r __ ... , ----◄'---~-· -,,,,., ',, / 7~•--•--I I •• \ . I I •• \ I I •• I I I•• \ I \,· ' ' ~ ~ I .•·,, 'I> -, __ _,, \ ----I ' ' \ I \ I \ I \ , \-. ____ , ______________ ...... ," surface water (new) surface water ( existing) soil/sediment monitoring wells existing monitoring weJJs leachate samples ,,. ,---,, h,rrlr,-.. nu...,,-.l, _______ , ', ,,, , I I -,, ,,,,' , ,,-~~ ._\\, ~ 12,c,tl$. . i ' I I \ I \ I ', I ,, I '""',..., I ,
, I ---, .. , ' , ' ... ......... __ .,, _, ' ~------------' \ 'CB LAND. :,,1~ Ci) ...... , , ... -.... __ .......... ,' 'Jct» -, .... __ , ', :n .............. .V-1 .... -....... _ ',, ---,, ......... ____________ .,------........... --,_ ---......... \ I I I I I ,-...... ,, I ',
, _____ , \ \ \ ' ' ' ' ' ' I I I I • I I I , I , , I , ,' ' , --, ' ' \ I I I \ \ ' ' I I I I I /( \ ' " \
FIGURE 2
DRAFT SAMPLING LOCATION/ANALYSIS PCB LANDFILL
ANALYSIS
SAMPLE ID
LOCATION
GROUNDWATER
I MW-IA-NEW EAST
2 MW-lB-NEW EAST
3 MW 2-EXISTrNG NW
4 MW 3-EXISTING WEST
5 MW-3A NEW WEST
6 N2-4 EXISTING SW
7 MW-4a NEW SW
8MW-5NEWN
9 MW-5aNEWN
10 MW-6 NEW S.E DRAW
11 MW-7 NEW SOUTH
12 MW-7A NEW SOUTH
13 MW-8 NEW N. E. ORA W
14 MW-9 NEW N. DRAW
15 MW-l0NEWW. DRAW
16 BACKGROUND WELL 1
17 BACKGROUND WELL 2
18 BACKGROUND WELL 3
PCB
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
DIOXIN/ BN/AE voe METALS OTHER
FURAN
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
--✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
✓ ✓ ✓ ✓ ✓
Background wells located 1-2 miles off-site in NW, SW and SE quadrants. Attached is list of constituents and
detection levels for each analytical test. Wells m2-6,8,9 and IO may require a nest if hydrogeological
conditioning warrants.
Total Samples/ Analysis
40 total; PCB 40; Dioxin/Furans 40; BN/AE 23; VOC 23; METALS 23 x7= 161 (As, Ba, Cd, Cr, Pb, Hg, Se)
DRAFT SAMPLING AND ANALYSIS PCB LANDFILL
SAMPLE ID
LOCATION
LEACHEATE
19LEACHEATE INLET
PCB
20 LEACHEATE OUTLET
SAMPLE ID
LOCATION
SURFACE WATER
21 SW-1 SOUTH UT NEW
22 SW-2 SOUTH WEST UT NEW
23 UTUS EXISTING
24 RCUS EXISTING (Below Bridge)
25 RCDS EXISTING
26 RCUS NEW (Above Bridge)
SAMPLE ID
LOCATION
SEDIMENT
27 USSS-ABOVE BRIDGE ON RD
28 BB BELOW BRIDGE ON RC
29 SS-1 SE DRAW ON UT
30 SSND N DRAW ON RC
SAMPLE ID
LOCATION
POND SOIL
31 PS-1 OVERFLOW PIPE BASE
32 PS-2 CENTER OF POND
DIOXIN/ BN/AE
✓
✓
FURAN
✓
✓
PCB
✓
✓
✓
✓
✓
✓
PCB
✓
✓
✓
✓
PCB
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
33 PS-3 DISCHARGE PIPE OUTLET ✓ ✓
SAMPLE ID
LOCATION
BLANKS
34 TRIP 1
35 TRIP 2
36 SOIL 1
37WATER 1
38 WATER-2
39WATER-3
40 HYDRO PA
41 LANDFILL SOILS
PCB
✓
✓
✓
✓
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
✓
✓
✓
✓
voe METALS
✓
✓
BN/AE voe
✓ ✓
✓ ✓
✓ ✓
FIGURE3
OTHER
✓ ✓
✓ ✓
METALS OTHER
✓
✓
✓ ✓
Other for landfill soils include particle size distribution engineering classification, liquid limit, plasticity index, moisture
content, organic matter, nutrients
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
FIGURE4
August 24, 1995
MEMORANDUM:
TO: Members of Working Group
FROM: Bill Meyer
NA
DEHNR
SUBJECT: Expanded Groundwater Monitoring On The Landfill
Enclosed is the previously submitted proposal for additional groundwater monitoring efforts on
the landfill. I will request that George Bain (private hydrologist that I think is both an expert and
unbiased in his perspective) review and comment on the proposal. I hope George will perform
this review free of charge. I would like to have the very best input to locate and design the
monitoring system.
It may be appropriate for the Work Group to consider giving directions for implementing the
expansion of the groundwater monitoring system. EPA Region IV has offered assistance with
sampling both new monitoring wells and the existing monitoring systems.
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX 919-71&-3605
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
FIGURE4
CON'T
Workplan for Upgrading the cround Water Monitoring System at the
PCB Landfill
summary
The Solid Waste Management Division <SWMO) has evaluated the current
ground water monitoring system, consisting of four wells, at the PCB
Landfill. The SWMD recommends upgrading the current system by
Installing six addltlonal wells. Two wells would be coupled with existing
wells MW-2 and MW-3, to form well nests. The other four wells would be
Installed north and northeast of the landfill In two well nests. Each well
nest would Include two wells Installed adjacent to one another and
screened at different Intervals. Assuming no unexpected circumstances
are encountered, the upgraded monitoring system should provide the
PCB Landfill with a better detection monitoring system.
Introduction
The PCB landfill ls approximately 3.7 acres In size. The landfill was
constructed such that approxlmately 50% of the cell was above the natural
grade and 50% below. Based on blue line drawings of the landflll, It Is
estimated that the landfill, Including the liner system, was approximately
38 feet thick and ranged from elevation 354 feet to approximately 316
feet above mean sea level.
The current ground water monitoring system at the PCB landfill was
Installed In 1982 and consists of four monitoring wells screened In the
surflclal aquifer .. These wells range In depth from 39 to 51 feet and are
completed between 10 and 17 feet below the water table.
Hvdroaeoioav
The parent rock beneath the PCB landfill has been mapped as a mica schist
by the North Carolina Geologic survey. The estimated depth to
competent bedrock Is between 70 and 90 feet. saprollte and residua! solls,
Including silty sand, sandy slit, and clay, overlie the bedrock.
The ground water flow direction at the site varies seasonally between
north and northeast. During the winter and spring, the flow Is generally
to the northeast and during the summer and fall the flow Is generally to
the north. Monthly water level measurements, collected over a two year
period from the four on-site monitoring wells, were used to determine
1 of 4
FIGURE4
CON'T
the trends In the ground water flow direction.
The water table extends Into the silty sand unit or the upper portion of
the saprollte. The average water table elevation varies between the
monitoring wells from a high of 319 feet In the upgradlent well to a low of
295 feet above mean sea level In the downgradlent well.
.
Piao tor uogradtng the Ground water Monttortng system
The plan for upgrading the ground water monitoring system at the PCB
landflll has several goals Including: better definition of the llthology
underlying the site; determining the vertical component of ground water
flow; defining any variations In the ground water flow direction In the
residual solls and the saprollte; and determining the ground water flow
rate.
lnltlally, the SWMD recommends the Installation of six monitoring wells.
··· one well would be Installed adjacent to MW-2 and one well adjacent to
MW-3. These wells wlll probably be completed In the saprollte zone,
Immediately above the bedrock surface <auger refusal>. The saprollte Is
expected to range from 60-90 feet below land surface.
The other four wells would be Installed as two well nests, north-northeast
of the landfill and as close as technically feasible to the landfill. Each well
nest would Include two wells Installed adjacent to one another and
screened at different Intervals. Within each well nest one well would be
screened below the seasonally low water table and one well would be
screened In the saprollte zone. The specific screened Interval for the wells
would be selected after reviewing the llthology encountered In the boring
and the boring logs from the other wells. Figure 1 attached Illustrates the
recommended locations for the proposed wells.
After all of the wells are Installed, the SWMD recommends that aquifer
testing be performed on selected wells. Data from this testing would
provide an Indication of the hydraulic conductivity <IO of the subsurface
material. The K values would enable the SWMD to develop an estimate of
the ground water flow rate.
At the conclusion of this work and assuming no unusual circumstances are
encountered, these six wells, In conjunction with the existing wells, should
provide a better ground water monitoring system for the PCB landfill.
2 of 4
Eleld work Guldennes
FIGURE4
CON'T
All fleld work shall be conducted In conformance with accepted
engineering and geologlc practices as well as the Groundwater section's
Guldellnes for the Investigation and Remediation of Solls and Groundwater
and the Hazardous waste section's sample Collectlon Guidance Docurnent.
Well lnstallatlon shall be In conformance with the North carollna Well
construction standards. A site safety plan shall be developed and
followed by all fleld personnel. All appropriate decontamination
procedures documented In the references above shall be followed.
During the Installation of each boring/well, a Qualified geologlst shall be
present and a boring log completed for each well. Split spoon samples
shall be collected at a minimum of every five feet and where there has
been a significant change In the penetratlon/drllllng resistance. Soll
cuttings shall be containerized untll the analyses of ground water samples
have been received from the laboratory. At such time, the appropriate
disposal option shall be selected.
Each well shall be constructed: a) In accordance with the attached
diagram; b) In conformance with the State's well construction standards;
and c) to be capable of yielding a ground water sample representative of
the ground water Quality at that location. The well casing and screen shall
be constructed of 2 Inch diameter PVC. The manufactured well screen
shall be sized appropriately, according to the soil type. Each well shall be
completed with a 5 or 10 foot well screen. The annular space from the
bottom of the borehole to a distance of 2 feet above the top of the well
screen shall be filled with an approprlately sized sand pack. A two foot
bentonlte seal shall be placed on top of the sand pack. Above the
bentonlte seal the annular space wlll be fllled with a bentonlte-cement
grout. Each well shall be completed with a protective steel outer casing
and a tocking cap. A sloping pad shall be constructed around the base of
the well In order to direct water away from the well.
Upon completion of the well, a water level measuring point shall be
established and the elevation determined to the nearest 0.01 foot.
Each monitoring well shall be developed after the seal and grout have
stablllzed and no sooner than 24 hours after completion of the well. The
well shall be developed until all suspended materials are removed or a
reasonable volume of water has been removed. All well development and
purge water shall be containerized untll the analyses of ground water
samples has been received from the laboratory. At-such time, the
3 of 4
FIGURE4
CON'T
appropriate disposal option shall be selected.
After all wells are completed, hydraulic conductivity value(s> wlll be
developed for the aquifer. A minimum of six slug tests or one pumping
test shall be performed In order to develop the hydraulic conductivity
value(s>. The specific wells to be used In the aquifer testing shall be
selected after an evaluation of the soll sample descriptions has been
completed.
Report
At the conclusion of the field work a brief report wlll be prepared
describing the upgraded ground water monitoring system. The report
will Include: a> a narrative of the work completed; b) a generalized cross-
section and c> an updated potentlometrlc map.
4 of 4
Steel Outer Casing
1 plastic inner casing)
Land
Neat Cement Grout
Well Casing
(2" or larger diam.)
Pelletized Bentonite --.-c
Glean Washed
Sand or Gravel
Lockin~ C
FI
-r.
,to# -C\I Surf ace
• ~-;: ,to# .. -~ . . .
lO • . . . .....
_j_
u,
Cl) ·-....
~ >
• ~ -N
'
FIGURE 13.
NOTE:
1. Borehole to be
larger than outside diameter of
casing.
2. Casing and screen to be
centered in borehole.
3 . Top of well screen should not
be above mean high seasoned
water level.
4. Casing and screen material to
be compatible with type of
contaminant being monitored .
5. Well head to be labeled with
highly visible warning saying:
•well is for monitoring and not
considered safe for drinking. •
6. Well to be afforded reasonable
protection against damage
after construction.
Recommended Construction Details For A Contaminant Mon itor Well
In An Unconfined, Unconsolidated Aquifer.
~ MEETING REMINDER
The Joint Warren County/State PCB
Working Group will meet 011
Tuesday, August 27, 1996
at 4 :_3 0 pm in conf ere nee roo1n of the
Warren County Office
Joint Warren County/State PCB Landfill Technical Committee
draft August 21, 1996 Conference Call Minutes
The conference call between the Technical Committee (Committee) and the Science Advisors was
facilitated by Ms. Nan Freeland. An Agenda was read and included the following:
1) Scope of Work,
2) Status of June 14 report,
3) Weekly progress reports-Are they realistic?,
4) Lines of Communication,
5) Future plans relating to contractual Framework, and
6) Progress reports, etc. and :Ooris' role.
Scope of Work and Lines of Communication
The scope of work was included in the subjects for discussion to make sure that what the Science
Advisors were working with and what the Committee knew to be the scope of work were the
same. The four areas of concerns were:
1) The Master Plan,
2) Site Investigation Activities,
3) Evaluation of Detoxification and Vendors, and
4) Development of Soil/Waste Removal Specification.
Mr. Hirschhorn advised that no change in these items, but there have been some scheduling
problems. He advised that some areas are dependent upon others, so if they are not completed
then one cannot move on. Ms. Freeland stated, to clarify what Mr. Hirschhorn said, that they are
no fundamental changes, just some schedule changes.
Mr. Hirschhorn said that he has been looking into different technologies. He was asked to be
specific because the Committee had received no information on technologies. Mr. Hirschhorn
said some new information had become available in the area ofbioremediation. At this point none
of the new information was at the research stage, so his basic view had not changed. Mr.
Hirschhorn was asked to have this new information available at the Working Group meeting. The
Committee was then informed of a Canadian Company, ECO Logic who has a patented process,
which is not BCD, but uses high temperatures. This process is fully commercialized and
successful and has been used on PCBs, dixions, and water. ·
The next question concerned the status of the soil/waste removal RFP. Mr. Barnes said this is a
joint task, which is being led by the State, but with significant input form the Science Advisors.
Mr. Barnes said in the original RFP a lot was left up to the contractor and we need to give more
specifics on how the contractor should proceed. Mr. Hirschhorn said that the Committee must
keep in mind that the State is the implementor. He said no matter what the Science Advisors do
or suggest be done or what reports are written, that ultimately the work is done by the State. Mr.
Hirschhorn said that the State is a member of the Working Group, but he is not sure what
j ..
authority the Working Group has. Mr. Burwell said that she would not be part of this Working
Group, and felt that the others would not be either, if she thought the State would not listen to
the recommendations made by the Working Group. So, once a recommendation is made to the
State and they approve it, then the Working Group expects the State to move forward with that
recommendation. Mr. Warren said that mistakes have been made by all ofus, but now we need to
find out what it is going to take to work with the State and move forward. It was suggested that
Mr. Meyer set a schedule and be held to it. The Committee then stated to the Science Advisors
that when a memo is sent to Mr. Meyer that one is sent to Doris, so that the Committee will know
what is happening and can hold all parties accountable. It was suggested that Mr. Meyer provide
the Working Group with a progress report, detailing where he is in his responsibilities.
Weekly Progress Reports Are They Realistic?
The weekly reports, are they realistic? The Science Advisors agreed that a weekly report is not
realistic. However, the Committee agreed that a report should be given before a task is
completed in case there are some complications and the deadline could not be met. The
Committee should know before the set completion date of any complications, so it was agreed
that the reports would be bimonthly.
Status of June 14 Report
Mr. Hirschhorn said that at this point he is not sure what should have been in the June 14 report,
probably technologies. Mr. Hirschhorn was asked ifhe could report on the ECO Logic company
and he responded that he is not at a point where he can make a definitive decision.
Future Plans Relating to Contractual Framework
Ms. Ferruccio said since the Science Advisors accept the landfill characterization, can that
information be used by the vendors. Mr. Hirschhorn responded saying that we have to give a
picture of what the cleanup is. He added that there may be three (3) samples a solid, water, and
soil contaminated by PCBs. So we must decide up front what we want them to test and will this
test include one or more of these samples. Mr. Ferruccio asked when can we expect to see the
bench-scale or pilot study. Mr. Meyer's office must do an RFP and get a contractor to do the
extracting said Mr. Hirschhorn. Ms. Riley again asked if we need the results of sampling before
proceeding with bench-scale testing. The response by Mr. Hirschhorn was that is the preferred
approach. The next question asked was when can we expect to have the results of the sampling.
Again that is a question for Mr. Meyer's office said Mr. Barnes. Ms. Burwell agreed and said that
only Mr. Meyer can answer when to expect the results. It was suggested that a Project Officer
be appointed, who would be accountable for sticking to a schedule. Ms. Holcomb asked Mr.
Barnes if he could submit to Doris what he has submitted to the State so that the Committee can
help keep the State on track. Mr. Barnes advised that he had done so and the information in his
last fax was what he submitted to the State.
2
Progress Reports, etc. and Doris' Role
It was agreed that the Science Advisors and Mr. Meyer would submit bimonthly reports to Doris
for distribution to the Committee. The Committee also wants an update from Mr. Meyer, will
recommend that the State appoint a Project Officer, expects a report from Mr. Hirschhorn on
technologies, and will discuss source of funding for first phase of testing. Mr. Hirschhorn is to
fax a report to the Doris on the ECO Logic Company.
Other Issues
Mr. Barnes said that in the area of annual sampling, he would propose that the State go ahead
with that so that we can try to get in compliance since we are behind and that can go ahead with
new wells later. He also said that soil, sediment and water samples can be done now. Ground-
water samples would have to wait and off-site samples would have to wait for approval from
property owners.
Ms. Riley asked the Science Advisors how they felt about the sampling plan. Mr. Barnes
responded saying it was a fair compromise Next it was asked why the Committee does not have a
copy of this plan. Mr. Hirschhorn said Mr. Meyer's office took over the responsibility of getting
the information to the Committee.
3
August 20, 1996
To: Technical Committee
From: Joel Hirschhorn
Subje<.,1: Respouse to August 19 memo from TC
I do not know exactly "hat has gone on, but something seems to be occurring that is not
c.onsistent with the strategy and Master Plan that the Working Group previously apptoYed.
I ha,·e not been focused on tbe issue of possible lea.king of the landfill What 1 have emphai;iud js
that the s.ite investigation work, which was approved, bas to be an integral part of conducting all
the work previously approved, particularly with regard to understandiug \\-hat the requirements
for any detoxification technology wouJd be.
It seems to me that there is an artificial division between talking about detoxificatio.n of the landfill
a.11d the detoxification of any contaminated mat~ls th!lt have been caused by the landfill.
Also, the need to detoxify a large amount of contaminated water fiom inside the L'llldfill is .a majur
issue for detoxification technology evaluation. BCD technology, for example, do~s 110t s~eru tu
be especially effective or efficient for water treatment.
If the Working Group wants to rescind its previous approval of the strategy aud plan1 that is their
right But members should understand the implications for major uncerta.io.tjes in the conclusions
.made about the feasibility and cost of detoxification technology. Any preliminary design and cost
estimate that this project produced would not be reliable, if the1e W:\S no or little reliable
ill.formation on the issue of whether sunou.nding soil or groundwater might be contaruinated
sufficiently to require detoxification.
Perhaps the Working Group should rethink everything that they have already approved. lf aJI you
want is a report ftom me saying that detorific.ation technology does exist an.d that, in. theory. is
feasible and could be used and might be safe and effective for treatment of the lancifill 's contents,
then that is possible.
Because ''technical feasibility" is of such. itnportance it should be WJ.derstood that this setm1ingly
simple concept includes a number of considerations, such as:
detoxification performance/effectiveness
reliability of technology/vendor · ...
implementability
regulatory compliance
1
1-20-1996 0 , 34A~-I FROM
safety
Most of these have site specific aspects that must be evaluated for a detem1ination about whether
a technology is good enough for all criteria to be deemed ''techuically feasible". But llO
professional and no governmental organiz.ation views technical feasibility without also cousidering
cost.
Lastly, the reason I have felt it necessary to bring up the ECO work is that there ve cor,tinuiug
staten:.ents that seem to me to be based on ECO's work, conclusions, and rec,otnmendatious.
2
4078%1822 · · t ,,,,.,.,.,-,:,:a.· ;.; hn·• D8/ 21 / l 9'35 14:14 BARHES FERLAHD ASSrJC {Jl
.. :1··:i·C ---~ ... : .. ~~~L~::?1~~~1.~i;"·.-t-~·:=;:~;~i~~:;~~::.. ··-·•··-. ~--. ~:i ·.t;~~l
I·. .... ·_---_ ... -·'·· --~~~~~~~;·••""••· ,_ ..... ,···:··:~;~--~--·:~~--·~*~~: ~:·Tt)t~i
j""'~~~~"qiK~_ '~: :·cc·c: .. c-••"··· '.f t ,,\
: · ___ Barnes; FerlfJnd :·ah"il-J!\sso~_iates J Inc. . ...... :.-.··,:.-. . ... -:··;;):}·
--:_ '. ~U:~iO [~01~~n~j ~ ~ --~osHl'' Fax No>B i t,71 ° ;~;,~l•II ~: :.; •;:c►-,•-· :\ .
. :-')'() . .8_ 111_.J_\ -f_E:\eJ _ ·· .. _·'.·~.7_·= .. • .• /;t, ./,,>/ · T ~\., -------··-:~·. ----;,;;;/t·t~---r:. ~.:.~--=~·:·. ---•.· .
•.• ,i:: -//',.,. () k'f"',• \ '• ... . . _._, ·..,,L~ ~.iJ_,.!_,,.;_t __ ! .. i:l...-------•-· s.-:-·-=·-·~:·f;.-:,'_,f'jf',✓ ~::fl I · ,• r ,,;'·' ·:
1
·. -----·-;,-;;;-· I,) ;\ · . . ~ , · l·ROM; .... : 1'~ Jr ~--·-·· ,t~ ?' ·r:.-,,,v<--1 v n ,~cpl. \: ';' . ''''I.L '1 .;~ 1' , •• :.. •• f, ···--'··-··-
, ... , .... ~t ~:,:~1~~~;'~:tJ~:;~~-...,_::)· ,, ~;-;;·~-~L...-.:..:-Z._ .:~--'"-t-=-~1'.•i:,~,1)~~:~~---·. :: ,;~ .. ,----·-·j ..
. -;, ·-··•·· .. _. ... ~ .. ~~-~:::_: .. /;::;·.~ ~~-~·:•~=~-:.-.,_....,;·;..~ .. ---·-_ ~------, -~ ~----· ···tt.." II · \ ·
I' ,··1•1-., ... "]') 1·9c>"" ,. -F11vi; (I i'•''',~ •I •· ,··1 i ··• ··-~"--.. r ~,_. __ .. ··,_-~------·•·,.,,: __________ .:__J . -'.' . ~; ·,-:c_~ t ... ugi.1st ·, ... ,IJ ~':-' ---' . ..,_,_.'~~i .. .::.! , · ,1 ,:.~ i L ------
s~rnii~~;_::~;;· ._·:-s.:rii ::~it~~~{~:~; t~Snppicmental Sampling Pinn and_Rcintril Ma,icr~ -· .. , ----" -~ ':?':I;:;~-~~'[:~-C • .. . --c ----.. -..
... Since we Hist ~p6ke_. :1 hti:Vc t5tlfO(~tied the following ...... .
-" . ---~ -~:_ . ---~es :.i ~.::'i~:e~~::;;-. ~ . . .. . . . . ... :i'.. . . . .. ,
': ·--~:, . : .. · : 1. ·Add(\d Reginiialf-lvcl,ogep)ogsr Serti0n to Plan and tied it b6th t(l ihc lo ca l l!•,drngcol1,g'i r,iid
.. _ _ _ (~c "'"1'.o,~d{tl1~~tib= ·. ---. -__ ~-: . • •. ---
2.·· ;\ddcd thie,-: (3) gb_<,>lggk :tross :,;ections through the landfill area icnninating al 1h r pn)1~r1scd ,veil' l<i~atio,,;:-zJ:jecnu~e--oi"_tl~e-lack of sub1-m face <lata ( e.g , i-;trikc tu1d dq 1 or the ;:1ipr(1litc
. --.··.. zc:i.nc)i_ ~evehtlass~Iii1p(_i()i\~-~~tf'ii'iade . J l()Wever,, the water level gradi,;;,r iofi,nnniiNJ mak 1.:S
·::; ·~ 11\c cfo~~ .. s6Ctt·o·11;:SliU ~;)ex)t~Use"tLI ··
. , -.· · ,,a:~:-·:-~ ,:l~-~ i;~;~=:.~;ii;~;::;~:·:_~----~: -·" ·
'. , . . --
J . Obt;:1incd>n full .~rij>Y .o('th~,,ji~.\Y EPA, May , l 9% SOPs am usin/? tht.:1r1 c_xl e11~;iVl'h lo
···•nh>dil\' the _c.lriHing i'jt(i~_C:<liii_~t}i1_~ well de~ign -~ections I <lon'l thi11k.pr,1n·d111 c.~ arL: 11t.:~~('!J
fo1 an~as _\,1IJi~.l)(>\l_~rlapj £itlUhe ·July, 1994 8ainpling Plan : Fm C1<j!ll11:;1c, in de~nibit)g _\hl
1,rofocol fN surf~t:e_watct shi11Bling I reference both the Julv Plan and the :Fl';\ S(ll'~. Pk.J<:
let n1f ~1h:.~}~;~1.~I~;~~~~ft].!,i~~?~s~ · ·· ··-·· ··_ .. · -· ·.=:-·:::~·. · · :. · · · _ ::: .
"•iJ l·'eiler(d_i~~.r;i_c~s~.gj:()j>iesJh'ard co11y and on disk) of site mar with sa1.fi11le :loc;i( 1tltl,\ ;, ;~ ;,,;,,~1.las
t:1e drat) Ct'fl~s-scrt:bhs/t,:{Jli:-,b -CJl~scr1s attention, These i1ems ar0 draf\ il lld l ao1 1(1,:,kiri n,,
·vour .input 'as sob11 !\-~ i)ti s~iole --·: ..
' --· ·:..-··.::.: .... ~ .. ~ •. , ..... -~~-~~·:":• .<:---.:~:~---..::--:~:.,:-,:-;,,;.-·.--
:, .. I IJH\'(; h~fl -Jn~::s;~J;~:f ;):·~:I,;c:.;1~s.~-!', his V(;i~c mail indicates he is dtlie; _()11 i:taci\l illll 1)1 in llit
iield Pfo,l'>C· h~.\1e .hirrr1'an ·Hit!'. wh'cn he gets back in. J want to )1Jah\ sui,.; \.V(' fH!l 1:\'. un v, hi1t
" .. -. "'":·•_ ··.··"·'' . --·· -.. -" '• .. _. .... -·
r.li1 (::c lin1 1 ti, t,\ke the tL~.!~ Hi_irnd fhat we ~\IC IJ()t cluplica.ting cffor~s .
. --:-.. ::. : .:-·:· -~· .
' --·•--~;·•·(;--~?.:~~:~..:.~~~~::~-: . -,-~-' . -.--· ·-. -
1\I:-:o , 1ikt1~c le(i~ic tn<i~v thciiialu~ of our July IS th invoice. A l~ you knO\\·': C~/Sh J}.1,; l'i r ! 1til·id jp
.a SIJJ,ill tinn1
• ... ::::;;,;·.-: :; ~·-::...~--~~ ~-':"~7~ ... :
Plc~a~o gi,1c me {ci~U.f~diiyi.}i{:;~~-iJ?.lc.
l .hf'i--tolhsfe~J~dilcling -•,.:3,p35 i_;;iw1on Ro acJ • Suite 11 1 • O rlando . rlq_rid') J2ern
. i:.i~. · .. : ::c:::, ; :, Office· (tfiJ7) 886-8608 · F.Jx ( 40 ?') 8%_: 18 22. . ....
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·.i
4tl 78'361822 BARNES FERLAND ASSOC FtiGE 01
---~-----~~~~--.,....____ -. . -----.. -==-~ --------~----
-
;:~:: _· ;~~:~:=:i1~s~,~e ~dt!-ci)$~~~d:-Jln#~i.igh~d Jp what we kr"io~ abov1 the'-sitc/s-=gcoiog:{'l11,{e<l=-oi~:11.~~·vc]'j:'7f":~;~~:'i~
-'.. -·-:;:='··-·:-:-'"Ji; fl i l ctJ. J)I forfr1 atio_ti"aVrilabJ e.==S ii1c~·~wc have ll O j nforln ation O l) tHe sfr* ~:'Qr:~_UJ;-·<)f Jh¢ J~f;;:i;fi if}i:!~~~l ..,.~. ' ----.. •,....:;.--•.•--•··· .. ·• .. •····---·----·-•-:a,:::. . --·-. ,.,... ---··-·----___ .. _. ____ .,._.,..,.Ji .. . ~ ~f !t.i;iie -::vh!{ b: i~-~~~~ev~d t~ -_~n{io,_l_:·gr:oundwa~er ~_ow a~ay ~p-010-__ !he ~1-~tlH!iL~f -p~~ !.('!ftiE_~l _··Jt:~j-. ::~.ii1
·'''-~ -~"':·: t1ic11igul;1iion a1flilysis ofthe o'iilyG{)nsifilent lithoJogic contact identifiedfoJh~.fl!.!J(' (9) so,IJ,orntg~-:~'.i: .. _~;,:;,r -.:
j ··;;;.:~itf~:::u~~;:~~~+i~~7:~~ bro:,, ~~ni~a~~~; i:e;~z?~~f ~~f ~t~:\\1
. ..: ~:, .. 'Upper 20 fcit, Jias . a "'Ni\ -~H-ike_::ar1"d . dips .at ··a slc>pe of oi1e foot '( vei:iicai} fo_,: __ ev~i':{.)0 ·19.1..•1 .. ''•:. --··':~
" •· · .-,~>-(h()rizo;1fol). Thii-' is·:coin.ct<.iental"\tith predominant regional strik~Tdip foat~1re~;· ·;tt als11 sup})vils :· _ i~.:r+~
: . . "the apparent fie)~ :oh,c;~-rvati.oiJ4h~I!.0Ck_:-Ollt crops OC(llf-at "higher el~'.M\tio11(~~)_ptt'1 and soutl11:,ist . ·: ..... ;;tFf.'.'
--... . :-\,fthc lantiflll: thon-to:waf.ds ·q!.~-Jiorif--This may also represent-the nttittftle of the ~aprnlitc 1n~c<~:--·· 1·~~~~.:
-:---~-~ · :· .: : .. ~ ){t -i:miniJnum. ~l 1ii.~~?is-:wel!s_}!!,_l})-eri·orth of the landfill ~nay 11e;1 tube -co,:i_s1i,uct~J d~cpc1 -thi,i{~:~t::.-:::;ii~
. ~'.:--:~-~~~:~-~J~os~ ~~~!he ~~~~~~i~~~~'.,~~j~~:--.~---7 --_ -=~;~~-~--:~;~~~t~:.i.~~~~:~~~~-~ .. ~:~:f~-~~;~~~~
-,,.~ :-~:;;,;, nform:Ht0h j~-•th~ -~m~'~i;t~;-:-;fi}t~lh~-sap.rolite zone is_lo~ated betwe_en 60 atld <)(fi'ccl h~h)\~: IA)~~1_· -:s:·: :~Li
-,-. . . ~Jli'!~c~_ This app~'.ar~"to ~eTn-;°tOD_tlif.t with data 0~1tai~~ from te!i-t-boring 711-. wh,cl1-i i-fts'ihtJ(•ii::::'::·:·: · _-:-'.~;-~ ·
. . "_ ~'.:iJ~-~:ht: \v~llt~~J:~_.r'~~*-~iQ~e-s'.~S: hpproxjmatel_x-jJ -feet.'.. Boring "It 1 :is __ ~_C'<lf t),!_C /Jit,,<J.i(,lhe _p, ;;._~-·_ ii_·r:/::::·r
; -"-.:~"-=~--_::: :dy~cloj;ecl .sile. -no f)}J1~r -h<:ir1ng~~ ~.nio_unlereiflhe weathf?i=ed r2s:k mat~ri~L(tij_e~ii.mt:~U:<) ··bi]hf "":.~ ~ .• .JI2'f~:
: ' -. : . _···s:sai:'-P(it (" · 1,(1~~Yev~n j_Ji~1:1jb)br~~-~Q A, 4_A-& -SA) were . C(~11struc:t_~d fo) .. ~~~fc,; -~le .. ;1 ~\gos _-I!i!( i:. ~ ~:,c·•\i:J:if
---.. =::: ·· ~ii.ppcfr'ts the notkj1(t1fat the_· weaU,ered . rock -zone may represent a. sub.c.ltied J cOct-ti<jn_ ~;f__hiitt ;:.~.· _, ~,::~~ : .
.. ~ ·;r~"~}~cc,, ?;:~;~~1~:~ .. . ----. _· ?--~-. :~ .. :~~~;;,7 ::=~:;t9t~tli
1
.~ •••. :fhis walysis has 1iorch~,m~ff~11t1Y=.of_ the proposed analyses," however, 'h doe~ ~uj,po1 t -s~_\iei·al key -_'~:~-:-_.:..· ~'.' ~-;•:·
:--;_ . a~~uii1pt i,-,11~-Whidi ha~ve t5een11ia'.iie iff developfng the ·supplemen,t_af samptt11g pl~n <1t1tl the 1,etci f (11: · ---~:::::·: --~-;:~.
-----•nore drillit1C: tand te;iting~:'l:--~---~---::~_ --· -. -' .,. -.:. . _.---::.::. ___ · -· ... ·: ::-.
, -,-.. .. ,--~--'·-~;;"~·-······~~~=,"~:_:·~~ -----~-::· ---~,: '.~--'..~~: ·,.,,--;>~:·=: :·~-;·:,·~~~
---------c .. ·c-·_ ... --· --_: __ :.-:_ ·: .•. c:7:.._:_::'..~~~~------.. Post-It" Fax f\!ote 76'71 ... Ual•J • -__ :---~ Ji-•~,i,<J►_ =--. ~ -; -•. ~-ii.,:·
-----.... _:~,:~-_;-:·~~.t~--:;_,:· To , .• jL C/ c, -~. ~ •~:r~;✓i::..--C:: '•.:-Ji · r ,:/l,1,.,g/8-2 1111vn .J,K,· ·-_ ··•---c 11:JE>l'll . ... /!. c~ .. ' , .. 1 •. ~----.. · ,.-_.,,;cc,,._,.,,
_,_ · --0 : \~ork~D~-<~r~:;~~-~ec~li'icii~~oj~;~i~tee ~;~:~rn-~fjf ffe?S~~----~~-.. · nd_{-e .->· ~"_:-~~: .. -.~~. ~~~::1~~
. -. . ;;: --Joel lfirscf1hor;)~·~:~: : .. -: _:~:.,.-.:,:_~:~~---. ..&l¥~t;q n .1X_'' l-·\ c=.~~:. . .. ------~~~:__ ~--~,"~.:..:. ~-., -"~··r
-· -----~ : -<c; ·,.-~i~~-'. "_ ,. -. -_ .. . . _ -.-.:::~--· · -~1~. : ___ .. :;::~:i,:;~~--;-~-~:;~_J:~;L
---·· --The Hofll'St8r:.6i.iifding .:.353~ Lawton Road·• Suite 111 • Onandti f1oric.1-1-J2803 .:: --~ .. -·
•· . . .. . . ::;'.~-~~::orli_~e (407) 696-8&08 • F<!,l'X (407) 896:1822 -~:,;.~,:_·· ":. __ .. .... ,.:::..;:c~•= • ..
--. -. ---==--.. ---=--·· . -·----_;_\~_:-:'., --~;-~~-.... ·-~.-:-·" --.. : .. ·------. ~ _ ... :~ ~:· _;" ;-:}~~~ ·-:-. .:_, 7: ~ .i=..~---= ··-.• --=~ ._ <--=---. -
_, •-. . :.. 7-~·. ~ .-~--.. 7'r~~--~:-:-~~~~-· . .:.~~-.;. -~~ ·-
j_ ':~ ~ .. ;. ': ~ -:-:~--~-~\:-"~~ ·~~ :-~tf~~-?jf\\.. . . -_ .~~ -. '
T.·_ :j3.J~~t~~;~~~~.~~~£q~6-nsu;ta~ts --~-t:;~~-
: ~? =-~ =-:s arn f1 S ,.~.Fe rl_i;,;n.tJ:...a tld ~;A$ 80~l {1 tes, Inc. ~~ ___ -~ -.. ·--;"; _-:--__ .. ,. -...:·····.~-.:-~_.:.~~-~. ~-~ .. :~-~-:· ... ;:_~~ -' . --:_:c.-e., ·-.·.---·~ -· ..
•· . ·-+-"MEMORANDUM ,:_-~;._~~~~-. .. . ,_ -~~~ .. ~~:~~~!~~~<:~~~: ~:~:~-~~:
} C~ ?/~1' .. -,J/~;;t~;;\f ~-h.-:...--~_,,~~_If?)-•': -~-. -;:;_;-~ ~\~ '-, .
~-• 0 ::-.-~•--.M·•• -••••• O O O .•• ~-.' _.o/._,~-=~-~; ~~~·:.;.\{_':, ,• -~;:•~--~-.: O =--.;..!'rMO
00
O ·----•:• •
. . . . ._ i~RO.M :: ·( ::-· ~r-a1rick i3'arries '.~-' . ,.,,,Z.~L~ -...:_ ~ :--'·"~ ;,,. . _::_ ,~-",. •·-';: ·. -.. · ::_: ,: .. ·: .:·~ )~ :·~-~-~; :~'.·t~:~·: ~~~t:i.: ~~~ -----· ·:=~---~-·--··· :.i=-
., ,.,. _--.. · ·._ , OAl.E.: '-:: :.. -,. .-~u_g':_lstJ_(;i, l.2,~ ::_:.:.;._ · · -__ ~·--~-.:.. -:-.-· ,~ ..
:·~•:;• ... ·.• •· .... _•_·: ~.\~ .... ~.:.•M~i-.•.~:~~ .. ~;~---~-~•:•:!'~,.-,.~.;~·-•.,_.~~.•_; ~<••.• •, -.::: ~-; ~-.--. ..;__ .. ~-;"._.~· ·-=;:_· • • - ~ • .:...:. -.;-~· ... ..:-:--:::::· -•.
• i· ·~ ~ ~-"': · ·_ SIJBJE(;,f.:· :-:St~i~i of~fW_otk_EITorts and Related Comments" .. ,, __ ~ -·--•"', . ::. ·:·:-~ -' ·'.·: ""-~: \~-_:. ,· :\ ::::::{,g;;11I~t: _---_ --. ---__ _ ,_-": : ->~t~.-? ::,~-..
~. · ·:-·: · . ·.-,J. conced~ tlittt :our: initi~f:·~hijl1gl1ts'tnrhow the project would proceed w~~~extremely _ opti,:nistif-• lt _ : · .. -.--:·-~:· -_
:: .·.:_-· ··i_s ·often:~ery .difl1~uffto ·.d.evelop a project schedule prior to thc.establishn~cnt -of.a woi~jn_g •. ""·· _~···: · 1 -' ., -.. -" -• • " ---' ' r=· '-.. : __ :, relationshi.Jr\yittla~l~e\1i~--.;.--:=.>..:.:: · -. • ·. 0 _ --~--, -.-··-•=-----< =---: --:.-:f·-~ •-·:_.~•-.. .-< •., -: ·;~::. •:"'~;•:t:~~-i.'0:T.~~/~:'.~ , . . •-, ' <· -:'. ~ ·: . ":· ~ ~::,.·:~· :-"' -;._·~:'. . r.~,'
-;"~:· -' ·. --· :\_The -_or~gi,,~J-"inte~,.~js: tan:~~::secfi · on the project Master Plan schedule,. was to-move :tl(?°:g· ~~-: ...
. I :· • -• -:_ -·~ .. :"00}1(urtenlly: in· four.:areas;~.: '-:2_-::-· ':" ' ~ --: ---" -' ' -: ·'' ' -__ , t?: --_--___ -. -J.: ;~=i~/;;;;;£::SJ±-f;{-' . -: . -~~t ;,,;c -~<
·~ :· -~.: ,.1,.:t-Sile-fo.~~s!it{~tipn":Adiviii~'.s'"::·-~·,-· . :' =::':"~. ··-":'~?:'." ~-~----
·~ :-:-;-· _,. · l::.Evaltiation·ofDetoxificat1on=andVendors . . =---·-'.: ---. :·;
-: · .~--; .. ·. · i ·nev~lbpn1eri~;of..Soil/Wa~ Re,~~-~al Specifi~tions .. , ........ -. -_ ·a .
I • ,. • • •.:..., • • .., "' ·_2· -'!_:-.:; ••· -•
: : .. ::·.:_· .--·_:;:~. ·,. =-_: __ , .~ .. -~~~-_:· -.. ~~~~---.. ~~·-~~·.' . -. ·--· ········ ·--:· -:~·-..
' ! _..' '.·.,. ':. ~::;,n _ ,11y" opinion_,jhe:: M:~si_efij~n -~~procedure and critical information iI.s~· cQllll)1Unicatef tf," )tit{~:,:· ::· ...• -j ,,--"
·-.:. -_ ~ '-.Working.Qr9u}'i,d~r1nf:ou"i'j\prrl-~5, -J996 presentation. That fad re~~lted in a "lack of'initial _ ... : -
,; . . focus ·.on the ~~a.'st~r ""Pliih~: 1:JJ"CilUS!! pf the need to comply with the. annual, sitmplirig require,rient '
·:of t~c TSC4 'pcrtnit-;: t~~~fgcus of.both the State and myself went immediately to Jhe dcvelo_pn'lent
. . . " -and ir:ni,lern~ntaF~n tif.a stip,plem~tal sampling plan' '. ' : ' .· -::. ---_. ' -' -' -:·=--. ' . r· : :._. :.-~-~> -•~.: _· _:/~:.--~•~~\-~j ·: ~'.>~:~:~-:•. j _-:---, •, . a -• -•• ."l' ·~ . . -, -:c:.: (:_,·. -. -.. -
... :-· ·My ."initial_ -though. ~~s le, ,flr~t_d,llcct samples from V,e existing-network' and several 'jfroj}OScd ' -
.:·. -. -:· '--surfat'.:e wM~(an~ ~ediilie~i -=s~~ple locations .. The additional groundwater (monitor_ing we.II)_-·~·----·
,-. . ..... ~-samples \~re t_o be colle~ed'.as a second phase Handling the sampling hi two rounds would have _ ..
~ · .. ~: ·. allowed us-:tin1e to coordiriat~ th~ ~rilling activities necessary ·to obtain addltionat monitoring well. .
:!.-· · :· ·. sainp"tes while ttill'moving'r~ri\'.ard ·_with the annual sampling requiremen(. However, during our -· ·-
. ' . July_ 3 ;. ,1996-"fheeting ~Ith" th_e.' State, it was generally agreed that movitig forwa1 d i,1iti1 ()lie ! ·_ ". " " . '
. . _. ~ _· ·_ ·sari_lpiing ~yent ;-aft~f -~"ilt\!I_ ·rttottitoring wells were installed would be-m_!ire· cost-dlective_l\ncf ---... ·
'~-:: <:' _-.. :.:-: ~~-~t~t~::.-~;.-~~~:tt.i~~<•:: ;j~~:~-~ _--_ ' -' " .:.. ·: :_ : ' ' ' --_ -~~-;. ;>:= -~. ~ ~~~· ~.~---~-.
_,-... _ ~im:e lhtf July)~d 1fieeti~g J haye):ontinued to work with the Sta.te's Bob Glaser and Bill Meyer . -. . ..
. ; ... ~:: -:_ -: on,the~aevelop1fi~nt _"o(il:'.S1.!P~le}nental Field Sampling Plan. The secofla)raft_ was foxed : to "ihcit,. :~ ; ~ ·_· ':.-:·
::-.. -. . .· ·offi~e ory July 18,J ?16;.. :T~f~ .~~s ~~me after detailed conversations with.State.-staff arid ~tlcr _the-:···"· .. -:c '..
//i;:~:/ <-~:\\~!=li::\-_ ---. : ::-. -. -~~?t:t{'. _::
' --·. · · .< ... -'r_he Ho[lisler BvffcHng·• _:3535 Lawton Road• Suite 111 • Orlan.do,, Florida 32803 ~. ··-~ _, ·--
. ·~'· .. --_. ___ ,_, -: ~--·:·-~-Omc:i~·tao'7)896-8608• Fax[phone] -:--. --
. , ';; __ .. . .. . ·. -~ -~--:."':~:._. ~ :-.<?\-.;:~;~~~c-:~::.~--, " ;:_~ " -:. :·~:.-,~: -·
!: -. · ...... • : . ..":~ : = . -;.--._ : ~:~-... ·= ~·: :.::~~--=·--..: -•, .:.._ 7°· • -.. --~-·:·· ::i _·::.~~'a:_~· .. ~-·:· .. :· ... :·.::~·:.~•::
:_. t .•~_ ..... ~. _: -~•.•:~;: -~~ ;--~•••• •• ~ I •' •~~ .·--·:.-.... _ _:w.:_;:~~~-:~·~~:~:~{
] 7 . ',•c ME~OJiANDm.~/' ,' ~" ;'!:;;-,f~'. • . • · -·-~ • · · .• C.a;; ":• c.,,. ~-\~};1
j; ~,_:}I ~::;~_::6:tt~"-Y ~:-;r . .. · . . · .. · . -.. _· :;'. \ -. _ · -: ·:-,z>>i-•_:_
,·:_.-·: ··.~State reviewed tl1e-draft o_utlinc.--,.he araft only included text for tho~e se.ctions wJ,ich we agreed .'·:-·• .... •-
.. · .:.· . _ ... \\;<mid be -0evei~ped -b/BfA· (I .believe the Working Group has been futnished R coi,y of t~~at :._--: ·•· -~-;--..
": : : ·· · --· drnft}. The sections. JeO, -~Jank -~er~ to be developed by the State in-~i truejqint effort ~s agreed to .· · _ , -.. · __
~-..... : '' .. irj_ourJuly)i~m.~~tit1g.-,~-·:.:; :_··_· .. · . . .. --··. -~····:;, •. _.· .. .
. -... . '. . . -.·-: .. : .. _: __ ·_-~_:_ .. . --:· -.:~~~:-··;{_·-~-:-·-;_-_ . .-· .. ··r··~.·::~•7·.~-:::·~ :.:..._:._~·.:-. -: ·. -. -.. _ .. : .. ·-.. -~·... -----·-----·••·
~·.:-.-·_'·since the Miistef--J'laf1 .'.'p.ieseiitaticm where the State and the Wo'rkio.s Gioup· agreed l<i the ·~: ~-. ,::::·'
: . . . :· ·alternati~tntpproach w·~l~hj~clui3e9 expanded sampling and analysis on the/rorit end, I have bc~1i .~;::/-. ~-'.~
; · · .. ·· working underthe ·premise djal the'Sampling Plan would be.· · .. -. · .--_ · ---· . ~-· _;.·--· · t ··· .. ;_,.· ::~-~..:· ·.-:~· ... ---~·.==,~:~t.d.:,._;_~::'f--:·<.-'. .. -·: ~·· . .:.._._·-;,_··-=-.:~._.,.· _.:· .= ··~ · .. -.:-,·--~,-~ _,""--<_-L
·. · .·.· ·. ··· · , . A supplement \p ~h~ existing 'find approved State Plan. The be.lief w;ls that there is no tJeed :t9. -·-· .: :· :-·· -
·· · -coinpJeteiy _reir,-~ent t)m ~!1_eel. -'This approac,h was agreed .would save time aiij effort and w;ts ··:·_ · · ~.: ·. > .
pattictilarly"iniporta~tbecau$e.::ofthe need for continuity. . .. ·._· .· • · __ · ·= :-:_---~ · . ·, . · -·
-~-. ~-,. .-' "'; .. • • 'Y"": • • .-~~-, -• ··= --.. ·. . : : . ,_.::-·.·.: ':: -.. · ... ,.; .~: .. "·., .--~-~~~~ .. :~hr -~t~p·~·~.y~~tp·~.:-~-:e~h~lb\~gies and other SOPS . for -samilie · 0cp_ll_c;;i·;m, -:ai;aly.~E .. ,:-;:::,· .. -. 1-=~:;_
. : .. ··. ; -decon(aminaiiori and 7othef fldd me\hods would be included as appen-dices and nol uecessarily . ---
.. _::_~ . =,' . ,'· irt -the text ·6f1h-e doctim~.ni.-·-.· . .,. · · · · --· ··--~ ·.:, -"~::_\; /:
; '. ·.. {b~ Au~~~; 2~~ ~~ 61h i{; d.:.i;ed convefsations with Bill M~;.; abo:u,: ;~w draft: Brn > :;; ;,
. ihought 'the b~ckground .-sectiot1 .should ~ontain-an analysis of the wqrk-~done to .Oi\l~. ··1. indicated· "t,:,
!-· · .·. : tl'iat itwo11ld ~~ best if his Qffice provided that analysis because l felt th~t it would be dilTJcul~_fol' _ .:-
.~ ·. . .. ·. ' -n~e 'to conclu~ively _foterpret the dl!ta without. some addiiional analysis: ,-.. .· ·_ . ·. --. ·. __ · .. : ;: __ ·..:: C ::~,: '
i .·:.':_:····~· · ...... •.·:·: r·.7.~.:.--. .... ..:... •--·~ :_ .... ~.~-~· . .:. , .. _.. '.,z ·:.-·· .. :.:.....".' •
. ' ., . He ·asked_ Jl}~ to Add~:~Qt~ -sp~cifics on the regjonal g~logy, 1;10re cioss:-s~ctio~-s showing b~r -~ ~ ·
-c-urrent jnterpretatfon of u;e ·s_ubs~rfa~ system anc:i more refererices·to .suppo.rt the p1opo:-ed . -· .
r supplemental investigation a9tivjties.. · -. . "' -.. · · _ -· __ --·· :·-~-· . ~-. _: ;·. _ .. .'-:-. ~ ·. ··. : . -.:<.··:·.· ·-,:. :· .~ ::•-~j~t~ -. . ' ... '• . ' ... : •. --·,::-.:. _--~.' ~.-: ~:, .. ·,t:-·· ,:./:·::_: ·:··· .-·., , .
. ... --The Slate1'agreed to ae'lelof Sections of the plan related to site ··acc~ss, ·Vv'ork .zones :imd siJe ·.~·-· ·._·.
I • ,• ••• ,' ~ontroi, ·decontatni~ation faci)itjes and procedures. The State had also agreed to "develop the-._-~'. . .
·. · analytical testing 6ett.idn .· ... 1-:reco1,tmended that they involve Joel in that effort_: Although 1 'agre~ . ·. .
. · wilh the conin\ents~tilitde bythe SJate (!n the work I submitted, I can 't undeistand why. c:.peciall~· .: ·:
· .::. lf this. is a joinfdfort. they were not tomm~micated to ·me_ sooner than 3 weeks· after I ~ub,nitt~d : · ·
· ..... '.,:. Jhe. drafl ._-__ --~: --·. :-.-~. · ·· ·· .-::-· >·. : · · · .: . • · · -~-·
.: :=· :-:::1·:: ·• . .-.;<.~--~·::_~....::i~:_~/·t .. ~--~~--·_:--~ .-. ~. --~<·· __ --_-·:·:t~/-~."'":~· .. "'·:
_;. ..-.,_ on-August 6th, Joel a(ld·1 agtee"d .it would not take a great oeat ·ofeffort to _dratl the T\•1aster Plaq_.,i
. :: .. . . and we dedded to ~expedite ... its c:ori1j,Jetion. Although this is not a critical. -path docui11em(· .u drnfl .. : : ., .
; · . .:_·. ~ho~ld be fUIJli~he~ to the W~ft<.!ng Group within the near future: ---. ---· . ' ~~.---·---.. '.:>.·t-·:<-.~~·:::-.~·--."._;-~·,<~-:~~--·i'.::.:J,·-_~~ -· -' . __ ·. "'='.,.:.·< . ·. -.,,_ ,-:;;'.f _ .·:~ _"-~'.·.
.. . ' : .. .. . w;.th re~pecno the vendor/ttth~ology assessment-effort, J don't agree with Joel' s_~tateri!eflt .i_il his ·,,·.. .
1 .. ·._ niost re~~h(n~~mcftha(ni~:.d,el~ys· .are the result of slippage of the sche~iile.On the in~estig!i~\ori.~-~~ :_ . --~·;:
· . :· . .-...... ·3ide. Jn .my ?Pi~1ion.,..-,.O}'o _ 1!."-:90¾ of that task is capable of completion without_ ariy. new ...
:>. ·. .. asses~ment~ata, ·: ~·=..:.: . !-... .-_--~=-.·. . . . . · : -~ · .. : . -· . ;._ -,, 0-··
1,·•. _..:.._-:_~.: .... ·.--·:....._.:·-.·~---••.~ ..... _: !!•· .. • .. ---~ ,, ··:·: ... ·-~ ... ~_ .. "=·.,_,_cf _
·:· •· • .. r· •. ·-. ~·::. , :-=-.,. .····:-=; · ,•~-=--:> ,,;~~--~ ;_ ... -_ -:·c.. ~-. --·:·
0 : •• -• • • • • • -.L _,.(., • • • .:. -• -
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· .. --· ..
. •. ·: .--... ·
.. .. -. -
l::lAt-<Nt.::i t-t.t-<L.Af-lU A::i:;jLII~
.;
; .-· • _.Ocveloh.ment ·of.~p~i~t·~~-iQ!1([◊_fiQil/waste removal is also an independe~t t~sk whicl~_docs.~ot-:>
... ·'-· -·_ . rtqµite compl_eti<:m-of any··o(t~etth~rs-mentioned. It is my understanding that the State will· lea~ .. -
·'. ~ ---~ : .th1s effort w1th .sigbijidanl-ipj)ut e:o.f!i the Science Advisors. . . ·_ · :-_ .. -. ·_ ·:;_~ -._ !~ :-":-_ ·_::· < __ ; :..'_ -.~: ·~:·,..:,:::•:~~-;~;~•:/t.-· .. ;::,;. . ' .... : <-;-·.--. ·_,<-<-~--.·"-~ ·--,-
: ·~ . .:_;·~-· . ·.' Seq.us~ tJ1e, dev~lopm_eni of any Sil!l_lpling Plan is · extremely subjecfrv~_(fhere is rnorc . that'!_ ~.)JIC .... 0
-· .•.•••
:_ -~ · .: -~ _':· ~iglit_.way •?·~ccoi~pi•i~r~:gO~lX llegative criticism is always poss\ble: .-:~ecause of an appah~nt ---'· · .. · . .-'
~ -: : ~ breakdown in ·¢otbQ'unication~ Jh~virection which this project has taken_ ov_er the past fow months ..
-.. _ · :is_ nor _ori{whi¢h wilfe~p~dite:the .·objectives of the· Working Group. Frorn my vantage pqint..it'"
:: ·. · ·= ~ ,~ ... 'appeats ·tna(onhec~ssicy·~c~Jt1pl~~it.i~s·_are being introduced to the project . Theie complt:~\-~it's,·-"'
., · ·: · whe11 eievated· ,n iinpqrtance;·.-wiJLaelay the project implementation. l do believe thnt the ~tate .
--~-stat}' are -,~~!king h~rd··op-::'mp\;_irig· this "project along; however, when rpinor i~sues _a!ISC, mole .-.
: ·. . . ~ ·effott needs_·_tp ·:be·=spe~Fo1(d~f~i-n1ining how to -move forward as q~ckly_ and efficiently' a~ ~--.
·. : .. possiblc '·,mstelid of ailow1ng tho~e .isst1es to elevate to a level of extrernc importance wh1cb ·.--. :
;.-. . . -·. ultirnat~I_{ itnpact~:. the<ptojecT;pt})gress. This same phenomenon was. yery evident {vith tlJe"'-~ -
·:· . :-~--.· _. prcV10~1s Sdcnce~,Advj~o('· ~'hf_ rny-=opinion, the parties involved seemed _ more inte!csted in
·: · ·_ ·• ·.· hig~ligh~ilig ~h~ prob!c~~s-~~soeiat~d with the work than identifying ho,w· to ~n_ovc forward in a
- . po~itive·direction.':-·::. ·<:.:,.··~-:7'_:-.-'"'.,,_ __ .. . . '_· _·. ,·. ·: ::~·-=:~·, .. :·.:.':~;<:-_:.:•{;_:~~-,~~--~ . ' ' .... =-. . '. . -r . the challe.ng~:.is (lfw~ atttru!f.working toge~her) to find a way to move the-project alohg -.in ,'\ .
. :· ' sc.ieiltifically :tpurid . and Cost:.efi'ecltve ·inanner whivh rneets the stated iriissiun of the w (jJ·krrig
'I:;:•
. Group._ lt is --impo~,int' that :we l<~ejfthis project on the high road . The groups and individuals: ..
. involved musf au inaintain,a great clei\t of respect and understanding forlhe_ opiriio,ns cujd posit ioi1s_-· -· -.. -.
. , ' . ~ of the _-affectesr pa~ie~t/ It ls;lilso .very important that the project--aavisors understand -!~}C : , ~--~ .
:·"~-_ .· .. -·-umq~~~j~ss:.:.· of~:(,iiflaffdfill '·anff'! that WC do not unncc-essarily "group its assess1i1ent _ -ail<.f ..
· . . . . detoxiticatioh: approach ~ith•·those whjch have followed , particularly as it rflates tn comm~r1ity _ .,__._ ' ·.:.~:-:-~~-,:_~:./~y~~?f;z;~~~~~t.~~~t~;ft~:~:-~· · . :. -_ ·--. : : __ --~-~---7--.=.:~-. ·::. ,_,~---~~-'.-:~/: :-~-~·-:; ~-
, · ---· · .1 apol,igiie··rc;y not wdtkirlg·harae( to _keep the communication Ope~. _..,._To that -end; and atih( ~,, ·_ · -~ >-_request of Ms.:Bur:wetVrh~v~ .• _ncluded several recently developed draft maps l\nd f1gures__i'o be-._ . -.
.. ~,: . -: · i~1~luded ~JI ·tii~ Sa.i1~pHng·_Plait.-.. tf atiyo~e has comments or questions please give me a call . ~-· ---
t'. '.• -~~•",·. · __ --.-•.•.•••·~:;:~·~_;.;_:,fr'-.::~<;:\~.'./-.·:-' .-·. ·s-.:=. . .. ---.: ..• :C""
·-_,~ _,,:: · f·_. am-glad".f askeij _ _Mt:-ifei~cdo fo provide us with copies ·of May-11 · _and '.Ma/2 l , .J99.t.-;''-. -•.
_, .. -~_.·. -· C()Jrt~po~dei,_~~s'betwe~n _1,e 'iuj~-S~c;retary Howes;---: They are very info,r91iltive; however, they dp
. . . .· · raise· sortie: key ql!estions. ·,:; ·. ~~~-· ~ ' . . -
·-r' _-·. ~-' ~-~---_.A:: 't.i:~;~tif ~~i-ti:~~itl~1~ -~ --am availabli both f~~ the A:gu;(· 2.1. :\9%~ 9:-00 ~i\.~~~~>/~~~ ... :-;i
._ ._:. ·-'co~fo~~n~e ce.U·at_1~)._he Atili~n~:1;-·1996 Working Group meeting. · . . . : , . 0
. ..·:':
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.... _ ... ·_; · · ):7~/;~r ~·i ->~-:~~~:----· ·: : , ~-~/:'"':.c,. · --
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06-12-1996 1=15 PM
WARREN COUNTY PCB LANDFILL
ANTICIPATED PREFERENTIAL FLOW PATHS
FIGURE
~~Environmental Consultants
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06-12-1996 M5 PM
CROSS SECTIONS
WARREN COUNTY PCB LANDFILL
FIGURE
fil,_,"73" ~ :!environmental Coneul!ama ifarnee, :F•r1en~ •nc. .Aioaoc,erN~. ::.:.!" wwm~v SallMENT S.WPLE (SS} EXISTING SURFACE: WATER s;.:-TIONS EXISTING W£U. ( WW} b, HYDRO PUNCH SAMPLES @ NEW W£U. CLUSi£R (MW) @ NEW W£U.. POSSIBLE CLUSTI:R A NEW CID WEI.I. (MW} ')'--1':,-1~~ !1·0::t .... WARREN COUNTY PCS I.NIOFU.L. FIGURE EXISTING~ PROPOSED MONITORING STTtS
~ ... -~ ,JE3W A Environmental Consultants /J/6/vnN, ;:~r,atuli llnai .il""oclatl6a, ,nc. [ID ill fil ~ iY LEGEND SURFACE WATER SAMPLE (SW) SEDIMENT SAMPLE (SS) EXISTING SURFACE WATER STATIONS EXISTING WEl.l. (MW) A-A· CROSS SECTION f::. HYDRO PUNCH SAMPLES @ NEW WELL CLUSTER (MW) I I = ® NEW WELi. POSSIBLE CLUSTER I A NEW DEEP WELL (MW) f'.16-:3-~-=Q") '.!·03 6"4 WARREN COUNTY PCS LANDFIU. EXISTING &: PROPOSED MONITORING sm:s FIGURE 1
~B 100 ~ PROPOSED NEV SAMPLE POINTS NOTES, Voter Level MeosureMents on October 5, 1995 CDoshed Areos ore Jnfered) Bosed on Do,o Received FroM $"tote Files 254' 337' Leoc:hote SysteM 316' Saty CloY. (0'-38') Cloyey S,lts · M;co Schist (70'-90') 330 320 310 290 240 ~&,Environmental Coneultanta /il,l!rn•e, 1r~,;.,nc l!nC .-,1111ocl1Jt•e, inc. ~~ ~,~ 1I ~ HOR!ZDNlAL 0 200' 400' VERTICAL 0 25' 50' ~B' 06-12-1996 07,29 AM G Jfal' a' ti I S #e en-Section ..... f,-E,' WARREN COUNTY PCS LANDFIU. FIGURE ;,,. ~ ..
~., .,, ~c TD @ Proposed New SoMple Points NOTES, \Jo ter Level MeasureMents on October 5, 1995 <Dashed Areas are Infered) Based on Data Rece;ved FroM State Faes 30' (70'-~0·) 100' 320' 310' ~ A Environmental Conauttanta taamao, ~•ri1mtli •ntll d.oooclair.ao, inc. mm ffi ~ iJ -~ HORIZONTAL 0 200' 400' VEl!T!CAL 0 25' 50' -c· l'l,;-!;i,-10Q6 ,.-,,:.a AM Cross Section C-C' WARREN C0UN1Y PCB LANOF1LL FIGURE
.. .., .-, j:) @ Proposed New So.Mple Points NOTES: Vo. ter Level Meo.sur-eMents on October-S. 1995 <Do.shed Areo.s o.r-e Inf'ered) Bo.sed on Do.to. Rec~ved ~roM Sto.te ~aes ~ MICA SCHIST <70"-90') 100' 240' re:,~,;;-. ~ Li.~ Envlronm,ntal Consultants !Jair.1<1111, J'r,r/.9nilll •ni:i Ji111111ot:l@t<1111, !m:. . . oo rn ill ~ v ~ HORIZCNTAL 0 200' 400' VERTICAL 0 25' 50' -:p' "'C:-1 ~-• oa~ ;7,~,;i ~M a-aea, rre ::::::mr,a SGIM en.a Sec:tlon ~, WARREN COUNTY PCS WjQFlU.. FIGURE I
NORTH A @ Proposed New So.Mple Points NOTES• Water Level Meo.sureMents on October~ 1995 <Do.shed Areas o.re lnfered) Based on Do.to. Received FroM State Faes /1///, 100· II n:;,,;'6"-i.:.,,-., MICA SCHIST <70'-,0"> 2•0· An"tiCiDC"t~o' Appr"'OX. LOCQ'tiOn oF Gr""oundwo 'ter D1v1ae ~,&,,Environmental Consultants 611mec, Fe11icndi cnci Jil.o•ocl11t••• ,nc. 0 0 .s.c.eu. HORIZONTAL 200' VERTICAL 25' SOUTH A' r:~ illaJill~V 400' 50' 06-12-1996 07,29 AM Generolizea North -South Cross Section of the WARREN COUNTY PCB u\NDFILL FIGURE ,.,. "~
tr 2167.362171
To: Pat Barnes
r-=rom: The Technical Committee
Date ; August 19, 1996
Subject Confirmation of meetings
WRN CO REG DEEDS
A conference call involving the Technical Committee and the science advisors
tlfls t>een scneouled tor August 21 at 9:00 a.m. A meettng whh the run committee has
been scheduled for August 27 al 4:30 p.m.
We are looking forward to your participating in both the oonference call and
the meeting. ·
P02
To: Joel Hirschhorn
From; The Technical Committee
Oate: August 191 1996
Subject: ConflITT1at1on or MeeUngs; Auguet 10th Mernr.J
A conference call involving the Technical Committee and the science advisors has
been scheauled for August 21 at s:oo a.m. A meeting with the full committee has
been sctleduled for August 27 at 4:30 p.m.
Toe Technical Committee has received your August 15th memo eKplaining reasons for
the delays and expressing tne following concerns to which we would llke
to respond:
1) .e.cw1u f)J.Qlll! The Working Grot.4> did receive your progress report with
other materials th~t seemed to require neither connrmatlon nor fee{Jbeck . Since
neither the Working Group nor the Techni~I committee met to respond as a group to
your pr~ess report, feedback from an individual member of tt,e group
could have been misconstrued as being representative of the group. In fact,
one member of the group prepared a detailed draft r&sp<>nse in writing on JUiy 23 to
your progress report but did not send it precisely because or the possibility that II
would be misconstrued as having gone ttrough the committee process.
The conducting paragraph or your progress report shifts the emphasis concerning
the detoxification decision trom technical feasibility, risk assessment, and
a failing landfill lo proving or ·disproVing that the landfill is leaking. Your August 15th
marno dOes the same. However. In his letter of 1982, Governor Jim Hunt does not
base his detoxification commitment on a leaking landfill, nor even on risks that the
lardlll poses to the community, but on technical feasibility. And when Secretary
Howes mentions risks, It Is clear that he is focusing on the po9sibllity or the liner
br8actling and on pOssible risks intrinsic to ttl8 detoxification process itself, risks that
should not be g,eater then those pos$d by the landfill. Therefore, if we need to
reassess the detoxJflcatlon solution, it will not be because we failed to PfOve that ttie
lanofill Is leaking, but because we could not demonstrate a safe and feasible
technology,
2) Secllon • It is clear from the statement by Secretary Howes quoted in your
August 15th memo ( p 2, paragraph 3) that Che state's commitment to deto.adry Is
contJngent on demonstra~ng a safe and feasibfe technology, not on proving or
dispro'ting that the landfill is leaking, an lnterpretaUon substantiated by your summary:
To sum '-4), ~proving or disproving that the landfill
Is leaking'" may noi have been Invoked as ~n
explicit requirement for deto><ification or your
landfill, but whether or not the landfill is leaking
will definitely decide the quality, strength, and
effectiveness or any proposal generated by the
2
Working Grcx.p to obtain funding for detoxification.
3) A polltlcal declelon le unfe•elble becauee or the expen" of
deloxmc111on. You have not aUbmtnec:t to the technical committee any data to
substantiate the probable cost of detoxifief)tion. Furthermore, the issue
r.annot and will not be abstracted from the political, historical, and empirical realities
informing the framework. Safe aoo «dlnically feasible detoxification leads
necessarily to the Governor's promise, and the Governor's promise as well as tho
responsibMity of the state and EPA lead necessarily to appropriations, or to a
sustained activism of public sentiment until the appropriations
are granted and the appropriatt acuons are taken. The argument that the
Governor's promi" Is Insignificant concerning approprie,lions and that
appropriations are contingent UPoO a leaching landf III overlooks the fact that this
issue IS among the most historl~lly significant, the most politteally embarrassing,
and the most potentially e)(!>losive for the ,tate and for EPA and underestimates
the political will of the justice community et tile local, state and national levels to
ensure that the resolution is compatible with Warren County's understanding of
environmental justice. The present framework dearly end unambiguously
expresses that understanding.
4) Critique, or ECO. Your continuous critiques of ECO are not even peripheral
considerations at this point in the process. Dismissing entirely the wori< of EOO still
leaves us With the fact that acx:ordlng to the state's own data ( quality analyzed and
quality controlled by the state's own ~bs) significant concentrations of PCBs
end dioxins have been detected inside the landfill, and stgnlflcant concentrations of
dioxins In excess Of federal limits have been detected outside cA the landfill. But
again, the responsibility r:.t tlis committee is not to bulld theories to explain the
presence of the dioxins as coming from the lanclill or from some other source t>ut to
a.c;certaln whether detoxification of the landfill (leaking Of not leaking) would t>e
technically feasible and to consider technical fea9iblllty within the context of risk
assessment.
5) "Entrenched" and "Slated" Thinking. Since detoxifi~tion is to be based on
considerations pertaining to t$Chnical feasibility arrj risk assessment rather than on
proving or disproving that the landfiN is leaking, and since the members of the
Technical Committee as well as the full committee are prepared to reassess the
detoxification SOiution if a safe and feasfbfe technology cannot be demonstrated, your
purely speculaUve position that the thirl<ing d some members of the committee Is a
function of •bias" and "entrench.cf thinking· would seem to transcend the bound! of
logic and creditlility. The committee has no intention of approving a resolution mat
·o· 21u1J6i111
3
would not be in the best interest of the people of Warren County and is therefore
committed to an open process within the prosent framework. Having said that,
members of the committee do have the right to express their own opirJons as you have
ck>ne In your memoranda.
The responsibility of the Technical Committee, The Working Group, and of all parties
involved, including the Independent scientists, is to attempt to resolve th8 crisis within
ttl9 5-point ffemework based on Governor Jim Hunt's open letter to the citizens of
warren County, October 20, 1982; on the memorandum to Secretary Howes. May 17,
1993; on Secretary Howes' letter to Ken Fenuccio, May 21, 1993; on Secretafy
Howes' letter to the people of Warren County, May 24, 1993; and as explained in the
Technical Committee's memo to you, August B; and in this memo as wall. We hope that
you will hefp us attempt to reach a resofution to the cri&is within the existing framework.
i-15-1 996 1 :2 7 AM FROM
August 15, 1996
To: The Technical Committee
From: Joel Hirschhorn
Subject: Response to Memo received from TC; progress report
Today I received by FAX the Memo that seems to be dated August 8.
With regard to the request for a conference call, the only time of the ones provided that I can
schedule is the morning ofWedn.esday August 21.
I can attend the August 27 meeting of the full Working Group.
With regard to progress reports and the delay oftbe report expected on June 14, I offer the
following explanation. There clearly has beeP~ a major delay in the schedule originally provided
for the Master Plan implementation. In my view, this has resulted from. a major delay in what was
supposed to happen \\ith regard to the site investigation activities. My own woik has been
affected by this for several reasons. First, I have had to spend significant time on the site
investigation component of the activity. Second, my view is that the original sch.edule ,vas based
on the pretnise of certain activities tracking each other, especially with regard to those activities
that were being directed by Pat Barnes verms those I am directing. A major delay in the site
investigation work means that my work will also, logically, be delayed. For me to go ahead
independently could result in large inefficient spending of funds. Nevertheless, l have continued
to perform some work on technology evaluation. I also completed the Wliting of the Maste.r Plan
parts I was responsible for and submitted it to Pat this past Monday morning.
I submitted a progress report and received no confirmatio.n that jt was distributed and received,
nor any comments or feedback of any kind. While I have maintained communication with Pat and
Bill Meyer, there has been little cnmmnnication with members of the Working Group.
Some other issues of a substantive nature were also raised in your Memo that I want to respond
to. Section 4 of the Memo refers to a five-poiut framework that I do not recaJI being raised or
discussed by the Working Group with respect to the presentation and approval of the Master
Plan. The Memo included a letter by Ken Fenucio to Johnathan Howes, in Ken 's capacity as
Director of the Ecumenical/Environmental Leadership Coalition. I do not know the ex1ent to
which the c.ontents of this letter represents the positions of the Working Group. 11,e other
enclosure is a letter to Ken from Howes, given as• response to Ken's letter. Since this com.es
from a state official it has some significance. But I do not agree with the interpretations on some
1
P. 1
1 -1 5-i 996 1 : 28AM FROM
key issues given in Section 4 of the Memo.
For example, the TC Memo says that "the detoxification decision is to be based on the technical
feasibility, risk assessment, and on the fa.ct that the landfill is filling. Detoxification is not
contingent upon proving or disproving that the landfill is leaking."
Here is what Howe said: ''the State stands by its commitment to detoxify the landfill once a
process is developed that will do so without posing a greater risk to citizens than the landfill
itself" This means that we have to know something about the risk of detoxification an,1 the risk
posed by the landfill itse]f. Every Tem.edial action poses some risks. But if the landfill itself poses
a high(er) risk, there ""ill be a sound reason to detoxify. However, the lower the risk of the
landfill itse~ the lower the jumification for detoxification.
I suspect that there are some members of the Working Group who fear that the planned site
investigation work. will not support their belief--based in large measure upon the incompetent
a11d unreliable work of the previous advisor ECO --that the landfill has leaked and contaminated
the envirnnmeut. The continuing use of these past findings indicates a bias agafost fiudiug out the
truth. l also want to emphasize that the mere leaking of this o:r any landfill docs not describe what
risk exists. Risk= hazard x exposure. Any risk assessment of health threats must be based o.n
closed exposure pathways. That .is, any toxic:chemical that has leaked from the landfi.ll has to iu
som.e credible way become an actual dose that people have because of ingcstiou, inhalation, or
direct dermal contact with the chemical contaminant emanating from the landfill.
In other words, failme of any b.aurdous waste containment system, such as this landfill, does not
necessarily equate to a real risk to public health. Third, even if there is some plausible exposure
route (current or future), the level of 1·isk also enters tb.e decisionmaking. This is not the place to
go iuto great detail, but let me emphasize that demonstrating significant health risk is uo trivial
.matter.
To sum up, ''proving or disp1oving that the landfill is leaking" may not have beeu invoked as an
explicit requirement for detoxification of your landfill, but whether or not the landfill is leaking
wiU definitely decide the quality, strength, and effectiveness of any proposal generated by the
Working Group to obtain funding from the state for detoxification. As I have said pre"iously, the
entrenched thinking of som.e members of the Working Group has been based on some key
erroneous facts. One is that a detoxification of the landfill would only cost a few .million dollars.
Of course, if detoxification was so cheap, maybe a political rather than ao environmental decision
to fund detoxification --regardless of whether the landfill is leaking and regardless of whether it
poses any significant .health threat --might be feasible. But ANY detoxification of the landfill will
be very expensive. And when it comes to spending $25 million or more, whether or not the
landfill is leaking mil be very important in making the case for detoxification . 'Jbe second
preferred belief of some people is that water buildup in the landfill equates to leaking that equates
to significant risk. This too is not necessarily con-ect. For example, water releases do not equat~
to substantial toxic chemical releases for chemicals that are not very water soluble.
2
P ,.., . ,:_
.,
1 -15-1 996 1 : 29AM FROM -
I will be happy to discuss these issues and any other matters of.interest at the meeting on August
27.
Please provide me with con.fumation as soo.u as possible about the phone confereuce call that I
can accomodate on the morning of August 21 and about the meeting on the 27th.
3
P.3
To: The Science Advisors
From: The Technical Committee
Date: August 8, 1996
Subject: Technical Committee Meeting
The Co-Chairs and the Technical committee had a conference call on August 7th and
decided that is was necessary to focus your attention on the following:
1) The scope of work approved by the Technical Committee and the Working Group.
2) The report on technologies and vendors that was due on June 14th. The Technical
Committee has not yet received this report nor an explanation concerning why the
report has not been submitted. Other due dates have not been met as well, including the
state's mandatory testing and the field sampling and testing draft which needs to be
approved by the Working Group.
3) Weekly progress reports based on the scope of work. You agreed to provide these
reports. This agreement occurred two months ago, yet the Technical Committee has yet
to receive any progress report based on the entire scope and schedule of work
4) The five-part framework which has informed the Working Group since 1993, and
which continues to inform the Working Group, makes it clear that the detoxification
decision is to be based on technical feasibility, risk assessment, and. on the fact that
the landfill is failing. Detoxification is not contingent upon proving or disproving that the
landfill is leaking. The five-point framework also makes it clear that the goal is to find
an on-site solution to the crisis (Enclosures: Memorandum to Jonathan B. Howes, May
17, 1993; Letter from Jonathan B. Howes, May 21, 1993).
5) The Working Group will meet on August 27. The Technical Committee needs to
meet with you before the meeting because the Technical Committee needs to make
recommendations to the full committee. The Technical Committee would therefore like
to have a conference call with you the week before the August 27th meeting, preferably
on Wednesday, August 21; Thursday, August 22; or Friday August 23. Your presence at
the August 27th meeting would be appreciated.
Enclosures: Scope of Work, Memorandum, Letter
€orrect dates appear in Q
July 23, 1996
To : Joel Hirschhorn
From: Ken Ferruccio
Subject: July 8th Memo (Progress Report)
Thank you for submitting to members of the Working Group your progress report.
I have read it closely and find that several of your statements must be regarded as
having a purely speculative status, that others are clearly inaccurate, and that the
analysis in its entirety misses the whole point concerning what the working group is
trying to accomplish as well as the purpose of the appropriations.
I am not at this time concerned about the integrity or lack of integrity of ECO or about
the validity or lack of validity of ECO's methodology, report, and conclusions. Nor am I
concerned about whether Pat Costner's comments and conclusions concerning the
ECO report reflected bias. Nor am I concerned about speculations that ECO was hired
to support "certain beliefs or fears of some members of the working group." Nor am I
concerned about what the state should or ·shouldn't have done during earlier stages of
the process. Nor is it the purpose of this committee to make detoxification contingent
on whether or not it can be proved that the landfill is leaching. I must say also that I
have no intention of predicating the scientific integrity of the process on the "good faith"
of state officials and scientists. ·::
Now, what am I concerned about? I am concerned about the 1.5 million gallons of
water threatening to breach the bottom liner. I am concerned that state data (quality
analyzed and quality controlled) have indicated the presence of significant
concentrations of PCBs and dioxins in the landfill and in the leachate collection
systems; that state data have indicated the presence of dioxins in excess of federal
limits in three of the four groundwater monitoring wells; that state data have indicated
the presence of dioxins on the surf ace of the landfill in the area of the vent, in seepage
on the side of the landfill, and in the creek; and I am concerned about the Governor's
1982 promise to the people of Warren County that he would detoxify the landfill when
technically feasible.
And so my immediate concern is the progress you have made exploring the universe
of technologies and vendors because the purpose of this committee is not to spend
money proving that the landfill is leaching or that it is not leaching, but to test
detoxification technologies for feasibility, the purpose of the appropriations to begin
with.
I would like now to respond to specific statements you make in your report:
Statement: "A large part of the problem is that ECO was probably hired because of
its willingness to support certain beliefs or fears of some members of the Working
Group and, therefore, ECO did not bring to the project truly objective and unbiased
capabilities " (1 ).
2
Response: This statement must be regarded as having a purely speculative status.
Statement: 11 [ECO] did not consider alternatives to expensive testing of split samples
that would offer similar benefits to the community ... (2). ·
Response: The committee insisted on split sampling because the committee felt, and
I believe continues to feel, that the scientific integrity of the process necessitates
split sampling.
Statement: 11 ECO's information on alternative detoxification technologies was
incomplete and inaccurate and the logic used to recommend immediate onsite
demonstration of BCD technology was seriously flawed. ECO never presented the full
range of technical and economic information to justify its recommendation, nor did it
adequately examine implementation issues for its recommendation" (2).
Response: I am eager to review your report on detoxification technologies, vendors,
and related issues mentioned in the above statement. ·
Statement: 11
••• [The state] could have_ and should have presented more critical
analysis of ECO's position that the data showed that dioxins had leaked from the
landfill 11 (3).
Response: The state gave several alternative explanations. You imprecisely state
ECO's wording rega~ding the issue of leaking.
Statement: 11
••• (T]he state could have given alternative plausible explanations of
the findings on dioxins 11 (3).
Response: The state gave the committee several alternative explanations.
Statement: 11 While I recognize the unusual historical nature of the project ... " (3).
Response: The following statement makes it clear that you do not understand
the historical nature of this project:
. . . (l]f new data do not support a conclusion that the landfill has
been leaking and contaminating the environment, then the current
detoxification solution may have to be reexamined. (4)
Response. Our rationale for detoxification does not center on a leaking
landfill but on the 1.5 mllllon gallons of water threatening to breach the
bottom liner, on the technical feasibility of detoxification as related to
risk assessment, and on the promise of the governor that the landfill will
be detoxified If technically feasible. The belief that such a rationale Is
3
Insufficient or unreallstlc must be attributed to a lack of understanding
concerning the significance of the political and historical context
Informing the negotiation framework within which the committee Is
working. I agree with you that the committee may have to reassess
the detoxification solution, but I disagree with you concerning the
reason. The reason would not be because we failed to show that the
landfill Is leaking, but because we failed to demonstrate a safe and
technically feasible method of detoxification.
I am eager to review your report concerning technologies and vendors.
Joint Warren County/State PCB Landfill Working Group
draft July 10, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called
to order at 4:40 P.M. Wednesday, July 10, 1996 at the Warren County PCB Landfill Office by co-
chair Mr. Ken Ferruccio. A generic agenda was distributed. Mr. Ferruccio had prepared an
agenda that was not available for distribution.
READING AND APPROVAL OF MINUTES
Ms. Deborah Ferruccio moved that the minutes from the June 20, 1996 meeting be approved. The
motion was seconded and carried.
REPORTS
Mr. Bill Meyer reported from the meeting with the Science Advisors. He reported that they
reviewed the sampling and analysis plan. They discussed the location of additional monitoring
wells, on-site and off-site; sediment samples; surface-water sampling; and background sampling
stations. Mr. Meyer advised that Mr. Barnes is working on a draft schedule for these activities
which is due on July 17, 1996. If the Division, Mr. Barnes, and Mr. Hirschhorn agree, this draft
will be completed and given to the Working Group. A meeting will be scheduled at that time.
Ms. Ferruccio asked the purpose of off-site monitoring wells (wells). Mr. Meyer said that the
wells would determine the background concentrations of chemicals that are not influenced by the
landfill. This information would provide a basis to compare the ground-water around the landfill
to other locations in Warren County. Ms. Ferruccio voiced concern with the wells; she stated
that if the wells show dioxins away from the landfill that data may be used against the effort to
detoxify the landfill. She questioned if this information helps in the effort to detoxify the landfill
or does it just prove whether the landfill is leaking. Ms. Burwell then said that after reading the
press release she felt as though the focus had turned away from getting the landfill detoxified to
proving that it is leaking. After discussion the Working Group decided not to use the press
release at this time. The Technical Committee, along with the co-chairs, would write another
press release.
Next, Ms. Williamson gave an update on several issues. She advised that the fax machine had
been ordered and would be delivered in approximately three (3) weeks. Ms. Williamson also
advised that the C P & L lines and poles are in and the transformers would be installed when
power needs are determined. Lastly, she advised that the names of the youth representatives
along with a new address for Rev. Leon White were included with the list given Ms. Fleetwood.
Ms. Fleetwood agreed and advised that the youth on the list were all seniors this past school year.
It was suggested that Ms. Naomi Allen be contacted to give new names for appointment.
draft July 10, 1996 Working Group Minutes
Page 2
A report was given on the Technical Committee's conference call with the Science Advisors.
During this conference call, because of the concerns with the status of the master plan, the
Division proposed a meeting with the Science Advisors. This meeting was scheduled for July 3,
1996. A report of that meeting was given earlier by Mr. Meyer. The Technical Committee asked
the Science Advisors to prepare a weekly informal report stating what they have been working on.
The Science Advisors agreed. The Technical Committee advised that at the last Working Group
meeting the topic of Public Relations (PR) was discussed and the Working Group decided that PR
should be handled by the Science Advisors. Mr. Hirschhorn volunteered to handle the writing of
a press release. During this conference call, the subject of on-site demonstration was broached.
The Committee decided that an on-site demonstration was too expensive and the bench-scale
study would be used. Mr. Meyer said that there are two (2) biotechnology companies in North
Carolina and asked if they were viable for this site. Mr. Hirschhorn advised that bioremediation is
not very successful with complicated sites. Mr. Warren added that whatever is decided, it must
be able to be sold to the General Assembly.
NEW BUSINESS
Ms. Ferruccio advised that Warren County had been given a $19,000.00 grant from the US EPA
for use by the PCB Working Group. She advised that she had received a packet of information
confirming the grant and nothing else. She said that she had tried to contact the project officer
and still she got nowhere. Ms. F erruccio thought that if this were handled by a city official more
information could be obtained and the grant funding released to the Working Group. Ms. Burwell
advised that she would talk to the project officer and would find out how we could work it in the
Working Group so the funds could be managed by our office.
Next, a letter from Ms. Billie Elmore was read regarding insufficient notification of regular
Working Group meetings and no notification of Technical Committee meetings. Ms. Burwell
suggested that a letter be sent or a phone call made to Ms. Elmore to explain that meetings over
the next several months will be sporadic. When time permits, she will be given the requested 14
days notice and 30 days notice. Ms. Elmore stated in her letter that she had discussed her
concerns with Mr. Warren about insufficient notice and asked him to relay this to the Working
Group.
Last, Mr. Cooper provided the Working Group with a budget of how the Working Group monies
are being spent and asked Mr. Meyer to comment. Mr. Meyer stated the Working Group is
paying full salary for a part-time secretary and full building maintenance, not a prorated share.
Mr. Cooper advised that the contract stated that the State would contribute $25,000.00 and
would be provided with a part-time secretary, provide supplies, and would help with the building
maintenance and that is what the State is getting. Mr. Meyer advised that he has asked to be
removed from the responsibilities of the contract, because he did not participate in the
draft July 10, 1996 Working Group Minutes
Page 3
negotiations, does not know what was told to the County about how the monies would be used or
what was agreed upon. After more discussion it was decided that Ms. Porter would get copies of
the contract, and review the contract and report her findings to the Working Group.
ADJOURNMENT
The meeting was adjourned at 6:10 P. M. by Mr. Ferruccio. No date was set for the next
meeting.
Doris R. Fleetwood
Warren County/State PCB
Working Group Secretary
Joint Warren County/State PCB Landfill Working Group
draft April 25, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called
to order at 4:28 P.M Thursday, April 25, 1996. The meeting was held at the Warren County
Office of the Working Group and was called to order by Mr. Ken Ferruccio and co~haired by
Ms. Daria Holcomb, Mr. Ken Ferruccio, and Mr. Tommy Cline. A generic agenda was
distributed.
READING AND APPROVAL OF MINUTES
It was suggested by Ms. Priscilla Tyree that minutes from February 22, March 7, and March 28
meetings be approved. Co-chair Mr. Ken F ermccio disregarded the suggestion to approve the
minutes from the last three meetings.
UNFINISHED BUSINESS
None.
NEW BUSINESS
Mr. Joel Hirschhorn introduced the Master Planning Project. He began by discussing the
Important Reasons for Changing Current Strategy. They are as follows: _:
1) Field testing of small amounts of site waste will not provide infonnation
that is more useful then bench-scale testing;
2) Costs of two field tests would be extremely high;
3) It is necessary to examine other detoxification technologies;
4) Current approach would not provide sufficient detailed information; and
5) A much stronger case for funding can be made by spending money on
more thorough site investigation and remedy design.
Next, 1-!r. Hirschhorn discussed the Key Steps of Recommended Alternative Strategy. They are
summarized below:
1 )
2)
3)
4)
5)
6)
7)
8)
9)
10)
11)
12)
Detailed evaluation of detoxification technologies and vendors~
Initiate site investigation;
Design soil/waste removal plan/select vendor;
Issue feasibility study report;
Invite vendors to conduct bench-scale treatability tests;
Science advisors evaluate test results and select/rank vendors;
Finalize site investigation report;
Working group meeting with highest ranked vendors;
Best technology vendor selected/pre-qualified for actual clean-up~
Selected vendor is hired as design contractor (under currem funding)~
Remedy selection and remedial design report; and
Report used as the basis for Working Group/DEHNR formally
proposing the landfill detoxification project to the State Legislature
to obtain funding.
0001-lSl-616:Xe~
draft April 25, 1996 Working Group Minutes
Page2
Mr. Hirschhorn advised that after all information has been gathered this approach will provide
the state with the information needed to provide funding of the detoxification project without
needing additional tests preformed. Mr. Hirschhom then asked for questions, then the meeting
was turned over to Science Advisor, Patrick Barnes. Mr. Barnes continued with the Master
Planning Project, starting with Site Investigation Goals, the reasons for additional testing and
they are as follows:
1) Establish conditions of liner,
2) Bedrock condition and topography;
3) Transmissivity of weathered rock zone;
4) Direction of ground water flow;
5) Identification of contaminant plume; and
6) Types and amounts of contaminated media requiring clean-up.
Next, Mr. Barnes discussed Site Investigation Activities, what steps would be necessary and
they are summarized below:
I) Collection of samples to conform with permit requirements;
2) Analyze existing data; _:
3) Develop and implement field sampling and testing plan;
4) Non-intrusive testing (Geophysics);
5) Soil borings;
6) Installation of additional monitoring wells~ and
7) Collection of additional surface water and sediment samples.
Lastly, Mr. Barnes introduced the Master Plan: its purpose, its contents, and its implementation
schedule.
The purpose of the Master Plan is to :serve as a:
1) Guidance document~
2) Road map;
3) Operation document; and
4) Stand alone document.
The Master Plan contents are outlined below:
PRELIMINARY TABLE OF CONTENTS
1.0 INTRODUCTION AND BACKGROUND
1. I Site History
1.2 The Working Group
1.3 The Role of the State
60 "d l0:t1 96 , £~ das 000 1-lSl-616:XEj
draft April 25, 1996 Working Group Minutes
Page 3
1. 4 The Role of the Science Advisors
2.0 PROJECT GOALS AND OBJECTIVES
2. l Mission Statement
2 .1. 1 Impact Assessment
2.1.2 Detoxification
2.1.3 Community Involvement
2. 1. 4 Responsibility of the Working Group
3 .0 DEVELOPMENT OF FEASIBILITY AND REMEDY SELECTION REPORT
3. l Detoxification Technology and Vendor Evaluation
3.1. l Review of Past and Current Approach
3 .1.2 Comparative Analysis
3.1.3 Recommendations
3.1.4 Work Plan for Treatability Testing
3.2 Landfill Soi.VWaste Removal Plan
3.2.1 Review of Current Approach
3 .2.2 Soil/Waste Removal and Vendor Selection Procedure
3.2.3 Testing Requirements
3.3 Treatability Testing
3.3.1 Bench Scale Testing Results
3.3.2 Analysis of Data
3. 3. 3 Recommendations
3.4 Remedy Selection
3.4.1 Effectiveness/Performance
3.4.2 Safety/Environmental Impacts
3.4.3 Cost
3.4.4 Comparative Analysis and Recommendations
3.4.5 Role and Responsibility of the Working Group
3.5 Procedure for Establishment of Remedial Goals
3.5. l Evaluation of Test Results
3.5.2 Ranking Procedure
3.5.3 Performance Standards
3.5.4 Responsibility ofWorking Group
3.6 Procedure for Selecting and Awarding Detoxification Design
Contract
3.6.1 Role of Science Advisors
3.6.2 Role of Working Group
3.6.3 Role of State
4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
4.1 Site Investigation
OT 'd 000 T-LS,:-616 : X"E' .:J
draft April 25, 1996 Working Group Minutes
Page4
4 .1. 1 Review of Past Sampling and Analysis
4.1.2 Field Sampling and Testing Plan
4 .2 Landfill Integrity
4.2.1 Leachate Collection System
4.2.2 Liner Condition
4.2.3 Water in Landfill
4.3 Scope of Off-Site Impact
4.3 .1 Soil
4.3 .2 Groundwater
4.3.3 Surface Water
4.3.4 Sediment
4.3 .5 Air
4. 4 Contaminant/Waste Releases
4.4.1 Fate and Transport
4.5 Estimates of Volumes Requiring Remediation
5.0 REMEDIAL DESIGN
5.1 Roles of Technology Vendors, Science Advisors/State
5.2 Site Layout and Logistics
5.3 Construction Phasing
5 .4 Health and Safety Concerns
5 .5 Impact Monitoring
5.6 Detoxification Field Pilot Test
5. 7 Preliminary Design and Operation Plan
5.8 Clean•up Cost Estimates
6.0 LEGISLATIVE RINDING
6.1 Briefing Document
6.2 Presentation Procedure and Materials
6.2.1 Role of Working Group
6.2.2 Role of Science Advisors
6.2.3 Role of State
7.0 PROJECT SCHEDULE
Below is listed the Master Plan Implementation Schedule.
ACTMT1ES
I ) Master Plan development
TARGET DATE
May 15
draft April 25, 1996 Working Group Minutes
Page 5
2) Detoxification TechnologyNendor Evaluation
3 ) Site Investigation
4 ) Soil/Waste Removal
S) Treatability Testing
6) Feasibility Study
7) Remedial Goals
8 ) Vendor Screening & Awarding of
Detoxification Contract
9) Site Investigation
10) Remedial Design/Remedy Selection Report
11) Legislative Funding
June 15
August 15
June IS
August 15
September 15
October 15
November30
December 15
December 31
April 30
Questions were asked by Messrs. L. C. Cooper and Ken Ferruccio, and Misses Deborah
Ferruccio and Daria Holcomb. The questions concerned whether the Working Group, if they
approved the entire Master Plan, would have the opportunity to give their opinions and approval
on each phase of the Master Plan before it is carried out. After these c-0n~erns were voiced and
after much discussion. co-chair Mr. Fenuccio restated the motion to accept the Master Plan
with the understanding that the Working Group would approve each phase of the Master Plan
before implementation. Mr. Cooper, who had earlier made the motion to accept the Master
Plan, reminded Mr. Ferruccio that a motion was already on the table. The original motion was
seconded and carried. Ms. Daria Holcomb opposed the motion.
Mr. Joel Hirschhorn asked ifit were possible that a smaller number of people could be contacted
when they were in need of a quick response. After discussion, it was moved and seconded that
the Technology Group would be responsible for working directly with the Science Advisors
when time is short. It was moved and passed that the Technology Group.
ADJOURNMENT
The meeting was adjourned by Co-Chair, Mr. Ken Ferruccio at 5:55 P.M. The date of the next
meeting is Thursday, June 20, 1996 at 4:30 P.M ..
Doris R. Fleetwood
Warren County/State PCB
Working Group Secretary
OOO T-lS[-616 :XE~
Sept. 10, 1996
To: Technical Committcc ......................................................... by FAX (S pages)
from; JoelHirscbhoni
Attached is • copy of a newly published article "A Needle in a Haystack0 that I think can be
educationa~ because it il.b.tstute, how cxpltining why positive nndmgs of dioxin have been found
in a study poses importan.t tecbnioal cbaluiilges th2t can, howevtt, be resoived.
In the c.ue described, some logical 111d thorough technical wor:k demon$tnted convincingly to a
government agency that the dioxm contamination came from a noo•site source. In this case aerial
deposition of dioxins logically explained wby JOme low level, of clioxms had been found in
w-1stewater efiluent at a site with a landfill The concept of analyzing ~ecific dimibutiQnS of
dio,cm isomers to address the origin. of dioxins is impo.rt.an.t. _:
Some of the other data in the paper are also of interest, such as TEQ dioxin found iD pure
laboratory water and the amount deposited from the m.
There are many ubiquitous source$ of dio~ in air.
60 :PT 96 , £l das l,lt"'l'U .J LJ.-11. I . t'I I ~ l -i:wl-?.:
OOOT -LS,::-616: x~ .:J dnrns 9NDk:l0Pl 8Jd
l,UYUI llUI J
A Needle in a Hay:stack
Tracking down the tlusjve dioxin source proved to be
ti. cha/kng~ at a California Air Foru base.
asdl! Air Force Base, nc:ar
ArM.1~r in Ca.lifomia's Ccnua1
Yallq, .hu been in exbtencc:
aina: 194 l. Until two yesu
sg<i, when ir h«cmc l ~icbtc for dr>-
surc, it wu die tnini.og a1nrer for all B•
52 bQn1bet and KC-135 r.:inkcr cce,t,,•
rntmb<-is. Over the ~f, futl-mait1ly
Jl>-4, Jr-8 and gi.soline-was handled.
wich ir-levi1:ibl= iew and o«Uienal apilh.
Other pl'OCt:Ul:.I pafun,,ed on the blx
included aircnft and 9-ru deaning. 11slng
nichkirocthylene (TCE) ud methrl
ethyl kt-iooe {M£K). painting ind sil~t
rccc,-c:ry. S1.1ffic:1tnt TCE entered 1he
puundwater fot the base to be dedued a
Nalional l'fioritics Luc (NPL) sire, and
Ch( TCE plume ii i:uttendy being ab:ued
chrotJSh a pump•and-<reat progi2m.
Casrlc's WUtl!Wara, after undergoing
primary ano secondary Cfl:iltfflent, h:.d
hi,tt:iriclllr b«n sp~,-cd O~t ,t leaeh•
field, 1 portion of 11:hich '111'1.S over a
c!o~d l;;andftll.
~k ·, JlOtlfl wata was collected bv 1,
mic, of c~ls and diKhetg~ int~ ll
nearby creek. The coMtrucdon of the
onals -.llcwa about one foot of ,watc:r :o
ci,llea ln the borrom before i, stara to
flow off bue. If du: canal5 ue empry
wn,n r~n begiru. it would ake :1001n
0.25 in.ch o( rain ro pr«7Vide 1ufficirot
w:ater e,, start a flow off base.
Concern, abour rhc pouibillty of the
spr.i.,·¢d was~ter IC2Ching haurdc,us
$ub,r1ncc3 fr◊m rl\e !2nd.AU 1ed. co a
chinge in the: Wl3ttwatrr d~c:ha~ lo,.
I: I E11Til'Cl'ft'l~tal PROTICTION
By Russell A. Stowe
c:ition. It wa.s decided to di:tehargc the
l!ffiu,nt inio the same creek as iht
norm ~'1ter.
This required • modification ro the
Nation.I Pollution Oi.sdurge FJimin.i.•
u<,n Sysctom (NPDE.S) permit. ln gtant•
ing the permit, rhe C.cmtral Valley
~iun-.1 Water QU1liry Con~rol B~rd
(RWQCB) dircctl!d mdng for I wide
ranse of conramlnanu lined in th¢
lnl:and Swf:ace W.i~t l'laA (ISWP), in-
duding dioxin.
Dioxin .,.,ting
The dioxio. t~rinJ on the wanewatcz cf-
flucm wv done 10 Oero~r 1993. The
re1ulu were pciitivc for two c:ongenet
groups, 130 p:uu per quidtillion for
OCDD, and 100 pg/L fur roral TCOD.
No 2,3,7,8 c:hlorinued iCOD ... .u
If dioxin were
octuolly precipitotin9
from the air,
then it should
be falling over
a large oreo,
not just on base.
,
founc!. On the teconuntnd.irion of the
RWQC8, the diluenr ..-u t~ml :ipiri
in Jianuruy. Th.ii time:, the level• wue
about half thoce in Cx«iber fo.f the same
two conscncn.
Br this tin;ic, tht coun luti .1et ci<k
the ISWP ari<i iu mndaids. However,
the RWQCB found ■ Yiolation of
Propo~ition 65 (du: Callf.-lrni:a S:1fe
Drinking Warer and Toxic:J El'lforc:cment
Act), whic..~ limits dioxin to 2 ,pg/L.
Thia ~uircd a notif1acion of du: heilth
boa.nl, which i"ued J ..-a1ning sming
ch~ -.-atcr in the receiving c~ck was .&
hnlm h#.~rd. The RWQCB directed
furthe( sampling ind ana.ly,ia through-
out the wui:~tc.r sy,tem. the rttl!1"'ing-
wueu and the scormwuer syuem co
find. die ,wpttted clk,xi n rourc-.e.
A careful reading c,( Prop 6$ lndie1t-
ed it :appli~ only to 2,3,7,8-TCDO,
whic:h -.va.s rtor foutid . The RWQCB in-
u:rpreted Prop 6~ to mean to:clciry
~ui•alcnu ('r£Qs). The dioxin l~u
expre.s.sed li, 2,.3,7.8-TCDO equiYlltnn
were well below the Prop 65 limit,
However, by this time. rhc rc,uln of
sediment te.Jting le the stotm waccr
ditchl!S :and receiving creek yiekied diox-
irir. The RWQCB fth rh;.. proved there
1'1as i dioxin tource som-11~ on base
ind dirc:ctccl furthet s.mpling and d.e-
velopmtnr of a remediadon plan.
labu-Andttson ln~. (LA) -Na$ con-
trSC~ to ~op 2nd implement a saln•
piing plan ro find me $Ouf(:C. Due cc the:
c,c~nu of aDilyzing for <lioxin--Sl.300
,,,..199'
r ~Q v£l~.:l ~ l · 0 1 966 1-60-C::
JU 1-c!. S,::: -6 T 6 : x-e .:! di10<J9 9~-l DlclOfll ffJd
J
J
ESTIMATED BUDGET
Science Advisors ................................................................................. $200,000.00
Extraction ........................................................................................... .
S. In . . 1te vest1gat1on ............................................................ · .................... .
100,000.00
250,000.00
Bench Scale Tests (3) .......................................................................... 225,000.00
Design................................................................................................. 100,000.00
Office, Miscellaneous.......................................................................... 50,000.00
Contingency . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. . . . . . . . . .. . . . . . .. . . . . . . . .. . .. . . .. . . . .. . . . . 75,000.00
rn·d
~-o·. l·kt-1~~ /...aJJc~ ttit.
}...0..,..A.a..( ..... 6..,.__.\ \.t..~
Tofl"\~'I C. \,·~ (._
~I I\,~ ~\ 1Y'\C<2..t.'...
~~l I M~ ~It.
F (G(lm · L) c, i,::.", \ \:' lc.L-\-u.,c,c-d
7>C& 'ND,tt,rv~
C) <2.1..~..,,,e .s c. c ic.. ~. \-0..1..:..i
$1,000,000.00
~ MEETING REMINDER
The Joint Warren County/State PCB
Working Group will meet on
Thursday, September 26, 1996
at 4:30 pm in conference room: of the
Warren County Office :
To: Mr. Henry Lancaster
Ms. Laura Butler
Mr. Tommy Cline
Ms. Billie Elmore
Mr. William Meyer
From: Ms. Doris Fleetwood
PCB Working Group
Secretary
Total Pages 14
10 "d £0 : t'T 96, £;:; das 0001 -.::.Sc-616:X'E'..:J
August 29, 1996
To: Technical Committee
From: Joel Hirschhom
Subject: Recommendations on decision making process and several actions
en Pros;,s
A) My advice is that the TC and WG use a more fomw means of communicating requests
to the state. There is a need to prepare carefully written memos or letters from the WG to either
Bill Meyer or a higher state official. Verbal requests or motions at meetings, such. as what
happened this w~k on the issue .I raised about EPA permits for removing materials from the
landfill, arc inadequate, unless they are followed up immediately by a written document that
precisely spells out the details of the request. Details and creating a documen1ed record of
requests and responses ate very important m these mtttets.
B) My advice is that the TC adopt a standard procedure for .making decisions about
actions recommended by the Scieuc:e Advisors. I am referring to action memos., not inf ormatfo.ual
memos, nor submis~ion of wor.k products. My recommended proceu is: ·
1. The SA £.axes an action memo for the TC to the WG office for immediate distribution
by fax to TC members and the other SA.
2. The office arranges for a phone cord'erenu call within 24-48 hour.s for the TC rn
discuss and make decisions on recommended actions.
3. During that call with the SAs., the TC asks questions md discusses a.ction
recommendations and either makes decision(s) on action ite~s), allowing followup activities b)'
SA(s), or some other decision is made. Secretary maintains :minutes of such calls.
4. Within 24-48 hours:
a) As appropriate:, the SA(s) faxes a work product to office for distribution to TC
(unless instructed to take sollle other action. directly, such as sending a memo or ma.kin! a call to
son1e party on behalf of the TC or WG) to facilitate the TC or WG implementing the decision .
OR
b) The TC or WG takes final action. Secretary keeps record of exactly what is
done.
l
000 1-LSl-616 :X~j
I'·;, ·,.
£2) fdr,11 stratesx
My advice is that the TC coMider and the WG adopt the followuig strategy to initiate
steps to build a case for federal intervention and actions that support the ~o•l of dotoxification of
the landfill. My analysis of tht history oftbis sit\lation leads me to conclude that the entire
Strategy of the community has been to dq,end on eventually obtaining the desired decisions aJJd
funding from the state. This strategy has several dis.adv.ant ages, not tbe least of which are: a
fundamental conflict of intetest the state has between being the owner and operator of the landfill
as wc11 u the protector of public health, and all of the difficulties in building a technical
environmental, and economic cas.e sufficient to obtain substantial state .funding. My
recommendation i1; that it is in the colillllWlity's interest to de\·elop a parallel strategy that is based
on the plausibility of forcing federal interest, answers to requesti, and various .interventions or
official positions that provide either pressure on the state to take certa.in ad.ions, or supply
irnporttnt support for what the WG recomm~ds to the state.
Th.ere are three immediate action recommmdation.s:
a) The WG should ~bmit a ,\-linen request to the state for a compliance audit and
summary report giveu to the WG within 30 days. The WG would ask very specific, c:uefully
crafted questions, based largely oo various federal requiremeIIts that the state wa, required to
satisfy.
b} The WG would submit a writtcn request to the EPA Region 4 Administrator to conduct
an official EPA compliance inYestigation under TSCA for the landfill, based on EPA eximiruttio.a
ofits records, state records, at1d a f:tcility inspection► if necessary. The need for very expedient
implementation would be made. Specific concern& would be identified.
c) The WG would submit a written request to Assistant Administtator Elliott Laws at
EPA Headqualtc:rs for his office to e:umme specific policy issue, under CERCLA/National
Contingency Plan by asking key questions affecting potential clemup of the landfill. The Jetter
wowd cite the details of the agree.went between the EPA and the state, in the fonn of a
;;1;;opG'f12.tr~•:gt:~t-!hat was funded und~ CERCLA/Supt:rfund. Specific policy
detcnninations would be requested oa specific iuucs, such as wheth~ the current fonn ()fthe
NCP applies to the landfill, and whether the statutory requirement for review of th~ remedy every
five years applies.
(J) §UMMY Cw: RFf fo,. obyinipg a tMhpology XSIW9[
The issue is how to most efficiently follow gt.ate requirements for obtam.ing detoxification
technology companies foT conducting be:nch-scale tests and for one selected cotnpmy to assist the
SAJ and WG in preparing a conceptual design of the desired rem~dy fo.r inchision in the pr'Jposal
to the state le;i.slatu.re. My idea js to use one RFP to cover both activities to save considerable
2
tO:tr 96, £c das ooor-Lsc-616 :x~j dfr0d9 9N DlcJClfll 8Jd
time. My recommendation is that the WG co.nsider my proposal and formally submit it to the
state and seek a dcdsion on whether it can be implemented in its present form or how it ~an be
modified to meet state legal requirements.
The key components of the proposal al"e:
.. The RFP would be described as the solicitation of a contractor that after completing a
successful bench or pilot scale test of detoxification technology will provide profession aJ services
in developing a conceptual engineering design of the full remedial action at the landfill. including
an onsite demonstration test prior to full ~ale use of the selected detoxification technology.
--The RFP would de.tine, the following steps for interested parties:
a) Based on information given in the RFP (including site b•ckground, a.lld scope-of work
fot ttst) 1 to 3 vmdors will be selected on the basis of AUbmiUed proposals to c,onduct a bench or
pilot scale test at their own f.icility 011 landfill materials provided to them.
b) After th.e selected companies submit the required repons on test results and provide any
additional information required, one company shall be scle<.-ted to provide the conceptua.l design
services, bucd on both. the test results, Qther information provided, and the bids m the company's
proposal
•-The RFP would ask for proposals that must contain certain types of information,
includmg bids for the initial testing and, if selected, for the design services, ba&ed on scopes of
work for the two phases given in the R.FP Technology companie$ would be urged n.1 tht RFP to
select a $Ubcontractor ( such as an environmental design and engineering firm) that has the
capabilities to contribute to the conceptual design of the total remedial action based on but not
limited to the detoxification technology.
--The state would enter into an initial contract with the tompanies selected for the bench
or pilot tests. This contract would contain a provision stipulating that the company is being pre -
qualified or short-listed by virtue of being selected to conduct the test for final selection as the
provider oftbe design services and that no other :RFP will be issued by the state. Subseq"Ueotly,
after ooc company is selected, the state would cnt,;y into the final contuc:t fo.r ~he prt'),-ui.Otl of the
design services.
i4l »st23ill51tjpp slsaove coel.J
ht order to obtain useful bench scale tests, it '\\ill be necessary to infoan potential vtndors
in the .RFP what the numerical goals of the detoxification are for key contammants. In othe:
words, we wust specify what level of PCBi md dioxins ue acceptable in tesidual treated
matemlJ th.it would, presumably, be backfilled into the excavated landfill. These le'\'eh would be
3
the preliminary cJeanup go~s (PCGs) or performance reqwremmts fur waste ucatment. They
would be given as preliminary ones, mainly because they might be ch1t2ged after all the test results
are obtained ( either increased or decreased).
The technical problem is deciding on what basis to use for the PCGs. Then: are two
principal approaches. A regulatory cleanup level may already c~st that either must be used or
may be used. For example, certain file docw:nents indicate that EPA would require treatment to
achieve a level less than 2 1,pm. for PCBs, but the state may typically require less than J ppm
(parts pc.r million.). When~cr a State has a more stringent requirement than. EPA. the state one
prevails.
The second approach is to use health risk based cleanup standards. Some ris.k based
concentrations already exist in the form of EPA generic Superfund Soil Screening Levels. Tb.ese.
however, are based on certain specific exposure and risk assumptions that may not be complctcly
applicable at specific sites. When they are not, only a site specific risk assessment can generate
other numbers. There are many tough issues for such risk assessments.
Consider PCBs, EPA dau. r~eal a 10·" cancer risk level for residential soil ingestion
exposure of70 ppb (pans per billion}. However, EPA uses a value of 1 ppm (1~000 ppb) as an
SSL and under its PCB cleawp guidance. This means that l ppm equals a risk of 1.4 x 10-~ (a
tenfold higher risk).
But if dioxins are also present, they must be considered. If diox:ins o.bly &re CQns.idererl,
then the 10"6 cancer risk level is 2 ppt (parts per trillion) for cwuulative in~estion, inhalation, and
dermal exposure to surface soil or 4 ppt if only ingestion is considered. EPA often attempts to
use a very high .level of l ppb for soil cleanup decisions, which is blatantly unacceptable. [I do not
now have a risk based co.o.centration for PCBs based on three exposu:ri= pathways, which would
be less than 70 ppb, possibly around 40 ppb.J
lfboth PCBs and dio,cins are present, however, then c:unmlative risk must be considered,
meaning that le..,els BELOW the Jo~ levels obtained for them individually would correlate with
Jo"' cumulative risk.
The problem is whether detox:ification technologies can achieve very lo·,.. 1esidual
contamina.nt levels conesponding to to·' risk le\·els. Therefore, while PCGs cm bes~ very
stringently, actual test dsta may show that no feasible detoxification technology can meet them
reliably and consistently ( especially with varying waste inputs, in terms of contaminant and W4ter
levels, for example). Jn other words, the technical feasibility of detoxification technology tbr th.is
application will depend on exactly wb.at cleanup perfonnanee requirements are demanded. Th(:
more protective the WG wants to be, the greater the probability that 110 feasible techllology cm be
shown to exist. One of the more subtle issues that must be cwsidered is whether typjcal exposure
pathways are relevant for the site after post•treatment residuals are backfilled into the Luid611. Ill
other words, if treated residues aie buried in. the ground and covered with elem soil. tb~ there
4
SO 'd OOOT -2.S.3-616 : Xej
may be no plausible exposure pathways ( as long as the containment remain~ effective), because
people will not iJlgest the material, or inhale airbome particles, or have direct dcnnal contact with
the material. The.re might be some concern about leaching of the contaminants over time into
groundwater, but because both PCBs and dioxins have low water solubility 1.11d high soil
adsorption, such leaching an.d migration will normally result in much highe1 acceptable levels than
those obtained on the basis of cancer risk.
EPA often uses this reasoning to justify higher acceptable cleanup levels. In the extreme,
it justific:, NO treatment because hazardous chemicals are buried in som.e type of contamm~t
system.
The WG must decide what cleanup goals to use. Here are some alternatives:
--Least stringent I or 2 ppm for PCB& and I ppb for dlox:ins (max 5 x 1 O"' risk)
••Stringent: 70 ppb for PCBs and 4 ppt for dioxins ( 4 ,\ 1 o•<i)
--Very stringent : 40 ppb for PCBs and 2 ppt Cot dioxins (2 x. 10'6)
--Extremely stringent: 20 ppb for PCBs and 1 ppt for dioxins (max l x 10.(, risk)
[All of these risk figutes ignore synergistic eff'ects.]
Note that consideration of noa•canoer health effects generally results in higher
contaminant le'.·els th.an those obtained on the basis of cancer risk assessment.
A practical problem is that if the RFP cites very low cleanup levels for PCBs tnd d1oxins
in residue!,, some companies may not be interested in pursuing the work. Or, companies may
pursue the work, but have to increase the intensity of tb.eir trutment, or plan OD retreating som=
rtsidues, th.at would increase costs substantially. The incremental treatment cost in.creases for
iucremental risk reductions can be ver:y large.
My recommendation is that the WG use the Striog-:llt alternative above as PCGs,
recognizwg that the RfP will wake clear that the lowest possible residual contamin311t levels arc
desired, consistent with obtaining a cost•effective cleanup, and that the test re.sults from tl1e
several vendors selected for th.e testing phase and other information they provide will be used to
select final cleanup goals. Aftcf the WG uwces a decision, I r~ommend that the $1.ate be
infonned in writing of that decision and asked for its concurrence.
<=l 1a{gtrn•U0a 2a "''"' ua 11od[t11
A major complication for detoxification .is the .Presence of watc:r in the 1andfilL because it
affects technology perfunnmce and cost. There is a need for more: complc:te and reliable
information from the state to asswe that the RFP and design of the bench sCAle test is adequate.
My recommendation is that the WO submit a written request for infonnation to the state. 111e
request would be for a technical summary of all ley information on water iu the landfill and
5
90 .d 0001-2.S.~-616 :XP.:J
answers to specific technical questions. Note the interest is NOT on what caused the water, but
rather o.n the details describing the nature of the current water.
f §l Biorw4if fign
I have seen evidence that the state is still pursuing bioremediation as a means of
d~oxifying the land.fill. .f have co.a eluded that no form of bioremediation is a candidate for
selettion as a fcaS&l>le technology f'or this application. Three other evaluatiollS over the years also
reached that "-OJJclusion. Therefore, I recommend that the WG formally requefit the st2te to stop
all activities related to bioremediation use for the land.61L because their resources are .far too
limited and are needed for many other more important activities.
6
0001-lS~-616:Xe~