NCD980602163_20020506_Warren County PCB Landfill_SERB C_In-Kind Services from EPA, 1998 - 2002-OCR

P~tricia M. Backus, PE
Divisibn of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: [phone] ext. 308
Fax: [phone]
Fax
To: Carl Swanstrom
Fax: [phone]
Phone: [phone]
Re: EPA Letter
□ Urgent 0 For Review
• Comments:
Carl,
NCDENR
From: Pat Backus
Pages: 4
Date: May 6, 2002
CC:
□ Please Comment □ Please Reply □ Please Recycle
Carl Palmer asked that I fax this letter.
If you still have trouble, have them contact John Kingscott. John is the director of the Technology and
Markets Program of the Technology Innovation Office and was the key person that pulled the EPA offer
together. His number is [phone].
Good Luck,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
Honorabll, James B. Hunt. Jr.
Oovcmor, State of North <.:arolin&i
Office of the Governor
-'20301 Mail Service Center
lul~igh, NC 27699--0301
Dear Oovemor Hunt:
, AUG 11 ~
O,,IClCI
SOLID WASTE AHO l'll(AOU.IC'I'
fllUPONI!
This letter concerns the propo3ed project to excavate and treat polychlorinatcd biphenyl
(PCB) wutc c.u,Tcntly disposed in the Wlll'ten Co\.lnty Landfill. On May 16. 2000, you wrote
Ms. Cerol M .. Browner, Administrator oCthe U.S. Envfronrncntat Protection Agency {EPA),
rcq\1esting financial assistance tor the prOJect. On Iuly S, 2000, Mr. John Hankinsun, Jr., EPA
R'-eional Adminis:rator for R.eaion IV in Atlanta. res13ondcd that altho:.igh the proposed
detoxification project does not cunently meet the criteria for use of Superfund trust funds, EPA
wvuhl c,;untiuue to sti.J"ch for other so~rcQa of funding.
As part of this ~earch. a member of my stltl' recently met with officials from the North
Carolini' n,.,,i~iM nf Wn.~te Mnma\!mcnt. EPA Region IV and EPA's National R.isk Maniiizemcnt
~starch Laboratcry (NRMRL) to learn more about the proposed detoxification effort and to
assells thi: po1~nLiisl fur fc:J=ral co1~1ributions. We arc awue or the $? million opprop::fotior. from
the State of North Carolina which will require some federal ma~ching to make the funds
available.
We ha1Je identified substantial federal contributions that we &re prep!red to make as in-
kine'. services. Toe largen of these can be pruviuc:tl by c:valuAting the chosen techrlology throush
the Supcrfund Inn~vttive Tec!\nology Evaluation (SITE) program. This demonstration project
wil1 LU1derwritc: milch of the work which is required to secure the netesse.ry 0pcr:1tion~l p~rmi1
l.!nd~r the Toxic Subnance Control Act (TSCA.). Use of the chostn ttrhno!osy -BM~ rPr~ly1.ed
Oc-cc,mposition or BCD • at this site will allow An opportunity to test the process for the first time
at full-scale on PCB contaminated soil. The tcthno!o&)' ts of lri'tere:.t because it pruvidi:s
altem~tive means for mnnaging re~iduals. The SITE contractor wil? prepare 11 Demonstrntion
Plan including Sampling ind A!lalysis, Quality Assurar.cc/Quality Control: and Heaith and
Safity Cl)mpol'\ent, whi~h will ,tso sati,fy tl\~ nttch ofTSCA SITE wo1.,1d be r~sponsihlP. fn:-
sample ~oi:eetion and !t1boratory analysis. The da[a wit~ be shared with tht technology v~ndor
wn0 would i:repare ana submit the application for the TSCA penniL Some inhi.d u=i,LinK will uc
~Ml'C..,.tt"tCIIIII• • Jll,,led wllh Vega11111e 01 lued ~u OIi ,~ Ree,~•2 ~.,., ,..,, ttuice"1untr)
\....,I
. . . \ . ,.
2
necessary to secure a Rc&tarch and Development permit to opera~e on a limited scale prior to
issuing the full permit. The typical cost to secure this p:nnit is $50,000. The approximate cost
fo1 a tcc_hnology opcrAtcr to then sccw-e the full permit is $450,000. Therefore, by f~cllitAting the
testing required Lmder TSCA throuib the SITE demonstration, we estimate that SS00,000 will be
saved on the StAtc procurement.
Secondly, the BCD technology is licensed throuah EPA's NRMRL in CinciM11ti. The
fee for ~t: of BCP i~ $7.5 .ooo. h ~ &&anted tor a year or operation with 6S p;r,~nt going to the
lttb &nd 3S percent to the individuals who developed the proeess. The EPA Laboratory has
agreed to waive its share of the fee as a donatton to this project. Thi! fee waivtrs wiil result in
direct uving1 to the state in their procurement.
Finally, we aie investisatlng the possibility of n~uin8 cxi=-LinK thcru111l Jcsorpliun
equipment available for use at the landfill site. The equipment. which includes two rota.rt
desorbers, air pollution control diwkcs, a water trca.tment unit and spare pans. is bccomi~g
3.v~ilable as work is oomploted at a fund-lead Supert\md site ir1 Maryland. The eurrent pl~n flt
that site is to complete treatment and then decontaminate and dismantle the units by the end of
Octo~er. TI1e equipment could be held onsltc 10 accommodate tt.e Warren Councy ~rojcct, but
should be removed by the end of the calender year. EPA would encourtge prospective bidders
for the dctoxifka~ion project io assess the condition of the treatment units, and will strive to have
the equipment 11voil11bl• fo:-that purpose. EPA is invHtigating mechani-'1m1i1 for tran;furins the
equipment to the state o(North Carolina for use on the J)rojcct. It is also necessary, however, to
recognize the partial interest of the state of Maryland. To the extent t.l\ese issues arc resolvea, the
ei:tuip:nent could be avwlablt to the detoxification vendor and would directly result in lower bids
for the project. The ori8inal purchase price of the equipment was about $3 million.. Asnur:ing a
ttn year service life and on, rct.z of' opennion nt the lAnd!ill, it would be reosonable to v~l~e this
contribution in a private sector eontext at approximately $300,000.
While we will continue to seek other opportW\itits, we believe that these contributions
r~pr~sent a significe.nt federal match. My s'.lff and I would like to support this project in any way
we can. If I ea."l be of any furth~r o.ssist&r1cc, plca.,c do nor he1ita.te to contact me ~t (202) 260
4610.
, 1 Oiv,
Timothy elds, Jr. '/'
Assistllnt Administrator
..
cc: Wi!liam Holman, NCDENR
._,, · :s · ·· . , Michael Kelly, NCDENR
Warr~n CountY PCB Citizens Advisory Bc1rd
1ohn Hankinson, EPA Reiion IV
Timothy Oppelt, NRMRL
---·······
NO RTH SU PE RFUN D ID: AU G 17'00 11:35 No.002 P.04 . . .. . . · .
UNrTED STATES ENVIRONMENTAL PROTECTION AQENCY
WASHNOTON. DC ?04M
Hohorablc Evil M. Clayton
U.S . I-louse of Representatives
Wathington. D.C. 2051 R
1.)ear Ms. Clayton:
AUG I 6 2000
OFJIC£ (Y
IOLIO WAITt Nfb AMIAQ!NC1'
fl!IN>N&E
This letter concerns the proposed project to excavate end treat polychlorinAted biphenyl
(rCCl) waste currently dbposcd in the Warren County Lilndfill. On Muy 12, 2000, you wrote
Ms . Carol M .. Browner, Administrator of the U.S. Environmental Protection Agency (EPA),
requesting financial assistance. We discussed the project by phone and I informed you ot my
r.()mmirmc:l"lt to ln(')k fnr rossihle contributions to the effort. On July S, 2000, Mr. John
Hankinson. Jr., BPA Regionni Administrator for Reiinn lV in Atlanta, form11lly responded that
allhuugh lht pr1Jpo:mJ u~\uKificutioo p1ojcct docs not ~Ul'T~ntly n,~ct the c:rhcria for use of
SJperfund trust funds, EPA would continue 10 search for other sources of funding.
As part of this ,earch, a m~mber of my staff recently met with offit.iAii.; frnm the North
Carolina Divi1ion of Waste Management, EPA Region IV and EPA's National Risk
Management Research Laboratory (NRMRL) lo learn more about the proposed cletoxlflcation
effort and to assess the potential for federal contributions. We are aware of the S7 million
appropriation from the State or North Carolina which will rcquirt some federal matching to make
rhc fund3 ova.iloblc .
We have identified substantial federal contributions that we are prepared to make as in-
kind services. Thi.'? largest of these can be provided by evaluatin2 the chosen technolc.>iY through
the Superfund lnnDvative Technology Evaluation (SJTE) program. This demonstration project
will unut<rwrilc much of Lhc work wl1ich is 1cqulied to secure the necessary operationai permit
under the Toxic Substanct Conrrol Act (TSCA). Use: of the chosen technology -Base Catalyzed
Decomposition or BCD -al this site will allow an opportunity to test the process for the first time
at full•icale on PCB contamir,ated ,oil. The technology is of interest because it providelil
alternative means for managing residuals. The SITE contractor will prepare a Demonstration
Plan inc:luding Sampling and Analysis, Qualily Assurance/Quality Control, and Health an~1
Saft~t~1 components which wilt also satisfy the needs ofTSCA. SITE would be responsible for
$ample collection and laboratory analysis . The data will be shared with the technology vendor
who would prepare and submit the opplicution for the TSCA permit. Some initi~l teatins will b11
NORTH SUPERFUND ID: AUG 17'00 11:35 No.002 P.05
. .
necesi;t,,ry to ser:urc a Rescarc.:h and Development permit to operate on a limited scale prior to
issuing the full permit. The typical cost lO sccwe this permil ii. $.SOtOOO. The: apprux.imal1: coi:.l
for a technology operator to then secure the full permit is S4S0,000. Therefore, by facilitating
the testing required under TSCA through the SITE demonsttatioo, w~Qstimate that $500,000 will
be 3oved on the stnte procurorncnt.
Seconclly, the !3C.:Ll technology is licensed through EPA's NRMRL in Cincinnati. The
foP-for ui:e nf BCD is ~75,000. his aranted for a year of operation with 65 percent going to the
lab and 35 percent t(I the individuals who developed the process. The EPA Laboratory has
agreed to waive iL~ lihtar, uf lhe fee u ra donation to this p:oj~,t. _This fee WAivcr.s will result in
direct savings to the state in their procurement.
Finally, we are inve,tigatins the poasihility of makiria ext•ting thenr.a.J desorrtion
· equipment available for use at the landfill site.• The eq~ipment, which includes two rotary
desorbers, air poHution control devices. a water treatment \lnit and spare plll'ts, ls becoming
available 11s work is completed at a fund-lead Superfund site in Maryland. The current plan at
that site is to complete treatment and then decontaminate and dismantle the uni\s by the end of
OcLobe1. The cquipmen1 could be held onsire to accommodate the Warren County pre>j,-ct, but
should be remvved by the end of the calender yeiir. F..PA would encow-age prospective bidders
for the deto1dtication project to assess the condition of the treatment units, and will strive to have
lhe equipmcm1 avRilable for thM rurrol\P. F'.PA •~ lnv~!:tigating mechanisms (or transferring the
equipment to the state of North Carolina for use on the project. It is also necessary, hawever, to
recognize the partial interest of the state uf Maryhmtl. To Lhc c~Lcnl lhc:::;c:: i~~uc:~ on: fe~ulvcd, the
equipment could be available to the detoxification vendor and would directly result in lower bids
for the project. The original purchase price of the equipment was about $3 million. Assumina a
t~n )'ear service lift: and ontt year of operation at the landfill, it would bt reasonable to vnlue thii.
contribution in a privatt s<.ictor context at approximately $300,000.
While we will e~ntinue to ·seek other opportunities, we believe that these contributions
represent a significant federal match. My staff and I would like to support this project in any
way we ean. Jf I can be of any further cusistancc, please do not hcsitntc to contllct me "t (202)
260-4610.
Timothy ••I~) )r,, •
Assistant Administrator
JAMES 8 . HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
Mr. Eric Newman (3 HS23)
Remedial Proje<.:t Manager
EPA Region Ill
1650 Arch Street
Philadelphia. PA 19103
Dear Mr. Newman:
@CJJ/ NORTH
/NVIRONMENT
October I I. 2000
CAROLINA DEPARTMENT OF
AND NATURAL RESOURCES
As you are aware. the EPA has offered rhe Stare of North Carolina assistanc e to suppon the
detoxification of the Warren Coun ty PC8 Landtill. Th,ll ,1ssistance was outlined in a letter from
Assistant Ad ministrator Tim Fields tu C,u, ernor .li111 Hunt ,rn .1\ugust 11 .
One of the ass istance items was rhe use ut·equipment from the Southern Maryland Superfund site.
Over the past month. Pat Backus nf1ny staff has discussed the possibility of using this equipment
with yo u and many others. She has revie11ed rhe specific equ ipm ent available, the condition of the
equipment. th e suitability of the eq uipment for the Warren County project. and the relocation of
the equipm ent to North Caro li,w. In addition . Par has considered the responsibility for
performance that would be assumed by the state if use of the equipment were required. While
so me of the equipment co uld be used in Warren Co unty. we fee l that when considering all the
aspects surrounding its use thm it would not be in the best interest of the state to use th e Southern
Maryland equipment.
We du appreciate the opportunity J-:111\ h,1s gi, en us to consider rhi s equ ipm ent and thank you and
other EP/\ st,1ll. the Corps 01· Lngi11L·e1·,. ,1mi thL· c111-ren1 oper,11or ,1i"the equi pment fo 1· prnviding
in formation tu help us 111 ake this decisiu n. \,\ e ,t\so look !"or\\ ,,rd to the opportunity to discuss
yo ur ex perience at the Southern 1\lar~ l,llld prujL'Ct su 11e c.111 benelit l"rom your ··Jes ons learnect.··
Cc: !'at l3,1ckus
Bill Meyer
Sincerely.
1 601 M AIL SERVICE CENTER, RALEIGH, N ORTH CAROLINA 27699-1601
PHONE 919-733--l98-l FAX [phone] WWW.ENR.STATE.NC.US/ENR/
AN EOUAL OPPORrU NITY / AFF1A"'1ATtVC: ACTION EMPL .J YER -50'-';> RECYCLED/10% POST -CONSUMER PAPER
Re: Meeting with BP A
1 of 1
Subject: Re: Meeting with EPA
Date: Mon, 10 Jul 2000 10:03 :00 -0400
From: Sherri Evans-Stanton <[e-mail]>
Organization: NC -DENR
To: Pat Backus <[e-mail]>, MIKE KELLY <[e-mail]>
Pat and Mike --Here is the response on "match". There is no specific dollar amount required for the
federal match funding. The Governor would like to see at least a few million provided to ensure that the
next phase of the project can be completed. I floated the idea of $500,000 and was asked to try to get
more federal match to make a good faith effort.
Sherri
Pat Backus wrote:
You have probably talked or received messages from Phil Vorsatz concerning the meeting with EPA on
the 10th and 11th. I have reserved Conference Room 1 (here at Oberlin) for the afternoon of the 10th
for the meeting. It will start at either 12:30 pm or 1:00 pm depending on flights. On the morning of the
11th, a few of the EPA folks will go to Warren County to see the landfill site and meet some of the
CAB. I have reserved one of our Surburbans for that if needed. I know Mike is attending on Monday.
Bill and Sherri, please let me know if you plan to attend so we won't be waiting for you.
I just talked to Phil and one question he asked was if "in-kind services" would count toward a match.
They are thinking of that as a possibility for assistance. The in-kind services would be from the SITE
program, but don't know the details. There is also the possibility of them waving the licensing fee for
BCD. (The information I have on that says it's $75,000 the first year and $50,000 the second year.)
Sherri, if you are not attending, I need to be sure that I am telling them the right interpretation for
matching. I thought we had said that matching was any amount ( even a $1) coming directly to the state
and that the match did not have to be a one-for-one match. After the past few weeks with no "official"
statement as to what the match means, I feel a little unsure as what to say with authority. EPA knows
that they cannot supply a one-for-one match. Even ifthere is not officially a minimum, I think we
should give them some amount to work against. Please let me know, even if just restating what you
have previously said, so I can be sure it is the right statement.
07/10/2000 10:24 AM
~ .i ,.__) (' ti_ {1 ( (") a.,,_A c1 ,,<) bl.-<..',)
~,-z ,__ r(. L ,;Cl.-(., 1 f:J ().., r .J --1 G
1k. d ;y-.._u...t--, 6 ~1
~hi
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.. ········1119'••·····•.
/. .... ...
. . ·•. ... .. .
Harry M. Williams, Ill,
Chairman
.. ..
Clinton G. Alston, V. Chairman
Michael A. Jones
Glen A. Richardson
Roger L. Williams
Angelena Kearney-Dunlap
Clerk to the Board
Telephone: [phone]
Fax: [phone]
WARREN COUNTY BOARD OF COMMISSIONERS
LORIA D. WILLIAMS, COUNTY MANAGER
P.O. BOX 619
WARRENTON, NORTH CAROLINA 27589
September 14, 1999 ·
Mr. Mike Kelly, Deputy Director
N.C. Department of Environment & Natural Resources
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
~
SEP 1999
WaReceived
steo"-1,·va,. ~agement s1on
-----. . , --------
RE: Resolution Supporting Federal Funding for the PCB-
Detoxification and Redevelopment Project in Warren County
Dear Mr. Kelly:
Thank you for your informative presentation on September 7, 1999 to
the Warren County Board of Commissioners. Please find enclosed an
executed copy of the above mentioned resolution for your records.
Should you have any questions or require additional information,
please feel free to contact this office. Thank you for your attention to
this matter.
LDW:akd
Enclosure
Sincerely,
~,o. MIi,,/¥,,
Loria D. Williams
County Manager
,I WARREN COUNTY BOARD OF COMMISSIONERS
..... •····1119········ .. ... ·.,.,...---,,,.,..,,,......-,,...• ...
LORIA D. WILLIAMS, COUNTY MANAGER
P.O. BOX 619
WARRENTON, NORTH CAROLINA 27589 : \
. . .. .. .. .. .. .
-.. ..
Harry M. WIiiiams, Ill,
Chairman
Clinton G. Alston, V. Chairman
Michael A. Jones
Glen A. Richardson
Roger L. WIiiiams
Angelena Kearney-Dunlap
Clerk to the Board
Telephone: [phone]
Fax: [phone]
STA TE OF NORTH CAROLINA
COUNTY OF WARREN
RESOLUTION
SUPPORTING FEDERAL FUNDING FOR THE PCB-DETOXIFICATION AND
REDEVELOPMENT PROJECT IN WARREN COUNTY
WHEREAS, the State of North Carolina did place a PCB landfill in Warren County
under a federal permit from the Environmental Protection Agency to dispose of
approximately 40,000 cubic yards of soil contaminated with polychlorinated biphenlys
(PCBs) that had been illegally disposed along more than 200 miles of North Carolina
highways; and
WHEREAS, the State of North Carolina promised the citizens of Warren County that
detoxification of the contaminated soils would be considered once technology had
been developed for this purpose in order to rid the community of this environmental
stigma; and
WHEREAS, approximately 10 percent of the material from federal property located in
the State of North Carolina; and
WHEREAS, the State of North Carolina, during the past three years, appropriated $1
million to assess the disposal facility and study detoxification technologies, and in
working with the local community did find and choose a technology capable of
detoxifying the contaminated soils, and has appropriated an additional $3 million
toward this project; and
WHEREAS, in August of 1999, the State of North Carolina set aside an additional $7
million for detoxification to match any federal funds obtained for this purpose, and
Warren County received an environmental justice grant to support a Community
Involvement Coordinator to work with the state and newly appointed Citizens Advisory
Board (CAB) with this endeavor; and
WHEREAS, the State of North Carolina has issued a contract for the final design plans
for detoxification of the PCB disposal facility, thus allowing the state to be in a position
to issue a contract for detoxification in early 2000 on the facility that today continues to
pose a threat of release of a CERCLA hazardous substance.
NOW, THEREFORE, BE IT RESOLVED that the County of Warren requests the U.S.
Delegation actively support the appropriation of $7 million in federal funds to match the
funds already set aside by the State of North Carolina to detoxify the 40,000 cubic
yards of PCB contaminated soils forced on this county in 1982, in order that this area
of approximately 134 acres can be detoxified and redeveloped into some type of park
or recreational facility beneficial to the citizens of this county.
Adopted this ih day of September, 1999.
Dunlap/
Clerk to ~he Board/
WARREN COUNTY BOARD OF COMMISSIONERS
Harry ~lliams, Ill
Chairman
JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
__ ,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 12, 2000
John Kingscott, PE
Director, Technology and Markets Program
U.S. Environmental Protection Agency
401 M Street, SW. (5102 G)
Washington, DC 20460
Dear John,
DIVISION OF WASTE MANAGEMENT
Sorry to have delayed in getting this information to you. I spent several hours today going
through files. The technology selection criteria were developed in 1995, which was early in the
effort to detoxify the landfill. The filing system then wasn't very good. I could not find one, final
version document that included all the details of the technology selection process. I saw
references to a "Master Plan" but haven't located it yet In order to prevent further delay I am
providing you with excerpts from several documents I found. I discussed the information with our
Division Director Bill Meyer who has been involved with the landfill since it's construction to
understand how what I have found fits together.
The second reference is the ''Proposed Technology Screening Criteria". Bill said that they added
an additional criterion that dealt with commercial availability but I was unable to find a specific
reference to that.
The third reference is from a draft document entitled ''Technology Screening: Remediation of the
Warren County PCB Landfill". In addition to the rating system, it listed ten technologies they
evaluated in their assessment I will mail you the rest of the report that contains a short
description of each technology and an initial attempt to use the point system. A lot of work was
obviously put into the criteria list and rating, however, it didn't work as well as they thought it
would. I don't know how the Working Group felt about the initial attempt, but in my opinion the
scores were essentially the same for most of the technologies, especially when you consider that
some of the criteria was subjective (How do assess community acceptability to assign a rating?
What is the objective difference between satisfactory and marginally acceptable? What's the
objective difference between small, moderate, and large volumes of residuals? ) I also found
references to discussions on whether the criterion should be weighted.
In the end, the community essentially deferred to the assessment of Joel Hirshhorn, one of the
community's independent science advisors. Some of his report, "Preliminary Detoxification
Technology Assessment" is attached. He briefly discusses each technology giving his opinion and
then recommends the BCD and ECO LOGIC processes for pilot studies. He also discusses an
alternative direction the thinks the group should take. There's always something extra. It gets
lengthy so I have only included the first few pages. I'll mail the rest of the report to you.
The last document I've included is ''Explanation of Selection of Two Detoxification
Technologies". It's is a brief summary of why technologies were rejected or selected.
I am sending you (Fed Ex) the additional text of the Technology Screening and Hirshhom's
report Everything is hectic now so if this material adequately responds to your question, please
let me know. The older Working Group infonnation is not filed to facilitate quick retrievaJ ,o(, .. 0 C,.
specific information. lilEI
¼ ,,/_ '-12. ; / 1646 MAIL SERVICE CENTER, RALEl<aH, NORTH CAROLl:'.7:':'~':':~.: ~OAJ I~ 401 OBERLIN ROAD, SUITE ISO, RALEl<OH, NC 27605
PHONE [phone] FAX [phone]
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(5) Instead of exclusiveness in decision-making, inclusiveness.
The prevailing model undermines the fundamental premises for a sound theology,
for a sound democracy, and for a sound ecology. It leaves us ultimately without
God. without lreedom, and without a planet. It Is a self-destructive model, a suicidal
model. It is a model for social disintegration, informed by a rationale for selective
human sacrifice. These are our concerns from the more global perspective.
Turning now to our local crisis, we need to resolve it within a framework
compatible with the principles of waste reduction and equity. These are the
bottom lines: ·
(1) The proposed Band-Aid approach is unacceptable. It's only
a stopgap measure. Our objective must be to restore the
ecological status of Afton to what it was before the siting
and lo restore its property values, by creating the
reality and the perception that Afton is a very fine and safe place
to live so that the people of Afton and of Warren Qounty will
be able to move forward once again to a safe and prosperous
future. We need therefore lo explore the option of on-site
detoxification, assessing costs. risks, etc. In other words, we need to
help Governor Hunt keep all promises made in his 1982 letter to the
people of Warren County.
(2) If our research indicates that on-site detoxification is not presently
a viable option, then. after on-site stabilization, future activity
at the site must involve monitoring and maintenance only.
Repeating the 1992 attempt to take advantage of the sacrifice
area by expanding from the foothold will be resisted.
(3) The solution must be restricted to the site. The solution
must not include an expansion of the present site, nor in any way
transcend its present borders. Expansion will be resisted.
(4) The trucking initiative must be precluded. Under no condition
will trucks loaded with PCBs leave the borders of the PCB
landfill. Such an attempt will be met with the most serious
forms of resistance.
(5) We will need to be convinced by disinterested scientists that
the filtering process will extract the PCBs from the 500,000
to one million gallons of contaminated water that
the state is planning to spray all over the site. The attempt to
(3)
Initiate this process before a disinterested scientific assessment
of risks has been explained and consented to will be resisted.
If the above conditions can be met, we can move forward together.
Finally, when your people come to Warren County, tell them that in 1982, three races
carried a cross together In the poor and predominantly black community of Afton,
here in Warren County, and that here, together, they were sacrificed. Tell them,
therefore, to come with reverence and with awe. Tell them that in 1982, In Warren
County , North Carolina, blacks, whites, and Indians transcended a history that had
divided them and came together in brotherhood and love, and that from their sacrifice
emerged new hope for a new history, informed not by a rationale for selective human
sacrifice, but by the universal brotherhood of man. Tell them to come as pilgrims on a
pilgrimage, because all this land is holy land, all this ground is holy ground.
Secretary Howse, that concludes my memorandum to you. And now I would like to
translate what I have said into the language of the people: What we have out
there, folks, in the poor black community of Afton ,is a bus. Now I know it doesn't look
like a bus. It's not supposed to look like a bus. It's supposed to lqok like a landfill.
But I'm telling you, it's a bus. And the bus is self-destructing. And I'm telling you that
one of our neighbors Is on that bus. And her name is Rosa Parks. I know Rosa Parks.
· Rosa Parks is a friend of mine. Bui instead of trying to get Rosa Parks off the bus,
and keep her ott the bus. we're getting ready to build a whole fleet of buses, just like
that one, and getting ready to fuel them with the high octane of Sub-D regulations.
And then we're going to drive those buses into the poor black and other poor minority
communities, put the poor folks in the buses, and then wait for the buses to self-
destruct, just like we did in Afton.
These are the big buses; these are the massive solid waste buses, containing toxic
and hazardous waste; these are the BOO acre buses, the 1000 acre buses, the
1500 acre buses. These are the buses that will contaminate the groundwater of the
poor black and other minority communities.
How long? Not long.
1n December of 1978, I was 36 years old, when I told the state of North Carolina that it
would be due process first, then civil disobedience if the state attempted to bury PCBs
in the poor and predominantly black community of Afton.
How long? Not long.
In 1982, I was 40 years old when as a last resort we had here the largest nonviolent
civil disobedience in the south since Dr. Martin Luther King, Jr. marched through
Alabama, according to the Duke Chronicle, and when I was arrested 8 times.
. . .
3
PROPOSED TECHNOLOGY SCREENnitlG CRITERIA
· These criteria are a merging of those proposed for technology evaluation in the
April 11 draft to the Suba>mmittee with those used by EPA in its Feasibility Study
process.
1. Community acceptibility
2. Extent of prior experience with this technology at similar sites
3. Short term safety and effectiveness, potential for worker exposure, planned and
unplanned releases.
4. Long term effectiveness-extent of reduction of toxicity, mobility or volume
5. Generation of residuals and degree of on-site management
6. Projected duration of full scale treatment from present to completion
7. Availability of pilot scale treatment immediately
8. Implementability at Warren County site, engineering feasibility, infrastructure
requirements, proximity of vendor equipment
9. Cost per unit treated, assuming similar infrastructure costs
With the exception of #9, I would suggest ranking each of these factors on a scale
from 1-4 as follows:
1= unacceptable
2= marginally or conditionally acceptable
3= satisfactory
4• outstanding
Technologies selected for further consideration and inclusion in a seoond round
RFQ would have a total score among the top three and no criteria evaluated as
unacceptable.
. ,·
SEr\T BY:Ktnko's Coples ; 6-20-95 ;Jt:14PM Klnko's Durham 1~ 818 715 3605;# 3/17
'• .
TECHNOLOGY SCREENING: REMEDIATION OF THE
WARREN COUN1Y PCB LANDFILL
DRAFfREPORT,JUNE 1995
Sqeenin~ Criteria
At the June 1 meeting of the PCB Landfill Joint Working Group, pro~
&aeening aitcria to be applied to potential remedial technologies for the landfill
were presented, along with a "short list" of technologies which met three minimal
criteria. Remedial technologies were retained for more detailed evaluation if they:
a) were cxmsidered potentially effective against halogenated semi-volatile organic
compounds in soil, b) did not involve high pressure, temperature or other stresses
which could effect the integrity of the landfill liners, and c) are considered in EPA
documents to be at the "full scale" level of development.
Comments were received from members of the aiteria development
subcommittee by June 12 and discussed by phone, with special emphasis on reaching
a consensus on the meaning and use of aiterion 1) Community Acceptability.
While this report will not evaluate technologies for that particular criterion, it was
an opportunity to clarify and define this parameter for later evaluation by
community members of the Joint Working Group.
One overall comment which had been received in response to the April 11 draft
aiteria submitted to the subcommittee was that the technology should be approved
by EPA and the state of North Carolina. The technologies considered in this report
have all been sufficiently tested at the pilot scale to merit consideration by EPA for
full scale remediation at CERCLA hazardous waste sites. One of them, incineration,
is considered "conventional" for PCB lreatments, as it has been applied numerous
times to similar sites. The other nine are considered "innovative" and have widely
differing degrees of experience with actual soil clean-ups. Several, including BCD,
have only been used on a pilot scale, with no full-scale results yet available. Because
of the strong commitment to detoxification of the landfill, some technologies
should be considered only as part of a "treatment train", as they are only designed to
reduce the yolume in which the contaminants are a>ntained.
As a result of these comments and discussions and the availability of data in
technical documents obtained by June 15, the following criteria and methods of
evaluating them will be used:
1) Community Acceptability. It is my understanding that all subcommittee
members agree that this criterion shall be a subjective measure of the community's
overall perception of a technology, after having the opportunity to read a
descriptiol} and evaluation of the technology as well as to ask questions of technical
adv~ The oommunity's assessment of acceptability will be prominantly
SE!\T BY:Ktnko's Coples ; 6-20-95 ;tt:14PM Klnko's Durham 1~ 919 715 3605;# 4/17
Q)
3
included with any distribution of this technology screening information and will be
extremely important in selection of actual pilot study and full remediation vendors.
(Suggested ratings: 4 • outstanding; 3 • satisfactory ; 2 • marginally acceptable; 1 •
unacceptable)
2) Extent of prior experience with this technology on soils at sbnilar sites. (Rating
based on the number of sites with PCB or dioxin-contaminated &oils which have
completed pilot or full-scale projects with this technology: 4 • more than five sites; 3 -
three to five sites; 2· one to two sites; 1 -no sites using this technology.)
3) Short term safety and effectiveness. Includes potential for worker and
community exposure due to planned and unplanned releases (excavation, gaseous
emission&, solvents) during operation. (Rating: 4 -Jn situ and well-contained
process m: "dosed loop" with essentially no chance of releases; 3 -technology
demonstrates very low release levels within regulatory limits; 2 -some releases
documented with technical improvements currently available; 1 -uncontrolled
release.& possible.)
4) Long term effectiveness. Reduction of toxicity or volume of toxic contaminants.
(Rating: 4 -demonstrated ability to detoxify amtaminants to at least 99% removal
level; 3 -demonstrated ability to detoxify contaminants to at least 95% removal
level, m: to reduce volume of contaminated soils to less than 30 % of original
volume as part of a "treatment train", with greater than 95% removal from
remaining fraction; 2 -ability to detoxify or concentrate contaminants to 90% level
or to higher levels under limited conditions; 1 -technology generally not effective
on contaminants and under conditions at the Warren County Landfill.)
5) Generation of residuals and ability to handle on-site. (Rating: 4 -no residuals or
completely treatable on-site; 3 -small volume of residuals, predominanlly treatable
on-site; 2 -moderate volume of residuals, mosUy treatable on site at added expense;
1 -large volwne of incompletely detoxified residuals.)
6) Projected duration of full-scale treatment. (Rating: 4 -less than six months; 3 -
six months to one year; 2 -one to two years; 1 -longer than two years.)
7) Availability of pilot scale treatment. (Rating: 4 -available to start immediately; 3 -
available to start within three months; 2 -available within six months; 1 -longer
than six months or unknown.)
8) Implementability of this technology at Warren County PCB Landfill. Number of
vendors available, technical impediments, extent of infrastructure requirements.
(Rating: 4 -more than three vendors available, no major technical problems
anticipated, system largely self-contained; 3 -two to three vendors, technical
problems are soluble with minimal expen.c,e and time, few unique requirements for
SEJ\T BY:Ktnko's Coples . . ; 6-20-9-5 ;11:15PM Ktnko's Durham 1~ 918 715 3605;# 5117
infrastructure support; 2 -one vendor available, technical problems may delay or
increase costs up to 25%; significant unique infrastruct\ll'e support needed £or this
technology; 1 -no vendors available, major technical problems, infrastructure
requirements too expensive or unobtainable at this site.)
9) Estimated cost per cubic yard of a:mtaminated soil treated. (Rating: the projected
cost range will be given and the mid-point of that range will be rated as 4 -less than
$100 per cubic yardi 3 -$100 to $300 per cubic yardi 2 -~$500 per c:ubic yard; 1 -
greater than $500 per cubic yard.)
TechnoJQgies Evaluated
t) In situ biodegradation
2) Slurry phase biological treatment
3) Controlled solid-phase biological treatment
4) Soil washing
S) Dehalogenation (glycolate)
6) Dehalogenation (BCD)
7) Solvent extraction
8) low temperature thermal desorption
9) High temperature thermal desorption
10) Incineration
For each technology, a general description, any suggestions for technology-specific
vendor selection criteria, a numerical evaluation of criteria 2 through 9 and a
swnmary rating (not including Community Acceptability) will be given. The report
concludes with some general recommendations based on these ratings and other
infomation obtained during the data search for this screening. Please note that
n1ermally Enhanced Soil Vapor Extraction, though included in tlte June 1 list of
technologies to be evaluated, has since been eliminated from this list. Upon closer
examination of the technology, it appears that temperatures approximating those
used in thermal desorption (300-lOO()oF) would be required for successful removal of
semi-volatiles such as PCB's, making this in-situ technology potentially damaging
to the landfill containment.
SU\T BY :Ktnko's Coples ; 6-20-85 :11:1SPM Ktnko 's Durham 1~ 919 715 3605;# 6/17
IN-SITIJ BIODEGRADA TION
Description
Generally, native micro-organisms (bacteria and fungi) which are already present
at a contaminated site and able to metabolize one or more of the toxic a>ntaminants
are provided with nutrients via injections of groundwater, and other c:onditions
modified to speed up their growth, thus shortening the time required to detoxify the
contaminants. This technology does not involve excavation, minimizing exposure
to soils, dust and air emissions. JI successful in speeding up metabolism of toxic
compounds to less toxic products, this is one of the least expensive technologies.
In the case of PCB'&, until recently mnsidered a>nsidered "refractory" to
bioremediation, it is now known that the first metabolic step in detoxification must
be removal of the chlorine atoms from the aromatic rlngs under mearobic
conditionst,2. The aerobic conditions usually applied in bioremediation encouraged
the growth of organisms which could not oomplete the detoxification until the
anearobic dechlorination is nearly complete. Although important progress has been
made recently in understanding degradation of l'CB's in sedimentsl,4, and there is
evidence of natural dechlorination occuring at the Warren County site
(correspondence to S. Rogers, DSWM from J. Jones, EPA and F. Mondello, G. E.),
bioremediation of PCB's has generally been judged incomplete and/or too slow to be
practical for full-scale remediations.
l;Ialuation
Criterion Rating
t. Community Acceptability
2. Extent of prior experience with technology at similar sites 3
3. Short term safety and eff ecliveness 4
4. Long term effectiveness, reduction of toxicity or volume 1
s. Generation of residuals, degree of on site management 4
6. Projected duration of full-scale remediation 1
7. Availability of pilot-scale study 3
8. Implementability at Warren County PCB Landfill 2
9. Cost per cubic yard of contaminated soil: $20-$100 4
Summary score (not including Community Acceptability) out of 32 22
SE\T BY:Ktnko's Copl~s ; 6-20-95 ;11:}5PM Klnko's Durham 1~ 918 715 3605:# 7/17
SLURRY PHASE BIOLOGICAL TREATMENT
Description
Slw-ry phase methods involve biodegradation conditions simllar to those
described in In-Situ Biodegradation, with the exception that the conlaminated soils
are maintained in a suspended state in a &0lution of water and nubients by a stirring
apparatus. Slurry phase treatment has been tried i!l·l!tll in river bottom sedio1ents
with limited success', but is usually carried out in stirred tanks after excavation of
10us. This is the most frequently used method of bioremediation of PCB'& (eight
lites), and shows some evidence of success at two sites, as indicated by its selection as
a full-scale remedyS. There is evidence at one site that dioxins are causing
interference with biodegradations.
Su&gestions for technolo.gy::§pedfic :vendor selroion g:iteria: bench scale treatability
studies must be performed by potential vendor before consideration for
performance of pilot study.
EyaJuation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 4
3. Short term safety and effectiveness 3
4. Long term effectiveness, reduction of &oxicity or volume 2
5. Generation of residuals, degree of on site management 3
6. Projected duration of full-scale remediation 1
7. Availability of pilot-scale study 4
8. Implementability at Warren County PCB Landfill 3
9. Cost per cubic yard of rontaminaled soil: $100-$160 3
Summary score (not including Community Acceptability) out of 32 23
-----SE\T BY:Ktnko's Coples ; 6-20-95 ;}l:15PM Ktnko's Durham 1~ 919 715 3605 ;# 8/17
CONTROLLED SOUD-PHASE BIOLOGICAL TREATMENT
l)esqjption
In the rontrolled solid-phase method of biodegradation, soils are excavated and
layered with soil amendments (nutrients, emulsifiers, etc.) in a large, shallow
containment with leachate collection systems and controlled moisture and
temperalure6. The present landfill configuration would not be suitable and would
require construction of a new and larger containment area. Further, this method is
intended primarily for aerobic degradation, which has not been successful in
remediatlng PCB rontaminated sites.
§valuation
Criterion Rating
t. Community Acceptability
2. Extent of prior experience with technology at similar sites 2
3. Short term safety and effectiveness 2
4. Long term effectiveness, reduction of toxicity or volume 1
5. Generation of residuals, degree of on site management 3
6. Projected duration of full-scale remediation 1
7. Availability of pilot-scale study 2
8. Implementability at Warren County PCB Landfill 1
9. Cost per cubic yard of contaminated soil: $100-$200 3
Summary score (not including Community Acc:eptability) out of 32 15
. • . .:.. --~T BY:Ktnko's Coples ; 6-20-95 ;11:16PM Klnko's Durham 1~ 919 715 3605;# 9/17
SOIL WASHING
Description
Soils are washed and scrubbed in a water-based solvent to remove contaminants
from the coarser particles in the &Oil and separated according to particle size. Present
aaturation of landfill soils will help washing, but waste water will need treatment.
Chlorinated semi-volatile organic compounds are adsorbed primarily to the day and
silt particles ("fines") and to the swfaces of the coarser &and and gravel particles7,
nus method can reduce the volume oI mntaminated aoils requiring detoxification
by amcentrating contamination in the separated clay and silt fraction of the soil.
The coarse fraction can be used for backfill if decontaminated to target levels.
Soil washing oould be used as part of a treatment train £or detoxification of the
concentrated PCB's, potentially providing 1ubstantial savings in treatment costs.
One possible treatment train would include thermal desorption contaminants from
the eeparated soil fines, followed by dechlorination by BCD or another process.
Some thermal desorber designs are known to have problems with caking of high
day/ silt soils, however, lowering the effectiveness of the treatmenL
Suggestions for techno]Q&)f·speci{ic vendor selection g:lteria: a) demonstrated ability
to remove contanunants from coarse fra.ction to target levels; b) suitable te"ture of
"fines" fraction produced for further detoxification treatments; c) experience of
vendor in coordinating volume reduction by soil washing with detoxification.
Evaluation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 3
3. Short term safety and effectiveness 3
4. Long term effectiveness, reduction of toxicity or yolume 3
S. Generation of residuals, degree of on &ite management 2
6. Projected duration of full•scale remediation 4
7. Availability of pilot-scale study 4
8. Implementability at Warren County PCB Landfill 4
9. Cost per cubic yard of contaminated soil: $170-$280 3
Summary score (not including Community Acceptability) out of 32 26
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DEHALOGENATION (GLYCOLATE)
Description
Soils are mixed with an alkaline polyethylene glycol (KPEG is the potassium
version) and heated in a batch reaction vessels. The PEG molecule5 replace the
chlorines on PCB's and dioxins to produe2 bi-phenyl compounds which are not
regulated as toxic by CERCLA, and probably more biodegradable in soils, but whose
toxidty has not been studied in detail. Waste water can be treated on-site by
conventional or innovative methods to remove any remaining organics before
release. Soll treatment is generally quite effective in reducing concentrations of
PCB's and dioxins to target levels. Treated soil is sometimes described as having a
texture similar to quicksand, unsuitable for backfilling on site.
This is generally a "stand-alone" technology, but could be used on soil "fines"
obtained from a soil washing step, for example, or on tbe oil condensate from
thermal desorption, containing concentrated contaminants. ·
@
Suggestions for technology-specific vendor ,election qiteria: a) ability to control or
improve soil texture following treatment; b) willingness of vendor to test for toxicity
of reaction products.
Evaluation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 3
3. Shorl term safety and effectiveness 3
4. Long term effectiveness, reduction of toxicity or volume 4
s. Generation of residuals, degree of on site management 2
6. Projected duration of full-scale remediation 3
7. Availability of pilot-scale study 4
8. Implementabllity at Warren County PCB Landfill 3
9. Cost per cubic yard of rontaminated soil: $~$700 2
Summary score (not including Community Acceptability) out of 32 24
SE:r\T BY:K1nko's Coples ; 6-20-95 ;11:16PM; Klnko's Durham 1~ 919 715 3605;#11/17
@
DEHALOOENA11ON (BCD)
Qescription
Base Catalyzed Dechlorination was developed in EPA's Risk Reduction
Engineering Laboratory and uses a &0mewhat simpler chemical process than the
APEG/KPEG type dechlorination8. Soils are tteated initially with thermal
desorption in the pre&ence of sodium bicarbonate al about 65()o F to partially
dechlorinate PCB's and dioxins and volatilize them from the soil9. These
amtaminants are recovered by an oil saubber in the vapor recovery system and are
concentrated in oil for later treatment with stronger reagents in a liquid tank reactor,
again at about 65()0. Removal of PCBs and dioxins from soils and dechlorination of
these contaminants in oil have been quite successful in pilot and bench scale
studies9,to. Air releases of dioxins have occurred in one test, from the thermal
desorber part of the system, due to insufficient air controls.
A closely related technology is the Soil-Tech ATP thermal desorber process,
which operates a unique flow system with internal BCD. The temperature of soil is
gradually increased, with a combustion final step after dechlorination, vaporization
and recovery of organic contaminants, which may require further detoxification.
The ATP process has been extensively tested and used on one full-scale remediation.
Su&sestions for technoloif•specific vendor selection criteria: a) well-engineered air
controls; b) willingness to analyze reaction products for toxicity
Evaluation
Criterion
1. Community Acceptability
Rating
2. Extent of prior experience with technology at similar siles 3
3. Short term safety and effectiveness 2
4. Long term effectiveness, reduction of toxicity or volume 4
5. Generation of residuals, degree of on site management 3
6. Projected duration of lull-scale remediation 4
7. Availability of pilot-scale study 4
8. Implementability at Warren County PCB Landfill 3
9. Cost per cubic yud of contaminated soil: $150-$350 3
Summary score (not including Community Acceptability) out of 32 26
SEJl.'T BY:Klnko's Coples ; 6-20-S.5 :11:16PM Klnko's Durham 1~ 819 715 3605:#12/17
SOLVENT EXTRACTION
J)esqiption
Solvent extraction is used to separate a>ntaminants &om soils and sediments,
reducing the volume which requires further treatment to detoxify. Organic aolvenlS
G)
have been used successfully for removal of PCB'& in lhe past, but can leave trace ·
levels in treated &Oils. Less toxic, water-baaed &0lvents arc now available from
teveral vendors and have removed PCB's to target levels with few residuals at all
but one site. One possible treatment train would be extraction of PCB'& and other
toxic halogenated organic compound from soil with a water-based extraction
prOCEss, followed by dechlorination (APEG/XPEG if in water, extraction into organic
solvent or oil for treatment with BCD type process). This type of treatment train is
currently in operation at one site.
Suggestions for technolo~-spedftc vendor selection criteria: a) toxicity of solvent
system; b) compatability of extract with further detoxification methods; c)
mmpatablity of solvent with soil characteristics
Evaluation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 4
3. Short term safety and effectiveness 3
4. Long term effectiveness, reduction of toxicity or volume 3
5. Generation of residuals, degree of on site management 3
6. Projected duration of full-scale remediation 3
'J. Availability of pilot-scale study 4
8. Implementability at Warren County PCB Landfill 3
9. Cost per cubic yard of oontaminated soil: $140-$560 2
Summacy score (not including Community Acceptability) nut of 32 25
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: . @
IDW TEMPERA1URE TI-IERMAL DESORPTION
Description
Low temperature thermal desorbers are designed to heat soils with mixing at
temperatures of 200-60C)oF in order to volatll.17.e organic.material and remove it from
contaminated $Oils. Several flow de;igns are.available, most operating in very low
oxygen or anaerobic conditions. All thermal deaorbers require treatment of off-gases
to remove particulates and recover contaminants for further detoxification, such as
dechlorination, and are considered a volume reduction methodll. A large number
of vendors offer thermal desorption services and equipmentt2. Umited data
indicate that temperatures below SSOoF may not be effective in removal of PCB's
and dioxins from soilst3, and that higher temperature desorbers are more reliable
for such compounds. High water content soils require dewatering to make removal
eo&t effective.
Suggestions for technolo.gy-spedfic vendor selection criteria: a) well-engineered
treatment system for desorber off-gases; b) c.ompatability of organic scrubber product
with following detoxification method.
Evaluation
Criterion Rating
t. Community Acceptability
2. Extent of prior experience with technology at similar sites 2
3. Short term safety and effectiveness 2
4. Long term effectiveness1 reduction of toxicity or volume 2
5. Generation of residuals, degree of on site management 3
6. Projected duration of full-scale remediation ' 7. Availability of pllot•scale study ' 8. lmplementabllity at Warren County PCB Landfill 3
9. Cost per cubic yard of contaminated soil: $140-$280 3
Summary score (not including Community Acceptability) out of 32 23
SE:r\T BY:Klnko's Coples ; 6-20-95 :11:17PM; Klnko's Durham 1~ 819 715 3605:#14/17
• ..
HIGH TEMPERA 1URE THERMAL DESORPflON
Description
Similar to low temperature desorption, except performed at 600-lOOQoF to
volatilize more semi-volatile organic compoundst t in order to remove them from
contaminated soils. High temperature desorption is often used in a treatment train
with dechlorination or incineration. Currently available BCD systems operate the
initial de&orber step in this range, as it appears to be more successful in removal of
highly chlorinated aromatic axnpounds, such as PCBst3. High water content soils
require dewatering to make removal cost effective.
The Soll-Tech ATP process, described under the BCD technology, ls a thermal
desorption process which operates with soil passing through chambers at gradually
inaeasing temperatures up to about 120()oF, and some degree of dechlorination
occuring within the desorber.
Syggestions for technology-specific vendor selection qiteria: a) well-engineered
treatment system for desorber off-gases; b) compatability of organic scrubber product
with following detoxification method.
Eyaluation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 3
3. Short term safety and effectiveness 2
4. Long term effectiveness, reduction of toxicity or volyme 3
5. Generation of residuals, degree of on site management 3
6. Projected duration of full-scale remediation 4
7. Availability of pilot-scale study 4
8. Implementability at Warren County PCB Landfill 3
9. Cost per cubic yard of, rontaminated soil: $1~$450 3
Summary score (not including Community Acceptability) out of 32 25
. SEJ\T BY:Ktnko's Coples ; 6-20-95 ;11:l?PM; Klnko's Durham 1~ 919 715 3605;#15/17
@
INCINERATION
Description .
Incineration is a very high temperature method (1,400 to Zl()()oF) designed to
destroy organic contaminants either as a singl~step method applied to
oontaminated &ails, or u the final step in a treatment train where thermal
desorption or another method has removed organic contaminants &om soils.
Several vendors offer a conventional rotary kiln design, with an afterburner and an
air pollution control system. Newer designs lnclude a circulating fluidized bed for
more even combustion, or infrared combustion at slightly lower temperatures. Air
emi&&ions controls are extremely aitical for incineration systems, as much higher
volume& of oxygen-a>ntalning off gases flow through the combustion chamber than
are required for thermal desorbers. Properly operated systems for incineration of
PCBs and dioxins meet the 99.9999% destruction require~ent for these compounds.
Combustion conditions can be maintained more uniformly if waste stream is
uniform and readily combustible, such as organics recovered from the oil scrubber
of a thermal desorption unit.
~u~estions for technology-specific vendor selection qiterja: a) altically engineered
air pollution controls; b) compatability of optimal incinerator waste stream with
output from soil removal technology if used in treatment train.
fiyaluation
Criterion Rating
1. Community Acceptability
2. Extent of prior experience with technology at similar sites 4
3. Short term safety and effectiveness 2
4. Long term effectiveness~ reduction of toxicity or volume 4
5. Generation of residuals, degree of on site management 2
6. Projected duration of full•scale remediation 4
7. Availablllty of pilot-scale study 4
8. lmplementabllity at Warren County PCB Landfill 3
9. Cost per cubic yard of contaminated soil: $170-$730 2
Summary score (not including Community Acceptability) out of 32 25
~T 8Y:K1nko's Coples ; 6-20-8-5 :11:18PM; Klnko's Durham 1~ 819 715 3605:#16/17 . . .
REFERENCES
1. Abramowicz, D. A, 1990. "Aerobic and Anaerobic Biodegradation of PCBs: A
Review", Critical Reviews in Biotechnology, Vol. 10, pp. 241-251.
2. Evans, B. S.; Dudley, C. A. and Klasson, IC. T., 1995. "Sequential Anaerobic-
Aerobic Biodegradation of PCB's in ~il Slurry Reactors", Applied Biotechnoloay
and Bioengineering, in press.
3. Unterman, R. et al, 1988. "Biological Approaches for Polychlorinated Biphenyl
Degradation·, in Enyjronmental Biotechnology (Omenn, G., ed.) pp. 253-269.
4. Harkness, M. R. et al, 1993. "In Situ Stimulation of Aerobic PCB Biodegradation
in Hudson River Sediments". Science, Vol. 259, pp. 503-507.
5. "Bioremediation in the Field". USEPA offic:e of Solid Wasle and Emergency
Removal, 1994. EP A/540/N-94/501.
6. Remediation Technolo~ies Sqec;nin& Matrix and Reference Guide. Federal
Remediation Technologies Roundtable. USEP A and the DOD Environmental
Technology Transfer Committeel 1994 EPA/542/8-94/13.
7. Soil Washing/Soil Flushing. Volume 3 of the engineering guide series
"Innovative Site Remediation Technology" USEPA, 1993. EPA/542/8-93/012.
8. Chemical Treatment, Volume 2 of engineering guide series "Innovative Sile
Remediation Technology" USEPA, 1994. EPA/542/JJ.94/004.
9. Timberlake, D., 1995. "Evaluation of Base-Catalyzed Decomposition (BCD)
Process for New York/New Jersey harbor Sediment Decontamination", Abstract,
RREL Research Symposium, 1995.
10. Superfund Innovative Technolo.-:y Evaluation (SITE) Pro&ram Technology
Profiles. Seventh Edition. USEPA, 1994 EPA/540/R-94/526.
11. Ihermal Desorption. Volume 6 of the series "Innovative Site Remediation
Technology". USEPA, 1993. EPA/542/B-93/011.
12. VISITT 3.0, USEPA, 1994. DOS-compatible database.
0
13. Alperin, E. S. and Fox, R. D., 1993. "Soils, Removal of Toxics" in Volume 51 of
the Encyclopedia of Chemical Processing and Design, (Mcketta, J. and Weismantel,
G, eds.) Marcel Dekker.
Innovative Treatment Technologies: Annual Status Report. Sixth Edition. USEPA,
1994. EPA/542/R-94/005.
-~T BY:Kfnko's Coples ; 6-20-95 :11:18PM Klnko's Durham 1~ 919 715 3605:#17/17
GJ
GENERAL RECOMMENDATIONS
t. That the Joint Working Group consider the possible advantages, both teclmical
and economic, of a "treatment train" for remediation of landfill soil. (Base
Catalyzed Dechlorination, as currently implemented, I& already an example of a
treatment train: thermal desorption followed by BCD in a liquid tank reactor. This
report describes other technologies, such as soil washing or solvent extraction,
whdh could remove PCB's and other halogenated contaminants from the soil-or
a>ncentrate them in a smaller &Oil fraction-and make them available for
detoxification with a dehalogenation technology).
2. 'That the Working Group arrange to contract with pilot &tudy vendors for all
innovative technologies being considered for inclusion in a treatm~t train. Except
for incineration, all of the technologies discussed in this report are considered
innovative by HP A, but have been demonstrated sufficiently to be considered for full
scale remediation at sites where they can be pilot-tested for effectiveness.
Incineration, on the other hand, ls considered a oonventional method, and has
been so widely used that a pilot study would not generally be rcrommended, but
could still be used as a "back-up" method if a BCD pilot were not successful. With
the data that we have in hand for BCD's effectiveness on PCB's and dioxins,
however, there is good reason for optimism regarding the outcome of a pilot study
at the Warren County site. The other principle alternative to BCD for detoxification
is a glycolate dehalogenation process, such as APEG, somewhat more expensive and
sometimes yielding solids that are not structurally stable enough for on-site
backfilling.
3. That the Div. of Solid Waste Manage continue to share research-scale samples of
the landfill contents for bioremediation studies wherever this does not compromise
the safety of groundwater or interfere with any pilot studies or other remedial work
at the landfill. Based on results to date on pilot to full scale in-situ or ex-situ
bioremediation projects involving PCB or dioxin-contaminated soils and sediments,
I do not feel that incurring substantial state expense for a pilot study, with the
expectation of rapid (less than 1 year) and effective detoxification, is merited at this
site.
Assistance to the research community, which oould benefit all persons and
ecosystems impacted by PCB contamination, might even include an on-site pilot
study of in-situ or slurry phase bioremediation, provided that a) it is acceptable to
the community, b) it does not interfere in any way with mntracted pilot studies or
any other remediation activities at the site and c) the NC DSWM and an
independent environmental engineer retained by the Working Group determine
that the design for the bioremediation pilot is sufficiently contained to prevent any
releases to air, surface soil, ground or surface waters. If the bioremediation pilot
study is mmpleted within the time allotted for contracted pilot studies ind _
demonstrates effective detoxification of landfill contents as judged by the same
aiteria as other methods, it should then be re-evaluated for full-scale remediation,
dependent on community acceptance.
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PR.ELIMINAllY DETOXDlCATION TECHNOLOGY ASSESSMENT
i .. _:'
WredesdfD
to
Wurm c.ouniy Pel' l•dfflJ WOl'km.l Group
Sod s. Hinclallom, lcitDcc AcM,or
Madi 7, 1996
11l• oommarcia1 devllopmmt of NIDld1atiml teQlmolop1 hat prop111d rapidly during
the put decade, 111cl amce early clcciliona were made that there wore no acceptable aherutivea to
ladStins the PCB wa•ta ill Wnnm CoUD.ty. Tile pmpo,o of tlm -1yaia i1 to review the
Cllln'Cllt ~ o(~ l&d objective■ ngardiDa the ue of cteto,d!cation tedmology for
the Warrctl County PCB I MMffitJ It aeema that ba.d 11pon previous work cbcrc ia • general view
among Wormg Group member, dw BCD clecMormatioa teolmology is the prdmod tcdmoloSY
and that two complllies will COAduct onsne 6eld clemoastntiou of their forms of the t.abnolo1Y
duriag the cumntly fimdcd projCQL
'nlere are two ,..aon•'ble quesrians to couider.
I) Are tbere other tedmoloJics dlat may o8'er net a.dvmtagea ova BCD dec:lilminatioJL in terms
of etfccdvcneas. safety or COit ad, therefore, tbat merit tome level of cqJJrioflion or tating?
2) Ia the pl.an to field test rwo dltfer1111 &nm of tha came teclm.ololY a wiN, neoeauy ad coa-
eft'eotiva approach?
Each of thcac questions will be examh>P.t:l to encouraae a thO\llbtfiil discuarion by tbe
Working Group . Also, a alternative atntegy is pretcmted for movjq forward with tcchu.ology
evaluation and aecuring fimd.mg £or actual ~~. Tu alternative ltntegy ii believed to oJfer a
number of advantqa over the am·~man and merits serious ooncideration 1,y the Working
Group.
Con1nt.111•Jaavt:1
Th1: use of tho term detoxi6.catiou teclmology iq,ties that teclmolosiea that are oouidered
deanup teclmolo&ics but tJu.t do not by themae.lvea detoxify PCBs ate 11ot appropriate for the
Warren Couty s.itoation. Tbis position is very imponant, becauu one of tht ueu of
considerable deve1opmcut hu been aq,uation tccheologies. These remove toxic COlltaminants
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ti-om IOit or other media, oancmtrate them to a~ amaJlcr volume, •d dt.ee. thoae are uually
,ent oft"site for aabtequent dilposal or lnl1mall. 'J1lia approach bu been med for PCB cleanup•
and mmy odaer types. For IXlmpla, tluirma1 cleao!ptm. aoJvalt n:tragtion_, aai1 walhina, ad IOi1
vtpor mnctioa hive aceiYed oamiderahle q,pmt. About 75% of dlump• other Chan thole
based oa COIM:IIDQIW lmd cU,pow'c:cmtammeat, iDcinenlioD., or ltll,iliaticmlaolidifiolriaa uv•
ueed Mparatioll ieclmo\oglel. In many cuai, Nptndoe tedmolopt offer lipiflont coat
1dvanta1ea •d tlm e,cpluu ny tu)' are acmnall)' uaecS.
Souwtirue8-wlkcrc CIMJ'OIIJDOGta1jultioe ilaae& b.ave ,-faced, comnmfti"rt llave take tle
-~-,.;Ii: ,. po~ that clclmlf" ahauld aot impoael,mdcma tm olbm'~ 11lia ~4• to a ·,> ·~ ~ > pRtereace io a_wid concmcrated toxic waaea beinJ llllt ollhe tor flaal 4!-f~~~~!.~ /('. P
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ii that me wastes will be KDt to OOIIIIIII.Ulitis that have a1na4y been placed at risk be"u• of ) ~ 1
lmardoua waste dilpoul o, tnatmlnt facilities. Hov.'IYfl', this poskion ia not compl'1e1y valid, J~t,AI-• -,cf;
because it is podle to require that .final dilpa&itioa of wastes be at a f&oility that ii iD. • r-t A.-.
COIM:'tUllky ~ere eaviromnentalj\dtice iwes 1re aot reltvmt. That ii, there arc oommmcially L ~~
l\'ailable ad permitted facilities ia place, wlacre the local community wanted th• oparatiml and 7 / .IA~
where poor, minorit)· people me not a~ factor. 1.,,,J,""--I d
--· This Scieocc Advisor assumes that the Working Oroup still 'believe, dw cm1y a ouite
detoxification teohDology thou.Id be \lied. Tbcrcf'ort, there wm be 110 aulyu of either separation
., technologies that have been widely used for PCB cbuups, nor will CQIMlltional lllld
di1po..Vecmtaimnco.t~ irlcillenucm, or 11abilmtioD/tolidi6Cltion be consldere4. Howsvc, it
ahou1cl be noted that at IOme point in the futtnt if md \\laa a cue ii made for mm, a
detoxification tcc:bnolol)', other panies may raise quettiona Ngardmg tile u,e of either acparatiou
or oonvcnti011at technoloai,N ad may aNClt 1bat one or moro of thceo wouJd o& c-,.t or other
advantagci. ID particular, wit.• a Jarge amoWlt of mcmey ia 1equest6d for Atll scale aae of•
· detomlcation tecbnolol)', ltatc o1Bciali may quution whedacr tllcrc arc other lower colt
teclmolops that abould be CODlidend. It is most likely that actual c1canup oost buod OD. onsitc
deto,cificatiOQ ~tl be It lea• $20 mitlio1l, and pemaps .;pmcaAtly more1 dep•dm1 on exaotly
how lm\Ch material will be treated. I
Thia does not mean dlat tho Working Oroup lhowd DeOOMUily abuadon it1 preference tor
&&ting on.sit• detoxification tec!mololY, but it does auaest the need to pay attention to two dlingi.
First, all iedmi~ &aatbl• dttoxmcatioD ted:mo.logies mould be fairly consiclcrcd aa.d paying
-attcutioa. to cost i1 appropriate. Second, It tome point ~e pN:fa-red ddoxuication technology
must be aialyzed in oompariaon to ac:paration and conwzmonal teclmologies to make the best,
supportable caae for politioal aupport of a hi&h ~• cleanup. Anyone oppoled to apenctiq a larae
· 1Assumtng 40,00o tcm1, a flgunllled by Gae state. m4 a total gost ors,oo per ioa,
covering deto>d.ficatiou and all other cleanup cost, yields $20 million. 11l.i.s author's oondderable
e,cpcrience with coats of 0Jeanup111 baled on ttea1UIC:D.t t~oJogjcs indicates that an aggregate
cost ofSSOO pc ton is a very appropriate co• to uce at this time; thii 001t would cover all
,pending on the actual oJeanup.
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mm of money m I dctoxmoation clNDup onld MID)· ob&aiD elm for a cll•p• cleanup
allemativt. 2
Abcum• Pe&oxffla#oo Tedmcla&«a ·
ICP Pmbleriaedon While k is ooJ'NQC u BCD 'Cedmolol)' 1w pmecl mcreasina
acccptu.oc, after )W'S of re er s ,...ll ad ~mant at EP~ it di ia • tedlaololY with lbaited
c,q,erimoe in fhll.scale deaaup applicadou for PCBs 111d limilar dilomatcd chemicals. A reomt
.i~i.i:~·-_,i, -~=~~~~o::::i~-==l~~~~ology
. . · had bee.a eelected m oaly three Qtcs out of I total of 291 taDavattve tedmologyapp'lioauoni .
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-There llave also bem other applicatioDa at aoa.-Supcrfimd liles. Althoup BCD is only ooe fonn
of diemi.cal dedalorinatioll. u ua become ~e prM41i11Ylt form.
· A 1995 GAO report concladed: .. It is an efficient. telarively inexpensive treatment prooeu
for PCB, md ptUari1Jty capable of treating PCBa at vimially any coaceatrado11. ...P»ld data OD
the performance u4 cost of BCD for PCB, and clioxm are very limltecl.-' In thia 111thor'1
profeNiolial opmion. die mo• lignfficant teclmic.al irme h BCD is the ocmtlol of toxio air
llmlliona and dac pollibk aeed to trMt other wutettreama, much mor. to than th• ability 10
destroy coorurriouta ad reach striqait clcaup audards. Suppo.rtma du view aro conchuionJ
· an BCD in a recent stud>' by the Congreuional OfBc:e ottedmology A&aeament: "ne reaction
· b)PJ'Oducts in trMted 10i1 bve not been well clw-aoterimd. ..• The eftlciaDcy iD fmDOWlS
cantamin~t& &om 1he off gaw i1 not W.U bown. Washwater used to dNn tile IOila after
~t will contain trace& of ccmtamio•nr~ ad process dlemi,w, acl may also Mquire
treatment.•• . · . · ·
. · 2There 1w been • drainatic tiwld ill recaat years for both feel~ Superfimd lbal and 1tate
deanup litca nationwide to uao low colt remediet, typically baled oa conttiDDlO't. rather than
tr~tmeDt optiona. la this case, o!iite disposal or use of ,eparltion technology with otiite
h.t7:,&r~oua Nlli.due dilpolll might very well be lipiflcaatly lower cost thaal onatc detoxification .
. 11tSupediwl·-Uae oflmlovatm Tedulologies b Site Cleanups,• Doc. 199S, GAOIT-
llCED-96-4 5.. · · ..
.. Superftmd -EPA Jw ldcatmtd Limited Alternatives to ln~illcraticm for Cleaning up
PC_B aad Dioxin Coowmnation.• Dec. 1995, GAOlllCED-96-13.
'"'Cleamng Up Contamin.ated Wood-Treating Sit~• Sept. 1995, OTA-BP-.ENV-164.
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A NQlllt EPA atudy o(tecimology decsiont at Supll'fimd ri1J pl'O\'id8d the foDowiD.g
-nltvaat Wbnmtioa about the ue of~ lldmoloJY:
-Ill lhldios ra1alcd to FY91 a4 F'i92 .Niaou, 4ochloriDation. WU ttettabillty teaed
ODOe, acl tut WU 1llt.lD008la6al
-For tbia aa pc:riocl, declllorimlticm was couidered in 50 caeoa, and ..i.cted ill three.
Otha dWI &olon related to IIDIUitable lite eoattmm~ the most commGll tealOft& for
tlimfflmna ~ wu hip DOit, the need for tnatabDily ltUdiel, potemial to form more
:; ,. : 1._; t ~<:~f1 ~ ~: 1,y~ and die ue4 ~ pa-aeatmad • di,posal 1readualc ___ · _
. -Prom 1982-1992, ~ had Hiil lUCltd 1!vc times, bui'ifa tbrce GUeltb.e .
cleciliona were later c1aaqed md dl&rmt dNaup wdmolopt uttd. ID thoac t1aree cases. the
liles ~ ~od wish PClb.
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-EPA lli4: "Facton aft'eettng tbe decilioas to replace at.ohlorinatioa include the Jar1e
. volwnel of d"blotklation tclidual• that required iuther treatmmt/di,posal, oo• of o5-llile
trearment/diapoul, ufety ~cau relatiq to .banclling u.zardous matcriak, ooll ofreagenu, low
p.-oductiou rat-, leaduna of'nlid111J reagmt from uated IOi1, 111d o&uivc odor problom&."
.. To ba fair, it should be Ji.oted tut m molt of the cues conlidcircd by EPA, clecbJomation
was probably baud oa the wty forms of the t.cbolo1Y (j,c., KPEG md APEO) ad Rot BCD.
But the general equipment waa probably about the w as tut uud &oday with BCD, boc11•te
the majo.-clif:FereD" is the reagenu uei. Mao.y ottlle iales. thcemre, may be valid for BCD .
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· EPA ha& also maed awctnw tor eondncma ttutabi1ity tests for clecblormabon
technology.' Perhaps tu most imporwrt pat oftld& doeummt ii its preaartation of the different
levels oftcAing apptopriatc for making deciliona about tile tecbnology. The EPA bmework is
oori-ect and is based 011 three levels of iesang: teclmology scremmg to determine potential
. feuibility. technology IClcotion to develop pcrfonnanee ad colt data. and testing to 6btaill more
-. , .. detailed data aad ocmmm pffl'ormance. For the Wmen County lituati®~ wbero the site
· · · ccnsttnrinant COlld.idoll ii not complex (i.e., dim is aemtially one chemical type that one
tedtaotogy can 11.aadle) and camlderable in.ft\"Ndon aJrea4y cwts OD how IOIDO teclmologiea
· treat PCBs, the 1CTeenmg and •t.ction decu.ou do not require aasite or 6dd teariua, In fact.
EPA uid that acreca.iD.I temq of thia teclmology "will senm.lly not be required when PCBa or
4io,dn1 are the OO!Jfamioanrs of concan. • Testing ill laboratory or bench·ICale or full acale
oqwpment at a ~or's ~ can ht used for ae1ec:ucm ueatability tclliag. Ill the £PA
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"'Pcalibility Study Aualyail, Volume I: Pindiqa md Ana1yai&," 2PA-S.t2-X-9S-OOt. May
199-'.
'"Ow.de ror Coll.ducting Trcatabllty Stu& Under CERCLA -Chemical DchaJoacm.ltion."
EPA/!40/R.•92/0lla. Ma)' 1992.
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framowork, the third level of testing ii during JaDDdy iq)lemcmtadon m4 .dm a legally bbting
4ed.lion is made t,y die govemmc:at to -ate"• aelectecl tcdmology md &md the C'Jelmlp. 'Ibis
le\-el of tcaa cSc6nxely requea the UIC of &n .. equi:pmmt an.d tilt trrina of ,qnifloor .
qntntttiec afmatcri&Js '° aDaw all tile aeoeuay 4.called elm to be obtaiud. M«-OVer, h tbia
third level of taring, EPA bu ancticmed tu pncdce of•pnquaBfyiag• oat OC' m.ote vadort
l,wcl OJl the reaalts ,roclaoecl during llrJ ~ tnaU1mity teldng at the Nlecaaa liava1..
. BioJosk,aJ l'Parnwnt For llllll)' years various Corm, of'bicmeatlw1t have bem pm.ad
~,;.i-:,.:~ . : . -~ aJamupa. I& the opiaim ofthi• Sdmoe Advilar, ldotrutmat k ~ot y11t proven e&ouve
· ~:·:I -"-· :::$ •~"1iabte en.c>up fbr use ebber' •••ta sltv or ex • teclmology, m •er!~-~-~-~~~~ f'mn
en: ,omo oomlrinatioD of them, fOT the Wamu COUDty applicatioD. While there ii no doubt dlat
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lipificast biodeandtrinn of ane PCB ~m oocm• under various OODditkms. • tightly and
reliabty ommoDed form ·otbioueatmart &om an c.ameam1 pa~ ii not yet proven foT full
l0Ale oommeroial uae.
Jn-sftu Yitrificatjoo Tim tcdmology la.a, -=a. 1111.dw ~ development tor may
years, ahWly withm the DOE l)'llflm. While 101D1C people have viewed t1ut tedmoloay u a
variallt of incmeration. midly becm1• it anp1oy1 very hip teq)eratmea, it uually • conliderod
u a unique technology. Buried wastes can be heated to Jmll all materials and form a vitttious or
. pssy material The pr~ tbmm!1y deJtroya orglllic OOl'tamioeatc tad an cxtm&iYc off 1u, air
pollution QOl\trot syttem ia med. latcreatmsJy. iD October 1995 EPA Jw grnted Geosafe a
National TSCA ()paa1iDJ Pctmit for the U1ionwidc troaunmt of PC81 within a large number of
·prescn"bed circn,rcv,tltloes,_i:nchMtmg maximmn average con.oattrltiosl1 of 14,700 ppm. and
maximum bat apot COAcatrations of 11,8~ ppm. TIM oompay obtained tma replato:ry permit
on the basis or a silo demon.sh'atlon dJat achie\,ed variou.s performance criteria, mcludm& £ix DDLH
dcsttu«ion md removal cf&inoy and leu than 2 ppm pCBs in viuifiod product. No det~able
diox:ill'tluan1 were mund in off paes. But the demonstration was aot on in aitu waae, amilaf to
the Warrm CoLlDty aitultion. nm teclmolo&Y milt be c.oasido:red deto,cificawm, ad it offers the
~ar•tM advantage of'baing intrinaically app&abit for in aitu tnatmmt, avoiding the need for
excavatkm of'materlals. In theory, the Uldmology could be 1pphd. dirfflJy to the Wurm County
Laridfi~ perhaps wkhm dewatering the me, although the lite'• location would pou llglri6cant
problem for um1 the extmJM eqq,mmt .
ECO LOGIC Gu Phau Ch,rniS&l lo4vsion TILi5 technolo1Y has bcm tested wUhm
EPA~• SITE program OG material, conwnilaa PCB, m 1992, and tedmio-1 fea11.1,iluy and aafety
we.re demoutrated; it ha■ alao been demontttated ia Cu.ada, een the wndor ia iocated. The
proceu operates in a hydrogen rich atmoaphere ad iD the absence of oxygen, vfrtuall)' prevemmg
the formation of clioxiDIJfurau u side products. ne ttclmology wa, improved after the EPA
test md now inoatp<>ratcs au improved design in its first suge where OODfanrintnt, an desorbed
from soil. m a heated baD mill A commerml unit ca treat ftom 100 to 3 00 ton, per day of
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contaminated toil. One 111\il 1IDit hu beea vsed ill a~ projeot and odler uit is to be
UMd by Gmen1 Motora eel IDOtlMr' compmy m Caaada.
ldc(Coqyrativt Alab'tia ID oonderiDa tu reqml'llllllmtl oftla• Warrm Cowlty IDcllll
cleanup it it dear the BCD teclmoJosy tn fact merits major attellticm. Ou can nde out
biotreatmeDI on tbc bui, of iDlufflckm pn1VC11 efl'ecdvcocsa, a4 probably iD altv 'Wlri&oatiOID Oil
th& basis of iudldmt AiD IClle appli.oadcm. Tl• other problem with ill atu vitti.ficatiOD. u tut
there ia ao limp• or coa-efreodvt way &o 1Cll the tealmololY D' ill Iii.tu w at Wmm CountY-It
.· . zl~;. , i ii~-libly to bt mncll man_ CXJM!DIM lblll B~. Tb.e ECO LOGIC proces5, lao~, ~ ~ · •. -· · be 6zrintted from oouidcrltimL It's ~nnerataliMMA bas i>cuaed OD PCD~ .. a.ti~J!.aa
· '1D), oomme:r•rietitd. From. an en\'ironmaltal pmpc<:tlve ii far len likely than BCD to pose
problana Mil. ngad to to,ck air ~ TIie ooq,aay ha1 mobile equipm=t that CCNld be
telled and u,ed at tht todftll It probably ii'°• oompttitive Mh BCD. Tlmcfon, if the Worma Oroap wu to Rmiilil1 OOUIIDitted to .bave 6eld demoutratiou of cle&oxi&aticm
technology .in the aear term, then it ii ncommeoded Git it would be more bmdici&l to 00DSidor
uvmg OJle BCD wndor ad ECO LOOtC ~ tats than to htve two BCD veaclors nm ldt.
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: fo • • F.ie14 teltiq in pilot or 1bD tcalc eq,aipmmt bas been widely med in the toxki waste site
\ ':?-. •. · . . _manup area. But it ii iq,mwi1 to undmuzd tll• n&SOllS wby this iuummlly dcme. There are
· --~ . . · . two primary reuans for 11cJd dcmoutration,. Bra, ill m cue, the umre of tht mmctial
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.. · · · 1edmology mous that tb.ere aro lip.ifiolnt f'adon that an loc:atioD apocific which atrect the
. •: pafomwaoe of the tedmoloay. Olwiausty, any type of in situ tedmoloSY m111t be provm
··· · eftective at a apeciBc locsticm. ne core iuue ill these cues ii ~ether the tedmology is
cffoctive. But for tn1Uut111t iedmologin £or wtuch. e,coavated matwll are tilt mput1, it i1 not
• ,· _loeationchathofcaaoem.
Instead, the issue is whothcr the teebnology ta dfectivc on the ,pod&~ waaw &om the
·· · · location .. Thia can be and umalty ia detetmined by tClltioa ao wute wilh bench scale toclmology
1D the vadol'a f.&cility or m 10m1 caaea ill pilot or fbJl scale cquipmmt that ii IYlilable cidic:r-at
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. · the vendor'& home location or at aome other locmOA where 1he •qujpment ui opentma. 1be tcm
· trcatability tett n::lcra to thil lcind ol'tettiog to d~ pedbrmsnoe c,r e&c.tiveaesa for a
particular waate, ~ it ii not ouite field telling.
Soeoed., 6elcl tesdng itaormally done dlt a wrador ii ~cd a, the fint lllop prior to
u11m1 fW1 tcale teeluaology at maxitnum productioa (woupput) levels for the equipmait at a aite.
Demonstration, trial, or test ac:dvities at a lite are done to verify that an previous cmu:Joliou
about wacto apocific eff6ctiwnea and technology/equipment Nfety 1Dd cmW'ODIDCIIJta1
per.fo~ are fully met u.d, if appropriate, that regulatory requiremeab .,.. -.idled. Unleaa
-very d~ tpeeifioatfo:H are met, the vendor Qan 111d should lose tile job, although normal)y the
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vendor may be pva,. more thlD ant try• IIIMtiaa tu apeos. 0.oe ill a while a vador &ila to
pa• tbc ouite t• ad either aodNr vador ii IOllpt or a di&rmt rane4ial teclmolo1Y
canlidered.
AJJY field telt OF dmltrlDml ia apmatve, -mcly NO&UIC or OOlll UIOQUN with
operatina eqaipmmt, la a1ao l!«wase oftlae mbl&aDtia1 ooltl of lDCMIII equipmmt to a location
and aeumg II up tbere. If• em,.1ogy ad vmdor M1eetioca om bt doll• lasfm:c field tams, tt ii
aormal pr:ac:doe to do IO. Mon. importamly, ii a leld demonstration 11 elem• before a omt@iCnMt
. is made 10 a veadot for actual lbc claaup, dim lbe COstS are ~ bipc, blCIDIC tu
i.;., -~ou ii that all the eqaipmmt w111 b.avt 10 be nmoved from. 11lt .. de comp;lttion ot
> ihe6e~ teat. -.;i~--:-.~~.;. . ..-.:
The siNatiou for the Wanen Comity IDd.Sll is that my mid ~(•) will be doac
before there ii u.y mm ~tml!'lllt by govemma.t aa-cics to fun4 the cleanup IIMl before a
vador cm be ocmuac:t-4 to per.form the &II acate cle&llup. nua, oom will be high (becaue
eqwpDMm will have to be moved to the lite ewe) and the riab &om the veadora perapecdve are
maximwD.. meaning that the vcdor will WUt to NCa\C all fWd damoDltntion COit&. 11>.c
unc.ertaintles of mm1ey, ldlednlc 11 wdl II vendor ~ combine to mean that when the
uncertdntiM are removed, my panieubr vendor, even anc 1hat hat snccessmlly comp~ed • field
demon•r•don, may •ot get the job.
Moreover, for die Wmm County landfill applioaticm., there rully l$ D.O location speQiflc
amCCSWIWN to be resotwd for any dctoxi&aticm tedmolol)' buccl OD tlellting e,ccavated
ma,eriala. Tnmbility tuU llaowd be 11-1 u, vcity performaAoc ud ~ea for landfill
wastes, and clew.Jed tteatability •-report• uould be produced to document tett r11uJ11 to
,uppolt the technology Nlectiou (the aeOOlad le\ret m EPA', &amwork).
for Warraa Comity, 1hc main l'CUOD fiJr couucting a &old demoa.stJttion of
detomcation ieQbnoloay wi1hill the cumnt eva!umon project ICCDlli to be to raise the comfon
... level of ~oming dtizc:Da about the tedmology llld, p&tticulady, about its suet)' for the
~. Tllis could be •ocomplitbecl at coadderal,ly lower co• 1,y briDpg the people to the
techlaotogy rather than ill• ttebnolol)' to t:b• ,-pie, howaver.
BCQ YcP4om A nasoublc qucsao.o. to ask ts whetb« It ll aeceuuy or coa-dl'fflivc to
have more than ou lite deaoutnticm ofBCD. It ii tJua Scienoe Adwol't polhion that it it
Dcither n.ccesary or cosi-cfl'cc:tlve. Any BCD vador mould be wdb!ly waluatcd on the basi&
· af all l'fl\'ioua testil.g IDd tbJl scale uae. No vendor lhould be aaed to perform a lite
demonltration if there an Krious umeaolvccl isales or if the vendor ii oot compar&ble to another
that ii deemed to be tu belt available cme.
lf'two BCD wndon ped'orm lite demoutratiou a.cl meet .n performu.ce nquiremcm1,
then the main benefit o~amed ft-om th• eo:neiderabte costa is that Workma Group members
achieve a eawn comfon level with the vendors. Selecting one of diem still requires a careful
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..al)'lia or elm, 1LOt only tu data 6-om. •e tett, belt al othe!' iD.6,nDltlo!l 11 ,wn, 0Al)' the most
wibl)' earegiou, 1llllibl)' beuvtor 1ry WDlbra would CID#~ to ... aome actMry at the
lite that mi.pt bo beapretcd u mlJlfe or lloppy. But nearly eva)'thbag of importlDce rNtl on
data. To.is athota cxpcriaK,e illdkaica that the co• ofa lite dlmoAICnltim tor BCD at Wlffll1
County"wftl prol,al,1y be at INtt S200,000, amt pcnapa c1o ... to S300,000 whm an eoa, are
accounc,d for.1 · n.c core ilmo ii uether oac ocnild ab a~ l>Uod oo avaBable
iDfonmtiaD dl&t 1bere ii ou a1eu "belt• BCD WD4or or wlaedacr two ue ooq,arable.
The Workina Group &lloald allo appreolltc dat tlObnictJ rcaliry that a limited &old tOlt
.;.tuocl OD treat-, a relattvcly DID amomat of ocnatamiuled matcri&l it aot ~ely to p1ocluce
,.-~, ldiabJe data to dcdia.idYely lRIW'a' iq,Oltlllt quelt.iont, -s,~ ones abo1u ~ ur -..lou IILd lmteriau handling probJMn&. ·· L•~--, .. ,__.. ____ ·
The auwer to dus cp..-«ioll depen4t on. the criteria uMd to fflluai. the mformatio&l on
dae vendort, blu this b norm,J tacbnology ,...,__, A tWlbla Mt of evaluation criteria
oou14be:
-ffJrrtimacy· weight of mdcn.cc .for dcc:tivalcu on af'ely deltTOyina 'PCBs aad INMmg
aringalt deallp ,tandll'd&
-Sefv: apogifi; m!ormation on COlltroID, tll \tt>UtellrellDI, particularly w eariuion,, 111d
IDNm8 replatory r.qlm'amllltl
-OmmmsW ,;oed;p,cc· prove experienu with W aGalt equipment tor elcaain8 tip 11tc:a
(particularly the tpecifie eqwpmem wt would be UMd in W lffl:D County), .epecially PCB aitea,
and availabil:icy or equ.ipmmt for actual Warren County cleanup
-Busiocaa pa:fmm,ngc; expe:rimc.c chat climts bavc had wkh. • vcador, ill term, of reliability,
schedules, eatimatea. reswatmy compliance, and prevmtion ad reaoluticm. oftcdmi~
, ~ aad 111.1.!l&gedal problems
•-co.L h'b!y coat, 111d tbelr uacenaiatiea
The oclcb are that ane BCD VCD.dor will surface H taperior oe tb balia ot a total ~ for
alJ ev&Juatioa criteria. TbJ.s author has previously evallwecl the two vmdon cwrmtly oOD.&ideftd
aa poteati,.1 teclmolo1Y daDOllalr•tors ad more recently baa apoken to botb compuie, aa well as
~ 1evd of colt is comi.ltent wid>. BPA'• tgures, whidl is that a level two rtmedy
selection trembllity i.•. narmaUy a laboratoiy type tut, typlca!y eo•• between s~o.ooo and
Sl00,000. EPA d~noccl the cost f'or remody telection teating as moderate and for R!lledial
aotioa.uhigh.
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An 4lwutivc 5travc>' for tlac Wan:n CMDO' 4nclftD S1CP•Uo,
TIie Nie p...-pote •f p1111atiaa Qil a1tanadv1 nrater' ii to .trw tile WCll'kiD&
Croap an optloa that 1w die potadal for uddyiaa dleir primary 10.i. aamel)' obtalatn1
die mo1t effecdve and nf•t cletodludoD ef dle laadfll widlout tardier leagday ddaya.
The real objcotivc ii aot tutina tecimoloJY INt ill uling tu• l>O"''l>le clean\lp tcdmology to _ .. _)•~•·:: .. :;7~co:.=·.=-11aeeJWn~IUatll)'dNCdbtdlllftia,.;s'M41't _~~A·• ~~ ' ,. . .. ·-• .. ~-., ..,iJ .... __ .,.. _______ .._......,.. .... ; ..
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With thit abmativo strategy, ~atioe tedmologi.N a4 vmdon would be
oonlidered and carefblly O"Va!uatcd on the balil of aD l\'ailable ~ panicularly from mil
ICllc applioation&, tnd tllm a lhott lilt of' vendon would be detamilled. followed by u.tal>Uity
te•a aad prunmg otdlt lhon la. Working Grt,up m n!Nrl could~ the pla~ ~.n
watabiJity tNting oa Warrm Comaty Lad.Sll wutet wa1 perfonned.10 Vendors adaieviq
ecccJ1eDt treatabllily tea resuh1 WOll14 tbm be asked to provide an opportunity Cor a ponp of
people to vilil a 0peratm,g faD scale &cility.11 Wor.tiaa Group membera could apaad one or two
days at tile Ike, u DCCCIIIIY·
From tho• vmdon that,_.... th• mf'ormation ad Ike wk nqwnmant~ • clecilion
would be made ud the "belt" vador telected. For the sdoctcd vendor a aareen,ent wowd be
entered into so that the vmdor would be pre-quaHfied for flDa1 sclec:ticm. which would have t0
wait until fimdmg wu aec:ured &om the ltate tor the ICitDal dcaaup otthe landfill. The agreement
would also apedfythat tu vendor would laave to mMt ~ bl a Seid demoestration
prior to ming tile~ acaJa tqu)p.m.t at producdoo rate& at the Wmm County Jmdfill
'Thi, Scicm.ce Advisor a\lthored "Tcdm.ology Autssmemt -TrcatIXJmt Tcclm.ologiea for
PCB Contaminated Sodiment - A White Pap~ oo the H»dsoa P.i\w. PCB Cleenup." for Hllclson
lUv=r Sloop CLEAkWATu, Nov. 1994. Both gompama gmrmdy bciul OOlllidered Cor me
dcmonlitmion were evaluated. SoilTech received the Jnsbelt ntiD.g, while ETG tile lowc• nm
tight technologies that were couidered viable ( om of a total of 1 ◄ ). However, there were I01l1e
lite 19eclilc flctora OODlidered ill the analysla, ad the coJq>lllies have prosresMCI lin.oe tbe
aalylia wa, perfonnecl.
1°hl some reapecta, \.'isiting a oompany's facility, nwrina i15 personnel, ad duc:GlliDg
teat.mg md test reaak& may have more impact Oil a per10n', view of dae vcador cha ICdDa tome
aspect• of' a site demoalttatiOA.
nTa aome extent. a vm4or that doe& aot 1aave ay of it& eqwpmeDt in operation
aomewb.cre may be deemed lea desirable than one 1hat does. In tome cue&, a vendor could
operate 9e1uipment at ill O'Wll taollity to provide tile neoetaary oppommity.
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Currcndy available buta oow4 be uM4 to compewto the vmdor for time IIMI matmlk
ftOQCSP~ to IIJPPOlt an Woridag Group and -o ICtMtiel for flmtlizm1 the cbmup
Bpeci4ratian• wt odl• upec11 of~e mnedla' .....,,, ad _.,r:1ng poJmcal mpport ibr bl&g
the KitUal clNnup. IA otherwarcll. ~1 lumdred 6oum4 clollm wou'l4 be lpMll-OD what
would o.ormally l,e ,.. •• •eahntct1 con•:trina oa remedial delip rather dim Oil a fia1d teat
cluriD& the rmnnt projtet." l!lcorpon.tins a tec:lmology vaa4or in •c.-dial deli&n repwtl
ammt attempts 1o greatly !mptOVO tile proceu for doamins 11Jt Jauardoua web aite8. ''
W_. tlul ttratqy the ia,ue of obtaimaa pGliacll mpport fbr I dttoxi&catkm cleanup of
the lad.611 do.sirc4 by dt.c WortiD& Orcnap Is fOOQMd cm fba4ms aloDe, ~ an teebnalOI),
•Jeed~11. Do~ IO ICIIDOYel mk ad~ ad ft• iateatiouJ dlla~ ~i &olD
po~ or aovcrnmcnt&I Mdria niliDg qumau about Melmolo1Y, tllthei' Heaute tleyhavt
lcsitimatc teolmical rmoema, wat to &nd a chap• deump, or want to delay malcins a clcaa.on.
ls)aad, cht 1uim!O' ao&l oftho ema;nt st miPion Pmi@ II io ¥ks hgth srdm0JQO ad 1
ft)odfir vmdor: so t)urt the cm!¥ temabain1 Yelk' iw1, s, &oftina tm me uculJ dumao, •4 not
wbOlhac clMQup la PRWO' Ot PP hpw jt will he MIC, ID other words, '70fflll1tly available 1\mda
would be UICd to oouolidate dedaon·makin& oa dlt 6aat--.d of.the coiapln proceu nd
Nldllcc riab for lo.ger term fiihate ,o 1ocomplish dae fimdammtaJ 1oal of the Workiq Group.
namely the we aucl timely detomication of the 1andfill.
The evmNa1 danup baled oa aay d.a.o,dSoednn teolmololY wUl de:taitely OOlt S20
m.itlioa or p,rc. thiJ ltrategy would 1111m a.+ mfBi:imt mooay wa11pmt on ol,taiajq
information on all aJtmutivt tedmolopi1 (detodlcation., aepamion, ad convemuon.al), makmg
aa ummpeac:uble cau mr ill£ dclired i.cbaology ad "mdor. and on COUl)'lc:tc site ioveltipti011
and characterizatiOft that supporu actual remedial decign, inclwlma the ,pecification of amounu
and m,es of materials to be remedi•ted (Miich may man more teag of the lite).
Moll importamly, widl this alternative antcgy it ii pouible to develop a IODlld,
impre&dve ca,e for an ac.curate estimate of•~ cleanup colt, bccmue more effort 1' plaQcd on
remedw design ~hich also allOM ~ vendor (in conjunction with the llltc md the Sd.cacc
Advisors) to arrive at a finD eltimat_ed cost. W'nh the ourrent 11ntegy, obtaining political support
fot appropriadng $20 million or mon would bt difficult bcicaulC of questiou raised al,c,ut tb.e
11Anothe£ advantaac of1hil altcmativc antcJY is that it woul4 tiditate making 1he
decisiOA to remove exetM water 6-om the landfDl It aa earlier time; that ii, after a vmclor is
aoloQt.od £or the maia clMnup callk af decoxi&adcm ad duriDg 1b.a ournm projeQt.
•~ Sdaacc Advilor. fbr ~le, ii CWTmdy aeniq 11 a todmleaJ aclviaor for a
on~ p-oup Bvm1 near tile Marzont hpldmd lik m Georgia, ad where 1hc PP.Pi mad
EPA ue usmg a proce&& that aDowed a teolmolo&)-veador (tllermal desorption) to be sele«ed
early ccoqh to allow partioipatio.ll in remedial delip. The vcador will demonatme il&
eqwpmmt u tho .6nt ltep in the actual anaite clemup. A diffctcnt company had previon'1y
. performed • laboratory treatabilty test to suppon tho technology seleotioll decision.
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nliabilsy of oo• Mimatec.
TIie ldectcd WD4or would be &net.ct to a,pport dlieir iavolveaamtt wkll lite inwltiptiou
and mmcliat deaip athcrthla aappMt a iakial hid~ prio1 to wndM Mlecwm.
111.c NlcNited wndor would ave to ab a oaliiwi«u•r to make eqwpmmt available once
fimdina for the acwat oleu,ue wu wed &om tlMI .... Puadina tbr W acaaa1 01-lap would
iacJude fimdl for 1he ••• uiaJ demoalttldon pdor t0 AID ecale/prodocdola use of the equ.ipa,eo.t,
wlLich ii the unut p~ t,r claanup1 ioday. Na type ofpBot toatmg of 1Ublt&11tial
IIDlOlllltl oflauardoua material m fiaD-ICllt equlpmtllC IIIIWl)' lutt for a DV,llll,er of' days. Most
.. mip~, • aDowa couldcal>Je c1ata to be o'buined to Dtwer aD impc,1Unt ufcty 111d
~·--~ quMionc The &mir cu be 1111d down for a period of weeks to: allow. tbe 4ata to _bc
collected and ml)1zed. Al by porbmmce m411Cct)· mkcria would mc't;ooiipiMo\lil9 ..
eahliahecl. Upon ~on tbt all criteria have bom tally utilfiecl (1 proceu reqmring
e>etensive p1rticip1U.D11 by die Scimoe Advisors), tk vador would be 1Dowc4 to tnldate filD
procluctlon levcla of clctoxi&atiml ofl11uWl mataiall muter appropriate ov~ by the ate
ud tbe iai•ce Advilors.
With the cu:mmt atntegy, a v&dor that did • mcocafbl field teat before ibadlng was
_ Iffland 1Dd had to remow the eqmpmalt would llDt neceswily b~ equipmam available after
flmdmg WH M0Uffd for tile cleaaup.
fmally, t1:m strategy oft'ers a way to expedite obtamg polilical aapport for the (XUciaJ.
cllcaon, wJdch ii fimcffns of the actUJ cleanup, tot tedmology ovahaation. Any onaitc field
llemoutrmoa(s) will require COllJiclerable time to plan, concluct a.cl evaluate u coq,arcd to the
activities that would, Ulldcr the altcmative strategy, lacl to both teclmololY and vaulor aelection,
a, wc!l as rlliabk total clunup cost Nrimttl"a. 11aia Scimce Advi10r'1 e,q>eiaee indicate6 that a
lite deman.uation. by a vtm.dot will take 3 to S DIIOllths, iDcladina plammg. execution, ad report
preparation. Two •• demonttrttions would probably tab a total of 5 to 7 months wer the
most opdmistic coa.ctitions aMOciat~ with back to bac:k demoutratio.ns.
CONCLJJSJQN
In oompamtm to dat curra1 sraU9SY, tu alternative stratesY, ill tbk Sclmce Aclvilots
profeaional opmioa. would more likely resaJt .bl one succeadll attempt to obta.. 11•fficien1
fimctin1 ibr a dctoxm~tioa danup. 'Die cmphaliJ on VU)· cardd amaJym o! available
mlormatln OD vendors' experimee, and capaldlidea and cm ueatat>Dity teltills at tit.• vadora
location rather dwl field demoo.ltratiOG at tho lito ii todmicdy c:otT"Cd, becente their ia no
loead.OD. IJ)«D.Q upecu to detoxmoation tcdmotogy that treat, DRvated material•. Onlito fiold
4emonltration of the tedmotom• mould occur u the fint step of the actual clc111up. The main
reuon tbr fivormg tile a!temative ltt&tegy i8 that it would remlt ill a paobge of tldmicat 111.d
oconomic Jnfo11111tio1:1, ind:udiq c:qmeeriD1 detip md cost data, that would be tDOTe complete
aad impreaive ud, therefo~, more capable bf~· aecuring political anpport aad funding.
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nu. ia oapodaly imporwrt because the coll of a dctoxificatiAn clN!lup wm be mb1tatw, at s20
million or DION. n. .,.i o!pnpariq mc:h I pec,kap "to preempt ID)' atteq,t by UlY party to
make a cue tut IOmt other deaup approada cleter\,W more caali49ntion or o&r, techaical or
cocmomic advutag• dum the oae teleoted 1,y ~• Workias Group. · · ·
:,: ' .
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12
1-6-23-1996 3 : 53At 1 FROt-1 P. 4
Appendix for technology RFP
EXPLANATION OF SELECTION OF1WO DETOXIFICATION TECHNOLOGIES
A detailed technology screening, evaluation, assessment and comparative analysis has been
performed for the Warren County PCB Landfill. All but two treatment technologies were
screened out. Only Base Catalyzed Decomposition (BCD) and Gas Phase Chemical Reduction
teclmology were found to he appropriate and potentially feast'ble.
The origmal use of the tmn detoxification technology by the state ofNorth Carolina implies that
technologies that are considered cleanup or remedial technologjcs but that do not by themselves
detoxify PCBs are not appropriate for the Warren County situation. Potential feasibility has had
to be demonstrated through prior successful full scale use of a technology for PCB detoxification
work.
All forms of containment technology such as caps and subsurface barrier v.--alls have been ruled
out as being inappropriate.
All forms of separation technologies that do not actually detoxify through treatment have been
ruled out. These include, for example, thermal desorption, solvent extraction, soil washing, and
soil vapor e~"traction.
All forms of stabilization/solidification have been eliminated as :inappropriate, because they have
not been thoroughly proven to actually and permanently destroy PCB molecules, rendering them
permanently nontoxic.
Arry use of high temperature incineration has been ruled out as being inappropriate because of its
potential for causing harmful toxic air emissions and its long history of being deemed
unacceptable by commtmities, especially 'w.b.en used in locations close to residential areas.
AU fom1s ofbiotreatment or biorcmediation have been screened out on the basis of insufficient
proven effectiveness. For many years various forms of biotreatment have been pursued for PCB
cleanups. The conclusion has been reached that biotreatment is not yet proven effective and
reliable enough for full scale use either as an in situ or ex situ technology, in aerobic or anaerobic
form or some combination. of them, for the Warren County applicatio:u .
In situ vitrification has been screened out because of in.su.£6.cient full scale application. This
technology has been under extensive development for many years, chiefly within the DOE sy~em.
While some people have viewed this technology as a variant of incineration, chiefly because it
employs very high temperatures, it usually is considered as a unique technology. Buried wastes
can be heated to meh all materials and form a \-itreous or glassy material. The process thermally
destroys organic contaminants and an ex1ensive offgas, air pollution control system is used
Interestingly, in October 1995 EPA granted Geosafe a National TSCA Operating Permit for the
1
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6-23-1 996 3: SA.At 1 FR0t1 -.
nationwide treatment ofPCBs within a large number ofprescnoed circumstances, including
maximum average concentrations of 14,700 ppm an.d maximum hot spot concentrations of 17,860
ppm The company obtained this regulatory permit on the basis of a site demonstration that
achieved various performance criteria. including six nines demucrioD and removal efficiency and
Jess than 2 ppm PCBs in vitrified product. No detectable diox:ins/furaDs were found in offgases.
But the demonstration was not on in situ wastes similar to the Warren County situation. 1bis
technology must be considered detoxification, and it offers the comparative advantage of being
intrinsically applicable for in situ treatment, avoiding the need for excavation of materials. In
theory, the technology could be applied directly to the Warren County Landfill, perhaps without
clewatering the site, although the site's location would pose significant problem for usiDg the
extensive equipment. Th.e conclusion has been reached that this technology is not acceptable or
feasible for the Warren County application, and that it could not be suitably evaluated through
bench-scale testing.
Because the objective is to select a detoxification technology that has already been proven
effective for PCB detoxification through full scaJe, commercial use, an.d that will be demonstrated
effective for full scale application at the Warren County PCB Landfill on the basis of bench-scale
testing of site contaminated soils, no technology that has not yet been fuDy deployed in a full scale
detoxification of PCB wastes will be considered appropriate and potentially effective for this
application. No technology that exists only as a research or developmental technology is deemed
appropriate and potentially feaSiole for this application and, therefore, for bench-scale testing.
2
P.5
,
To:
From:
MACTECETG
Environmental Technology Group
MEMORANDUM
Dollie Burwell, Field Representative-Case Worker
Mike Kelly, NCDENR, Special Assistant Environmental, Div. Solid Waste
Pat Backus, NCDENR, PCB Landfill Project Manager
Rick Shoyer
Subject: Status Federal Funding Dollars Through EPA ORD
June 2, 2000 Date:
Mactec ETG and our affiliate companies, Pacific Environmental Services (PES) and
Environmental Science and Engineering (ES&E) have been networking with various
personnel within the EPA Office of Research and Development (ORD). The Cincinnati
ORD Laboratory is where the Base Catalyzed Decomposition (BCD) technology
originated. The Cincinnati Laboratory includes the National Risk Management Research
Laboratory, of which the Air Pollution Prevention and Control Division is located in
Research Triangle Park, North Carolina.
There maybe a possibility of obtaining federal funding for the Wanen County PCB
Landfill Detoxification and Redevelopment Project through the ORD. Rationales for our
assumptions are as follows:
1. The BCD technology has not been evaluated and tested at the full-scale
operation, as it will be in the Warren County PCB Landfill Detoxification
project. This will provide the EPA a chance to follow through on a
technology, which they spawned. Note: It my understanding that the Navy
PCB Quam BCD project was operated at approximately 1 ton per hour,
whereas, the system proposed for W airen County is designed for 15 tons per
hour.
2. The Quam project emphasized the BCD technology on contaminated soils,
whereas, the WaiTen County PCB project addresses not only soils, but also,
pond sediments and filter cake (produced in the process condensate treatment
system), and oils containing PCBs. To our knowledge, the PCB liquid
treatment system as designed for the Warren County PCB Landfill project has
never been demonstrated in the United States.
3. The Warren County PCB Landfill project has a significant air monitoring and
sampling program, which the Air Pollution Prevention and Control Division
located locally, in Research Triangle Park could participate and/or observe.
-Federal Funding Update-EPA ORD National Risk Management Research Laboratory
June 2, 2000
Page#2
4. In addition to PCBs, the Warren County PCB Landfill project also has a
dioxin component to the project, which could be of interest for the ORD Air
Pollution Prevention and Control Division.
5. By having the EPA ORD Air Pollution Prevention and Control Division
involved in the Warren County PCB Landfill project, this would provide a
opportunity for the EPA laboratory to be involved in a local project, and
support the local community.
6. For a "small" project cost contribution, the EPA ORD would be able to be
involved in the testing and evaluation of all phases of the BCD technology at
full-scale operations.
7. Politically, it would be beneficial for the EPA to alliance with the State to
jump-start the remediation phase of the project, and support the
environmental justice movement and local community.
To update you on our latest meeting with EPA ORD, Mactec ETG met with Mr. Frank
Princiotta, National Risk Management Research Laboratory, Director Air Pollution
Prevention and Control Division Wednesday, May 31 , 2000. Mr. Princiotta though
interested in the project and technology does not at the present time have any available
funds that he could use for this project. Presently, 90 percent of Mr. Princiotta' s budget
is dedicated to the in-house laboratory operations. He did say he would follow-up with
his counterpart, Mr. Robert A. Olexsey, Director Land Remediation and Pollution
Control Division which is part of the National Risk Management Research laboratory
located in Cincinnati, Ohio. Mactec ETG has contacts that know Mr. Olexsey, and we
will follow-up directly with Mr. Olexsey after Mr. Princiotta has had an opportunity to
prep Mr. Olexsey on the subject matter.
Mr. Princiotta did indicate that Mr. Tim Fields would be a key player in finding
additional federal funding that could be channeled towards this project. Willingness from
Mr. Robert Olexsey to participate in the project could assist Mr. Tim Fields in securing
federal funding.
We will keep you abreast of our progress on this matter. Any questions and suggestions
can be directed to my attention at ( 610) 941 9700, or e-mail at [e-mail].
CC: T. LiPuma, PES
B. Fitzpatrick, ESE
P. Campbell, Mactec
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
20301 MAIL SERVICE CENTER • RALEIGH, NC 27699-0301
JAMES B. HUNT JR.
GOVERNOR
The Honorable Carol M. Browner
Administrator
May 16, 2000
United States Environmental Protection Agency
1200 West Tower
401 M Street, SW
Washington, DC 20460
Dear Administrator Browner:
NC SCHOOLS
~Ffgf,f:
, -IN AM..£fl.lC.A. ·.:·
2 0 I 0
As you know, North Carolina has committed over $8,000,000 to detoxify the PCB
landfill in Warren County. The North Carolina General Assembly required that this money be
matched by some federal dollars in order to be released. We have utilized a full citizen
participation process in which the community has played a vital role in selecting the technology
and determining the use of the property once detoxification is completed.
At the encouragement of the citizens, the Legislature has endorsed the base catalyzed
decomposition detoxification process. This is a licensed EPA technology, however it has not yet
been used for a project of this scale. This is an ideal opportunity to pai1ner with the State of
North Carolina to use this EPA-approved technology. We believe that the detoxification project
in Warren County could be used as a model for other communities as they struggle to eliminate
hazardous materials from their environment and rebuild their communities.
Time is of the essence. It is critical that some federal matching funds be made available
immediately so that we can finalize our commitments to the Warren County Community. There
is also significant interest in this issue by some members in our Congressional delegation and
you should expect to hear from them soon.
My warmest personal regards.
Sincerely, ---....
•
James B. Hunt Jr.
JBH:lmr
LOCATION: 116 WEST JoNES STREET • RALEIGH, NC 27699-0301
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
20301 MAIL SERVICE CENTER • RALEIGH, NC 27699-0301
JAMES B. HUNT JR.
GOVERNOR
The Honorable Louis Caldera
Secretary of the Army
The Pentagon
Washington, DC 20310
Dear Secretary Caldera:
May 16, 2000
NC SCHOOLS
2 0 I 0
I am writing this letter to request your assistance on an issue of great importance to me. In the
late 1970s, several thousand gallons of Polychlorinated Bi-phenyls (PCBs) were illegally disposed by
spraying along approximately 210 111 iles of state roadways. PC B's were used extensively as transformer
fluids in the early 1970s prior to being outlawed in 1976. Of the 770 truckloads of contaminated material
placed in the Warren County PCB landfill, 10% of that material was from Ft. Bragg property. The
original cost of the landfill was $2 .95 million. The federal share consisted of $343,377 from the Dept. of
Defense; $2,163,021 from USEPA. The State's share was $445,779.
In 1982, I made a commitment to the people of Warren County that if appropriate and feasible
technology became avai I able, the State would explore detoxification of the landfi 11. In 1995, the State
appropriated $1 ,000,000 to study detoxification. We have utilized a full citizen participation process in
which the community has played a vital role in selecting the technology and determining the use of the
property once detoxification is completed. Since 1995, North Carolina has committed over $8,000,000 to
detoxify the PCB landfill in Warren County. The North Carolina General Assembly required that this
money be matched by an unspecified amount of federal dollars in order to be released.
The landfill was constructed to be a dry tomb facil ity. Approximately 1.5 million gallons of
water was estimated to be in the landfill and was required by US EPA to be pumped out. It is imperative
that we detoxify the landfill before it becomes a serious liability. Iain seeking the military's partnership
equivalent to 10% of the $16rnillion cost to detoxify the landfill which will eliminate the potential of
future liability for all parties
Time is of the essence. It is critical that some fed eral matching funds be made available
immediately so that we can finalize our commitments to the Warren County Community. There is als o
significant interest in this issue by some members in our Congressional delegation and you should expec t
to hear from them soon .
My warmest personal regards.
~--~ncerely,
•
James 8. Hunt Jr.
JBH :lmr
LOCATION: 116 WEST JoNES STREET• RALEIGH, NC 27699-0301
•11nl -!l.J -uu IIUl't 0•U.J VUIIU1 L..Vl1 VLfl l lVlt L/UI VI
EVA M_ CLAYTON
1ST 0tsr;,1~T. rJOIIN C,\~•lLINA
COMMITTEES;
AGRICULTURE
StJBCO"-J-..\lTt.£5:
01::r•.\,,r.vtNr OPt:1,ATllfN,. a,,,, "~•c;,-n-.
Nv1iUTl(lN, ,volO FontsrDy
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CONU:A'w'ATION, A.NCI C.:kt.Olr
([ongresz of tbc ~niteb ~taten
j!)ouse of .1Represcntatiues
Mlas~ington, t!l€ 20515-3301
BUOGtT
General Walter Slocombe
Under Secretary of Defense
Office of the Secretary
The Pentagon
Washington, D.C. 20301-1155
Dear General Slocombe:
May 12, 2000
I I 4 L
WASHINGTON OFFICE:
l-t.fO R"v,::.;11~ H~(;~ o,~1~E 81..''U>\.G
W.l!,!Wl"-iTO►f. oc 2051S
l'-02122$-3101
l:CIAy,on li!!'m•H.hau,e.gov
I wi sh to bring this cri lical issue to your attention and request the Department of Defense and/or
Army's assistance.
In the early l 970's, Warren County, North Carolina had 60,000 tons or 40,000 cubic yards of
polychlorinated biphenlys (PCB's) contaminated soil placed in a federally funded and state built
landfill. Most of these soils came from 200 miles of highway shoulders in 14 counties whkh had
been illegally dumped. However, ten percent (10%) of the contaminated soil came from Fo11
Bragg. (See attachment.)
In 1982 Governor Jim Hunt made a commitm~nt to the people of Warren County that if
appropriate and feasible technology became available, the state would explore detoxification of
the landfill. The detoxification process selected destroys the PCB molecule. Destniction of the
PCBs to non-toxic compounds \.vill eliminate further regulation of the site and permit unrestricted
future use.
In 1999 tbe General Assembly appropriated $1M and reserved an additional S7M to match
federal funds to detoxity the landfill. The state and community have worked with tbc EPA 10
enable the project to move forward in a phased-funding manner. The $7M appropriated cannot
be rd eased until the state receives some federal matching funds. The total estimated cost of the
detoxification project is $14-18 M. A ten percent (10%) share of the cost of detoxification for
The Department of Defense would be approximately $l.6M.
Warren County is an economically depressed community and has been designated as a Tier I
County for economic development.
orsTRl'Qi@fi~Fe.l Walter SloG(,mbe
v, .. ""E"' ConN,;.as Si ,,,,.r1N(, Ctr, r~"
Reure I, S:.i1r~ 7
Posr OHt((. 8rj) 610
N,-,Wi,•N,o1 NC I 7563
12S21 •S6•4800
f,,,: 175 21 •l,;c;.2,;11
DIS 7R/CT OFFICE:
.c.co M,.'-:-, ... LvriH: ~ t-:u.;.:.. ~--~:.•••f
Sv1r:. 1,)6
<3.:~=••11u ( !.c 21e2J
1'.!S-21 7~~.f.~ll'O
1-~oo-~-:-;-eo1;:
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vunu, L\ICI VLIII lU11 L/UI UI
General Walt~r Slocombe
Page 2
May 12, 2000
l f11\ l1Ut L-.1~1..JULVJ.l I• J...J
This malter is critical and ti.me sensitive because of the Governor's tenure and the: conditions
placed on the state dollars.
Please give this matter your urgent considerations. I am available via the telephone to further
discuss thjs ma.Her. Again, I thank you for your considerations on behalf of the citizens of
·wan~n Counly ~nd Nortl, Carolina.
EMC:dbb
l"IH y-1 j-uu l"IUl'l ti, uo vUl~u. C. V n vLn I I Ul1 U.J t VI ' '
SPECIFIC TO DEPARTMENT OF DEFENSE MATERIAL
• The total quantity of contaminated soil in the landfill is 40,000 cubic yards (or 60,000 tons).
Ten percent of the soil came from Ft. Bragg (4,000 cubic yards or 6,000 tons.) A ten percent
share of the cost of detoxification would be approximately $ l .6M.
• A landfill provides containment of contaminated material. The material in the landfill is still
toxic. As a contributor of material to the landfill, the Department of Defense still retails
liability for the materials. Should there be a failure of the landfill that require further action,
the Departml!nt of Defense would be a principal responsible party. The remediation will use
a process that will convert the PCBs to 11on-toxic substances and thus remove the site from
regulation and future liability.
• The landfill was designed assuming the soil going into the landfill would be relatively dry.
1vJaterial from the roadsides transported by the North Carolina Department of Transportation
met that criterion. Closure of the landfill was delayed by several weeks to accommodate the
placement of Ft Bragg material in the landfill. During that delay, the site experienced a
significant amount ofrainfall that resulted in a large quantity of water in the landfill that
could not be removed before closure. The original leachate removal and treatment system
was not designed for lhe amow1t of water in the landfill. There has been concern over the
impact of the additional water on the integrity of the landfill.
• The original cost of the landfill was $2.95 M .
Federal Share
DOD
EPA
Total Federal
State Share
Total Cost
$ 343,377
$ 2,163,021
$ 2,506,398
$ 445,779
$ 2,952,177
• The total amount received in settlements ,·vith the Ward estate (the principal party that
dumped the material on the roadsides) was $3.SM (cost+ interest).
Federal Share
DOD
EPA
Total Federal
State Share
$ 407,095
$ 2,564,405
$ 2,971,500
$ 528,500
HAY-15-00 HON 8:58... CONG. EVA CLAYTON DST OF FAX NO. 2524562611
EVA M. CLAYTON
1ST 0•ST~ICT, NORTH C .. !10\.INA
COMMITTEES.
AGRICULTURE
:S•J&Cor..c""1 r r(ts:
Oc;r;.nlt.,;Nr 0111:!A•\f10NS, Ovc"'SIG~f.
NuT~IJION. ANO Fe;,,e,, •. ,
R"'""'"c M"Mae"
G<:NCnAl fAOM C0MMOOll'II~. At,;¢u11,e
C0Nst:nv,1r,o,-,.1, .-.No CRtO•T
<lCongress of tbe Wniteh $fates
l!)ouse of it,epreEentntibes
~asfJington, il9Ql: 20515-3301
BUDGET
The Honorable Carol M. Browner
Administrator
May 12, 2000
United States Environmental Protection Agency
1200 \Vest To\ver
401 M Street S.W.
Washington, D.C. 20460
Dear Administrator BrO\vner:
P.02
WASll:NGTON OFFICE:
24.W RA"'elV"N 1~0~1~ Onie, 8\.-tl..C-\.J
w,,;ir1.'lo1·:,..__ oc 20s1s
IW2l 225-3101
EClayton l,j;)n,all.ho1,,~ ~,v
I wish to bring to your attention a very c1itical environmental project \vhich has positive
potentials as a developmental and reinvestment demonstration.
In the eady I 970's, Warren County, North Carolina had 60,000 tons or 40,000 cubic yards of
po!ychlorinated biphcnlys (PCB's) contamin2ted soil placed in a federally funded ancl state built
landfill. Most of these soils came from 200 miles ofhigh\vay shoulders in 14 counties which had
been illegally dumped.
The U.S. EPA has long acknowledged that the "Environmental Justice" movement in America
began with the siting of the \Varren County North Carolina PCB Landfill. Although the
landfilling of the PCBs spraying incident was a recognized TSCA solution to a CERCLA
In 1982, Governor Jim Hunt made a commitment to the people of Warren County that if
appropriate and feasible technology became available, the state would explore detoxification of
the landfill. The detoxification process selected destroys the PCB molecule. Destruction of tile
PCBs to nontoxic compounds \Vill eliminate further regulation of the site and permit unrestrictc·d
future use.
In 1999 the North Carolina General Assembly appropriated $IM and reserved a.n additional 7Ivf
to match federal funds to detoxify the landfill. The state and community have worked with the
EPA to enable the project to move forv.'ard in a phased-funding manner. The 71\,1 appropriatc:d
cannot be released until the state receives some federal matching funds. The total estimat~J cost
of the detoxification project is $14-18M.
DIS rRICT OrFICE:
\rV.l1lf.'£N Cor,,.icas S1-4Ci""1""c C£1PEA
Aovrr 1, S•JlfE 7
P:.>$iT O"IC~ cc, 67tJ
Nr;i,u.,,uA , NC 2i'Sd3
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tC,U M.,r.:"' lvr ~• ,:.1N:;; ,;a c_:,. .r
5,.,.1: 1:>o
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1.ff•:c. z:-1-ee1,
I-" .. , I~!:. •~9-•t:i~·
HAY-15-00 MON 8:59 CONG. EVA CLAYTON DST OF
The Honorable Carol Browner
Page 2
May 12, 2000
FAX NO. 2524562611
North Carolina should be used as a model for: I) involving the community in selecting the
detoxification technology; 2) working with the state and federal agencies as partners; 3)
demonstrating how a landfill can be cleaned up and rehabilitated as a recreational use; and
in addition 4) creating economic opportunities along with career options for the youth.
P. 03
The US EPA has been involved in an "environmental justice" campaign for several years in an
effort to develop strategies to identify and eliminate the vestiges of environmental racism and
craft citizen-influenced solutions to commonly understood environmental injustices.
The US EPA commitrnent to environmental justice is baseless without direct and substantial
financial and teclmical assistance in detoxifying the \VaiTen County PCB Landfill. Although
Region 4 has committed to provide funds for a three-year period through the WaJ.Ten Family
Institute: to hire a Community Liaison Coordinator to work with the citizens, state p~rsonnel,
Citizens' Advisory Board and contractor during the detoxification, that money is not yet in hand
and does not represent the full extent of what the agency can do on a matter such as this.
\Vamm County is an economically depressed community and has been designaled as a Tier I
counties for economic development.
Sincerely,
~Cla!·ur
Member of Congress
EMC:dbb
HAY-15-00 HON 9:00 ~ CONG. EVA CLAYTON DST OF FAX NO. 2524562611 P. 04
STATUS OF PCB LANDFILL DETOXTFICATJON
,vARREN COUNn', NC
24 1\:Tftrch 2000
BACKGROUND:
In the late l 970s several thousand gallons of polychlorinated bi-phenyls (PCBs) were
illegally disposed by spraying along approximately 210 miles of state roadways. PCBs were used
extensively as transformer fluids in the early l 970s. However, because they were suspected
carcinogens, they were outlawed from manufacture in 1976 and strictly controlled in disposal as
transformers came out of service.
Listed as a Superfund site under the US EPA program. the roadways were dug up and the
contaminated soils disposed in an approved PCB landfill built in Warren County. There was much
opposition to the landfill and the Environmental Justice movement supposedly got its stare at this
site.
In 1982, Governor James B. Hunt Jr. made a commitment to the people of Warren County
that if appropriate and feasible technology became available, the state would explore
detoxification of the landfill. In 1995, $1 million was appropri:ued co study detoxification. The
General Assembly provided this money for the sole purpose of studying various detoxification
technologies, including bench scale work; confirming that detoxification is possible; and
identifying the best technology available to do the work.
The Warren County PCB Working Group (WG) was established and consisted of local
citizens, state employees and members of various environmental organizations. This group
worked together in a joint partnership with the state to explore detoxification.
ASSESSMENT STATUS:
The WG, through the Division of Waste J\fanagement (D\VI\1), contracted with two
independent science advisors to provide technical expertise to the \VG and to help outline the
steps necessary to explore detoxification.
With staff from the DW1'.-1, the WG and s~ience advisors outlined activities that needed to
take place during the detoxification studies. These activities included an extensive site
investigation, installation of monitoring \veils, boring into the landfill to extract soils for testing,
and the actual detoxification studies.
HAY:-15-OO MON 9:01 ~ CONG. EVA CLAYTON DST OF FAX NO. 2524562611 P.O5
l\fobiliz.:1tion/site work:
On February 12, 1997, DWM personnel and science advisors began work at the PCB
landfill to jnstall additional monitoring wells and begin the site investigation. Fifteen new
monitoring wells were installed around the perimeter of the landfill and in the immediate area
within .25 rniles of the landfill. Three were placed off site as background wells, approximately 1.5
miles away. Two boreholes were placed in the landfill from which soils were extracted and
containerized for the detoxification studies. Extraction wells were installed in the boreholes.
Two eight-foot square areas were dug out to a depth of approximately two feet in order to
examine the top liner of the landfill cap system . 11 Split spoon" samples were taken of the clay cap
and the landfill contents. These samples were analyzed for a variety of things including moisture,
compaction, permeability and PCB content. A l 0-mil plastic liner covers the clay cap. Sections of
this liner were cut out and sent to a testing laboratory for examination. The cut out portions was
replaced and the holes refilled.
Snmp1ing:
Extensive sampling was done in rhe monitoring \vells and streams around the landfill. Soil
and sediment samples from selected locations around the area were taken. These samples were
analyzed for a variety of chemicals including PCBs. dioxin, heavy metals, pesticides and volatile
organic chemicals.
J)etoxificntion studies:
Beginning in 1996, the science advisors for the Working Group, along with DW}.1 stair~
conducted a detailed technology screening, evaluation, <1ssessment and comparative analysis on
potentially feasible technologies. Potential feasibility had to have been demonstrated through
prior successful full-scale use of a technology for PCB detoxification work. Any technology that
existed only as a research or developmental technology was deemed inappropriate.
Twelve different technologies were considered. All but two were screened out. Only
Base Catalyzed Decomposition (BCD) and Gas Phase Chemical Reduction technology were
found to be app1·opriate and potentially feasible for the Warren County landfill.
Two companies were subsequently picked to conduct bench scale demonstrations. ETG
Environmental, using BCD, and ECOLOGIC, using the Gas Phase Chemical Reduction
technology, were provided samples of the contaminated soils from the landfill, along with very
stringent guideltnes and treatment goals for both PCBs and dioxin. Following their bench scale
studies, each company submitted phase I reports that \.Vere analyzed by the WG, state stafLmd
science adviso.-s.
2
HAY-15-00 HON 9:01 _ CONG. EVA CLAYTON DST OF FAX NO. 2524562611 P. 06
As a result of these phase I studies, the Working Group concluded that feasible and
effective detoxification technology was available and selected BCD as the preferred technology
for detoxification of the PCB Landfill. ETG Environmental, Inc. (ETG) was subsequently
awarded a contract to perform a Phase II preliminary design of a full-scale BCD detoxification
system to remediate the PCB Landfill (ETG performed the successful Phase I bench scale BCD
study.) This Phase II design was used as the basis for requesting funds from the General Assembly
for final design and detoxification of the PCB Landfill utilizing the BCD process.
The BCD process utilizes non-incineration chemkal reactions to detoxify the PCBs and
dioxins/furans in the contaminated materials. Chlorine atoms are chemically" removed from the
PCB and dioxin/furan molecules, and replaced with hydrogen, rendering them non-hazardous.
The resulting non~hazardous oil can be recycled off site. Detoxified soils will be replaced on site,
covered and re-vegetated. The process has been proven at several full-scale project applications.
The preliminary conceptual design of the full-scale detoxification project is divided into
two components. The first component provides written conceptual designs for site preparation,
excavation, treatment, confirmation/verification sampling, stormwater management, security, site
reclamation, decontamination, and demobilization. These aspects of the project have been
conceptually designed to provide the basis for a detailed cost estimate for detoxification.
The second component presents those aspects of the project, which will be completed
during the final design po11ion of the Phase HI Design/Build detoxification. Outlines have been
provided to introduce these final design items, as follows : ernergency response plan, permitting
plan, performance demonstration plan, air monitoring plan, quality assurance plan, health and
safety plan, construction quality assurance plan. and technical specifications.
The Design/Build detoxification contractor would include Program l\·fanagement, workir.g
in conjunction with the state, to ensure that the local community hc1s a strong role in the
detoxification project's implementation. The Design/Build detoxification contractor would also
include a coordinator to ensure maximum economic benefit to local/minority businesses and the
loc'11 economy. Di red local economic impact is estimated in the range of $3 million to $5 million.
which includes the hiring of local individuals and utilization of local businesses for supplies,
materials, and services to support the detoxification project. A detailed cost estimate has been
prepared to perform th~ detoxification project utilizing the BCD process. A cost of $23,975,000
was established, which included a $2,079,000 contingency and approximately $),000,000 for air
monitoring and testing.
MAY~15-O0 MON 9:02 · CONG. EVA CLAYTON DST OF FAX NO. 2524562611
The North Carolina General Assembly appropriated $2 million in 1998 to begin
detoxification of the landfill. This appropriation bill also specified the BCD technology and
cleanup levels of 200 parts per billion PCBs and 200 parts per trillion toxicity equivalent
concentration (TEQ) for dioxins/furans.
P. 07
In January 1999, the state hired 11s. Pat Ba~kus, PE, and a chemical and environmental
engineer, to be the project manager for detoxification.
On February 16, 1999, Henry Lancaster, then the Deputy Secretary for DENR Mike
Kelly and Pat Backus met with representatives of the EPA Region 4 in Atl,rnta to discuss
potential funding support for detoxification and the permitting requirements from EPA to do the
work. Henry Lancaster and Mike Kelly also traveled to Washington in February 1999, and with
Jim McCleskey, of the Governor's Washington ofl1ce, met with various members oft he North
Carolina Congressional staff The purpose of this visit was to update them on the project and to
visit the Pentagon to discuss the possibility of securing funds from the Department of Defense to
help in the detoxification effort. Approximately 10 percent of the contaminated soil in the PCB
landfill carne from Ft. Bragg.
A contract for Pha~e III. fi11al Design, \Vas awarded to ETG Environmental in May oi
1999. The DWM then sent out requests for(! statc::ment of interest to various vendors with the
ability to use BCD technology on a fu!i-scale operntion. The DWtvl wanted to begin looking at
the number of qualified firms available to bid on the full -scale detoxification. Ten companies
submitteJ letters of interest and qualification packages.
The general assembly passed an additional apµropriarions bill during the 1999 session to
set aside $7 million out of reverting funds. and 10 also transfer $1 million from the solid waste
white goods fund for the PCB landfill detoxific::ation project. The appropriations bill for the S7
million will require some federal matching funds .
In August 1999 the WG was reorganized as a Citizens Advisory Group (CAB) with?.
mission to pursue detoxification and the ne cessary funding to complete the project. Their
responsibilities also were to continue working with the state staff and contractors to comple1e the:
final design plans for detoxificatio:1 and to help finalize plc1ns for the red eveloµment of the land
once detoxification was completed.
In December 1999, as a result of state needs for hurrica11e relief, approximately$ 1.42
million of non-obligated money was transferred from the detoxification fund back to the stale
budget otlice.
4
HAY-15-00 HON 9:03 ~ CONG. EVA CLAYTON DST OF FAX NO. 2524562611 P. 08
CURRENT STATUS:
The Environmental Protection Agency (EPA) has agreed to provide $225,000 ($75,000
each year for three years) out of their Environmental Justice Program for the hiring of a
Community Involvement Coordinator to work in Warren County as a liaison between the local
communlty, CAB, state staff and the contractor for detoxification. The individual hired will work
through the ·warren Family Institute and will be located at the Warren County PCB office.
Applications are currently being accepted for this position.
On Febniary 3, 2000, Pat Backus and Mike Kelly, along with representatives from ETG
Environmental, met with the permitting staff at EPA headquarters in Washington. DC. The
purpose of this meeting was to bring the EPA staff up to date on the current detoxification
efforts and to discuss a phase-funded approach to the detoxification project. The detoxification
project will require a permit from EPA. The Final Design Phase III document was completed and
turned over to the state on March 9.
DENR staff met March 21 with state contracting personnel to discuss the RFP for a
phase-funded approach to the detoxification. Work is progressing on this RFP. Under the
current schedule, it is anticipated that a contract for the actual detoxification will be signed this
fall.
Efforts are currently being undenaken to find additional funding to complete the project cs
well as the matching federal dollars required under the appropriations bill from 1999.
CONTACT: Michael A. Kelly, Deputy Director
Pat Backus, Project Manager
·5
919-715-3644
919-733-4996, exr. 308
MAY-is~oo HON 9:03
EVA M. CLAYrON
CONG. EVA CLAYTON DST OF FAX NO. 2524562611
1$T o,s"'•~T. NrJA"fw CflAIJLINA
COMMITT(ES:
AGRICULTURE
SU8t.'OMMntns:
Ctr,u~'t.lCNT OrtllAIIOAil!, OvE11t1GUT,
Nvrs:tlllON. ANO Fo11t:,;r11'-t
R.uJ(INY MEMO£"
GtNtn,\1,, F'.Anr., Cot.o..100,t1E~. ~EiC)U~cr.
Cor,1,S(ClV,\TCON. ANO C'1COIT
([ongress of tbe ~niteb ~tates
3:.~ou~e ot ~eprescntatibcg
ma~binuton, ~~ 20515-3301
BUllGfT
Iv1r. Under Secreta1y Bernard D. Rostker
Under Secretaiy of The Anny
The Department of The Arrny
The Pentagon
Washington, D.C. 20301-1155
Dear Uuder Secretary Rostker:
May 12, 2000
P. 09
WASHINGTON OFl=ICE:
24•0 R."~u~ .. Hovn O<F•CE Buo,c, 'G
W,\Sllf'\1~1'UN. DC 20515
12021 22S-J 10 I
ECl~,;ton 1,?muil,J'lovu 90v
I wish to bring this critical issue to your attention and request the Department of Defonse and/or
Army's ,1ssistance.
In the early l 970's, W arrt:n County, North CaroliHa had 60,000 tons or 40,000 cubic yards of
polychlorinated biphenlys (PCB's) contaminated soil placed in a federally funded and stale built
landfill. Most of these soils came from 200 miles of highway shoulders in 14 counties which had
been illegally dumped. However, ten percent (10%) of the contaminated soil came from Fort
Bragg. (See attachment.)
In 1982 Governor Jim Hunt made a commitment to the people of Warren County that if
appropriate and feasible technology became available, the state would explore detoxification of
the landfill. The detoxification process selected destroys the PCB molecule. Destrnction of the
PCBs to non-toxic compounds will eliminate further regulation of the site and pennit unrestricted
future use.
In 1999 the General Assembly appropriated $1M a.n<l reserved an additional $7M to match
federal funds to detoxify the landfill. The state and community have worked with the EPA to
enable the project to move forward in a phased-funding manner. The $7M appropriated cannot
be released until the state receives some federal matching funds. The total estimated cost of the
detoxification project is $14-18 M. A ten percent (10%) share of the cost of detoxification for
The Department of Defense would be approximately $1.6M.
Warren County is an economically depressed community and has been designated as a Tier I
County for econornic development.
DISTRICT OFFICE:
\.V1n:.rp, cc,r,~,tns S11Ct"P1sc CPHF.SI
~OVT! 1, su,fE 7
PuH (Jr:,c, 8v> 670
'lO•ill••·· NC 2156)
(2~2• •S~--•~OO r-.,: 12S2l l5&-1tjl I
DISTF!ICT OFFICE:
400 M ,vi1r. lu!'1•C'r' K·•~:-•• J•. r~ ,t
S1J1rt: • -Joa
G,·::•;",~lt .... ,c 2783l
12~21 75:'-~=~~o ,.e·;o-1'! .:572
F,u· 1i SJ1 7';.~1U21
MAY-15-00 HON 9:04 ~ CONG. EVA CLAYTON DST OF
Mr. Under Secretary Bernard D. Rostker
Page 2
May 12, 2000
FAX NO. 2524562611
This matter is critical and time sensitive because of the Governor's tenure and the
conditions placed on the state dollars.
P. 10
Please give this matter your urgent considerations. I arn available via the telephone to
further discuss this rnatter. Again, I thank you for your considerations on behalf of the
citizens of Warren County and North Carolina.
Sincerely,
~M. !;onur
Member of Congress
EMC:dbb
HAY-15~00 HON 9:05 CONG. EVA CLAYTON DST OF FAX NO, 2524562611 P. 11
SPECIFIC TO DEPARTMENT OF DEFENSE l\-1ATER1AL
• The total quantity of contaminated soil in the landfill is 40,000 cubic yards (or 60,000 tons).
Ten percent of the soil came from Ft. Bragg (4,000 cubic yards or 6,000 tons.) A ten percent
share of the cost of detoxification would be approximately$ l .6M.
• A landfill provi<les containment of contaminated malerial. The material in the landfill is still
toxic. As a contributor of malerial to the landfill, the Department of Defense still retails
liability for the materials. Should there be a failure of the landfill that require further action,
the Department of Defense woul<l be a principal responsible party. The remediation will use
a process that will conve11 the PCBs to non-toxic substances and thus remove the site from
regulation and future liability.
• The landfill was designed assuming the soil going into the landfill would be relatively dry.
Material from the roadsides transported by the North Carolina Department of Transportation
met that criterion. Closure of the landfill was delayed by several weeks to accommodate the
placement of Ft Bragg material in the landfill. During that delay, the site experienced a
significant amount of rainfall that resulted in a large quantity of water in the landfill that
could not be removed before closure. The original leachate removal and treatment system
was not designed for the amount of water in the landfill. There has been concern over the
impact of the additional water on the integrity of the landfill.
• The original cost of the landfill \vas $2.95 M.
Federal Share
DOD
EPA
Total Federal
State Share
Total Cost
$ 343,377
$ 2,163,021
$ 2,506,398
$ 445,779
$ 2,952,177
• The total amount received in settlement~~ with the Ward estate (the principal party that
dumped the material on the roadsides) was $3.5M (cost+ interest).
Federal Share
DOD
EPA
Total Federal
State Share
$ 407,095
$ 2,564,405
$ 2,971,500
$ 528,500
Jan 14 2001 12:13 F·. 02
NORTH CAROLINA DEPAR.l'MENT Of'
ENVIRONMENT ANO NATURAL RESOURCES
Raymond J. Fatz
Deputy Assistant Secretary
for Environment, Safety &
Occupational Health
U.S. Department of the .t\.rrny
110 Amly Pentagon
Washington, DC 20310-0110
Dear Mr. F atz:
December 14, 1998
In 1982, the state of North Carolina entered into agreements with the
Department of Defense to accept PCB contaminated soil from Fort Bragg for
disposal in the Wa1Ten County PCB LandfilL The state constructed the landfill
to dispose of other PCB waste. The amount of the Fort Bragg PCB waste in
7,211 truckloads constituted about 10 percent of the total amount of PCB waste
landfilled. The Army paid the state its share for landfill construction and
maintenance costs, \Vhich according to records received from Fort Bragg was
about $200,000.
Various state funded studies as well as examination by the U.S. EPA
Region 4 have confirmed that the \Varren County PCB Landfill is deteriorating
and that some federal regulatory requirements are not being met. Our intention
is to permanently and safely use detoxification treatment technology invented by
EPA, called Base Catalyzed Decomposition, to eliminate the PCBs, Dioxins, and
Furans in the landfill waste. The North Carolina General Assembly appropriated
$2 million in its 1998 legislative session to begin detoxification of the landfill.
The General Assembly also specified that the detoxification method will be Base
Catalyzed Decomposition (BCD). At the completion of the proJect, the landfill
will be closed and neither North Carolina nor DOD will have any future risks
and liabilities.
The purpose of this letter is to declare the intent of the state of N 01ih
Carolina to seek reimbursement from DOD for its fair share of the total costs of
the detoxification project. It is estimated to cost as much as $24 million. Based
on the original DOD use of the landfill and its clear acceptance of its pro rata
share t)f the costs of managing its PCB wastes, we believe that DOD should take
the necessary actions to contribute as much as $2.4 million as its share of the
landfill detoxification project costs. We would like to work on preparing a ne\V
Cooperative Agreement that clearly defines the DOD commitment to contribute
its share.
Raymond Fatz
. December 14, 1998
~ . .
Page2
Jan 14 2001 12 =14 P.03
Please do not hesitate to contact me if you have any questions or
concerns. We look forward to working with you on this important clean up issue.
cc:
Sincerely,
~~~
Wayne McDevitt, Secretary
Eva Clayton, U.S. Congress
Dollie Burwell, Co-Chair,
Henry :rvf. Lancaster, II
Deputy Secretary
Joint State/Vlarren Co. PCB Landfill Working Group
Frank Ballance, NC State Senate
Mike Kelley, Waste Management
I .
HIRSCHHORN
i@c?ASSOCIATES
t~ .'1 oivietor, or Hr,tiiflt1tles En11it'On~;; S..W..es i l~c. ,u1te 411
24'01 e1u•rld&e Awr)ue
Whcllton. t.40 20902
April 1, 1996 ............... _ .................................................................... :by FAX
ftt'IOM: (301.) O◄O•l:.23!
F3lt: (301) 94t,12~7
To: Co-Chair&, Executive Committee, Jomt Wma County/State PCB Landfill Working Group
From: Joel S. Hirachhom, ~ A~r
.. .
SubjCQt: Submiieion otmltW report; muter plan
·'..':., '~,: i~:: :.l ,'.; · -~Nd i, a oopy of a report by myself •titled "Pndin,incy Detoxifioa~.J...~.9~11 .,,_, •.
..
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t i
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Aneummt" that I am submitting to the Co-Cbaits.
I bad aent a copy of this document on a dale io BiJl Meyer, matbd. draft~ so that I could obtain
aome profeaaonal feedback and to check my site informatloa before official 111bmis&ion to the
Wortm1 Group. Subscq-ueutly. Bill iuformM me that he generally agreed with my report's
prekntation but that he foresaw some potential diffiQalues with the Group's m.embcnbip because
of som.t of my information and recommendations. He suggeltod n.o changes or corrections in the
repon. t told him that I too realized that I was presenting what could be seen. as distwbing new
information and analysis, bm thai I had a prof'esdoaal and ethical rc111>011sa"bility to inform the
Group as 800Jl u posa'blc about mfonuation that l b.ew dlould have a smterial impact on the
Group', thinlina a1ld ~ .
Bccau~ it has bcca 110me time ainoe J have heard from Bm, and th• Group'• meetin.g he had
discussed with me did not materialize, l fee] it prudent to submit thi$ report at tbi£ time.
This morning I recdved a memo ftom the Co-Chairs regardi.og development of a master plan.
The probJctn I have is that sueh de\'elopmmt setm$ to N premised cm currently available
information and thinking ,bout the fmldammtal goat, and strategies of the Group .. It aeems
somewhat illo~al to me to devel~ muter p~~~ut first ha~ ~t:-~.~~ ~~!~ ~ some Aii: iuslCJ1ondcint t»(king ~bo11t what premises ~4--•ssunmtions the ~!l~!..tlan is
~iiied on. l do not btlieve that the mteivicw·mcetiog T had or any other discussions or ao.y
matcriah I b.ave been provided offer a sound basis for developing a master plan. In not~ at this 17
time there is inlufficient definition of wh4t a master plan should attempt to clo and illclude. For L,-1
fltlmple, I would like to receive from. the Group some speci&ations about 'Ml&t the master plan )
pertams to and its dedred scope. DMA it pertain to th.c individuals_ clenco Advisor's activities or
. the entire 0U1Tently 1\mdcd dron, for e,cample? Also, in the significamt time since the selection of
the Scien.ce Advisors, I have uot bcco provided whh any site documents, without whi~h it is
difficult to carefully assess filtuie activit:iN.
I want to emphum that I believe it is critically important for the Group to seriously examine and
then openly diacuu my rc,port, beca-use of its implioation, for how CWTeC1tly available state
funding wm be spent and bow the Science Advisors will be utilized. Hence, it seems logical ,o me
that my report be considered~ efforts are expended on master plans. Please feel free to call
me with :my questi.oas you may h~e.
_,
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PRELIMJNARV DETOXD1CAT10N TECHNOLOGY ASSESSMENT
lptrgflpsdM
to
Wmm County PCB landfiD Working Group
loel S. Hirdhom, &citnCC Ad\Uor
Muc.b. 7, 1996
.· ' . .:..:aw .... ___ ....,._;....~;....-.... ;...,
'Ihe commarcial d.evelopment of remediation teQlmologies hat progresNd rapidly dwing
the put decade, and &inoe early decisi.ona wcrc .made that thCR were no acceptable alternative& to
landiilting the .PCB wastes iD Wamm County. The purp0t10 oftlm .alyais ia to reviow the
cmtellt ltato o(und.entandm.s u.c1 objectives reganfin.a the UN of deto,dncation technology for
the Warren. Cowrty PCB I ADdfiU It setms that baaed upon previous work there i& a general view
among Working Group members that BCD dechlorination tedmology ii the prefmod tedmoloSY
and that two companies will conduct onsile i.eld 4emoas:tntions of their forms of the technology
duriag the oumntly funded projegt
There are two reaaan•b~ questions to COJUider:
1) Are there other technologies dlat may offer net advantag• aver BCD decbl.oriDation. in terms
. of dfeetivcneas. safety or cost and, therefore, tbat m~rit eomc level of ~:wro,tion or teltiog?
2) l1 the plan h) field test two cW!erem thnm of the came teclmology a we, necessary and ooa-
eft'eciuv. approach?
Each of thcac quenions will be examined to encouraae a thoughtful discussion by tbe
Workiag Group. Also, aa alternative atrategy is presented for moviq furward \\ith tecltuology
evaluation and NCUring tun~· g for actual cl up. :1'h-alt~• .atrate~ ii believed to offer a
number of advantages over the cun and ments serious co.naderatioll by the Working
Group. ·.· . '
. -. . ~ .. ,.I'.;•
Thi: use of ihi: tCllll dctoxw.Qltion tecbology iq,lies that teelmologies that are oonsidered
cleanup technologies but that do not by tbemaehrea deto,cjfy PCBs are not appropriate for the
Warren County sitoation. Tbu position is very important, ~uae one of the areas of
considerable developmmt bu been separation tcchllologies. Th.ese remove toxic contaminants
l
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ftotn aoil or other media, concentrate chem to a much smancr volume, ad then. these are usually
,ent off'sitc for Mlhlequmt disposal or treatment. Thi, approach ha1 been used for PCB elcanups
md many other type&. For example. thermal desmption. aolvent extraction, iOil washing,. ud soil
vapor mracuon have received ccmsiderable mpport. About 75% of cleui.up1 other dwl those
ba&ed OB convaational land di,poul/co11tainmeat, mcin.eratiotl, or •abiliutio.D/aolidifioatioll )lave
uted scparltioll ~ologb. Jn many cues, a.p.-.don teclmologMS oft'er sipiflo,nt coat
advan111es .,4 this explain& wby tuy are llonnally used.
Somerime-, where co.wODJJ:1eGta1 jullbOO .-e, bave ,uri'aced, communities have taken tile
poajtioa. that clcmwps ahould aot impoac bmdcm cm other gc,IDIJIUDitiei, 'l'bia ln4a to a
pr$ence 10 a;void ccm-,trated toxic waste, being teat otfme tor 8aa1 ~~~'!'1:.-~!e~~ /i' D
ii that the wastes wiD. be sent to communities that have already been placed at risk because of ) trV'-1
hoardoua waste dispoul or treatment facilities. Hov.wa\ this podion is not completely valid. J~lf"I ,er
because it is poai\le to require tha final diapo&ition of wastes be at a faoility that ism. a r-\ ,.;.._
comm\Ulity where environmental justice iSS\les are aot relevant. That ii, th.ere are commercially ,, ~~
available ad permitted facilities in. place, wlac:re the local community weted the opmatiOll &0d 7 I .i.A~
where poor, inmorit)· people are not a rekvmt factor. 1~W' -· f d
This Seia,cc Advisor &$$Ul11e$ that the Working~ still b.lieves that only an onaite
deto,dfication teohnology lhould be uted. Therefore, there will be 110 analysis of either separation
., teohnologies that ~'e been widely used for PCB clcanupi, nor will coaventional land
dispolllfcontaimnalt, incinention, or ltabilizatiOD/tolidificaticm be «ntsldered. How.vor, it
lhould be noted that at aome point in the future~ if and \\ilesa a oaAe is made for USD18 a
dctomicatiOll technology, other puties may raise question& regardmg tlle use of either tcpantion
or ooitvcntional tc,chnololiet ad may aNCrt that one or moro of lhC8C would offer co.st or other
advantages. ID particular, when a large amount of money is ,eq_uested for &ll scale u!WI of•
deto,cjfica~on tec.ba.ology, ltatc o1Bciali may question whechcr there are other lower colt
teclm.ologics that should be COlllidaed. It is most likely that aotual olcmup cost buod oo. onaitc
detoirifieation ~11 be at least $20 millioti, and pezhaps sigoiSeaady more, depecidmg 011 exaotly
how much material wiD be treated. 1
This does not mean that the Working OtOl.Jp lhould ~ abaudoo ita preferenoe for
using OUQte detoxification technology, but it doe, augest the need to pay attention to two things.
First, .n ~icdy feaaible detoxmcation tecbnologies should be fairly ccmsidercd md payms
-attention. to c;ost is appropriate. SCCC)lld, .i tome point the prefared &:to,riiication technology
mua be an~ in comparison to 11Cparation and conventional teclmologies to make the best,
supportable case for political support of a bi&h cost cleanup. Anyone opposed to apending a large
1 Assuming 40,000 tona, a figure Wied by 1be state1 and a total cost of s,oo per toll,
covering detoxification and all other cleanup costs yields $20 million. This authol's considerable
experience with colt& of oleanupa baled on tteauoeo.t technolo~cs indicates that an aggregate
cost ofSSOO pes ton ia a w:ry appropriate cost to uce at this time; this colt would cover all
spending on the aotual cleanup.
2
IJ..~~
,I~' £;w-~
v.A•'fV'
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sum of DlOllC')' on a dctoxiJigation cleanup eould eadly obwn dau £'or a cheaper cleanup
ahemativc.1
AUcr;um• Dc&oxifiatiop Tcrbnolasia ·
BCD Pt&blm:iaedon While it is '°rreci Wt BCD tedmoloay hu gamed io.«easing
acceptuoc, after yura of researdl and development at EP" it still it • technology with limited
experience in fhll-scale deaaup applications for PCBs and mnilar chlormated chmDioals. A reoent
. ·-m~ais by the Gcacnl AeOOllntins <>&.Oil.-of imaovativ• cleump i.d>n.ologi•-, s f.or
,;!~le;rapo!'.tecl that for Superfiuld sites &om 1986 through 1994, dodllorination tedmology
had b~ telected in oul)' three wcs out of a total of 291 bmovative tecbnofo'gyapp1ioaiioiis. .
-There have also bec:m other applicatiooa at 11.00.-Supcrfimd lites. Altho\lgh BCD is ollly oo.c form
of dierical decblorinatioll, it ua become the premninait form.
· A 199 5 OAO report concbied.: "It is an efficient. relatively inexpensive treatment process
for PCB• and pM«>ti•Jty capable oftreatiq PCBa at virtually any con.eentration .... ~Id data on
the performance md cost of BCD for PCB& and dioxin are very limited ... bl this author's
professiorial opmjon, the roollt lignificant technical iBle 1br BCD i• the control of toxio air
emissions md tile possible Deed to treat other wa,te,trea.m,, much mon so than the ability co
· destroy contamin,uts and reach strm.gCllt clcaup tWJ.dardJ. Supporting tbis view are co.nclwions
· on BCD ill a recat stw1y by tile Congreuioul OfBce of Tedmology A.uemaent: "The reaction
· b)PJ'Oducts in treated aoil have not bnn well cluracterized. . .. 11te e5cicmcy in romo~
oantamin~t& &om the oft'gaaes it not well known. Washwatcr used to dean the aoik after
trea~t wJll contain traces of c.cmtamioants and process chemicah, and may also require
treatmont. '"1 . · . •
. · 2There has beeo a dramatic trond in recent years for both federal Superfimd sbM and state
cleanup sites nationwide to use low colt remedies, typically baled on. contai:nmem, rather than
tr~tment optiona. In this cue, oftsite dispos.al or uae of aepal'ltion technology with offime
baur~oua -.due disposal might very weD be significantly lower cost thaA onsite detoxification.
:i..Supdnd. -Use of lnllovative Tecbnologie., fur Site Cleanups,• Doo. l 99~, GAO/T-
RCBD-96-4 S.. .
.. Superfbttd -EPA Haa Idaitmed Limited Altematives to Incineration for ClCIDDli up
PC_B and Dioxin Cootaminltiou." Dec. 199,, GAO/R.CED-96-13 .
"'Clean.mg Up Contaminated Wood-Treating Sites.."' Sept. 1995, OTA-BP-ENV-164.
3
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A rKGllt EPA atudy of'wdmology deciaiOJLI lt Supetfimd-" provided the foDowiug
relevant iaformatioa M)()Ut the UM of d~ udmology:
-In ndics Rlatcd to FY9 l md FY92 ~ons, dochlori:ution wa, ttettability teated
once, ancl that wu \1UUOceaaml
-For thiJ· aamc period, deohloriution was COD.Siclercd in so wies, and Mlected ill wee.
Other thm actors related to umuitable lite cOlltamin~ the most commcm reaaona for
1Jiminarin1 deohlormaticm was mp DOit, 1he lleed for treatability ~ pocendal to form more ( .:~,.<~~ or ~;1,y•pr~ 1nd tht uod tor polt•treatmcat or clitposal o(resuluak.. _
. \ . ,,.,. la . . . '. '" . ·.,. . .
. -From )982.1992, d~ had HIil 1e1.ected 1!vc mnes, ~ 0bl three ~the··
deci&ions were later c.hangecl and di«erem cleanup t.clmolope, uacd. ha thoae ~ ease'-the
lites 'WCl"C contlmiutod will\ PC1h.
--EPA laid: "Factors •«ecrini tbe decisions to replace dechlorination include the large
. volumes of d~hlotklatio.n tClidu1l1 that reqvired fbrthei treatmmt/cliaposal, ~• of oO:.lite
treatment/dispo~ safety conaems relating to handling h1.mdous materials, cost of reagent&, low
px-oductiou rate., leaeb.mg·ofnlidual reapm from trated IOi1, md offaisive odor problom&.11
To be fair, it should be noted tht m moc of the cues oonlidorcd by EP~ dechloril\ation
was probabty baaed oa the wty forms of the uclulology (i.e., KPEG and APEO) and not BCD.
But the gencnl cq11ip:ment Wll probably about the a.me as that used today with BCD, because
the major diew-~ is che feageass acL Mao.y of'tlte iaaies, theremre, may be valid for BCD .
. .
· EPA ha& al&o issaed auidmoe fur condnc:dng trutability tests for dechlorination
technology.' Pethaps the most important put ofthk documeat ii ita preamtation of the difrcrmt
levels of testing appropriate for making deciliona about tbo tedmology. Tho EPA hmework is
oorrect ad is based 011 three lovcls of testing: technology scremmg to determme potential
. feasibility, technology Mlection to develop pcrfonnance ud cost data. and testing to obtain more
. , . . detailed data and cxmmm pe.rformanoc. For the Wme:n County lituatioxi, wllcro the site
· · · cotrt,minant oondition ii aot complex (i.e., there ii essentially one dlcmical type that one
technology can handle) and consi.derable informadon alrudy ems OD. how aome teclmologiea
. · treat PCBs, the S<:Toemll8 and •lection deaaiolla do not require onsite or &eld testing. In fact,
EPA aid that s«eca.inl test.ini of thi& technology "will aenmlly not be required when .PCBs or
dioms are the contaminants af rmecm. 11 Testing in laboratory or bench .. scaJe or full acale
equipment at a vendor's location. oui be used for 1e1ec:ticm treatability testing. to. the EPA
"'Feasibility Snady Au\yail, V~lume I: Finctin.ga and Analyaia," EPA-$42-X-95-001, May
199~.
'"Owde for Coll.ducting Trcatabllity Stu~ Under CERCLA -Chemical Dchalogcm.ation."
EPA/S40/R.·92'013a., May 1992.
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framework, the third level of testing ii during ~ implemC1ttation and d.Gt a legally bio<ling
decision is made by the govern.meat to use the selected tcdw.ology and fund the eleu.up. 'Ibis
level of tcmng dcfimtcly requirea the U1C of fb.118011• equipmmt aad the taana of ligai!oant
quantities of materials w allow all the 11eoeawy clew1ed data to be obtained. Moreover, for tbiA
third level cf telling, EPA bas 1111cticmed tu pra.ctice of .,pr.quaHfyiag• ono 0( more vaador£
based o.1t. the results pr~ during my ptMOU, treatamlity teaing at the Mlect:icm level
_ Biotqli,Qal Ima1mmt For mmy years vuious £onm ofbicmeatmeot have been puraued ~ ,; , .. f •. ,: mr PCB ~ups. hl the opillion of thia Sci1111oe Advisor, biottoaarmnt i& ~ot yet proven e1fective
· :r:: .J:·~~-.§ IDlt(reJiable on9ugb for Ule eb:ber as a. bl situ or CDC titu tec!molo!)', m Hf~~-~-~-~~!)~~~ ~rm
ox soJXIO oombm.ation of them, for the WumJ. Couuty application. While there i& no doubt that
lignificant biodegradation of some PCB congmcra oocm, under various ~ondition1, a tightly and
reliably controlled form ofbiotteatmcnt 1rom an cqjneaing per~c is not yet proven foT full
aoale oommeroial use.
Jn-mn Vitrificatioo This tcdmology baa b"'1 wd~ e,ctenlive dcvdopmart for mey
yeara, chiefly within the DOE system. While aomc people have VX\Wd this tedmoloey as a
variant of incineration, chiefly bCCIWIC it a:nptoy1 very high teq,eratures, it \llU&lly ill conlidered
as a unique technology. Buried wastes can be heated to melt all mat~rials and form a vitteovs or
. glassy material. The process thermally demoys oqanic OOD.tarninaots 111.d an extensive off lllit air
pollution control system ii uac:d. latereatixagly. ii October 1995 EPA has graAted Geosaf:e a
Na\ional TSCA Opcra1iDa Pcnnit for the aation-Mdc ucaunent of PCBs witruo a large number of
· prescnbed ctr~um•.anoes, _ incmding maximum average oonoentratioD.s of 14,700 ppm. and
maximum hot spot coacentratiom ot 11:86Q ppm. The company obtained this regulttoey permit
on the baSis ora sito demonstration tbat aehie\ied various performance crir.erb, mcluding mx ni:nH
destruction md removal dliaenoy and leu than 2 ppm PCB, in vitrified product. No detcc:tablc
dio,cins/t\irana were mund in off gue&. But the demonstration was aot on in litu waiitea &imila: to
the WUTm County ctuation. 11m *hnology mua be considered detomication, ad it offers the
comparative advantage ofbaing intrinsicaJly applkable for in mu treatment> avoiding the need for
e,(Cavation of materials. 1n theory, the tedmology could be applied directly to the Wurm County
Landfill, perhaps without dewatering the lite, dtbough the me'a locatfon. would pos. dgni&ant
problem for umg the extensive ~t.
ECO LOGIC Gu Phay Ch,otigJ lteduc;tipp Thi& techuology has beCll tcitcd within
EPA'_s SITE program oo materials contaiDhlg PCBs in 1992, and tecbmoAJ fea&l'bilily and safety
were demonlb'atcd; it ha■ also l,ecn demot1suated ill Cuada, where the vendor ia located. The
process opa-.tes in a hydrogen rich atmolpbere and iD the absence of oxygco, vtrtually preventing
the formation of dioxuu/furau u side products. The technology was improved after the EPA
test and now inootpOratos an improved desigD. in its first stage where contaminant, an d~sorbed
from soil in a heated ball mill A oommer~ unit can treat from 100 to 300 tons per day of
·-
~miaatccl toil. One S\Jch wait has been used in au Australian pmjffl and other uit is to be
uted by Gmeral Moton ud aDOther compaay iD. Cauda.
Brlef Coq,arttive Aaal),i, ID cc,nsMe:rmg tile requinmmts ofth• Warra County landfill
c;leanvp it it cJMr tM BCD techaolosY in ftet merits major tttentioD. One can tule out
biotteatmmt on the balil of .inmfficimt provai o11'ectivalcss, and probably iD ldtu wriaoadon on
the basis of insuf&~ Ail1 acale app1ioatioa. 11,.e other problem with m mu vitrifi.catiOll is tllat
'~
. there ia 110 limpt. or ooa-eft'ecdve way to WIit the tealm.ology for in situ me at W mm Coumy. It
is ~ .Ubly to be nmdl more CXJM!Dllve than BCD. 1he ECO LOGIC proceu, laowa\'$', cannot .··... . ,,_. '· ;_ b ~. __, L-"d . 1:r ___ _._...:.1:-....:.~ ... L.-_.... nr-e _, __ ,," -dtt' i·, · • · e PIIIIIIIIT-At. uvw. COD.A etltiOIL 1. 1 liiVIIIIUIA.~uvD .ual ~ on ~~-~~~ ... ~ ...... .-.
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. '
&Dy oommttci•lized From an enwomnmtal pcnpcc::tivc it far less likely than BCD to pose
problans with regud to to:idc air ~ The oompaay ha1 mobile equipm=t that co\lld be
teaed and uMd at the landftll. It probably ia ~• oompetitive with BCD. Therefore, if the
Worm1 Groap was to rcmam oouunitted to have field clcmoutrations of deto:id&ation
technology ia the near term, then it ic recommended dw it would be more bmcficial to consider
hrvia.g one BCD wa.dor a.ad ECO LOOIC perfoqn tests than to uve two BCD veadon nm t~a.
Field Dtnata•o:at101 of Itcla1a•oc ·
Field testing in pilot or tun scale equipmalt has been widely used in the toxic waste site
. __ Qleanup area. But it is impo:na1l1 to understand the reason, why this is JLOnDlllly done. There arc
· . two primary retiOti for .tleld demoutrationa. Fir,t, iD some case& the nature of 1he moedw
· tcdmology mous that 1hm are li.pmcant factors that are .location specific whioh afl'ect the
•.· paformmoe of the tedmology. Obviously, aay type ofin situ. tcdm.ololY mast be proven
· ·· · effective at a apeci& location. 1he core iaue ill these caaes is whether the tedmology is
dfectiYe. But for ttcauncmt i.c:tmologin £or which. excavated matmula are tile inputs, it i1 not
.. location tMt h of coacem.
hlstead, the issue is whether the technology ta effective on the apocific wa•ea &am the
· · · location .. Thia can be and umally u detcnnined by testiq ate waste with bench scale tochttology m the ven.dor'a f&cilit)-or m tome caMS ill pilot or fhll scale equipment that ii available eidim-It
. · the vendor's home location or at some other location where the equipmmt ii1 operating. 1he term
· trcatability test re&r, to thiJ kind of tetring to determine parbm.anoe c,r eftediveness f'or a
partic:war waste, but it is not onaite field tesmag.
Sceottd, 6eld testing is normally done aftl.r a vaador is Hl"'cd N tho lint lllop prior to
using full scale technology at JOll,ntnutn production (thtoupput) levels for the equipment at a site.
Demoutration, trial, or test activities at a lite ue done to verify that all previous conclu&i.on.s
about waste apoci& ~eness and technology/equipment Mfety and cnviromneutal
pe:rfo~ arc fully m.et ad, if appropriate. that regulatory requiremeab a.re satiafied. Uuw
vtry detaile(I tpeclficatio:ns are rn-, tbe vcdor on and should lose the job, aJthough normally the
6
vendor may be gi\'Cll more thin one try at mNtina the spoo1. Oacc ill a while a vador &ila to
pass the oalite tNt. and ather mother vendor ii 10Upt or a different remedial tedmology
coumerect.
AJSY field tett or dcmon-uation ia e,q,euive, DOt mady 1teoause of colts 1110<Utcd with
operating equipmmt, but mo because of the mbl&antiaJ oosu of moVD13 eqwpmmt to • location
ad aeumg i1 up tbere. Jf tedmaJn!Y ad vendor Nlecti.oa cm be dolle tacfqrc field testia1, it is
normal pt_1Clice to do so. More importaatly, if a field demonstrati0l1 i& d00e before a conimitment
· is made to a vendor for aeaual ate claauj,, dlim the costs ue even higher, because the i:. pres,umptiou ii that an the eqmpmmt wm llaYe to be nmoved from tll• ~. der comp:lttion of
::.: the field teet. -a.~--~~-...... ;,.,.._ __ .....;..
The situation. fot die Warren. County landfill is that my fiald demoutntion(s) will be done
before there ii any mm onrnrnitmmt by govemmmt aaon~e• to ftuid the cleanup aod before a
vecdor can be contracted to perform. the &n IClle clea.nup. lb.us, cost, will be high (beense
equip~ will have to be moved to the lite twiee) and the ri&b ft-om the vmdoi's per,pecrlve are
maximum, meaning that the vcdor will 1Mlnt to ~ all Wd demoD.ltntion 0osta. The
uncertam.ties of money, schedule 11 well as vendor selcctioD combine to mean that -when the
uncertainties are removed, my parricubr vendor, wen one 1hat ha& snoceslfully complc,tcd a .field
demonltration, may not get the job.
Monovcr, for the Wmm County lmdfill application, there really i$ n.o location il)l~C
uncerwntiN to be resolved for any 4ctoxi&aticm tedmoJogy based on treating eicRvated
materials. Treatability teas should be u.Nd to verily ptrlormancc and ~ea.ea for landfill
wastes, and cletailed ttatability tut report, lhould be produc.d to document test ruuh• to
IUpp()rt the technology lelectiou (the second level in EPA's framework).
for WaTal Comity, the main rcuon for ~dllcting a ficlcl demcna.stratiou of
detoxific:ation teQlmology 'Within the CUil'alt evaluation project seems to be to ruse the comfon
.. level of oocu;oming ~• about the technology md, particularly, about its safety for the
convhUnity. 1"hit could. be •c.eompluhed at ~aclera1,ly lower co• by brinsmg the people to the
teclm.ology rather than tb.e ttebnology to the people, however.
BCD VCIQdom A rcasoublc qucsd.on. to ask ts whether it is Aeees&ary or cost-d"ectivc to
· have more than one site demoutntioa of'BCD. It i& thia Scimoe Advisor's position that it is
neither n.cccsacy or eost-eff«:tive. Any BCD vador lbould be carefully evaluated on the basis
· of all previoua testing IDd tbD. sea.le use. No vendor should be aaed to perform a aite
dffltODt:tratiOJl if there arc serious unresolved issues or if the vondor is not comparable to another
that is deemed to be tile best available c:me.
If two BCD vcdon ped'onn site demmiarationa and meet all perfonnuice requirements,
then the main benefit obtained. ft-om th6 oontiderable costa ia that Wol'kiq Group members
achieve a "1tam comfon level with the vendors. Selecting oo.e of them still requires a carefW
7
analysis of data, not only the data ft-om dle tett, but al other iD!omMtion ,H '\Wll. Only the most
visibly ego~ volik•ty behavior by work.era would cauae m.t:mbeft to aee aome acdvtty at the
8ite 1hat apt be immpreted aa mmfe or sloppy. But nearly everything of importance ruts on
data. Tb.is athor's c,cpaia,.ce indicata that the cost ofa lite danoDstraUoll for BCD at Warren
COWlty w,11 probably be at bit $200,000, ad po.rhapa clo,a:-to $300,000 when all COit& are
accounted for. 1 · n.c coro .iaai.o ii whether oae C0\1ld inake a juclgmmt bated oo available
informati.oo. that there ii one clear -t>csl" BCD wndor or whelher two are comparable.
The Worldni Group should alto appreciate the toohnical reality that a lumted &ld tOlt
. : buecl on trcatlq a relatively mwl amount of ~taminated material is not ~ely to p1odu.ce
'~cat ldiable data to dcmiuvely alWa' bq>ortant questioa&, fllPOCiallt ,~~~~~~~~-~
amiaiou md ~ l,and\in1 problam&. ·
The answer to this qllCStion depends on the criteria used to .... atu-i. the mfonnation on
the vendors, but this is noPNI tecbnology .. ..,__.. A rea10Gable Mt of evaluation criteriA
oould be:
--,Eff;ctjygteu; weight of evidence for effcetivcneA Oil safely dcstToyins PCBs and ~8
aringent deaaup atandard&
•· Safm: spc;ifi~ mformation on control-, all wutesrream.s, particularly air emiuicms, and
mMtmS replatory requi:remattta
-Am1Mf£41 e,qu;riqce; proven experimee with JW1 SQalt cquipmeGt for ~1~ up sites
(paniculatly th., tpecifie ~utpmem wt would be uud in W uren County), Mpecially PCB litea,
and availability of equipimnt for actual Warren County cleanup
--Busbmaa pcmn,p,ngc; experience that climts have had with a vendor, in terms of reliability,
&chedules, estimates, rqulatoiy compliance, and prevention aad resolution of technical,
~e aad managerial problems
--CoL bbly coat, ll1d their uncertamtw
The odcb are that one BCD vaidor will surf&~ as superior Oil the basis of a total aoore for
aD evaluation criteria.. Tbis author bas previously evaluated the two vendon currently oouidfJted
as potential tedmology dcmoa.arators and more recently bas spoken to both companie, aa well as
--i-1.cvd of cost is oouislont with. E.PA's flgurts. which is that a level two remedy
telection treatability i.1t, narmaUy a laboratory type test, typically costs between U0,000 and
$100,000. EPA dc.cn'bed the cost for remody 91!1lection teatittg as moderate and for rmicdial
action u high.
a
1()1lM'JODe tt EPA fanu1iar with them.•
4-D 4lcmaativc StraflC)' for the Waa,n Couney '4ndftll Stcv•do•
TIit Mle p~ •f ,,_.ndq tldl alCll'lladvt nra~ h to offer tile WoritiD1
Croup an optioa that Ila, die pGtdtial lor 11tufyiD.a dleir primary 1oal. aamely obtailllin1
the mo1t effective and 1af .. t detoJ.fflcadon of die landf'al widlout flll'tha-leagday delays.
The real objcetivc ii l1C>t telting tedmology but in u,mg the best po•'l>le cleanup tedmology to
·: '. ·trt~ ... ~•~:·~=-:.=·= 1he altematm lttatel)' dalcrlbtd htft is r=~~~::,-..
With thia alterutivc strategy, detoxmcation teclmoloFOB a.cl vmdon would be
conaideted and carcfblly evaluated OJI. the bali1 of all available informa~ particularly ftom full
soalc applioaticn&, and thai a short list of'vendon would be determined, followed by veatability
teas and pruning otthe lhon liat. Working Group memhen could vitit the place where
treatability tNi:ing on Warm County LandBll wutea wtl permrmed.10 Vendors achieving
Cl(cellent treatability tut resws• WOllld thm be asked to provide an opportunity Cor a group of
people to visk an operatinJ fall scale facilky." Wor.k:ing Group members could apc:nd one or two
days at the lice, a, llCCCIAt)'.
From those Vllldon that .,..-the informlticm and site wk requirement&, a decision
wou.ld be made ad the "belt" vendor selected. For the selected vendor an agreen,ent would be
entered into so that the vendor would be pre-qualified for final selection, which would have to
wait until fimdmg wu aecured 1tom the state for the actual ~lcmup of the landfill The agreemeat
would at.a specify that the vendor wo'1ld have to mMl ~Cffloa$ in a Wd demonstration
prior to usms the ain scale eqwp~t at productiml rate& at the Warren County llndfiJJ
91"bk Scialce Advisor authored "Tcdu>.ology Asscssmcl\t -Treatment Tcolmologiea for
PCB Contaminated Sodiment ~ A White Papot oo the Hu4&oa. P.iv« PCB Cleanup." for Hudson
liv=r Sloop CLEMWATER. Nov. 1994. Both oompaic& gun-cudy being oouidered for site
demonstration were evaluated. SoilTech received the higbeat rating, while ETG 1hc lowest nm
eight technologies that were con.aidered viable ( out of a total of 14 ). However, there were some
aite speci1lc fac:tors eolllidered in the analysis, ad the coiq,anies hav1 progressed uce the
analysil waa performed.
1°In some respects, ~, a company's facility, mttring its personnel, a.d disaassing
teat.hlg IDd test rclUlts may have more impact OD. a peraon1, view of the vendor th111 sccmg liODlC
aspects of'• cite demonstratiOA.
11To aome extent. a vmclor that does n.ot have any of its eqwpmellt in operation
somewhere may be deemed leu delirable than one that doCi. In eome cases, a vendor could
operate equipment at ill own &cility to provide the neceewy oppommity.
9
. .
..
CUl'TCllrtly available ftmda oowd be uaecl to compeneatc the vendor for time and matciak
noc:c5Aty to mpport all Worldng Group and ate acdvmes for fio•Jiziu,1 the elcaDup
speci&ation1 and ot.h• upte11 of ~e remedial cletip, wt NOUriDg polmoal mpport for fimdbtg
the aauaJ cleanup. In other word,, several hwd,ed tholl1111d dollan would be 1p•t·oe what
would aormatly he IND a, techzrical .-:onsnlrins on remecJiat dclip rather than Oil a field tut
durin& the omrmt project. 12 Inoarpondng a tcdmotogy vm4or in rcmcdiat desi&n repreMDta
currmt attempts 1o greatly imptoVO tho prooeu for drains up lauardoua wute aites. '1
Wida thia ltrltegy the iJNe of obtaimaa political tupp0rt for I det0xification cleanup of
the i.nd611 dcsirod by the Wadrmg Group is foouaed cm mdmg alolle, 11.ot on toelm.ology
•Iection. Do~ so rCIIXJ'Yel riak and 1111"1'tainty nd even intentional~~ romlring .from
po~ or sovcrnmcat.J mriries taiaiDg questiou about tedmology, eitherbecau~se t1loyhavc
kaitimate tedmical QODcemt, wam t.o find• cheaper dCIIIUJ), or want to delay wnaldng a cleciaon.
Instead, oe annn!Q' aoal oftb,o CUJXSpt st :oripjon mcua w to SGks hnth scd:eo0JQO od • .,oclfi, vendor so thu the onb( Viillllbdoa vftid isae j5 fim4ina tor Jhc •mYl rwP111t n4 not
wbotho: clo1AAP ii PQQSiPO' Ot OP hpw it »ill be done ID other words, gwnmtly available .fundii
would be used to consolidate dedaion•making OD. die ftcmt..-d. of_tbe complex ptoceaa and
reduce rub for loager term failure io aocomplisb. the fuudamental goal of the Workina Group.
namely t~ we and timely detomcation of 1he landfiJl.
The eveunw danup baaed on my deto,dSc:,,don teolmology will ddmitoly ooc S20
million or: more. This strategy would ezuun that mf&imt money -was spem on obtaining
information on all ahemauve tedmologiea ( detodficatioa, tfll)amion, and t0nveotional), aking
121 unimpeachable CAM mr the daired tochnology md vm.dor, and on COU1)1ctc site m.veltisatiOll
and characteriutiOft that supporu actual rcmcdW deaign, includma the specification of amounu
'21d m,es of materials to be remediated (which may mean more teating of the site).
Most importantly, with this alternative mtegy it ii possible to devdop a IOUlld,
impressive ca,e for au ac.curtte estimate of actual cleanup cost, became more etfort is placed on
remedW design ""hich also allows the vendor (in conjunction with the •ate md the Soicu.ce
Advisors) to anivo at a finn Ntimat_ed cost. W'nh the 0WTent amegy, obtaining political IUJ)POrt
. fut appropriatini $20 million or more would t>. difficult bccauae of questiou raised about the
12-Another advantage of this ahemative matc1Y is that it would &~e making the
decisiOD. to remove exc.1& water &om the landfill at 111 earlier time; that u., after a veador is
IOleotod for the main oleanup t:alk of detoxi&aticm aad duriq di6 omrem projec:t .
•~ Sdcmce Adviaor. for cumple, ia CWTcntly ten'U1I II a t«hnicaJ advilor for a
co~ !Joup livmg near the Marzone Supemmd me m Georgia, and where 1hc PP.Pa and
EPA are uamg a procec, that .UOwed a tflclulomay v•dor (thermal desorption) to be selected
early cnoqh to allow padioip&tioJl in remedial design. The vcador will demonatm.e iu
eqwpmmt as tho 5rst ltep in the actual anaite cleanup. A diffe1cot t0mpany had previottdy
perfonncd a laboratory treatabillty test to support tho tochi1ology aeleotion decision.
10
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--
reliability of oo• •Mimates.
The ldectcd veador would be funded to support their iavolvemmt with site investigation
and tmmeliat delign tathcr than. auppon an iaitia1 field d~ prior to vendor lelection.
The aelc,Qted vc,n.dor wowd have to make a "-Oiiilhitment to make equipmmt IVlilable once
fimdmg for the act\la1 olemup was secured &om the staU. Fuadmg fbr the accv.al olcaaup would
iaohsde .fimCS. for -the cmme trial demonttration prior t0 fill! scale/producdoll use of the equ.ipa,eo.t,
which ia the normal procedure i>r: cleanup• today. 'Ibis type of pilot tostm.g of M1b1t&11tial
11DOUD.ta ofhazanloua material in fiaD-LM:lle equipmcm UIUl1ly lutl for • nwnber of days. Most
_ imponandy, ii allow• couklerable cbu to be obtained to uawer a11 -.,ottant aafety_ and
--: ~c. quwiao,. 1be &mil cu be '1un down for a period of weeks~· allow tbe data to . be
collected and analyzed. Al key perbmanc:e md safety crkcria would havcoooif previouilf'·.
ntablilbecl. Upon c;ertificaiion tut all criteria have bocm ftaD.y &&timed (1 p~ requiring
e,ctensive participation by the Science Advisors), the vmdor would be allowed to initiate full
production levcla of dctoxifioation oflmd!ll matmals Wlder appropriate ovmaight by the st.te
and the &cien.~ Advisors.
With the currmt strategy, 1 vendor that did a suc:'1CSldbl field teat before Amdmg was
_ .ecvrcd 1Dd had to remove the equipmmt would not necessarily have .quip.n:.-t available after
ftmdmg WU MCUJ"«i fot the cleaaup.
Fm.ally, this strategy offers a way co expedite obtaiomg poJitical aapport for the QNcial
docaon, wluch is functins 'lf the a=tl cleanup. not techbology ovaluatioll. Ally onsitc field
demonatration(1) will require GOllRClerablc time to plan, c:oncluct and evaluate as c:oq,arcd to the
activities ~at "vwd, under the altcmative matqy. ltad to both technology and vmdor aeleotion,
as wen aa reliable total cleanup oost estimarioa. Thi$ Science Advisor', e,q>erumce mdicate$ that a
aite d~a by • vendor will take 3 to S months, including plamua.g. execution. and report
preparation. Two site demonstrations would probably take a total of'S to 7 months uder the
most optimistic conditions a~t~ with back to back clomoutrations.
CONCLUSION
In. compariM>n. to the current categy, the ahem.at.iv• stntegy, in this Science Advisots
professional opinion, would more likely result in one sueceadul attempt to obtain .. ,fficient
fundm1 for • deto,dncation cla&wp. The emphaliJ 011 Vet)· care1ul analym of available
illformatlon. on vendors' experiences aaMJ eapabilaa and an treatal>ility tettma at the vendors
location. rather than field demonJtration at the fiitc ii todmk..Uy co~. beceuee their ~ no
locttiOll apcomo aspects to deto,cmcatio:u tcdmology that treats oxcavated material•. Onsito 6old
demon.atration of the teclm.ology mould occur u the first step of the actual cleanup. Tb.e main
reason for favoring 1he alternative 6ttategy is d1lt it would remlt in a package of tedmical and
economic information, indudiq i:,qmeerin.1 desip md cost data, that wouJd be more ~le(e
aed impressive aad, therefo~, more otpable of quicld)· aeouring political au.pptKt and funding.
11
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·--. : .-.·
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Thia it o.-pccia!y importmt because the cost of a detoxificatiM claanup will be mbatantw, at $20
million or more. The goal 0£ prcparillg men a package is to preempt any attempt by any party to
make • caae tlLat some other cleanup approacll detervcs more conli.cleration or o&ra tecluaical or
cconomic advantage& tllan the one aeleoted 1,y the Worlcing Group. · ·
'··I -~'
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12
Appendix for technology RFP
EXPLANATION OF SELECTION OF TWO DETOXIFICATION TECHNOLOGIES
A detailed technology screening, evaluation, assessment and comparative analysis has been
performed for tlle \N arren County PCB Landfill. All but nvo treatment technologies \Nere
screened ont. Ou1y Base Catalyzed Decomposition (BCD) and Gas Phase Chemical Reduction
technology were found to he appropriate and potentially feasible.
The original use of the term detoxification technology by the state of North Carolina implies that
technologies that are considered cleanup or remedial technologies but that do not by themselves
detox.iiy PCBs are not appropriate for the Warren County situation. Potential feasibility has had
to be demonstrated through prior successfol full scale use of a technology for PCB detoxification
work
All forms of containment technology such as caps and subsurface banier walls have been ntled
out as being inappropriate.
All forms of separation technologies that do not actually detoxify through treatment have beeu
mled out. TI1ese include, for example, them.1al desorption, solvent ex·traction, soil washing, and
~oil vapor eA-craction.
All forms of stabilization/solidification have been eliminated as inappropriate, because they have
not been thoroughly proYen to actually and permaneut]y ci.estroy PCB molecules, rendering them
permanently nontoxic.
Any use of high temperarnre incineration has been rnled out as being inappropriate because of its
potential for causing harmfol toxic air emissions and its long history of being deemed
nn.acceptabk by communities, especially when used iu locations close to residential areas.
All forn1s ofbiotreatment or bioremediation have been screened out on the basis ofiusufficieut
proveu effectiveness. For many years various fonns ofbiotreatment have been pursued for PCB
cleanups. TI1e conclusion has been reached that biotreatment is not yet proven effective and
reliable enough for full scale use either as an in situ or ex situ technology, in aerobic or anaerobic
form or some combination of them, for the Wanen County applicatiou.
ln situ vitrification has been screened out because of insufficient full scale applicatio:1.1. This
technology has been wider e:x.1ensive development for many years, chiefly within the DOE sy~tem
While some people have viewed this technology as a variant of incineratio~ chiefly because it
employs very high temperatures, it usuaJJy is considered as a unique technology. Bmied wastes
can be heated to melt all materials and form a vitreous or glassy material. The process thermally
destroys organic contaminants and an ex1ensi:ve offgas, air pollution control system is used.
Interestingly, in October 1995 EPA granted Geosafe a National TSCA Operating Permit for the .. ~
I
r-"'. LL
Fi:;.:0t1
natiou-\-vide treatment of PCBs \Vithin a large number of prescribed circumstances, including
ma.\..'lIIllllll average concentrations of 14,700 ppm and maximum hot spot concentrations of 1 i ,860
ppm The company obtained this regulatory permit on the basis of a site demonstration that
achieved various performance criteria, including six nines destruction and removal efficiency and
less than 2 ppm .PCBs in vitrified product. No detectable dioxins/forans were found in offgases.
But the demonstration was not on in situ wastes similar to the Warren County situation. This
technology must be considered detoxifica6on, and it offers the comparative advantage of being
intrinsical.ly applicable for in situ treatment, avoiding the need for excavation of materials. lu
theory, the technology could be applied directly to the Warren County Landfill, perhaps without
dewatering the site. although the site's location would pose significant problem for usiJJg the
ex-tensive equipment. The conclusion has been reached that this teclmology is not acceptable or
foasib.le for the Wanen Cow1ty application, and that it could not be suitably evaluated through
bench-scale testing.
Because the objective is to select a detoxification technology that has already been proven
effective for PCB detox.-ification through full scale, commercial use, an.d that will b~ demonstrated
effective for frill scale application at the Waneu County PCB Land.fill on the basis of bench-scale
t~sting of site contammated soils, no technology that has not yet been fully deployed in a full scale
detoxification of PCB wastes will be considered appropriate and potentially effective for this
applicarion. No technology that exists only as a research or developmental technology is deemed
appropriate and potentially feasibl~ for this application aud, therefore, for bench-scale testing.
2
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