NCD980602163_20030305_Warren County PCB Landfill_SERB C_Letter to Jim Warren-OCR

March 5, 2003
Mr. Jim Warren
NC WARN
PO Box 61051
Durham, NC 27715-1051
RE: Response to Letter Dated January 27th
Warren County PCB Landfill Project
VIA HAND DELIVERY
Dear Mr. Warren:
Attached are responses to your questions raised in the referenced letter. Included with the
responses are batch summary reports and the latest air monitoring results. Please feel free to call
us if you have additional questions or require further information.
Sincerely,
Pat Backus, P .E.
PCB Landfill Project Manager
/attachment
c: Jim Cloonan, Earth Tech
Bill Gallagher, Shaw
Dollie Burwell
1 e
Deputy Director, DENR-DEH
Patrick Barnes, Community Technical Advisor
Terry Lyons, USEPA
CAB Office
RESPONSE TO LETTER FROM JIM WARREN DATED JANUARY 27, 2003
1. Please provide a written explanation to confinn the number and percentage of batch failures
to date, and provide regular updates to the CAB about batch failures.
A. In the future, the Citizens Advisory Board (CAB) will be provided with monthly batch
summary reports. The reports for January and February of 2003 are shown as Attachments I
and 2. Shaw also provides a detailed batch summary report (Attachment 3) at the end of each
month to the technical staff and technical community advisor.
The reports indicate the number and percentage of batches passing since the beginning of the
project, since the shakedown period and for the individual months. The reports show the
passing percentage both in tenns of the number of batches and the weight of batches since the
batch amount varies. During the shakedown period, Shaw was adjusting operating parameters
based on the contaminated soil conditions. Almost half of the failures occurred during this
period. The average PCB concentration is also listed for all batches passing and for the
month of the report. Since January I st, only one batch out of 38 has failed.
2. Please provide a written explanation as to why the community should not be concerned about
air emissions given the high percentage of batch failures. Specifically, why do you believe
there is no correlation between batch failures and air emissions?
A. The detoxification system works by using heat to evaporate PCBs from the soil and into an
inert (low oxygen content) carrier gas. The system operates under a slight vacuum and the
carrier gas is sucked from the desorber into the air pollution control system. Process gas is
not emitted to the atmosphere at the desorber
In the air pollution control system the gas is cooled and the PCBs are condensed into a liquid
phase for further treatment. Most of the gas is then recycled back through the desorber for
use as carrier gas. A small percentage ( <10%) is vented. Before venting, the gas is treated
through High Efficiency Particulate Air (HEPA) filters and carbon adsorption systems. This
treated vent gas is the process stack gas that is emitted to the atmosphere.
The operation of the air pollution control system is somewhat independent from the desorber
operation. Adjusting operating parameters of the components of that system rather than of
the desorber controls perfonnance. The stack gas has been analyzed several times as part of
the TSCA permitting process and has been well below TSCA requirements.
There have not been a high percentage of batch failures (see response to Question I). In
addition, a review of the perimeter air monitoring data shows no correlation between batch
failures and PCB concentrations measured at the perimeter. On sampling periods when the
individual result exceeded the annual standard (which was mistakenly referred to as an
exceedance ), the corresponding batches being treated passed. This result can be verified by
comparing the Summary of Air Monitoring Results (Attachment 4) with the batch log
summary report.
3. Please provide a written explanation for "scheduled maintenance" shutdowns and a copy of
the protocol related to such shutdowns: Is there an actual schedule? What is the frequency
and duration? When are future maintenance outages scheduled? What specific maintenance
functions are preformed?
A. Maintenance shutdowns are rarely scheduled very far in advance unless a crane or other
special equipment that requires advance notice is needed. The next scheduled shutdown of
this type will most likely be to remove one of the two cyclones ( only one is operated at a
time) to enable it to be rebuilt for later reinstallation. Other reasons for shutdown would be
to accommodate special events such as the performance demonstration test in January, where
the EPA contractor had to be scheduled months in advance and could not readily change their
schedule and for holidays such as Christmas to allow the crews to go home for the holidays.
Many routine maintenance functions can be and are performed with the system in operation.
If a non-critical equipment problem (one that does not force an immediate shutdown) that
cannot be fixed during operations becomes apparent, it is noted on a list kept by the
operators. Many times the necessary parts are already on hand at the site. If not, parts are
ordered and delivered to be on hand so that the problem can be fixed during the next forced
outage.
The procedures for shutting down for scheduled maintenance are the same as for any
controlled shutdown. Briefly, the soil feed to the unit is stopped and the desorber is allowed
to run until it empties itself of soil. After there is no more soil in the system, the liquid and
gas treatment systems are shut down. Finally the nitrogen gas, which is used to inert the
system, is shut off.
All outages, whether scheduled or not, are noted on a daily "Plant Operations Report"
prepared by Shaw. Earth Tech also includes scheduled outages on their "Daily Progress
Report." Both reports are e-mailed to several people, including the technical community
advisor, Patrick Barnes. Shaw or Earth Tech staff can be contacted for more details.
4. Why did neither Shaw nor Earth Tech's on-site officials order shutdown of the equipment,
instead of the call being made when Jim Cloonan came into town? Also, what was the
specific nature of the problem with the pollution controls? How long had the problem
existed? Has that particular type of problem, or any other problem with pollution controls,
occurred since the project began?
A. As described at the community meeting on February 4th at the John Graham Center, Earth
Tech's on-site representative Dennis Jones ordered the shutdown of the equipment based on
opacity from the product cooler. Under the project protocols, Dennis informed the Earth
Tech project manager, Jim Cloonan, of the shutdown and cause. The problem had been
observed for approximately one hour, as Shaw was given an opportunity to rectify the
situation prior to shutdown. This was the only occurrence to date of this situation. Since the
shutdown, Shaw has switched to another cyclone and there have been no other reasons for
shutdown.
5. Please provide a list of any other shutdowns of any component of the decontamination
equipment stream since the project began, and describe the specific reason for the shutdown.
A. There have been no other instances of Earth Tech requiring shutdown of the equipment.
Shaw has shutdown the equipment for maintenance and the unit has gone down when ice
storms have caused interruption in the power supply.
6. Was ambient air sampling conducted when the cyclone malfunction was discovered in order
to determine the potential exposure to workers or the community? If not, why not? If so, has
the data been returned yet?
A. The unit was shutdown on January 2nd• PCB and dioxin concentrations cannot be determined
with a direct reading instrument but instead require a 48-hour sampling event as is performed
for perimeter air monitoring. Ambient monitoring was not scheduled for that week, as the
Performance Demonstration Test was scheduled for the following week and this involved a
full monitoring effort. The cyclone is located after the desorber and any particulate emissions
would have been of treated soil. The PCB concentration of the batch produced during that
time period was below the quantitation limit, the lowest concentration that could be
measured, of 33 ppb. To date all ambient air parameters have been within the North
Carolina ambient air guidelines.
7. Please explain the two exceedances for dioxin and the two for PCBs, and explain why the
community should not be concerned.
A. Earth Tech apologies for the inadvertent use of the term "exceedance" to describe individual
air monitoring results. The perimeter air monitoring system detects emissions from all site
operations not just the treatment unit, e.g. excavation of contaminated soil from the landfill
and handling of soil before processing. The North Carolina ambient air guidelines are annual
standards. Individual results are averaged over time for comparison with these standards for
PCBs, dioxins/furans, and particulates. As of the second week of full-scale operation on
January 16th (the latest results available), all monitoring stations and the landfill are within the
State average guidelines. However, there have been a few instances where individual stations
were above the annual limit. When this has occurred, Earth Tech has reviewed the operating
conditions to determine potential causes and recommended modifications to Shaw ( e.g.,
housekeeping on Pad I).
8. Why was technical advisor Patrick Barnes told on January 8th that were no exceedances from
ambient air sampling? After visiting the landfill and learning the next day that there had been
exceedances, he had to revise his report to the CAB on the day of the CAB meeting, causing
him to miss much of the meeting.
A. As explained in Response #7, there have been no exceedances. Air monitoring results are
issued after the analyses have been validated and the concentrations calculated. In the case
noted, the validation was received after Mr. Barnes visited the site on January 8th• In the
future, Mr. Barnes will continue to be provided with the updated air monitoring results once
the analyses have been validated and the concentrations calculated.
PMB ATTACHMENT1 Warren County PCB Landfill Detoxification Project Soil Processing Information Total Number of Batches Total Number of Batches Treated1 Total Number of Batches Failingb Total Number of Passing Batches Total Batches Passing Batches Passing since 9/12/2003 Jan 03 -Number of Batches Jan 03 -Batches Passing Jan 03 -Batches Passing a Batches 5 and 8 were the same material. Batch 8 was created when material was resampled and placed in another bin. b Five batches failed at the beginning of treatment from 8/24/2002 through 9/12/2002. 72 71 11 60 84.5% 90.9% 19 19 100.0% through 1/31/2003 Total Weight of Material Processed Total Weight of Residuals Recycledc Weight of Soil Processedd Weight of Passed Batches Total Soil Passing Soil Passing since 9/12/2003 Total Ave PCB Concentration Jan 03 -Weight of Soil Processed Jan 03 -Weight of Soil Passing Jan 03 -Soil Passing Jan 03 -Ave PCB Concentration cResiduals recycled are mainly soil particles removed by air pollution control system in the form of filter cake. d1735.64 tons failed at the beginning of treatment from 8/24/2002 through 9/12/2002. 200301 Rpt 27,689 tons 988 tons 26,701 tons 22,911 tons 85.8% 91.8% 0.126 ppm 6,939 tons 6,939 tons 100.0% 0.153 ppm 1/31/2003
PMB ATTACHMENT 2 Warren County PCB Landfill Detoxification Project Soil Processing Information Total Number of Batches Total Number of Batches Treated• Total Number of Batches Failingb Total Number of Passing Batches Total Batches Passing Batches Passing since 9/12/2003 Feb 03 -Number of Batches Feb 03 -Batches Passing Feb 03 -Batches Passing a Batches 5 and 8 were the same material. Batch 8 was created when material was resampled and placed in another bin. b Five batches failed at the beginning of treatment from 8/24/2002 through 9/12/2002. 91 90 12 78 86.7% 91.8% 19 18 94.7% through 2/28/2003 Total Weight of Material Processed Total Weight of Residuals Recycledc Weight of Soil Processedd Weight of Passed Batches Total Soil Passing Soil Passing since 9/12/2003 Total Ave PCB Concentration Feb 03 -Weight of Soil Processed Feb 03 -Weight of Soil Passing Feb 03 -Soil Passing Feb 03 -Ave PCB Concentration cResiduals recycled are mainly soil particles removed by air pollution control system in the form of filter cake. d1735.64 tons failed at the beginning of treatment from 8/24/2002 through 9/12/2002. 200302 Rpt 34,834 tons 1,241 tons 33,594 tons 29,389 tons 87.5% 92.2% 0.131 ppm 6,902 tons 6,477 tons 93.8% 0.148 ppm 2128/2003
ATTACHMENT 3 Warren County PCB Landfill Detoxification Project NC sco Project ID#010440101A Shaw project #827062 Treated Soil Batch Weight and Treatment Certification Log A 8 C D E F G H I J K L M N 0 p Q R s T u V w Results of PCB analysis approved Weighted Balch# Bin# Date Time Date Time Belt scale Belt scale Belt Residuals Net tons Shaw Name of Lab Lab (mg/kg=ppm) Approved, Rejected, Total tons Total tons batch Running Avg PCB complete complete start start complete start scale recycled for batch sample# lab report# report or0.5 of BQL can be must be approved rejected tons•PCB Total of =V/S ltons\ ttons\ net tons (tons) date must be <0.5 backfilled retreated =K•P col U must be <0.2 1 1 08/24/02 20:15 08/23/02 16:45 354.22 30.61 323.61 1.75 321.86 01-001 Toxikon 0208307-01A 08/24/02 1.1 1 321.86 0.0000 0.0000 #DIV/01 2 2 08/27/02 18:30 08/24/02 20:15 780.39 354.22 426.17 15.75 410.42 02-002 Toxikon 208306 08/29/02 0.91 1 732.28 0.0000 0.0000 #DIV/01 3 3 08/29/02 20:12 08/27/02 18:30 1182.98 780.39 402.59 5.30 397.29 03-003D Toxikon 209086 09/11/02 6 1 1129.57 0.0000 0.0000 #DIV/01 4 4 08/30/02 4:05 08/29/02 20:12 1 269.07 1 182.98 86.09 1.80 84.29 04-004 Toxikon 209087 09/11/02 0.0285 1 84.29 1129.57 2.4023 2.4023 0.029 5 1/6 09/07/02 18:30 09/06/02 16:27 1 538.22 1 276.72 261.50 8.58 252.92 06-008 Paradiam 52679 09/17/02 0.98 1 84.29 1 382.49 0.0000 2.4023 0.029 6 2 This was small amount (6.77 tons) of material returned to the oole barn 01-006 Toxikon 020987-03A 09/11/02 3.2 1 84.29 1 382.49 0.0000 2.4023 0.029 7 2 09/12/02 11:16 09/11102113:23 1 904.07 I 1 544.99 I 359.08 5.93 353.15 02-007 Parediam 52519 09/13/02 0.55 1 84.29 1 735.64 0.0000 2.4023 0.029 8 Batch 8 was created when batch 5 was moved from bin 1 to bin 6 • Results are shown under batch 5 84.29 1 735.64 0.0000 2.4023 0.029 9 4 09/13/02 18:57 09/12/02 11:16 2 403.90 1 904.07 499.83 23.04 476.79 04-009 Paradiam 52680 09/17/02 0.17 1 561.08 1 735.64 81.0543 83.4566 0.149 10 3 09/14/02 12:18 09113/02 19:10 2 652.76 2 403.90 248.86 8.25 240.61 03-010 Paradiam 52681 09/17102 0.19 1 801.69 1 735.64 45.7159 129.1725 0.161 11 3 09/24/02 14:04 09/23/02 20:30 2 894.67 2 652.76 241.91 9.55 232.36 03-011 Paradiam 53245 09/25/02 0.18 1 1 034.05 1 735.64 41.8255 170.9980 0.165 12 2 09/25/02 14:06 09/24/02 14:04 3 232.12 2 894.67 337.45 12.60 324.85 02-012 Paradiam 53348 09/26/02 0.1 1 1 358.90 1 735.64 32.4850 203.4830 0.150 13 1 09/26/02 5:42 09125/02 14:06 3 476.49 3232.12 244.37 23.00 221.37 01-013 Paradiam 53477 09/27/02 0.0165 1 1 580.27 1 735.64 3.6526 207.1356 0.131 14 3 09/27/02 14:25 09/26/02 13:45 3 839.83 3 476.49 363.34 24.82 338.52 03-014 Paradiam 53540 09/30/02 0.28 1 1 918.79 1 735.64 94.7856 301.9212 0.157 SHAW INVOICE #19 FOR PERIOD THROUGH 9/30/02 COVERED THROUGH BATCH #14, TOTAL INVOICED TONS TO DATE• 1,918.79. 1,918.79 1,735.64 0.0000 301.9212 0.157 131 CORRECTION TO BATCH 13 ACTUAL RECYCLED TONS •23.95 I 0.95 I /0.95\ 0.0165 1 1 917.84 1 735.64 -0.0157 301.9055 0.157 CORRECTION ON LINE ABOVE WAS MADE AFTER SHAW INVOICE #19 WAS PREPARED ADJUSTMENT TO BE REFLECTED ON INVOICE #20 FOR OCTOBER WORK. 1 917.84 1 735,64 0.0000 301.9055 0.157 15 2 10/01/02 14:15 09/30/02 10:15 4 248.00 3 839.83 408.17 8.88 399.30 02-015 Paradiam 53722 10/14/02 0.375 1 2 317.14 1 735,64 149.7356 451.6411 0.195 16 1 10/02/02 11:07 10/01/02 14:15 4 582.00 4 248.00 334.00 8.23 325.77 01-016 Paradiam 53834 10/03/02 0.017 1 2 642.91 1 735,64 5.5381 457.1792 0.173 17 3 10/03/02 10:10 10/02/02 11:07 4 947.30 4 582.00 365.30 6.37 358.93 03-017 Paradiam 53970 10/04/02 0.017 1 3 001.84 1 735,64 6.1018 463.2810 0.154 18 4 10/04/02 14:37 10/03/02 10:10 5 405.90 4 947.30 458.60 8.60 450.00 04-018 Paradiom 54090 10/07/02 0.06 1 3 451.84 1 735.64 27.0000 490.2810 0.142 19 1 10/05/02 6:30 10/04/02 14:37 5 634.49 5 405.90 228.59 4.26 224.33 01-019 Paradiom 54091 10/07/02 0.017 1 3 676.17 1 735.64 3.8136 494.0947 0.134 20 3 10/09/02 14:00 10/08/02 13:08 6 133.60 5 634.49 499.11 22.60 476.51 03-020D Paradiam 54476 10/14/02 0.055 1 4 152.68 1 735.64 26.2081 520.3027 0.125 21 2 10/10/02 8:30 10/09/02 14:00 6 515.00 6133.60 381.40 5.40 376.00 2-0210 Paradiam 54477 10/14/02 0.068 1 4 528.68 1 735.64 25.5680 545.8707 0.121 22 1 10/11/02 10:16 10/10/02 8:30 7 018.50 6 515.00 503.50 7.09 496.41 1-022 Paradiam 54478 10/14/02 0.0165 1 5 025.09 1 735.64 8.1908 554.0615 0.110 23 4 10/13/02 3:30 10/11/02 14:38 7 717.12 7 018.50 698.62 18.80 679.82 4-023 Paradiam 54545 10/15/02 0.017 1 5 704.91 1 735.64 11.5569 565.6184 0.099 24 2 10/16/02 14:45 10/15/02 15:45 8 108.47 7717.12 391.35 6.77 384.58 2-024 Paradiam 54756 10/17/02 0.21 1 6 089.49 1 735.64 80.7618 646.3802 0.106 25 1 10/17/02 14:05 10/16/02 14:45 8 545.00 8 108.47 436.53 15.50 421.03 1-025 Paradiam 54848 10/18/02 0.13 1 6 510.52 1 735.64 54.7339 701.1141 0.108 26 3 10/18/02 22:00 10/17/02 14:05 8 945.00 8 545.00 400.00 22.88 377.12 3-026 Paradiam 54996 10/21/02 0.08 1 6 887.64 1 735.64 30.1696 731.2837 0.106 27 4 10/20/02 2:40 10/18/02 22:00 9 468.73 8 945.00 523.73 10.44 513.29 4-027 Paradiom 55049 10/22/02 0.076 1 7 400.93 1 735.64 39.0100 770.2937 0.104 26 1 10/23/02 5:00 10/21/02 23:30 9 928.20 9 468.73 459.47 24.55 434.92 1-028 Paradiom 55228 10/24/02 0.069 1 7 835.85 1 735.64 30.0095 800.3032 0.102 29 2 10/24/02 14:09 10/23/02 5:00 10 504.00 9 928.20 575.80 15.70 560.10 2-029 Paradiam 55308 10/25/02 0.092 1 8 395.95 1 735.64 51.5292 851.8324 0.101 30 3 10/27/02 9:00 10/24/02 '14:09 11100.00 10 504.00 596.00 13.71 582.29 3-030 Paradlam 55536 10/29/02 0.087 1 8 978.24 1 735.64 50.6592 902.4917 0.101 31 1 10/28/02 13:10 10/27/02 9:00 11 580.00 11100.00 480.00 16.05 463.95 1-031 Paradiam 55537 10/29/02 0.55 1 8 978.24 2 199.59 0.0000 902.4917 0.101 32 2 10/29/02 16:05 10/28/02 13:10 12 083.00 11 580.00 503.00 6.93 496.07 2-032 Paradiam 55675 10/31/02 0.29 1 9 474.31 2 199.59 143.8603 1046.3520 0.110 33 4 10/30/02 17:30 10/29/02 16:05 12 533.92 12 083.00 450.92 14.04 436.88 4-033 ParadiQm 55762 11/01/02 O.D75 1 9 911.19 2 199.59 32.7660 1079.1180 0.109 SHAW INVOICE #20 FOR PERIOD THROUGH 10/31/02 COVERED THROUGH BATCH #33, TOTAL INVOICED TONS TO DATE• 9,911.19, NET FOR PERIOD• 7,992.40. 9,911.19 2,199.59 0.0000 1079.1180 0.109 34 1 11/03/02 18:30 11/02/02 17:28 12 984.00 12 533.92 450.08 27.91 422.17 1-034 Paradiam 55951 11/05/02 1.2 1 9 911.19 2 621.76 0.0000 1079.1180 0.109 35 2 11/05/02 18:30 11/03/02 18:30 13 076.81 12 984.00 92.81 31.81 61.00 2-035 Paradiom 56247 11/07/02 0.0165 1 9 972.19 2 621.76 1.0065 1080.1245 0.108 36 4 11/08/02 23:59 11/07/02 17:20 13 606.00 13 076.81 529.19 20.92 508.27 4-036 Paradiam 56563 11/12/02 0.018 1 10 480.46 2,621.76 9.1489 1089.2733 0.104 37 3 11/12/02 19:00 11/11/02 14:36 14 062.32 13 606.00 456.32 20.02 436.30 3-037 Paradlom 56706 11/14/02 0.066 1 10 916.76 2 621.76 28.7958 1118.0691 0.102 38 2 11/14/02 0:10 11/12/02 19:00 14 518.00 14,062.32 455.68 10.28 445.40 2-038 Paradiom 56841 11/15/02 0.24 1 11 362.16 2 621.76 106.8960 1224.9651 0.108 39 4 11/14/02 14:00 11/14/02 0:10 14 729.86 14 518.00 211.86 8.97 202.89 4-039 Paradiam 56842 11/15/02 0.12 1 11 565.05 2 621.76 24.346 8 1249.3119 0.108 40 3 11/16/02 23:00 11/15/02 19:05 15193.50 14 729.86 463.64 18.83 444.81 3-040 Paradiam 57173 11/19/02 0.033 1 12 009.85 2 621.76 14.6786 1263.9905 0.105 41 2 11/17/02 19:00 11/16/02 23:00 15 484.42 15 193.50 290.92 9.06 281.86 2-041 Paradiam 57174 11/19/02 0.11 1 12291.72 2 621.76 31.004 8 1294.9953 0.105 42 4 11/21/02 13:15 11/20/02 4:45 15 962.60 15 484.42 478.18 27.15 451.03 4-042 Paradiam 57441 11/22/02 0.04 1 12 742.74 2 621.76 18.041 1 1313.0364 0.103 43 3 11/23/02 3:15 11/21/02 13:15 16 512.45 15 962.60 549.85 15.66 534.19 3-043 Paradiam 57573 11/25102 0.045 1 13 276.93 2 621.76 24.038 6 1337.0750 0.101 44 2 11/24/02 11:00 11/23/02 3:13 16 945.39 16 512.45 432.94 17.76 415.18 2-044 Paradiom 57686 11/26/02 0.093 1 13 692.11 2 621.76 38.611 7 1375.6867 0.100 45 4 11/29/02 1:35 11/27/02 3:00 17 518.23 16 945.39 572.84 15.21 557.63 4-045 Paradiom 57921 11/29/02 0.24 1 14 249.74 2 621.76 133.831 2 1509.5179 0.106 SHAW INVOICE #21 FOR PERIOD THROUGH 11/30/02 COVERED THROUGH BATCH #45, TOTAL INVOICED TONS TO DATE• 14,249.74, NET FOR PERIOD• 4,338.55 14,249.74 2,621.76 0.000 0 1509.5179 0.106 46 3 I 11/30/02 I 11:00 I 11/29/02 1:351 17 860.66 I 17 518.23 342.43 20.53 321.90 3-046 Paradiom 58060 12/03/02 1.00 1 14 249.74 2 943.66 0.000 0 1509.5179 0.106 47 2 12/02/02 1:09 I 11/30/02 18:30\ 18 273.77 I 17 860.66 I 413.11 8.90 404.21 2-047 Paradiam 58061 12/03/02 0.089 1 14 653.95 2 943.66 35.974 7 1545.4926 0.105 481 1 12/04/02 21:00 I 121021021 1:09 I 18 758.64 I 18 273.77 I 484.87 19.00 465.87 1-048 Paradiam 58851 12/13/02 0.98 1 14 653.95 3 409.53 0.000 O 1545.4926 0.105 Shutdown for oower outa e due to ice storm lost 8.58 dav1 crocessina time 14 653.95 3 409.53 0.000 0 1545.4926 0.105 49 4 12/16/02 14:45 12/13/02 10:50 19 427.75 18 758.64 669.11 16.76 652.35 4-049 Paradiam 59119 12/18/02 0.42 1 15 306.30 3 409.53 273.987 0 1819.4796 0.119 50 3 12/16/02 23:22 12/16/02 15:18 19 544.20 19 427.75 116.45 13.46 102.99 3-050 Paradiam 59120 12/18/02 0.07 1 15 409.29 3 409.53 7.209 3 1826.6889 0.119 51 2 12/21/02 2:00 12/19/02 14:33 20 033.18 19 544.20 488.98 21.69 467.29 2-051 Paradiam 59493 12/24/02 0.0145 1 15 876.58 3 409.53 6.775 7 1833.4646 0.115 52 3 12/22/02 8:29 12/21/02 2:00 20 449.50 20033.18 416.32 32.52 383.80 3-052 Paradiom 59494 12/27/02 3 1 15 876.58 3 793.33 0.000 0 1833.4646 0.115 53 1 12/22/02 16:15 12/22/02 8:29 20 554.98 20 449.50 105.48 10.71 94.77 1-053 Paradiam 59495 12/24/02 0.085 1 15971.35 3 793.33 8.055 4 1841.5201 0.115 SHAW INVOICE #22 FOR PERIOD THROUGH 12/31/02 COVERED THROUGH BATCH #53, TOTAL INVOICED TONS TO DATE• 15,971.35 NET FOR PERIOD• 1 721.61 15,971.35 3,793.33 0.000 0 1841.5201 0.115
54 4 01/02/03 330 12/31/02 13:32 21,102.64 20,554.98 547.66 11.88 535.78 4-054 Paradiam 59857 01/03/03 0.0165 1 55 2 01/02/03 11:45 01/02/03 4:30 21,208.01 21,102.64 105.37 105.37 2-055 ParadiQm 59858 01/03/03 0.0165 1 56 2 01/08/03 0:35 01/07/03 1:01 21,613.27 21,208.01 405.26 25.52 379.74 2-056 Paradiqm 60322 01/09/03 0.46 1 57 4 01/09/03 6:05 01/08/03 0:35 22,084.94 21,613.27 471.67 9.23 462.44 4-057 Paradiqm 60516 01/10/03 0.016 1 58 1 01/09/03 14:05 01/09103 6:05 22,271.20 22,084.94 186.26 3.64 182.62 1-058 Paradiom 60517 01/10/03 0.061 1 Times and belt scale readinqs for 57 and 58 "ad·usted" to make qraphinq spreadsheet work, 58 (which was the two 4 hour "spiked" runs of performance demo test) was actually done in the middle of 57. 59 3 01/11/03 2:00 01/09/03 22:37 22,745.68 22,271.20 474.48 19.76 454.72 3-059 Paradiqm 60679 01/13/03 0.19 1 60 2 01/11/03 23:59 01/11/03 2:00 23,114.27 22,745.68 368.59 14.91 353.68 2-060 Paradiam 60680 01/13/03 0.08 1 61 4 01/14/03 11:12 01/12/03 19:00 23,628.50 23,114.27 514.23 28.35 485.88 4-061 Paradiom 61141 01/15/03 0.13 1 62 2 01/15/03 14:05 01/14/03 11 :12 23,997.50 23,628.50 369.00 6.64 362.36 2-062 Paradiam 61258 01/16/03 0.16 1 63 3 01/16/03 14:05 01/15/03 14:05 24,352.10 23,997.50 354.60 7.44 347.16 3-063 Paradiam 61397 01/17/03 0.14 1 64 4 01/17/03 14:00 01/16/03 14:05 24,686.20 24,352.10 334.10 8.18 325.92 4-064 Paradiam 61550 01/20/03 0.15 1 65 2 01/18/03 16:00 01/17/03 14:00 25,037.60 24,686.20 351.40 4.99 346.41 2-065 Paradiam 61553 01/20/03 0.15 1 66 3 01/21/03 13:00 01/18/03 16:00 25,492.00 25,037.60 454.40 18.04 436.36 3-066 Paradiam 61667 01/22/03 0.24 1 67 4 01/22/03 15:15 01/21/03 13:00 25,892.00 25,492.00 400.00 6.67 393.33 4-067 Paradiam 61815 01/23/03 0.23 1 68 2 01/23/03 15:00 01/22/03 15:15 26,237.00 25,892.00 345.00 4.39 340.61 2-068 Paradiam 61831 01/24/03 0.19 1 69 3 01/25/03 8:00 01/23/03 15:00 26,559.89 26,237.00 322.89 32.06 290.83 3-069 Paradiam 62047 01/28/03 0.093 1 70 2 01/27/03 23:00 01/26/03 23:00 26,898.48 26,559.89 338.59 17.92 320.67 2-070 Paradiam 62161 01/29/03 0.24 1 71 4 01/30/03 8:00 01/28/03 18:00 27,438.50 26,898.48 540.02 13.55 526.47 4-071 Paradiam 62388 01/31/03 0.038 1 72 3 01/31/03 6:30 01/30/03 8:00 27,734.04 27,438.50 295.54 6.86 288.68 3-072 Paradiam 62391 01/31/03 0.3 1 Ad·ust aporoved tonnaae to deduct 2 tons of soil contaminated with diesel fuel from 11/6/02 2.00 12.00 1 Adjust aooroved tonnaoe to deduct 1 ton of soil contaminated with PCBs from oad 1 1.00 11.00 1 SHAW INVOICE #23 FOR PERIOD THROUGH 1/31/03 COVERED THROUGH BATCH #72, TOTAL INVOICED TONS TO DATE= 22,907.38, NET FOR PERIOD= 6,936.03 73 2 02/01/03 23:30 01/31/03 6:30 27,950.73 27,734.04 216.69 18.99 197.70 2-073 Paradiom 62150 02/03/03 0.42 1 74 3 02/03/03 21:00 02/02/03 18:00 28,381.40 27,950.73 430.67 24.88 405.79 3-074 Paradiom 62707 02/05/03 0.085 1 75 4 02/05/03 14:12 02/03/03 21:00 28,763.23 28,381.40 381.83 7.57 374.26 4-075 Paradiom 62791 02/06/03 0.16 1 76 2 02/06/03 14:15 02/05/03 14:12 29,128.63 28,763.23 365.40 24.28 341.12 2-076 Paradiom 62837 02/07/03 0.08 1 77 3 02/08/03 14:45 02/06/03 14:15 29,538.23 29,128.63 409.60 17.93 391.67 3-077 Paradiom 62956 02/10/03 0.17 1 78 2 02/09/03 14:00 02/08/03 14:45 29,858.80 29,538.23 320.57 6.94 313.63 2-078 Paradiom 62957 02/10/03 0.29 1 79 4 02/10/03 16:35 02/09/03 14:00 30,249.50 29,858.80 390.70 10.54 380.16 4-079 Paradiqm 63288 02/12/03 0.11 1 80 2 02/11/03 16:45 02/10/03 16:35 30,621.50 30,249.50 372.00 9.16 362.84 2-080 Paradiom 63370 02/13/03 0.14 1 81 1 02/12/03 15:00 02/11/03 16:45 30,961.00 30,621.50 339.50 6.12 333.38 1-081 Paradiom 63371 02/13/03 0.05 1 82 3 02/14/03 20:30 02/12/03 15:00 31,351.20 30,961.00 390.20 17.73 372.47 3-082 Paradigm 63811 02/17/03 0.053 1 83 2 02/16/03 2:00 02/14/03 20:30 31,823.10 31,351.20 471.90 17.94 453.96 2-083 Paradiqm 63812 02/17/03 0.017 1 84 4 02/17/03 14:25 02/16/03 2:00 32,309.30 31,823.10 486.20 10.91 475.29 4-084 Paradiom 64075 02/19/03 0.43 1 85 3 02/17/03 23:55 02/17/03 14:25 32,454.78 32,309.30 145.48 4.90 140.58 3-085 Paradiom 64076 02/19/03 0.23 1 86 2 02/20/03 14:00 02/19/03 6:30 32,909.50 32,454.78 454.72 17.61 437.11 2-086 Paradiom 64274 02/21/03 0.058 1 87 3 02/21/03 21:00 02/20/03 14:00 33,318.60 32,909.50 409.10 8.47 400.63 3-087 Paradiom 64406 02/24/03 0.067 1 88 2 02/23/03 6:00 02/21/03 21:00 33,758.90 33,318.60 440.30 11.63 428.67 2-088 Paradiarn 64407 02/24/03 0.016 1 89 4 02/25/03 2:00 02/23/03 6:00 34,200.11 33,758.90 441.21 16.72 424.49 4-089 Paradiom 64576 02/26/03 0.9 1 90 3 02/26/03 6:45 02/25/03 2:00 34,563.76 34,200.11 363.65 8.12 355.53 3-090 Paradiom 64577 02/26/03 0.39 1 91 2 02/27/03 7:13 02/26/03 6:45 34,879.42 34,563.76 315.66 3.25 312.41 2-091 Paradiom 64810 02/28/03 0.073 1 Adjust approved tonnaoe to deduct 7.5 tons of soil contaminated with diesel fuel from 2/7/03 7.50 17.50 1 Adjust aoproved tonnaoe to deduct 1.13 tons of soil contaminated with diesel fuel from 2/11/ 1.13 /1.13 1 SHAW INVOICE #24 FOR PERIOD THROUGH 2128103 COVERED THROUGH BATCH #91, TOTAL INVOICED TONS TO DATE= 29,375.95, NET FOR PERIOD= 6,468.57 TOTALS 34,834.39 1,240.62 33,593.77 GRAND TOTAL, NET TONS OF TREATED SOIL 33,593.77 33,593.77 <-------------VALUES IN THESE THREE CELLS MUST MATCH ---------------------------> file name for blank form· batch log form 100802 SCALE ENTRIES CHECK belt scale net tons to date ADJUSTMENTS initial start tons 34,834.39 gap belween batches 4 & 5 batch 6, see note Total adjustments Adjusled tons lo date 34,879.42 Most recent "complete" tons 34,879.42 30.61 7.65 6.77 ~ UPDATE THIS ENTRY AFTER ADDING NEW BATCHES Summary of tons approved, by month Approved in : Sept 02 Oct02 Nov 02 Dec 02 Jan 03 APPROVED SO FAR lN FEB. IDiffereOCe'"'Mv·sr ::::-0~~ ~ 1Total approved to date: 16,507.13 3,793.33 8.8404 1850.3604 0.112 16,612.50 3,793.33 1.7386 1852.0990 0.111 16,992.24 3,793.33 174.6804 2026.7794 0.119 17,454.68 3.793.33 7.3990 2034.1785 0.117 17,637.30 3,793.33 11.1398 2045.3183 0.116 17,637.30 3,793.33 0.0000 2045.3183 0.116 18,092.02 3.793.33 86.3968 2131.7151 0 118 18,445.70 3,793.33 28.2944 2160.0095 0.117 18,931.58 3,793.33 63.1644 2223.173( 0.117 19,293.94 3,793.33 57.9776 2281.1515 0.118 19,641.10 3,793.33 48.6024 2329.753( 0.119 19,967.02 3.793.33 48.8880 2378.641( 0.119 20,313.43 3,793.33 51.9615 2430.6034 0.120 20,749.79 3,793.33 104.7264 2535.3291 0.122 21,143.12 3.793.33 90.4659 2625.7957 0.124 21,483.73 3,793.33 64.7159 2690.511c 0.125 21,774.56 3.793.33 27 .0472 2717.5588 0.125 22,095.23 3,793.33 76.9608 2794.519( 0.126 22,621.70 3,793.33 20.0059 2814.5254 0.124 22,910.38 3,793.33 86.6040 2901.1294 0.127 22,908.38 3,793.33 0.0000 2901.1294 0.127 22,907.38 3,793.33 0.0000 2901.1294 0.127 22,907.38 3,793.33 0.0000 2901.1294 0.127 23,105.08 3,793 33 83.0340 2984.1634 0 129 23,510.87 3,793.33 34.4922 3018.6556 0.128 23,885.13 3,793.33 59.8816 3078.5372 0.129 24,226.25 3,793.33 27.2896 3105.8268 0.128 24,617.92 3,793.33 66.5839 3172.4107 0.129 24,931.55 3,793.33 90.9527 3263.3634 0.131 25,311.71 3.793.33 41.8176 3305.1810 0.131 25,674.55 3.793.33 50.7976 3355.978E 0.131 26,007.93 3,793.33 16.6690 3372.6476 0.130 26,380.40 3.793.33 19.7409 3392.3881 0.129 26,834.36 3.793.33 7.7173 3400.1058 0.127 27,309.65 3,793.33 204.3747 3604.4805 0.132 27,450.23 3,793.33 32.3334 3636.8139 0.132 27,887.34 3,793.33 25.3524 3662.1663 0.131 28,287.97 3,793.33 26.8422 3689.0085 0.130 28,716.64 3,793.33 6.8587 3695.8672 0.129 28,716.64 4,217.82 0.0000 3695.8672 0.129 29,072.17 4,217.82 138.6567 3834.523! 0.132 29,384.58 4,217.82 22.8059 3857.329! 0.131 29,377.08 4,217.82 0.0000 3857.329! 0.131 29,375.95 4,217.82 0.0000 3857.329! 0.131 29,375.95 4,217.82 0.0000 3857.3299 0.131 29,375.95 4,217.82 0.0000 3857.329( 0.131 29,375.95 4,217.82 0.0000 3857.329( 0.131 29,375.95 4,217.82 0.0000 3857.329( 0.131 29,375.95 4,217.82 0.0000 3857.329( 0.131 29,375.95 4,217.82 33,593.77 Weighted avg PCB for February only 1,918.79 0.14782 7,992.40 4,338.55 1.721 61 6,936.03 22,907.38 6,468.57 THIS WILL BE FINAL FOR FEB 29,375.95
ATTACHMENT 4 SUMMARY OF PERIMETER AIR MONITORING RESULTS -PCBs WARREN COUNTY PCB LANDFILL DETOXIFICATION PROJECT Prevailing Wind Event Date(s) Direction Shakedown # 1 8/26/02 to 8/28/02 sws Shakedown #2 10/28/02 to 10/30/02 ENE Shakedown #3 11/23/02 to 11/25/02 SW PDT#l 1/7/03 to 1/9/03 WSW PDT#2 1/9/03 to 1/11/03 WSW Full-Scale Week 1 (# 1) 1/14/03 to 1/15/03 SSW Full-Scale Week 1 (# 2) 1/15/03 to 1/16/03 sww Full-Scale Week 2 1/21/03 to 1/24/03 SE Full-Scale Week 3 1/30/03 to 1/31/03 NNE Full-Scale Week 4 2/5/03 to 2/6/03 SSW Full-Scale Week 5 Full-Scale Week 6 Full-Scale Week 7 Average Cone. (mg/m3) for Station Average Cone. (mg/m3) for Site (average of all stations) NCDENR Guideline -Annual Limit (mg/m3) NOTES: Downwind Station(s) North/East South North/East East East North East North South North 3.8E-05 8.3E-05 1. Where there is co-located data, value for that station is average of the two results. 2. Full-Scale Week 4 results are preliminary. Station #1 Station #2 (South) (East) 3.2E-05 1.4E-05 7.4E-05 3.7E-06 3.4E-05 l.SE-04 2.0E-06 7.lE-05 l.SE-05 9.8E-05 4.lE-05 1.4E-05 5.0E-06 2.4E-05 1.5E-05 1.lE-05 3.9E-05 9.lE-06 5.8E-05 2.6E-05 3.lE-05 4.2E-05 DRAFT Station #3 Co-Located (North) Station# 1.8E-05 3 3.9E-06 1 l.3E-04 1 9.9E-05 2 5.6E-05 3 2.lE-05 3 2.2E-05 3 2.0E-06 3 2.0E-06 3 4.lE-05 3 4.0E-05
SUMMARY OF PERIMETER AIR MONITORING RESULTS -DIOXINS/FURANS WARREN COUNTY PCB LANDFILL DETOXIFICATION PROJECT Prevailing Wind Event Date(s) Direction Shakedown # 1 8/26/02 to 8/28/02 sws Shakedown #2 10/28/02 to 10/30/02 ENE Shakedown #3 11/23/02 to 11/25/02 SW PDT#l 1/7/03 to 1/9/03 WSW PDT#2 1/9/03 to 1/11/03 WSW Full-Scale Week 1 (# 1) 1/14/03 to 1/15/03 SSW Full-Scale Week 1 (# 2) 1/15/03 to 1/16/03 sww Full-Scale Week 2 1/21/03 to 1/24/03 SE Full-Scale Week 3 1/30/03 to 1/31/03 NNE Full-Scale Week 4 2/5/03 to 2/6/03 SSW Full-Scale Week 5 Full-Scale Week 6 Full-Scale Week 7 Average Cone. (mg/m3) for Station Average Cone. (mg/m3) for Site (average of all stations) NCDENR Guideline -Annual Limit (mg/m3) NOTES: 1. NS = No Co-located Sample Collected Downwind Station(s) North/East South North/East East East North East North South North 1.lE-09 3.0E-09 2. Where there is co-located data, value for that station is average of the two results. 3. Full-Scale Week 4 results are preliminary. Station #1 Station #2 Station #3 (South) (East) (North) 2.6E-10 8.7E-ll 3.6E-ll 6.2E-09 2.7E-11 7.9E-11 2.7E-10 6.2E-09 l.9E-09 1.7E-10 1.9E-09 9.5E-10 3.lE-10 6.2E-09 9.0E-10 1.2E-10 1.4E-ll 9.7E-11 3.9E-12 7.8E-11 9.8E-12 1.6E-10 7.lE-11 1.5E-11 NA NA NA NA NA NA 9.4E-10 1.8E-09 5.0E-10 Co-Located Station# NS NS 1 2 3 3 3 NA NA NA
SUMMARY OF PERIMETER AIR MONITORING RESULTS -PARTICULATE WARREN COUNTY PCB LANDFILL DETOXIFICATION PROJECT Prevailing Wind Downwind Station #1 Station #2 Station #3 Event Date(s) Direction Shakedown # 1 8/26/02 to 8/28/02 sws Shakedown #2 10/28/02 to 10/30/02 ENE Shakedown #3 11/23/02 to 11/25/02 SW PDT#l 1/7 /03 to 1/9/03 WSW PDT#2 1/9/03 to 1/11/03 WSW Full-Scale Week 1 (# 1) 1/14/03 to 1/15/03 SSW Full-Scale Week 1 (# 2) 1/15/03 to 1/16/03 sww Full-Scale Week 2 1/21/03 to 1/24/03 SE Full-Scale Week 3 1/30/03 to 1/31/03 NNE Full-Scale Week 4 2/5/03 to 2/6/03 SSW Full-Scale Week 5 Full-Scale Week 6 Full-Scale Week 7 Average Cone. (ug/m3) for Station Average Cone. (ug/m3) for Site (average of all stations) NCDENR Guideline -Annual Limit (ug/m3) NOTES: Station(s) North/East South North/East East East North East North South North 26 50 1. Where there is co-located data, value for that station is average of the two results. 2. Full-Scale Week 4 results are preliminary. (South) (East) (North) 29 8 11 77 56 6 15 25 20 10 56 40 43 34 21 54 22 17 19 17 13 33 18 15 42 13 13 28 15 9 35 26 16 . Co-Located Station# 3 1 1 2 3 3 3 3 3 3
POBox61051
i Durham, NC 27715-1051
Phone: (919} 416-5077
Fax: [phone]
[e-mail] www.ncwarn.org
January 27, 2003
Jim Cloonan
EarthTech, Inc.
Bill Gallagher
Shaw Group, Inc.
Subject: Communication with Warren County Citizens Advisory Board on Issues Relating to
Safety of the PCB Landfill decontamination
Dear Jim and Bill,
I am quite concerned about a number of statements you made at the January 9th CAB meeting.
There were various discrepancies in your presentation to the group and in answers to several
questions. By way ofthis letter, I ask that you clarify these issues, and that in the future, Shaw
and EarthTech be more forthcoming with information regarding the progress and safety of the
decontamination process.
During your presentation, you painted a picture of a very smooth-running process, implying
there were few problems, if any. However, upon being questioned, you stated that batch failures
( when decontamination was insufficient during a batch of soil's first pass through the equipment)
had been "very low." Upon further questioning by Dollie and myself, Jim stated that 5 out of 55
batches, or "about 10%," had failed, and Bill added that most of those had occurred at the
beginning of the project.
However, after even more questioning, we learned that in fact, 13 of the 55 batches had failed,
and several failures had occurred recently. I protested about the discrepancy and the need for
accurate communication to the citizens. There was some effort by others to patch over this
controversy and move on with the meeting, but the misstatements were clear, and can be
confirmed by audiotape of the meeting.
1. Please provide a written explanation to confirm the number and percentage of batch
failures to date, and provide regular updates to the CAB about batch failures.
I also asked what effect on air emissions the batch failures might have. I found the description
by EPA's Terry Lyons, with input from both of you, to be incomplete and lacking logic. The
three of you indicated that there would be no effect on air emissions. However, it seems
reasonable to suspect that if the equipment is not performing as planned, air emissions could be
effected.
,__ __ Cu
2. Please provide a written explanation as to why the community should not be
concerned about air emissions given the high percentage of batch failures. Specifically,
why do you believe there is no correlation between batch failures and air emissions?
During your presentations, I already knew that the decontamination equipment had been shut
down for several days the previous week. I had assumed this would be conveyed to the CAB
during your presentation, and was concerned that it was not. When I brought it up, Bill made
light of it, and stated that it was "scheduled maintenance," and that you have those
"periodically." We had already heard that the project was down for the holidays, and I found it
hard to believe you scheduled a maintenance shutdown only days after that. When I pressed for
more information, and asked who made the call for the shutdown, Jim finally stated, "I should
say that we [EarthTech] pointed out a problem with the Cyclone and called for the shutdown."
When I then asked whether that was before or after the so-called scheduled shutdown, Bill and
Jim indicated it "led into" the scheduled shutdown. Frankly, I find many of your statements
during that whole discussion to be highly misleading.
3. Please provide a written explanation for "scheduled maintenance" shutdowns and a
copy of the protocol related to such shutdowns: Is there an actual schedule? What is the
frequency and duration? When are future maintenance outages scheduled? What specific
maintenance functions are performed?
Related to Jim's statement that the shutdown was triggered by problems with the Cyclone: I did
not push the point at the meeting due to the lateness of the hour, but I believe that Cyclone refers
to a brand of control equipment for air pollution. Of course, the precise and proper functioning
of pollution controls is vital to the safety of workers and the community.
4. Why did neither Shaw nor EarthTech's on-site officials order shutdown of the
equipment, instead of the call being made when Jim Cloonan came into town? Also,
what was the specific nature of the problem with the pollution controls? How long
had the problem existed? Has that particular type of problem, or any other problem with
pollution controls, occurred since the project began?
5. Please provide a list of any other shutdowns of any component of the decontamination
equipment stream since the project began, and describe the specific reason for the
shutdown.
6. Was ambient air sampling conducted when the Cyclone malfunction was discovered in
order to determine the potential exposure to workers or the community? If not, why not?
If so, has the data been returned yet?
Due to the above discrepancies, I am also interested in whether you have told the CAB all there
is to know about the four exceedances in ambient air sampling.
7. Please explain the two exceedances for dioxin and the two for PCBs, and explain why
the community should not be concerned.
2
8. Why was technical advisor Patrick Barnes told on January 8th that were no
exceedances from ambient air sampling? After visiting the landfill and learning the next
day that there had been exceedances, he had to revise his report to the CAB on the day of
the CAB meeting, causing him to miss much of the meeting.
All of these points, along with earlier revelations about stormwater discharge problems, conflict
with the presentations made by EarthTech and Shaw describing a seemingly flawless
decontamination process. Also, these discrepancies make me more concerned about the issue
Patrick brought up earlier, the potential conflict of interest with having Shaw contracting directly
with the lab that tests air and soil samples. I would like to discuss this again, either at the next
CAB meeting or with the technical subcommittee (I ask that Pat Backus include me on all future
communications between contractors, Patrick, and the state).
With this letter, I ask that Mike Kelly and Pat Backus agree that technical advisor Patrick
Barnes' contract time should be frontloaded so that he can spend more time on this project now;
it is clear that we need him at this time. The CAB is trusting that Mike can come through with
additional money for Patrick's oversight if it is needed in the future. At the very least, I request
that this be an agenda item for our next scheduled meeting.
I believe that EarthTech and Shaw employees desire to conduct the project safely. However, the
fact is that the two companies are working together, with employees in daily contact. This
creates a potentially difficult situation for Earth Tech, which is charged with overseeing Shaw.
Also, the reality is that both companies have very large contracts, and as with any large
corporation, there is inherent pressure from out-of-town executives for project personnel to
maximize profits. On this project, maximizing profits means keeping the project going. This
makes it more important that the state and the CAB have adequate checks and balances in place
in order to protect the community from air or water releases that could be harmful.
It is not my wish to make anyone's job harder; we all want to keep the project moving forward.
But Earth Tech and Shaw have a responsibility to be forthcoming, not to make CAB members
extract information from you, which raises the level of suspicion that there could be more
significant problems that have not been shared. For many years, communities all over the U.S.
have earned a distrust of corporations and government regulators that have lied to them, and
treated.them condescendingly, about hazards similar to the PCB Landfill issue. In Warren
County, after many years, we have learned to trust and cooperate with Mike and Pat and other
members of the state. But your two companies are still new here.
Because the two companies are on the job each day together, it is understandable that you
sometimes might prefer to handle problems between yourselves. But it is not your decision as to
how much to convey to the public. This is not Shaw and EarthTech's project to decide how
much to disclose. It is your responsibility to ensure that the community -through the CAB and
its technical advisor and the state -is honestly apprised about the full extent of any problems or
abnormal conditions you face, how you are addressing those problems, and what are the potential
impacts to the public.
We know this is a complex project, and we expected that there would be difficulties. You can
build trust by being candid about problems and proposed solutions. That will also help avoid the
3
potential for raised suspicions leading to exaggerations, rumors, and community uneasiness.
When problems are detected, your diligence in acting immediately -including stopping the
process if necessary until problems are fully corrected -is especially important because of the
long lag time between air sampling and the return of results.
I look forward to your prompt reply to my questions, and ask that you copy your reply to the
others on the list below.
Sincerely,
Jim Warren
Vice Chair, Citizens Advisory Board
cc: Dollie Burwell
Mike Kelly
Pat Backus
Patrick Barnes
Citizen Advisory Board Members
Terry Lyons
CAB office, to be placed in the record
4