NCD980602163_19951201_Warren County PCB Landfill_SERB C_Correspondence - Pauline Ewald, 1991 - 1995-OCR

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facsim
TRANSMITTAL
to:
fax#:
re:
date:
pages:
Susan,
Susan Thornburg
703-308-7030
E.C.O.
December 1, 1995
, including cover sheet.
I have divided the information that you requested into 3 groups and will fax each group
separately. The first group deals with education background and qualification verification - 9
pages including cover.
Group two -Contract with State of NC -13 pages including cover
! , Group three -Peer review of ECO's final report -11 pages including cover
Group four -ECO's final report, copy of cover page and table of contents. The report was 27
pages long. If you need a copy of the entire final report, I will fax at later date/mail -4 pages
including cover.
If you need anything else, please give me a call.
From the desk of ...
Bill Meyer
Director
Division of Solid Waste Management
919-733-4996
Fax:
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL
RESOURCES
Will iam L. Meyer
Director, Solid Waste Manage ment Di\·ision
Pl ease:
Draft a reply fo r my sign;i turc.
Take appropriate action.
Approve.
For yo ur inform ntion
Dale: 8/!t/ 'f5
1'-iotc and return att ached ma terial to me
See me :ibout attach ed
Handle and report to me
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08/11 /199'5 14:27 9192572604 EELC FERRUCC IO PAGE 01
ECO RICHMOND TEL N0.804 798 430 5 Aug 11,95 13:30 P.01
E NVIRONMENTAL
C OMPl,IANCE
0 RGANIZA TION
Professional Waste Mana ement Consultants
I 06 Robinson Street Ashland, Virginia 23005
TO:
FROM:
RE:
DATE:
KEN FERRUCCJO
PAULINE EWALD
OVERSIGHT STAFFING
AUGUST 11. 1995
[phone]
As per our te_leph~ne conversation of.this date, I strongly disagree with the sole
focus on engmeenng staff and expen1se for what is more clearly a
gco)ogicaVchemical problem. As you know, I am very committed to a multi-
disciplinary approach to environmental research and remediation, and feel that a
diverse staff is much more appropriate to successfully completing this task to the
ultimate benefit of the community.
Additionally, I want to restate to you that at no time have I indicated in writing or
verbally to any individual that I was a certified Professional Engineer (P.E.). My
undergraduate concentration was in a program tracking toward environmentAJ
engineering and included chemistry, biology, math and physics. My law school
major programs area was government regulation/with a sub-specialty in
environmental law.
The above stated notwithstanding. because there is some apparent emphasis or
perceived need for engineers to staff the Wmen County PCB landfill oversight.
ECO respectfully offers to provide any one of several staff members who are
Professional Engineers, certified and in good standing in the State of North
Carolina to act as Technical Advisor to the Working Group. J would however~
request that the requirement for demonstrated_ and certifi~d engineering education
and expertise be applied to all applicable parties. Accordmgly, I would .
recommend that the Working Group request that the State program lead_er/proJcCt
manager also provide proof of engineering degree and professional certification.
08/11/1995 14:27 9192572504 EELC FERRUCCI □ PAGE 02
..
ECO RICHMOND TEL N0.80 4 798 4305 Rug 11,95 13:31 P .02
KEN FERR UCCIO MEMO
A.UGUST 11, 1995
PAGE1
Please let me know if I can provide additional infonnation or assistance that wilt
expedite the urgently required pilot study and remediation of the PCB landfill.
Everyone at ECO remains available to assist the residents of Warren County in
this regard.
E NVIRONMENT AL
r f'\UIH 'A l\.Tri.
ECO RICHMOND
t:.t:.L\.. r t:.r<:r<:U\..\...LU
TEL N0.804 798 4305
E NVIRONMENTAL
C OMPLIANC£
0 RGANIZA TION
Professional Waste Mana ement Consultants
I 06 Robinson Street Ashland, Virginia 23005
TO:
FROM:
RE:
DATE:
KEN FERRUCCIO
PAULfNEEWALD
OVERSIGHT STAFFING
AUGUST 1 I. 1995
Aug 11,95 13:30 P.01
[phone]
As per our telephone conversation of this date. I strongly disagree with the sole
focus on engineering staff and e,cpertisc for what is more clearly a .
gcologicaVohemical problem. As you know. I am very committed to a multi-
disciplinary approach to environmental research and remediation, and feel that a
diverse staff is much more appropriate to successfully completing this task to th~
ultimate benefit of the community. ·
Additionally, I want to restate to you that at no time have I indicated in writing or
verbally to any individual that I was a certified Professional Engineer (P .E. ). My
undergraduate concentration was in a _program tracking toward environmental
engineering and included chemistry. biology. math and physics. My law school
major programs area was government regulation/with a sub-specialty in
. environmental law.
The above stated notwithstanding. because there is some apparent emphasis or
perceived need for engineers to staff the Wanen County PCB landfill oversight.
ECO respectfully offers to provide an! one of seve~l ~taff' members who are
Professional Engineers, certified and m good standing U\ the State of North
Carolina to act as Technical Advisor to the Working ~oup. 1 ~oul~ however~
request that the requirement for d~onstrated_ and certtfi~d engmcenng educatton
and expertise be applied to all appltcablc parties. Acoordmgly, I would .
rcoommend that the Working Group request that the State program leader/proJect
manager also provide proof of engineering degree and professional certification.
08/11/1~95 14:27 9192572504 EELC FERRIJCCIO PAGE 02
ECO RICHMOND TEL N0.804 798 4305 Aug 11,95 13:31 P.02
KEN FERR UCCIO MEMJ
AUGUST JJ, 1995
PAGE2
Please let me know if I can provide additional info1TI1ation or assistance that will
expedite the urgently required pilot study and remediation of the PCB landfill.
Everyone at ECO remains available to assist the residents of Warren County in
this regard.
ENVIRONMENTAL
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APR 28 1995
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ENVIRONMENTAL
FACSIMILE COVER PAGE
/ To: SHARRON ROGERS From: PAULINE EWALD
Time: 14:40:11 Date: 4/24/95
Pages (including cover): 7
ECO HEADQUARTERS
E NVIRONMENTAL
COMPLIANCE
0 RGANIZATION
ECO HEADQUARTERS
Professional Waste Management Consultants
106 Robinson Street Ashland, Virginia 23005 [phone]
TO:
FROM:
RE:
DATE:
MEMBERS OF THE JOINT WARREN COUNTY STATE PCB
LANDFILL WORKING GROUP
PAULINE EWALD, ECO
GENERAL ISSUES -MEMORANDUM DATED 4/7 /95
4120195
I want to begin my expressing my sincere concern about the failure for this
project to progress in a manner that is necessary for ensuring that a pilot project is
implemented expeditiously. It is very troubling to me that a memo containing nvo
pages of motions and "tasks" ,focuses solely on issues that have already been
touched upon and discussed, while failing to make any reference to beginning to
utilize the vendor information which the State insisted needed to be collected.
I remind committee members that ECO requested to perform telephone
interviews of the vendors for the purpose of preparing a comprehensive report on the
availability of vendors and likely cost for proceeding with a full scale pilot study. Had
we been allm;ved to proceed with this work, we would already be in the process of
negotiating the actual work. Instead, we are back to a point, where I am being asked
to justify, once again, the choice of BCD for the remediation of this landfill. To
repeat, BCD is the only non-incineration treatment method suitable for treatment of
halogenated waste streams, that has been demonstrated and approved to work in
North Carolina sites by EPA Region IV, and shown to have wide community
acceptance. In point of fact, at two other sites with waste streams similar to the PCB
landfill , NCDEHNR wrote to EPA actively in support of choosing and implementing
BCD.
. .
ECO HEADQUARTERS
PCB H'orking Group Jvf emo
April 20, 1995
Page 2
ECO HEADQUARTERS
Despite references to the contrary by State personnel, ECO staff are very
familiar with a wide range of innovative technologies. Attached as Table 1, is a
comparison chart of all technologies that have been EPA full scale demonstrated for
use in treating PCB contaminated soils. Innovative technologies that have not yet
undergone full scale, EPA approved demonstrations were excluded from
consideration.
As to Motion 3 of the Memorandum, We are not in possession of Bill Meyer's
memorandum on Koppers or FCX. The fact is that the Koppers demonstration project
did experience several start up difficulties, and ffi'O minor air releases were noted.
These releases were rectified, and the entire BCD process as it is being offered by the
industry has been greatly refined since the Koppers demonstration project , and even in
its earlier format as implemented in Morrisville, the project was considered a success
by the State, EPA and the community. If the State had large concerns regarding the
use and/or implementation of BCD as a remedial alternative at either of these sites,
then those concerns should have been voiced during the remedy selection process. I
was present at all meetings for each of these sites, and had the opportunity to review
the entire public record regarding site determinations, and North Carolina made no
attempt to indicate concerns that would have warranted the selection of some remedy
other than BCD.
Again, Motion 5, is inappropriate at this stage of this process. The
chairpersons of the working group were provided with staff resumes and credentials
nearly a year before I was brought onto this project. Additionally, all my attempts to
have this contract awarded to ECO \Vere rejected in favor of this proceeding as a
personal services contract which included only myself. Therefore, attempts to provide
information on ECO staff and to have them included in this contract have been
rejected by the State. Additionally, I would expect that the State to reciprocate on
this Motion by providing the names and credentials of both State and outside
personnel, who have prepared and/or reviewed information pertinent to this project.
Notwithstanding the foregoing, ECO personnel are more than adequately qualified for
work on this, or any other project, and a brief organizational chart is attached to this
memo.
..
ECO HEADQUARTERS
PCB Working Group !demo
April 20, 1995
Page3
ECO HEADQUARTERS
Additionally of critical concern, is the plan to handle this site remediation under
the authority of TSCA (PCB law), rather than RCRA ( hazardous waste law), or
CERCLA (Superfund). Remediation of this site under TSCA ignores the contribution
of dioxinifurans to the existent contamination, and will allow the State to proceed in a
manner that is less formalized, and does not require community or citizen input. A
comparison of the proposed cleanup under different regulatory authorities is attached
as Table 2.
Finally, I am very concerned that ECO continues to be assigned and scheduled
for work tasks which are essentially meaningless. As already noted, none of the
issues that I was "required" to address in this memo deal with the substantive
challenge at hand, which is the implementation of the pilot study. It is my sincere
judgment that all members of the committee who are dedicated to fulfilling the
promise of detoxification of this landfill must resist any and all future attempts to
distract the group's focus from this one clear, concise and crucial goal.
PME/winword/msiattchs. 4
ECO HEADQUARTERS ECO HEADQUARTERS
TABLE 1: FULL SCALE DEMONSTR-\TIONS OF PCB TREATMENTS
TECHNOLOGY TECHNOLOGY FUNCTION COMMUNITY FULL SCALE PCB
CL4SS APPROl,~L DEMONSTRA TIO,\'
(THRESHOLD
DECISIO!\J
LOCATION 1-ENDOR
THERMAL Thennal Desorption Separation Possible Outboard Canonie
TREATMENT Marina I Environmental
Waukegan Sen~ces I Soil
Harbor, IL. Tech ATP
Services
(Anaerobic
Thennal
Processor)
Wide Beach Soil Tech ATP
Development, Services
NY
ReSolve RUST Remedial
Superfund Site, Sernces
MA (XTR..-'\.Xl
Middleground ELI EcoLogic
Landfill, MI
Vitrification Destruction Possible Site yet to be
completed
Mobile Incineration Destruction No NIA NIA
CHEi\UCAL Dechlorination Destruction Yes Wide Beach Soil Tech ATP
TREATMENT Dehalogenation Development, Sernces
NY (APEGi
Koppers Site, EPA RREL
Morris,~e, NC (BCDJ
Solvent Extraction Separation New Bedford CF Systems
Harbor, MA (Propane
Extraction)
Grand Calumet Resources
River Site, IN Conservation
Company
(BEST)
Solidification Immobilization Possible No sites
completed to
date
PHYSICAL Soil Washing Physical/ Possible Refinery site, BioGenesis
TREATJ\,IENT chemical MN ( Soil Washing l
separation
MacGillis and BioTrol
Gibbs ( Soil Washing l
Superfund site,
MN
Saginaw Bay Bergmann USA
Facility, MI <Soil Washins1i
ECO HEADQUARTERS
ACADE~1IC CREDENTIALS:
PAULINE EWALD, B.S ., JD. -Engineering L aw
SANDRA MORSE, B.S., M.S. -Biology/Education
BRENDA SAHLI, B.S., M.S., Ph.D. -Toxicology
JOHN SCHUBERT , B.S., M.S., P.E. -Engineering
STEVEN FRAZIER, B.S. -Analytical Chemistry
ECO HEADQUARTERS
ADDITIONAL NON-:MANAGEMENT STAFF \YITH HOURS TO\VARDS
THE \VARREN COUNTY REPORT:
JOSEPH HAILER, B.S., M.S., P.G. -Geology/Chemistry
SEAN DAVIS , B.S. -Geology
RUSS BILLMEYER, B.S., M.S. -Geology
GREGORY SMITH, B.S. -Chemistry
en a:: LU ~ ::, 0 ~· ::i: 0 (.) LU ~ LU ~ ::, 0 ~ ::i: 0 (.) LU ~ . TABLE 3: COMPARISON OF REGULATORY ENVIRONMENTS Does the regulation emphasize on-site treatment? Does regulation require application of technologies that reduce, immobilize or destroy wastes? Are public comment and community relations required? Is regulation applicable to PCBs, dioxins and furans? Does the regulation require consideration of i1movative technologies? Does regulation provide grant funding for community technical assistance? Docs regulation require human health risk assessment and risk driven clean up standards? SUPERFUND TSCA yes no yes no yes no yes no yes no yes no yes no
' I \ ECO MANAGEMENT Key Staff ,, PAULINE EWALD Compliance Director .. -\ \ I JOHN SCHUBERT SANDRA MORSE BRENDA SAHLI ,· Director of Director of RCRA Chief Toxicologist Engineering and Training . ' ' ' ... I I I I I I I\ I'\ I\ .. RICHARD TURI STEVEN FRAZIER MARG ERi TE THOMAS BURKE Director of Planning Chief Chemist SHAPIRO Asbestos Chief Biologist Abatement Manager ' ~,.~.;)!t-<".., ;1 -•'·"t,'."',jt,X:.:j'. '~.'t'U'l,i:t'i'j•,>. .;:, •. l °'."•11,.a,. :_:~ ,•-~·r•.,;·,.11 .. · < ,;1'tf'lr"": • . ' ' --,,,. ,;,!:,:;.,.· . ·•,-,,-~!
Ms. Pauline Ewald
ECO
106 Robinson Street
Ashland, VA 23005
Dear Pauline:
April 7, 1995
The Joint Warren County and State PCB Landfill Working Group met at
the Warren County Court House on April 6, 1995. The working group made
and unanimously approved several motions that affect you. I was asked to
convey those motions to you.
Motion 1
That the Division of Solid Waste Management move forward in developing
and providing (a) a generic overview of the PCB landfill, and (b) a safe and
effective engineering design to breach the PCB landfill liner system in
anticipation of a pilot scale test and future remediation.
Motion 2
That by April 20, Pauline Ewald provide the working group with a
comparative analysis of the technologies that she considered for the PCB
landfill and state why she chose the BCD process over the other technologies.
Motion 3
That a subcommittee composed of Sharron Rogers, Bill Meyer, Billie
Elmore, Jim Warren, and Nan Freelon will review criteria for site remediation/
detoxification put together by the Division of Solid Waste Management. The
criteria will then be presented to Pauline Ewald for review. The state will also
suggest other technologies that might meet the criteria after the criteria is
developed.
Motion 4
That Pauline Ewald respond in writing by April 20 to Bill Meyer's
memorandum of March 2 on BCD tests on the Koppers Site and FCX thermal
desorption.
Motion 5
That Pauline Ewald provide the working group by April 20 with a list of
ECO staff who have worked on the PCB landfill project, the credentials of those
staff, and an organizational chart of ECO.
Motion 6
That by May 1, 1995, Pauline Ewald respond specifically to each item in
the state's review of her Final Report.
Motion 7
That the three co-chairmen of the working group go to a meeting with
John Hankinson in Atlanta on April 13, 1995, at 2:30 p.m.
You should send the information/responses in the above motions to
Sharron Rogers, Division of Solid Waste Management, 401 Oberlin Road, Suite
150, Raleigh, NC 27605.
The PCB working group also asked me to inform you that the next
meeting of the group is on April 27 at 4 p.m. in the Grand Jury Room of the
Warren County Court House, Warrenton. You or a professional member of
your staff are expected to be at that meeting. During the course of the April 27
meeting, the group will set future meeting dates at which you are to be present.
If you have any questions concerning the motions, please contact me at
919-715-4149.
Sincerely,
Henry Lancaster
Co-Chariman
PCB Working Group
NC WARN
MEMORANDUM
To: Secretary Jonathan B. Howes
Department of Environment, Health, and Natural Resources
From: Ken Ferruccio, Co-Chairperson )£):;t _ ~~~__:_
The Joint Warren County and Stat~~B~dfW Working Group
Subject: Dioxin Contamination at PCB Landfill Site
Date: February 21, 1995
A Final Sample Analysis Report presented to the Joint Warren County and State PCB
Landfill Working Group by its Independent Science Advisor Pauline Ewald of
Environmental Compliance Organization documents that dioxin groundwater
contamination at the Warren PCB / Dioxin landfill far exceeds the "trace levels"
of dioxin previously identified by the Division of Solid and Hazardous Waste.The
report documents higher levels which the state was aware of but tried to excuse while
denying the landfill's failure.
The report documents several serious on-site and off-site locations of dioxin
contamination, including dioxin contamination of three of the four groundwater
monitoring wells and dioxin contamination of nearby Richneck Creek. Dioxin is also
present in the landfill's two leachate collection systems.
The surface soil near the air vent is contaminated as well as the seep on the landfill
slope, both with high concentrations of Octa Dioxin.
According to Ewald, "In the absence of other likely sources of chlorinated
contamination, it is likely that the PCB landfill is the source tor the dioxin and furan
contamination noted at the site." Ewald said, "The implications are devastating." She
advised " that plans be immediately commenced to begin full scale pilot testing of
BCD [Base Catalyzed Decomposition, a detoxification technology} at the Warren
County Landfill .... "
Under the Environmental Protection Agency's own standards, the site
needs to be detoxified.
cc: James B. Hunt, Jr., Governor
The North Carolina News Network
I-'. 01
TEL:[phone] Mar 22 ,95 9 :37 No.002 P.02
' I
Sta fe of North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James 8. Hunt, Jr., Governor
Jonathan B. Howes, Secretory
NA
DEHNA
March 21, 1995
MEMORANDUM
TO: William L. Meyer, Director
Division of solid waste Management
THROUGH: John I. Freeman, D.V.M,, M,P.H., Ch '
Environmental Epidemiology Section
FROM: Kenneth Rudo, Ph.D., Toxicologist
Environmental Epidemiology Section
SUBJECT: Response to ECO Final Sample Analysis Report
· I have reviewed the "Final sample Analysis Report" written by the
Environmental Compliance Organization (ECO) for the Joint Warren
County and State PCB Landfill Working Group (February, 1995).
With the exception of the following statem~nt concerning the ECO
review of the Stata Laboratory of Public Health (SLPH), I will
confine my comments to the dioxin/furan groundwater data, the
review of which has been the extent of my involvement at the PCB
landfill site.
I find myself completely in agreement with the response of Roger
McDaniel, the Chief of the Environmental Sciences Section, to the
ECO report. The SLPH has been subjected to a totally
inappropriate attack in this review. Dr. McDaniel's response
addressed very well the specifics of ECO's misstatements. The
SLPH is one of, if not the best analytical laboratory in North
Carolina. SLPH maintains a level of quality control that is
routinely of the finest caliber, producing analytical reports of
groundwater samples that arc consistently reproducible and in
instances where split samples are analyzed at other labs, very
consistent with other lab reports. If the reporting format was
not up to the detailed level that ECO wanted, the quality of tho
results were extremely accurate. SLPH is a high volume lab,
analyzing well water samples that are instrumental in protecting
the drinking water supplies in North Carolina. AS the state's
risk assessor in charge of evaluating both public and private
water supplies, I do not know of a single instance where SLPH has
erred in an analysis.
P.O. Box 27687, l?alelgh, North C~olina 27611-7687
An Equal 0pPOrtunity Affirmotivo Action Employer
.,, . ' DEHt-WJENVIR. EPI · TEL:[phone]
Mr. William L. Meyer
Page 2
March 21, 1995
Mar 22,95 9:37 No.002 P.03
~s I have discussad with the residents in Warren county, I find
myself agreeing with the ECO report in identifying dioxins and
furans in monitoring wells at the site. The levels in tha
samples exceed the laboratory blanks and appear to indicate the
presence of dioxins and furans in these samplas. However, the
source of this contamination cannot be scientifically determined
at this time because inadequate or non-existent controls were
utilized at the time the sampling was done. Indeed, part per
guadrillion (ppq) dioxin and furan levels may be ubiquitous in
groundwater. We simply do not have an existing data base for
these compounds at ppg levels. Until resampling is done with
proper controls, as we have discussed on several occasions, any
statements about probable sources for these compounds in
groundwater are hypothetical at best. Therefore, the ECO
statement on page 35 of the report is just their opinion,
completely unsupported by scientific data. The statement on page
37 of the report about the rarity of d~tecting these compounds in
water is also a supposition. Until a data base exists for ppg
levels of dioxins and furans, their rarity in groundwater is not
factually established. The additive levels of dioxins and furans
in several monitor well samples exceed EPA's MCL of 30 ppg for
2,3,7,8-TCDD. From a public health standpoint, this may pose a
slightly increased lifetime cancer risk if this water was
conswned over many years. At this time, it is evident that
groundwater from this site may contain dioxins and furans.
Further evidence of their presence and possible link to a source
can only be determined by sampling this site again with proper
controls. The ECO report completely fails to address this fact,
and their findings of dioxins and furans in groundwater related
to a possible source (the landfill) is a scientifically-invalid
statement. Because the groundwater presence of dioxins and
furans appears to be the only public health concern outside the
landfill at this time, the ECO report should have supported an
attempt to acquire reliable, scientific data on the groundwater,
with proper control samples. Regrettably, they failed to do so.
KR:td
' .
State of North Carolina
Department of ·Environment,
Health and Natural Resources
Division of Laboratory Services A.TA Jomes B. Hunt. Jr., Governor
Jonathon 8. Howes, Secretary
Samuel N. Merritt, Dr. PH, Director
DEHNA
MEMORANDUM:
TO: William L. Meyer, Director
Division of Solid Waste Management
FROM: Roger L. McDaniel. Ph.D., Chicf@1l
Environmental Sciences Section ,fl,
THROUGH: Samuel N. Merritt, Dr. PH, Director )t1i
Division of Laboratory Services
DATE: March 1. 1995
SUBJECT: Response to the ECO FiMl Sample Analysis Report
I have reviewed the Final Sample AMlysis Report written by the Environmental Compliance
Organization (ECO) for the Joint Warren County and State PCB Landfill Worldng Group (dated
February 1995). I am outraged by the misstatements and innuendoes contained in this document
regarding the quality of the work performed at the State Laboratory of Public Health (SLPH).
This document is laced with comments apparently intended to discredit the State by impeaching
the validity of the analytical results. The State Laboratory of Public Health firmly stands behind
the data regarding the Warren County PCB Landfill as being timely, complete, and accurate;
The recwring complaint in ECO's review of work perfonned at the SLPH is the reporting format ··
used to present the data. ECO stated (at every opportunity) that because the State Laboratory of
Public Health did not follow the Contract Laboratory Program (CLP) reporting format, all results
were considered unreliable and therefore Wlusable. ECO then contradicts its own conclusions by
using SLPH data throughout the report.
There are several valid reasons why the SLPH does not report resul~ using CLP format. First of
all. SLPH chemis~ perform the final review of all raw and finished data generated by this
laboratory. Since the programs do not routinely review raw data from this laboratory, inclusion
of volumes of instrument tuning, calibration, and quality control documents (as required under
CLP) would not be particularly beneficial. Secondly. O.,P fonnat is extremely labor intensive and
requires a tremendous amount of clerical work to assemble the packages. For a high volume
laboratory. such the SLPH. productivity would be greatly' reduced. For example, a typical two
page summary report, if reported under CLP format. would fill a 2 inch notebook. Tiiis would
impose a great burden on this laboratory, increasing both the cost and turnaround
· ···•}Hi
P.O Box 280-17. lkieigh. North Carolina 27611-8047
An Equol Opportunity Afflfmotive Action Employer 50% recycled/ I~ post-consumer~
William L. Meyer
March 1, 1995
Page2
----' •"--
time, without providing any additional benefit to the supported programs. Contrary to ECO's
·Final Analysis Sample Report, the SLPH did not agree (nor were we asked) to report results
from the Warren PCB Landfill in CLP format. Although the SLPH does not routinely report
results in CLP format. all standard quality assurance / quality control procedures are strictly
followed.
Overall, the ECO report was poorly written and contained numerous misstatements, omissions,
and significant erro~. For example, ECO devoted seven pages of this report to illustrate a
calculational error in a PCB calibration from a SLPH worksheet. This analysis, in fact, was a
rough qualitative confirmation of PCB used as part of a degradation study. These results were/or
internal use only, and did not undergo a standard final review by a SLPH chemist. It should have
been obvious to ECO's reviewer that these calculations were not used in the final results. The
ECO narrative and comments regarding this particular analysis are therefore totally irrelevant.
Other enors are addressed in Attachment 1.
I can understand the difficulty that the ECO reviewer must have experienced in trying to interpret
another laboratory's raw data. However, I must point out that no effort was made on the part of
ECO to contact the SLPH to request additional information. to ask for an explanation, or to
request help in interpreting any of the raw data or quality control Jne$ure5. Several statements
regarding missmg quality control data were made throughout the report. 1be ECO reviewer
apparently failed to recognize, or chose to ignore, the many quality assurance / quality control
measmes that were apparent in the raw data. For these reasons, I question ECO' s sincerity in
pcrfonning an accurate and impartial evaluation.
The SLPH has been in the business of environmental analysis for 90 years. It ~ been continually
certified by the USEPA since the inception of the certification program in 1978. The latest EJ>A
on-site evaluation (performed in May 1994) included a review of all personnel, equipment,
analytical methods, records, and quality control procedures. No deficiencies were found. The
attack on the credibility of this laboratory by the ECO report is totally unfounded.
In appendix A, I have responded to many of the errors, misstatements, and omissions that were
contained in the ECO report which are relative to work perfonned at the SLPH. Pleue contact
me at 3-7308 if you need additional information or have questions.
ATTACHMENT 1
Response to errors, misstatements, and omissions in the ECO Final Sampl~ Analysis Repor1 of
the Warren County PCB Landfill (February 1995).
Secdon 6.0 Metals Analysk.
Page 11. Table titled DETECTION LEVELS should be titled LOWEST REPORTING
VALUES.
Page 11. Since some barium was found in the soil samples and TCLP extracts, inclusion of a
detection limit is not particularly relevant.
Page 11. The report stated that "mercury detection limits differ by greater than 1 OX.
indicating an error." The report, however, failed to take into account the dilution
factor of 20X prior to digestion and analysis. There was no error in the mercuey
analysis.
Page 11. Holding times for samples (from Field Collection to TCLP extraction) are 28 days
for mercury and 180 days for other metals.
Page 12. Response to the second paragraph under the heading Calibration. Calibration of
the atomic abso1ption spectrophotometer for graphite furnace analyses Is
accomplished using a blank, two standards, and checking a third standard (at the
less than reporting value concentration). A quality control standard is then
analyzed along with a reagent blank (unspiked) and a fortified blank (spiked).
Samples are analyzed only if these values are within acceptable range.
Page 12.
All samples are tested using methods of additions (spiked recoveries) for the
graphite furnace metals. Quality control samples are checked initially, every 20
samples, and at the end of the run.
Calibration of the inductively coupled plasma spectrophotometer utilizes a blank
and one standard. A quality control standard is analyzed along with blanks. If the
results are within acceptable limits, the samples are analyzed. Quality control
samples are checked initially, every 20 samples, and at the end of the run. Ten
percent of samples are analyzed a5 duplicates or spikes.
On both instruments, calibration is performed according to the instrument
manufacturer's specifications. These procedures have met EPA's approval as
indicated by the many satisfactory site visits and examinations of laboratory data
and procedures.
Concentrations of standards were mostly above the sample concentrations. Most
sample data was reported a5 less than values.
Section 7 .0 Volatile Organics
Page 17. Response to paragraph titled Calibration. For the record, the gas chromatograph
mass spectrometers are tuned, and initial and continuing calibrations performed
with external standards. An internal standard (bromochloromethane. 40 ppb) is
used with every sample. Field blanks, and laboratory blanks are also analyz.ed.
Page 19. Table 2 omitted 48 ppb 1,4 dichlorobenzene reported by the SLPH for sample WL
002LC.
Section 8.0 Semi-Volatile Organics
Page 20. Calibration. For the record, three recovery checks were made on each sample.
Also. each sample contained an internal standard (d-10 anthracene).
Page 23. Titled PCB Calibration Error (also includes Appendix A, Figures 1-5). This
example was addressed in the cover letter. This calibration data was not used in
any fmal results.
Page 21. Table 3 is incomplete. Values for 1,3-dichlorobemene and 1,4-dichlorobenzene
for wnple WL 002 LC should be followed by the letter "le'' (indi~ amount
present is less than stated value). Also sample WL 004 BL that cont.ained 6333
ppb phthalate, also contained 22000 ppb dibutylphthalate. This contamination
probably occurred during the sampling procedure.
Page 25. Table 4. Sample WL 004 BL also contained .0042 ppm PCB 1260. Samples WL
028 SS which contained 1.45 ppm PCB 1260 is erroneously listed in the table as
PCB 1248. Similarly, sample WL 029 SS, which contained 0.22 ppm PCB 1260
erroneously appears in the table as PCB 1248. The units of the table are in Parts
Per Million (ppm) not Parts Per Billion (ppb).
i '
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I • 'II
02/27/95 17:22 !!'919 541 0239 llRDD/AREAL,RTP !l10021oos
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ATMOSPHERIC RESEARCH AND EXPOSURE ASSESSMENT LABORATORY
RESEARCH TRIANGLE PARK
NORTH CAROLINA 27711
February 27, 1995
MEMORANDUM
SUBJECT:
FROM:
TO:
Review of ECO Final Analysis Report -Warren County PCB Landfill
Robert G. Lewis, Ph.D~----
Senior Science Advisor/MR.DD (MD-77)
Sharon E. Rogers
Assistant Director for Policy, Planning, and Development
Solid waste Management Division
N. C. Department of Environment, Health and Narural Resources
401 Oberlin Road
P.O. Box 27687
Raleigh, NC 27611-7687
I have reviewed the Joint Warren County and State PCB Landfill Working Group's Final
Sample Analysis Report dated February 1995. This report was apparently prepared by ECO, who
recommends immediate remediation of the land.fill by the BCD method . I have passed the report
on to Robert L. Harless, who is our resident expert on PCDD/PCDF analytical chemistry1 for
possible further comment.
Without complete sample location identification, I cannot tell where all the samples were
taken, what samples (if any) were spikes or field blanks, or, in many cases, what were duplicates.
Therefore, I cannot provide much comment on the quality of the data. However, I am familiar
with Triangle Laboratories, Inc . (TLO, and have a great deal of confidence in the quality of their
data. The report is poorly prepared and is obviously not intended to be readily interpreted by an
individual who is not intimately familiar with the monitoring and analysis efforts.
As you know, I was intimately involved with the PCB spill cleanup, was responsible for
monitoring potential air emissions from the landfill shortly ·after it was closed, and served on
Governor Hunt's first commission to study detoxification of the landfill. Therefore, I do have
some appreciation of the subject. I am an expert on PCBs and semivolatile organics and a.in
somewhat knowledgeable concerning PCDDs/PCDFs. I am not an expert in hydrogeology or
ground water translocation of chemicals, but have seen a lot of data on movement of chemicals
leaking from landfills through soil and water. With those qualifications, I have the following
comments:
General Comments
. .!,h;,,;.eport is highly cri~cal of the State ~aboratory for allegedly po_or O~OC practice~
which are not documented, yet 1t uses data provided by the state as the basis of1ts ·
recommendations. Had it relied on its the ECO results obtained from PACE, there would be no
basis for the recommendation that the landfill be immediately remediated .
The rg,ort is very poorly written and structured. The several unnumbered tables on the
pages you have hand-numbered 5 through 8 and the tables of detection "levels" on pages 11 and
13 need headings; units arc missing in the text (e.g., for PCB concentrations on p. 23 and
retention times on p. 24); "Aroclor" is usually misspelled; there arc typographical errors; and
entries such as ''Ph" for "pH", the redundant "GC chromatograms" 1 use of the term ''isomer" to
refer to ''congener'', the criterion "extremely stable" (rather than "very'') to characterize PCBs,
and the omission of L from the TEQ equation suggest that the author of this report critiquing
chemical analytical results was not a chemist or even a careful scientist. The report also contains
serious errors in scientific deductions presented in the Discussion of Issues section.
Analytical Results
It is difficult to interpret the analytical results since they are not presented in any logical
fashion and there are several sample identifications that do not appear in the section on Sampling
Locations. Even those that are identified cannot be precisely located -without a map or
coordinates indicating direction and distance from the land6U, etc. I will confine my comments to
semivolatile organic chemicals (SVOCs), PCBs, and PCDDs/PCDFs.
SVOCs. It is difficult to believe the lack of detection of SVOCs in the samples listed.
Apparently, the target analyte list was very short and the detection limits high. The two
chlorobcozenes are, of course, residual solvent from the Aroclor mixture deposited in the landfill.
The results obtained by the N. C. State Laboratory (NCSL) and unidentified laboratory "ETC,, for
I, 4-dichlorobenzene agree very well in the case of wet landfill contents (3 3 0 ppb for WL 002 LC
and 388 ppb for IC 003 LC, respectively). ETC reported 474 ppb for this analyte in the dry
landfill contents (IC 002 LC), but the corresponding State sample (WL 001 LC) is missing from
the table. No other comparison is possible. The samples ending in "LE" and "BL" and sample
WL 001 SS are not identified on pp. 5-8. They were negative except for WL 004 BL, which
contained a very high concentration of "Phth,,, presumably phthalates, probably representing
laboratory contamination. Was this a blank?
PCBs. The results obtained by NCSL for the landfill contents (wet, 151 .8 ppb and dry,
301 .4 ppb) are consistent with previous analyses with which I am familiar and with expectations
based on original soil concentrations. The unidentified laboratory ''WST" obtained 303 ppb and
880 ppb for duplicate dry samples and 303 ppb for the wet sample. Samples WL 003, 004, 028,
and 029 SS are not identified on pp. 5-8. The results indicate no significant translocation of PCBs
from the landfill.
2
.., '• ' 02 127 /95 li:23 U-919 541 0239 KRDD ./AREAL, RTP laJ 0041005
PCDDs. Results are presented for seven specific PCDD congeners in Table 5. Except for
one sample, all positive results were obtained only by TLI. One split sample shared with PACE
was positive for OCDD. Three groundwater samples and two unidentified samples (WL 001 LE
and WL 002 LE) [leachate?] were positive for 2378-TCDD and several higher-chlorinated CDDs,
with the former showing levels about twice those of the latter (11-17 ppq of2378-TCDD and up
to I 050 ppq of OCDD). These samples appear to be taken from three of the four monitoring
wells closely surrounding the landfi)] Results for the fourth well are missing. TLI also found
higher-chlorinated CDDs in Richneck Creek at 50 to 400 ppq and in the landfil1 contents at much
lower levels(0.03 to 2 ppq, wet). Several other samples were found positive by TL! at levels
ranging from 4 to 57 ppq, but the sites from which these samples were taken were not identified
in the report. he lone positive result from PACE was for one of a du licate set of d samples
taken from within the landfill 002 LC and IC 003 LC). PACE reported 0.3237 ppb
( •3 23, 700 ppq) for one of these and nothing in the otheLfihe PACE results should be
discounted due to the large variance in duplicate results . From the TL! results, coupled with the
fact that the dumped Aroclor was negative for PCDD (USEP A and NIEHS, 1978-79), suggests
that the landfill is not the source of the PCDDs found in the groundwater and R.ichneck Creek. ....,_
PCDFs. The majority of the data contained in the report is on PCDFs. Ten samples of
various types were found by TRI to contain up to ten PCDF congeners. PACE found PCDFs
only in the duplicate dry landfill samples. Again, many of the samples are not identified on pp , 5-
8. 2378-TCDF was found at 65-93 ppq in the three groundwater (monitoring well) samples,
along with similar concentrations of several other PCDFs. TLI also found 59 ppq of 23 78-TCDF
and 19-73 ppq of higher CDFs in Richneck Creek, but only traces of PCDFs in the Jandfi]] itself
(0.08 ppq 2378 and 0.3-4.6 ppq higher). Once more, PACE found PCDFs only in the duplicate
dry landfill samplers, but their results are rather strange. The PACE results are reported in ppb at
five significant figures and correspond to 33,000 to 14,000,000 ppq. The duplicate results differ
by 3-5. While the PACE landfill results (of0.1-14 ppb) would not seem unreasonable in light of
the PCB concentrations (up to 40 ppb of higher-chlorinated PCDFs were found in the soil before
the spill was excavated), the poor precision of their analyses and their failure to detect PCDFs in
other samples cast doubt on their findings. I would be inclined to believe TLI, which has a
worldwide reputation of excellence for these type of analyses. As was the case for PCDDs, the
TL! results suggest that the landfill is not the source of the off-site PCDFs.
-----l
Discussion of Issues. This section of the report is filled with improper terminology,
misspellh1gs, and technical errors. The authors consistently misspell "Aroclor", misuse the terms
"lipophilic,, (fat-loving) and "absorption., to describe PCB adsorption by soil particles, and the
term "azeotropic,, to describe PCDD water solubility. !he principal error made, however, is the
statement that PCDDs and PCDFs are more water-soluble than PCBs and that this property
accounts for their preferentially leaking out of the landfill. Despite the fact that PCDDs and
PCDFs contain oxygen (in ether bonds that are low in h dro hilici the are in fact less water
~oluble t~an s. or examp e, at 2s•c the solubilities of2378 TCDD and of2378wTCDF are
2 x 10 ... mg/L and 4 x 10 ... mg/L, respectively, compared to 1.14 x l 0·3 mg/L for the structurally
corresponding PCB, 33'44' TeCB (cf MacKay et al., Illustrated Handbook of Physical-Chemical
3
DDD IAREAL,RTP Ill 0051005
Properties and Environmental Fate for Organic Chemicals. Vols. I and II, 1992, the "bible" for
such information). Other tetrachlorobiphenyls have water solubilities as high as 10·1 to 10·2 mgtL.
The fully-chlorinated OCDD and OCDF exhibit a thousand-fold solubility advantage over
octachlorobiphenyls (e.g., 2 x 10"" mg/L for 22'33'55'66'-0CB vs. 10·1 to 10·• mg/L for
OCDD/OCDF). Data on the other congeners likewise show that PCDDs and PCDFs are always
more water soluble. PCDDs and PCDFs are also known to strongly adsorb to soil particles,
perhaps more strongly than PCBs, due their generally more planar structure and electron-rich
oxygen orbitals.
Even if PCDDS and PCDFs were more water soluble and more mobile than PCBs, it is
entirely unreasonable in the light of the fact that the latter arc present in the landfill at thousands
of times higher concentrations that no PCBs would leak out with them. In the event of leakage,
PCB concentrations in the monitoring wells and surface waters would be higher even if
PCDD/PCDFs were leaching out at 1000 times higher rates. Furthermore, the second law of
thermodynamics dictates that the concentrations of PCDD/PCDFs must be higher inside than
-those-Outside the landfill if the landfill is the source. Therefore, the report's conclusion that "the
PCB landfiU is the most likely source for the demonstrated dioxin and furan contamination in the
on-site monitoring wells" is absolutely without support and contrary the principles of science.
cc. RL Harless
4
JOINT WARREN COUNTY AND STATE PCB
LANDFILL WORKING GROUP
FINAL S.AMPLE ANALYSIS REPORT
FEBRUARY 1995
E C 0
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I REPORT CONTENTS
1.0 SUMMARY
2.0 CASE NARRATIVE
3.0 SAMPLING PARAMETERS
4.0 SAMPLING LOCATIONS
4.1 State Sample Collection
4.2 Split Sample Locations
5.0 FIELD CHANGES TO SAMPLING PLAN
6.0 METALS ANALYSIS
6.1 Summary
6.2 NC State Laboratory Analysis
6.3 Split Sample Analysis
7.0 VOLATILE ORGANICS
7. 1 Summary
8.0 SEMI-VOLATILE ORGANICS
8.1 Summary
9.0 PESTICIDES/PCBs
9.1 Summary
10.0 PCDD/PCDFs
10.1 Summary
11.0 DISCUSSION OF ISSUES RELATED TO SAMPLE RES UL TS
11.1 Relative Solubilities of PCDD vs. PCBs
11 .1.1 Properties of PCBs
11 .1.2 Properties of Dioxins
11.1.3 Transport and fate in water systems
11.2 Evaluating PCDD/PCDF Concentrations
12.0 SCIENCE ADVISOR OPINIONS AND CONCLUSIONS
I
I /
LIST OF TABLES, FIGURES AND APPENDICES
/ TABLES
TABLE 1-COMPILATION OF METALS AND EXTRACTABLE
DETECTIONS
TABLE 2-COMPILATIONS OF VOLATILE ORGANIC
DETECTIONS
TABLE 3 -COMPILATION OF SEMI-VOLATILE ORGANIC
DETECTIONS
TABLE 4-COMPILATION OF PCB DETECTIONS
TABLE 5-COMPILATION OF PCDD/PCDF DETECTIONS
TABLE 6-TOXICITY EQUIVALENCE FACTORS (TEFs)
FIGURES
FIGURE 1-WATER SOLUBILITY OF PCDD/PCDF/PCBs
APPENDICES
APPENDIX A -FIGURES 1 - 5
PCB CALIBRATION EXHIBITS
APPENDIX B -WORKSHEETS -
·, \\
State of North Carolina
Department of Environment,
Health and Natural Resources
General Services Division
Jomes B. Hunt, Jr., Governor
Jonathon B. Howes, Secretory
Laird Davison, Director
Ms. Pauline Ewald
1 06 Robinson Street
Ashland, Virginia 23005
Dear Ms. Ewald:
May 3, 1994
AVA
DEHNR
Enclosed please find two (2) signed duplicate originals of Contract Number
V 4030 between Pauline M. Ewald and the Department of Environment, Health,
and Natural Resources. I would appreciate your executing these documents
and returning one (1) duplicate original to my office, within 30 days. Until such
time that this contract is signed by all parties and returned, the process for
payment cannot be completed.
Invoices or matters regarding invoices should be directed to the Contract
Administrator, Bill Meyer, Division of Solid Waste Management, P.O. Box
27687, Raleigh, NC 27611-7687.
Should you have any questions, please contact me at [phone].
Sincerely,
%¼/.~
John L. Perkinson, Chief
Purchase and Contract Section
JLP/smg
Enclosure
cc: Bill Meyer, Division of Solid Waste Management
P.O. Box 27687, Rcieigh, North Caolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
AGREEMENT INFOllMA'IlON l
1. PAJlTIES 10 nus AOREEMENT:
A.-~-------------~
BILL MEYER (919)733 14996
PCB LANDFILL
2. TJll.E OF AOREEM£NT:
PAULINE EWALD
. .. .
3. PlJlPOSE OF AOREEM£NT: RECOMMENDATION OF EVALUATION PROCEDURES, METHODOLOGY FOR WATER
REMOVAL, DETOXIFICATION TECHNOLOGY, AND LONG-TERM CONTROLS FOR PCB LANDFILL IN WARREN COUNTY.
4. 11MEPEPJOOOFAOREEMENT: BepnnlncO.te~~:i!:_ Endina0.~~~...!2_ Mondi Day Yar Mandi Day Yar
5. AOR.EEMENT STATIJS: El New D Continulna D Reviled Year of Initial Apeement 5-:$ -.If 'f
6. FlSCAl. INFORMATION: Doe, thla qrecmmt Involve dlabunement of fund:? (g-'&om Dept. 0 to Dept. D N-,
I hdm!• I Seate . s s·2,9.so
SUBHEAD: fund _1 7_6_o __ _ OBJ 1990 RCX:: 7621 PROO 009 5
GENERAL SERVJCES USE ONLY
PAYMENT SCHEDULE: PAYMENT UPON RECEIPT OF INVOICES (P.AYMENT AT RATE OF $75 EER BOUR;
CONTRACT AMOUNT NOT TO EXCEED,$82,950)
7. NEEDSTAlEMEm': SERVICES A.~E NEEDED TO PROVIDE TECHNICAL EXPERTISE, GUIDANCE AND
LEADERSHIP IN THE IDENTIFICATION, DEVELOPMENT, AND IMPLEMENTATION OF TASKS IDENTIFIED
BY THE WARREN.COUNTY/STATE PCB WORK GROUP TO ADDREsS THE PCB LANDFILL PROJECT •
8. JUSTIF)CATION:
DEHN'P. 2500 cimaed l l/99)
0aicra.?Scrvtca(P.mtw1/91)
. ·•
CONTRACT NEEDED AS STAFF IS NOT AVAILABLE TO PERFORM THESE TASKS.
. CG
N.C. ~mnm, o( Envit011rnent, Haith, ind Natvnl:,r;.,ru{_ ~
Oivilion of Omni! Semca ',J /IO/ 't r Page ...L. of -L..
CONTRACT BUDGET Contract No.•-0@@ CT)@
05/01 ,_9_4 __
£ffecti~ Date
05/01 95
T erminadon Date
SOLID WASTE MANAGEMENT
Division/Section/Prosram
For Fiscal Year ---
C-ontnct System No. [z} ~ 13'.)~ (2] (iJfil/
Purchase Order No. ll) ~ Ez] [z]@•
llmsion No. 0 0
PAULINE EWALD PCB LANDFlLL C-onttactor: ----------------Purpo&e: -------1-...;,:;.------,;,,_,---
PAULINE EWALD ,i~ 9:§ JL,., /\ Q Project Director: --------------Total Bud~t: S---'----· _7V ___ ~~.;;..C/ ...... _~~~~~~ $40,00 budgeted in Revision 12-0365 for first half of this contract. Portion of the $40,000 not used in FY93-94 to be carried forward; additional funds to be budgeted in FY94-95.
ITEM DESCRIP11ON
PCB LANDFILL
GENERAL CONTRACTED SERVICES
r~~d; t2 e -ry 7 <f
,.,---
l7{c;D-l1?1J-?&i-/-00 ?!:]
Conttactor Authorized Official
0EHm 2<82 (i"ilecl I 1189)
ITEM
CLASS NO.
SVC;CNTR 0100
./
~
DEHNR
CONTRACTOR CONTRACT
AMOUNT AMOUNT
I ,ft} l{)~t), t)'T)
I J!2, 95°9!! I
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STATE OF NORTH CAROLINA
COUNTY OF WAKE
CONTRACT NO. V _ ~ Q 3 Q
CONTRACTOR'S FEDERAL 1.D.
OR SOCIAL SECURITY NO.
099-52-2339
THIS AGREEMENT, made and entered into this 3rd day of May, 1994, by
and between Pauline M. Ewald, hereinafter referred to as "CONTRACTOR", and
North Carolina Department of Environment, Health, and Natural Resources,
hereinafter referred to .as "DEPARTMENT';
W I T N E S S E T H:
THAT WHEREAS, the CONTRACTOR has submitted to the
DEPARTMENT a proposal for the performance of certain technical or
professional services; and
WHEREAS, the DEPARTMENT desires to enter into a contract with the
CONTRACTOR to perform the services set out in the proposal;
NOW, THEREFORE, for and in consideration of the mutual promises to
each other, as hereinafter set forth, the parties hereto do mutually agree as
follows:
1. The CONTRACTOR hereby agrees to perform in a manner
satisfactory to the DEPARTMENT, the work described in "ATTACHMENT A"
(Scope of Work -PCB Landfill) which is incorporated as a part of this contract.
2. The DEPARTMENT hereby agrees to pay the CONTRACTOR a
sum of money not to exceed EIGHTY-TWO THOUSAND NINE HUNDRED
FIFTY DOLLARS ($82,950.00). This amount is based on the hourly rate and
time estimates shown in "ATTACHMENT B" (Preliminary Time/Cost Estimate)
which is incorporated as a part of this contract. This payment will be full and
complete compensation for services to be rendered under this agreement.
(a) Payment for services will be made upon receipt of
expenditure reports (DEHNR 2481) or invoices from the CONTRACTOR
documenting the costs incurred in the performance of work under this contract.
(b) Expenditure reports/invoices are to be submitted to the
Contract Administrator at least quarterly. Final expenditure reports must be
received by the DEPARTMENT within 45 days after the end of the contract
period.
(c) Amended or corrected expenditure reports must be received
by the office of Fiscal Management within six months after the end of the
1 of 4
.
CONTRACT NO. V _ ~ Q ~ Q
contract period. Any reports received after six months will be returned without
action.
3. The CONTRACTOR represents that he has, or will secure at his
own expense, all personnel required in performing the services under this
agreement. Such personnel shall not be employees of the DEPARTMENT.
4. None·· of the work to be performed under this contract which involves
the specialized skill or expertise of the CONTRACTOR or his employees shall be
subcontracted without prior approval of the Contract Administrator. The Contract
Administrator must approve all subcontracts.
5. The CONTRACTOR is an independent contractor and assumes all
responsibility for self and does, therefore, hold harmless the Contract
Administrator for the DEPARTMENT, the DEPARTMENT or any other state
government persons for payment of federal and state taxes and any other
required payments. This Agreement will in no way be construed to constitute an
employer/employee relationship.
6. The services of the CONTRACTOR are to commence on the 6th
day of May, 1994, and shall be undertaken and completed in such sequence as
to assure their expeditious completion in light of the purposes of this agreement,
but in any event, all of the services required hereunder shall be completed by the
5th day of May, 1995.
7. If, through any cause, the CONTRACTOR shall fail to fulfill in timely
and proper manner the obligations under this agreement, the DEPARTMENT
shall there upon have the right to terminate this contract by giving written notice
to the CONTRACTOR of such termination · and specifying the reason thereof and
the effective date thereof. In that event, all finished or unfinished documents,
data, studies, surveys, drawings, maps, models, photographs, and reports
prepared by the CONTRACTOR shall, at the option of the DEPARTMENT,
become its property, and the CONTRACTOR shall be entitled to receive just and
equitable compensation for any satisfactory work completed on such documents
and other materials. The CONTRACTOR shall not be relieved of liability to the
DEPARTMENT for damages sustained by the DEPARTMENT by virtue of any
breach of this agreement, and the DEPARTMENT may withhold payment to the
CONTRACTOR for the purpose of set off until such time as the exact amount of
damages due the DEPARTMENT from such breach can be determined.
8. The DEPARTMENT may terminate this agreement at any time by
notice in writing from the DEPARTMENT to the CONTRACTOR. In that event,
all finished or unfinished documents and other materials shall, at the option of
the DEPARTMENT, become its property. If the contract is terminated by the
DEPARTMENT as provided herein, the CONTRACTOR will be paid in an
amount which bears the same ratio to the total compensation as the services
2 of 4
CONTRACT NO. V _ 4 0 ~ Q
actually performed bear to the total services of the CONTRACTOR covered by
this agreement, or for each full day of services performed where compensation is
based on each full day of services performed, less payment of compensation
previously made. The CONTRACTOR shall repay to the DEPARTMENT any
compensation he has received which is in excess of the payment to which he is
entitled herein.
9. The parties to this contract agree and understand that the payment
of the sums specified in this contract is dependent and contingent upon and
subject to the appropriation, allocation, and availability of funds for this purpose
to the DEPARTMENT.
10. The DEPARTMENT may, from time to time, request changes in the
scope of the services of the CONTRACTOR to be performed under this
agreement. Such changes, including any increase or decrease in the amount of
the CONTRACTOR'S compensation, which are mutually agreed upon by and
between the CONTRACTOR and the DEPARTMENT, shall be incorporated in
written amendments to this contract.
11. Any information, data, instruments, documents studies or reports
given to or prepared or assembled by the CONTRACTOR under this agreement
shall be kept as confidential and not divulged or made available to any individual
or organization without the prior written approval of the DEPARTMENT.
12. The filing of a petition in bankruptcy or insolvency by or against the
CONTRACTOR shall terminate this agreement.
13. The CONTRACTOR shall not assign or transfer any interest in this
agreement.
14. In accordance with Federal regulation CONTRACTOR certifies that
he will not engage in the unlawful manufacture, distribution, dispersing,
possession, or use of a controlled substance in the performance of this contract.
15. No reports, maps or other documents produced in whole or in part
under this agreement shall be the subject of an application for copyright by or on
behalf of the CONTRACTOR.
16. It is agreed between the parties hereto that the place of this
contract, its situs and forum, shall be Wake County, North Carolina, and in said
County and State shall all matters, whether sounding in contract or tort relating
to the validity, construction, interpretation and enforcement of this agreement, be
determined.
17. The CONTRACTOR agrees that the State may have the right to
audit the records of the CONTRACTOR pertaining to this contract both during
3 of 4
CONTRACT NO. V _ 4 Q 3 Q
performance and for 36 months after completion or termination. The
CONTRACTOR must retain all records relating to this contract and allow
employees or agents of the DEPARTMENT to inspect such records during the
period of time set out herein.
18. The CONTRACTOR agrees that he shall be responsible for the
proper custody and care of any State owned property furnished him for use in
connection with the performance of his contract and will reimburse the State for
its loss or damage.
19. Bill Meyer is designated as the Contract Administrator (project
coordinator) for the State. However, any changes in the scope of the contract
which will increase or decrease the CONTRACTOR'S compensation shall not be
effective until they have been approved by the DEPARTMENT Head or
Authorized Agent.
IN WITNESS WHEREOF, the CONTRACTOR and the DEPARTMENT
have executed this agreement in duplicate originals, one of which is retained by
each of the parties, the day and year first above written.
CONTRACTOR
By~ I!). f'iµJ_);
Contractor's Signature c
Pauline M.Ewald
Typed Name
WITNESS:
Approved as to Form:
Attorney General of North Carolina
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT, HEAL TH AND
NATURAL RESOURCES
}Jonathan B. Howes, Secretary
Direclor' ---: ___ -_
-~I /""'\ Div. of General Service~
. . ey,N:(,, J C< t ~ ...J k'.11 ~
Department Head's Signature
or Authorized Agent
WITNESS:
Signature
DUPLICATE ORIGINAL
4 of 4
AITACHM£NL A.
SCOPE OF WORK-PCB LANDFILL
I. RECOMMEND PROCEDURES FOR EVALUATION EXISTING ENVIRONMENTAL
CONDITIONS AT LANDFILL
1. Develop health and safety plan for all contractor personnel
and on-site observers.
2. Water fluctuation study.
3. Leachate (water in landfill) volume study.
4. Gas venting study.
s. Top liner evaluation.
6. Bottom liner evaluation.
7. Groundwater monitoring system study.
8. Leachate system evaluation.
9. Water treatment system evaluation.
10. Surface water/sediment evaluation.
11. Vegetation evaluation.
12. Chemical/physical sampling and analysis including all toxic
constituents and specifically dioxin and furans.
13. Human, animal and wildlife evaluations.
14. Identify indirect impacts of PCB landfill.
15. Other evaluations/studies identified by working group.
II. RECOMMEND METHODOLOGY/TECHNOLOGY FOR REMOVAL OF WATER FROM
LANDFILL
1. Feasibility study of removing water from landfill relative
to protecting landfill integrity and detoxification
efforts.
2. Desfgn system for removal of water, treatment and on-site
disposal.
a. Alternatives include using existing systems with
modifications or designing alternative system(s).
III. EVALUATE POTENTIAL TECHNOLOGIES FOR DETOXIFICATION OF
MATERIALS IN LANDFILL
1. Review published data on technologies including chemical,
physical, biological and thermal (excluding incineration)
amenable to detoxification of PCB materials.
2. Select applicable technologies.
3. Identify and select vendors with existing capability to
apply selected technologies for detoxification of landfill.
4. Invite selected vendors to make presentations for proposals
to detoxify landfill. Presentations should include all
technical aspects and risks associated with technology,
probability of success, on-site disposal of residues,
schedules and budgets, cost and financial capability
(liability and assets) of vendor.
5. Select applicable/successful technologies and determine
cost estimates.
IV. RECOMMEND DETOXIFICATION TECHNOLOGY(S) AND BUDGET FOR
IMPLEMENTATION FOR FUNDING/APPROPRIATION TO GENERAL ASSEMBLY
1. Propose detailed reports and data sufficient to provide
General Assembly with information to make decision for
funding.
2. Plan efforts to work with elected officials at all levels
to build support for detoxification.
V. RECOMMEND LONG-TERM INSTITUTIONAL CONTROLS FOR OPERATION AND
MAINTENANCE OF PCB LANDFILL
1. Plans developed for monitoring and upkeep of site.
2. Responsible agencies assigned for monitoring and care of
site.
3. Budgets for long-term care.
4. Contingency plans in place for unanticipated events.
VI. PERFORM OTHER TASKS AS IDENTIFIED AND APPROVED BY THE JOINT
WARRE~ _ _cOUNTY/STATE PCB WORKING GROUP
E NVIRONMENTAL
COMPLIANCE
0 RGANIZATION
ATTACHMENT' B
106 Robinson Street Ashland. Virn:inia 23005
PROFESSIONAL \\TASTE :MANAGEMENT CONSULTANTS [phone]
PRELII\HNARY Tll\1E/COST ESTl!'\1ATE
SCOPE OF \VORK
NORTH CAROLl:'\A PCB LANDFILL PROJECT
I. RECOMMEND PROCEDURES FOR EVALUATION OF EXISTING
ENVIRONMENTAL CONDITIONS AT THE SITE
Perfonn in oYersight · assistance capacity for items 1-14 to include on-
site obsen·ation and split sampling designated under item 12.
TIME ESTIMATE: 373 man hours
COST ESTIMATE : 373 man hours XS 75.00 /man hour= 2 roundtrips
of approximately 400 miles @ S .25/ mile =
S 28,175 .00
II. RECOMMEND METHODOLOGY·TECHNOLOGY FOR REMOVAL OF
WATER FROM LANDFILL
Perform in an oversight/assistance capacity including written reports for
listed tasks 1-2
TIME ESTIMATE: 175 man hours
COST ESTIMATE: 175 man hours X $75.00/man hour= 2 roundtrips
of approximately 400 miles @ S.25/ mile =
S 13,325.00 .
PRELHIIX-tRJ' TLUEICOST ESTL\l-tTE
SCOPE OF TFORX
.\'ORTH C-tROLJ\:-t PCB L4.XDFILL PROJECT
P.-1.GE 2
III. EVALUATE POTENTIAL TECHNOLOGIES FOR DETOXIFICATION OF
MATERIALS IN LANDFILL
Perform in an oversight1assistance capacity for items 1, 2, 3 and 5 to
including written reports for items 1,3, and 5
TIME ESTIMATE : 350 man hours
COST ESTIMATE: 350 man hours XS 75 .00:man hour..,. I roundtrip
of approximately 400 miles @ S .25 .'mile =
S 26,350 .00
Time for item 4, ca1mot be estimated prior to better understanding the pool of
potential Yendors . ECO participation in this task will be billed on a straight time
-cost basis .
IV. RECOMMEND DETOXIFICATION TECHNOLOGY(S) AND BUDGET FOR
IMPLEMENTATION FOR FUNDING.1APPROPRIA TION TO GENERAL
ASSEMBLY
It is not clear that ECO's assistance would be required for tasks 1 and 2
under this SOW heading. Should ECO's assistance be required, it
would be billed on straight time + cost basis.
ENVIRONMENTAL
COMPLIANCE
0 RGANIZATION
.....
PRELLUJJ\:-tRJ' TIME/COST ESTIMATE
SCOPE OF J,VORK
NORTH C4ROLIN.4 PCB L-4..'!\"DFILL PROJECT
PAGEJ
V. RECOMMEND LONG-TERM INSTITUTIONAL CONTROLS FOR
OPERATION AND MAINTENANCE OF PCB LANDFILL
Perfonn in oversight'assistance capacity for items 1 and 4 to include
preparation of detailed site closure report. It is not clear that ECO
would significantly in tasks 2 and 3.
TIME ESTIMATE : 200 man hours
COST ESTIMATE : 200 man hours XS 75.00 iman hour= 1 roundtrip
·of approximately 400 miles@} S .25 /mile =
S 15,100 .00
VI. PERFORM OTHER TASKS AS IDENTIFIED AND APPROVED BY THE
JOINT WARREN COUNTY;STATE PCB WORKING GROUP
ECO may be a\'ailable to perfonn additional work outside this SOW at
a t1at rate of S 75.00.·man hour, Senior Technical Staft~ plus travel,
supplies and per diem expenses at cost.
TOTAL ESTI~1ATE Tll\1E THIS PROJECT:
TOT AL ESTII\1ATED COST THIS PROJECT:
1,098 MAN HOURS
S 82,950.00
E NVIRONMENTAL
COMPLIANCE
0 RGANIZATION
.. MEMO
• ..
oe c e ,
O t o o :
Ot
G c,·
0 1
CCI:
C Cl f o e :
C 0( o e ·
C. 0 f •• c.. 0 .. o e
PAULINE M. EWALD
EDUCATION:
t B.S., Em1ronmental Engineering, Cornell University, 1980
Minor in Community Planning and Development
t J.D., Syracuse University College of Law, 1984
Law School major in Government and Regulation ·
t Graduate work In Blochemlst11·, Syracuse University,
ongoing CLEP in environmental and regulatory law
AJE!tf BERSHIPS:
t Member, Emironmental Law Section American Bar Association
t Member, Hazardous Materials Control Association
t Member, Metropolitan Washington Emironmental Professionals
t Certified, Emironmental Professional Manager
RELEJ,>U\'T EXPERIENCE:
As Former Director of the Virginia CERCLA Program, Ms. Ewald has over
5 years experience in the supervision, training and oversight of a large staff
of engineers, chemists, geologists and attorneys, in the discovery,
assessment and remediation of waste sites across Virginia. Ewald was
responsible for the development and institution of QA/QC sampling
programs utilized as a model for states by U.S.EPA Region III. Under her
direction, the Virginia Program successfully completed the first QAPP in
the nation, allowing State personnel to sample on behalf of EPA and utilize
sampling results for site analysis and ranking, enforcement, civil and
criminal actions. Her position entailed project management and oversight
for over 400 million dollars in remedial and removal projects in the
Commonweal th.
As Director of Regulatory Affairs for Chem Treat, Inc., Ewald initiated and
developed RCRA contingency, SARA III, and employee safety plans for a
multi-facility manufacturing firm. Ewald was also responsible for creating
a fire brigade and emergency response team for industrial parks in Virginia
and Texas. Additionally, she has been actively involved with local
emergency planning commissions in Texas and Virginia. Ms. Ewald is the
1990 recipient of the prestigious Cav<1llll award for excellence in the
administration of government and husiness.
1-• ~ ,.. •·. •► X ;f ·• , .. ·-. ';~ ... ·' l
c,,"-~.f State of North Carolina ..
........__~!""\e·partment of Environment, Health, and Natura_) ~~otJrces . ,., .. ,, · 1 •
512 North Salisbury Street • Ralt:igh , North Carolina 27604
Division of Solid Waste Management
[phone] · Jonathan B. Howes, Secretary James B. Hunt, Jr., Governor
Dear Registrar:
1he Personnel Office Is In the process of wrtfying post secondary degrees/diplomas and
professional licensure, cenification, or registration of new employees and applican1s being
considered for appotntmenr.
We would appreciate your assistance In this endeavor by compleling the l'lforma1ion at the
bottom of the page for the Individual listed below.
As you can see from the reverse side of this fonn, the applicanllemployee has signed a s1atemenr
to release the l'lforma1ion.
Name under which degree/diploma was awarded:
Pauline M. Ewald
First Middle Last
Social Security No.: __ 0_9_9_-5_2_'-_2_33_9 _______ Year Graduated: __ -..11"""'9~8P"'----
THE FOUOWJNG IS TO BE COMPLETED BY TJIE OFFICE OF TIIE REGISTRAR
Enrolkd from_9jJjJ_7 ,0 __ 1_21_2_3_/_79 ________ _
:iuu:-s cu,nple,td Semester x Quaner
Did s1uden1 receive a degree(s)@Bachelor of Science no ------
Uso, what degree(s) 01/ 16/80 major(s) ....,A..,.g.,..r=i=cu=l=t=ur::.;:e=---------
• Did studenr receive a diploma @--s.:.t,am~e=---------no _________ _
Uso, what diploma ----:~--:----------------------Did s1uden1 receive a cenificare? yes _________ no ________ _
If~. whatcenjficate ~ ...,u~ <"'"' ,~\ ;r .. ,-
Signed David S Yeh University Registrar
Registrar
NOTE: Please use official stamp and/or raised ieal.
Date 4/26/94 ---------
PLEASE RETURN TIIIS IN TJJE AITACJJED SELF ADDRESSED ENVELOPE
PO Box 2761!7, Rale~.ti. North Carolina 27611-761!7 Telephone 919 7H491!4 Fix I 91~733-0513
An Equal Opportunity Att1rma1ivc .A.ction Empluyl-r
TEL N0.804 798 4305 .., .... _,.., .. ,.,. ... Apr 21,94 15:35 P.04 ,., ~
DBPARrMBN 0/1 BNVIRONMBNr, HBALrH • NAnJML RBSOVRCBS
v?/Qme.· thwktol( m .. Ew8~P
v$SN: ~ff· 62 -2JJ CZ
Olwslon: ___________ _
Posl1lo11.• -------------
Dear Bmp1o~ee.·
Wh,n you ~ltttd, e Slat, Appllcotlon/or Employment, you 1l1ned this 1tatemen1. •1 cenll}>
1h01 I ho~ 1tvtn 1ru , occurate and comp/11, l'lfonnorlon on 1h11 form to 1h, bl11 qi m»
lmowledgi, In 1h, nl w'lflnnmlon 11 nted,d In co1111tcllon with noi work, I 0U1h<>rlu
1duco1lonal ln.slltutlo , AJ.rocl01lons, r,gl11ra1lon """ /lc,,ulng boord1, 11nd othlrs 10 .fi'mlsh
wha1ev,r de1all 11 o I/able concernlna m1 qual~C'tltlons. I omhorlu lnve11l1otlt>n o/ oil
110,em,nts modi '" th appllcotlon and uNl~ntand that /alSt l'lfonnotl<>n or docum~motlon, or
o fallur, 10 dlrclo1t tlt~anl ltlfonnallc>n mQ) H 1roun41 for r,J1ctlon o/ my oppllca,1011.
dlsclpllna~ octlon or tsmlssal VI am 1mp/oy,d, on,J (or) criminal ocllon. lfurth,r 11ndus1a111J
lhol dl1ml~10I "1()11 , iploymtnt 1hall h, maru/o,ory If ,froudul1n1 dllCIOlUT"el or, 1lven 10 meet
polltlon ,,ollflootlons •
'
,,., ,,,,~, jOn lhl N rse o/ this Jonn wlll bt mall,d ,~ lht lnstlt11tlon '""'"' lhl ouoltfflng
degrtt 10 ¥1rll)i )'Dur redtntlal1. P/11111 compl1t1 lh, lttfonnatlon b,low ond "''""' IO Sc,lld
W0111 Mo~411m1n1 lvlilon, P, 0, 101 J,111, ltol1l1h, NC l161 J-'1611. ___.................... ____ .......................... ·-··· .. · .... ·---·• .................................... ..
~ame undtr which De r,e/D!plomtJ WQS awarded: __ e_A_;;_, ..,./Jl).._1 ll.,il,f:_ .... m __ . __ . ---~..:,;W~B ........ bz ... P __
O.,reell>l aaward,d.• _]....,. ,.$_, ______________ _
• ""-qf A°wordlng 1111,wn: Cc& II 'k I.. tWJ j} £R ,s: I 11
141Nttoltd)orCM,pus.· COkLe:G.lr of A G,iJC.Ut.-rvRc-~. Ltff Sc,wc£S
,fllry.• Stall,' tJ . j. Zip: / '-/ 'i 6' 0 I&
I oUlhorl~ eduootlcma IMtltutlons, o.r1<>e11111on.s, rtgtstrollon.r """ /lc,n1ln1 boart/1, and othtrs
10 Jl,mt1~ lvhate!'l'r d oil ls ~JJt,ble ~ncemlng my 11ualU,co1lon1.
~loyel!'I s1,no1ur,~ ~ tn . e_vJ,J,l l>Rte,• L{ Lis /qr ,wl 7
411---..-.t'O-
~i
_ · 1\\' 0 ·I 1ctu j ~}} ~ -1-, I •• 7 · ••
.. I •,.,, 9 .., . l r _, ! ,,.•~ r;,F;!?__
~.i,~ ~,£ State of North Carolina · . ·, ·, ., .
. ·-_. ___ . ~ epartment of Environment, Health, and Natu~L~~s<?y~ce~_:;., 1 \.iJ.
512 North Salisbury Street • Raleigh, North Carolina 27604
Division of Solid Waste Management
James B. Hunt, Jr., Governor [phone] · Jonathan R Howes, Secretary
Dear Registrar:
1he Personnel Office Is In the process of verifying post secondary degrusldiplomm and
professional llcensure, cenlficaJlon, or reglstrtulon of new employees and applicants being
considered for appointment.
We would appreclme your assistance In this endeavor by completing the l,ifomuulon at the
bottom of the page for the Individual listed below.
As you can seefrom the reverse side of thlsfonn, the applicant/employee has signed a s1a1ement
to release tht lrifomuulon.
Name under which degree/diploma was awarded:
Pauline M. Ewald
First Middle Last
Social Security No.: __ 0_9_9_-5_2_'-_2_33_9 _______ Year Graduated: ____ 1....,.9""'8..._0 __
·-----------------------------------
TIIE FOUOWING IS TO BE COMPLETED BY TIIE OFFICE OF TIIE REGISTRAR
Enrolled from_9JJ1J} __________ to __ 1_21_2_3_l7_9 ________ _
:io14rs cvmpleted Semester x Quarter
Did student receive a degree(s) ~ Bachelor-_ o-f-=-S-c-ie_n_c_e __ no ____ =-===========
lfso, Whal degru(s) 01/16/80 major(s) __ A....,g::,..,r'"""i:.:::c=ul=t=u=r=e ______ _
• Did student receive a diploma ®__..s..._am=e=---------no _________ _
lfso, what diploma ---------------------------DI d student receive a cenlficate? yes _________ no ________ _
f/~.wha1cet1lfictue ~ ~~ ...-::::: , ~.....,.\ ,,.-
Signed David S Yeh University Registrar Dau ---------4/26/94
Registrar
NOTE: Please use official stamp and/or raised real.
PLEASE RETURN TIIIS IN TIIE A TTACIIED SELF ADDRESSED ENVELOPE
P.O. Box 27687, Raleiboh, Nonh Carolina 27611 -76!17 Tekphone 919733 ~9!1~ Fax# [phone]
An EqUJI Opponunity Affirmative Action Employl'f
Z' n
0
JiCEIVfo
, l
4 ~ State of North Carolina 0
-1-9,
Department of Environment, Health, and Natural ~esou L-_.__.-
s12 North Salisbury Street • Raleigh, North Carolina 27004
Division of Solid Waste Management
[phone] · Jonathan B. Howes, Secretary James B. Hunt, Jr., Governor
Dear Registrar:
Tht Personnel Ojfice Is In the process of verifying post secondary degrees/diplomas and
professional llcensure, cenificaJlon, or reglstralion of new employees and applicanis being
considered for appolnrmeni.
Wt would appreclaJe your assistance In this endeavor by completing the l,ifonnatlon aJ the
bottom of the page for the Individual listed below.
A.f you can see from the reverse side of thlsfonn, the appllconJlemployee hm signed a staJement
to releme the l,ifonnatlon.
Name under which degree/diploma was awarded:
Pauline M. Ewald
First Middle Last
Social Security No.: _o .... 9 .... 9'--=5 2=---=· 2'""'3"""3 9:;.._ ______ Year Graduated.~ _1_9_8_4 ___ _
--------·---·---------------------------·------
TIIE FOUOWING IS TO BE COMPLETED BY TIIE OFFICE OF TIIE REGISTRAR
Enrolled from August 25_,_1_98_1 _______ to August 14, 1984
!!c-ZJr; cmnpltiul 85 Semester x Quaner _____ _
Did studenJ receive a degree(s)? yes __ x ________ no ________ _
lf so, what degree(s) JURIS DOCTOR major(s) _L_A_W ________ _
• Did studenJ receive a diploma? yes __________ no x
lfso, what diploma ---------------------------DI d studenJ receive a cenljicate? yes ---"------no _x::.:...... _______ _
IJ~, wha1cenlfi~e
Signed -~ xi tl ti
' Registrar
Dale April 28, 1994
NOTE: Please use official stamp and/or raised 1tal.
PLEASE RETURN TIIIS IN TIIE AITACIIED SELF ADDRESSED ENVELOPE
PO. Box 27687. Ralc:ib,h, Nonh Carolina 2761176!17 Tdqilmne 919 733 49!14 fax I 919-733-0513
An Equal Opponunity Affirmative Action Empl11yl1'
ITEMS FEDERAL EXPRESSED TO PAULINE EWALD
1) LETTER: TO: Secretary Harrelson
Secretary Cobey
FROM: James Lofton
Dated 6-11-91.RE: PCB Landfill Agreement-Warren County
2) LETTER: TO: James Hunt
Charles Jeter
3)
4)
FROM:
Dated 12-14-81.RE:
conditions.
Plans submitted for approval to
LETTER:
Dated
Waste
LETTER:
TO:
FROM:
6-4-79.RE:
Landfill for
TO:
FROM:
James Hunt
John White
Federal Register regulations-Chemical
PCB submitted by NC (on EPA letterhead).
William Phillips
Thomas Devine
Dated 11-22-82.RE: Cooperative agreement signed-requirements
of State after closure to fulfill agreement.
5) DOCUMENT: Dates/itinerary-four pages.
6) LETTER: TO: Citizens of Warren County
FROM: Governor Hunt
Dated 10-20-82.RE: Governor Hunt meeting citizens of Warren
County.
7) Final report and recommendations of the the Inter-governmental
Work Group on PCB detoxification.
TO: Governor Hunt-Dated 12-12-84.
8) Leachate removal, sampling and analysis of PCB Landfill-
Document with tables/graphs-1982-1993 (from Bill's file)
9) Administration action final Environmental Impact Statement
of N. C.
FROM: Secretary Burley Mitchell (CC&PS)-Dated 11-13-80.
10) LETTER: TO: Bill Meyer
FROM: S&ME, Inc.
Dated 11-20-92.RE: PCB Landfill, Warren County-four pages
front and back.
11) PCB Landfill Project Report -July 8, 1992 by Randy McElveen
12) Section 2-Conclusions drawn for results of study-PCB Landfill
(one page).
13) Waste Disposal Site drawings -Dept. CC&PS-large blueprints
(approx. 12 pages).