NCD980602163_19961017_Warren County PCB Landfill_SERB C_CODEVCO Meeting-OCR

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August 19. 1997
To: Mike Kelly, Technical Committee, Pat Barnes
From: Joel Hirschhorn
Re; CQ.!llIPents on Draft Eco Logic Phase 1 report
Table 4: add dio"-.i.n TEQ levels in feed, similar to PCB data.
Table 6: data on PCB levels --and perhaps other contaminants -appear tc, be rounded numbers,
compared to Table 4: only actual data sh.ould be used. The PCB data in Table 4 does not
correlate exactly ·with dat.a in Appendi.x E; it appears that Total PCB + EMPC data were not nsed
and, if so, thau the repo11 should defend excluding the EMPC data.
All tables: whenever ND is gjven as a result place actual detection limit in parentheses next to
ND. If some data are ruspect because of findings in blanks, then that should be noted. For
example, it is sns.-picious that toluene was found at a higher level in Run 2 treated solid than in
odginal feed.
In the calculation of dioxin TEQs it is not acceptable to assume NDs = 0 if the NDs are high; a
more proper and conservative approach is to use onehalf of the NDs.
Section 5: should include some infonnation on length of time for actual full-scale cleanup of the
site. Should check statements about estimated price of $350-400 per ton an.d what it includes or
excludes. ls it really a total, tum-key remediation cost, which statements now imply?
Section 4.2.3: ,.vould like to see some more detailed explanation ofhow TRJVf temperature ... ,-as
''inadvertently allo-.ved to drop to 500°C, which is below the minimum operating temperature of
S50°C." How would this type of malfunction be prevented in actual full-scale equipment?
Section 4.2.3: statement about infeasibility of reaching a 1 ppt TEQ should he reexamined,
because it is not correct.
Table 9: would like some exJ)lanation for finding of dioxin in Run. 3 treated scrubber water and
whether th.is would be found in full-scale equipment. The explanation on p.25 about "interference
in the analytical technique" is not satisfactory.
Would like to see a special sub-section in 4.2 about levels of PCBs and dioxins in all process
waste streams (solid, air, water) and discussion of meeting regulatory requirements and/or
providing treatment of proc,ess residuals in company's equipment, or whether o:ffsie
t.reatment/disposal would be required. Sl1ould have some discussion of PCB/dioxin air emissions.
Section 5.5: statement that the process "requires minimal processing of untreated soil prior to
treatment" should be amplified, so that exac,,1 processitig that may be necessary in full-scale
operation is fully detailed.
Was PM measured in exhaust gas?
TI1e dioxin data for Run 2, Sl and S5 need more discussion. In both cases the levels and
distribution of dioxin congeners is not typical for PCB impurities. But in the treated material,
there is even more dioxin.s than in the feed material, especially of the most toxic forms. Is it
possible that some reactions have occurred during desorption processing?
Titere should be more detailed information on exactly how the materials received by the company
were treated and handled prior to becoming designated as the feeds for the three runs. Was a
composite made from all incoming contain.ers? Did each nm correspond to one particular bucket?
How much oversize material was screened out as a percent of the origiual soil sample provided?
What did this malelial look like?
The report should present some discussion of its approach to give PCB data m. tenns of total
PCBs rather than more typically used method of giving data in terms of Aroclors. At least for the
SI data~ some ruscussion of lab data should be given to relate to more typical data on Aroclors.
Should present some infomiation on relative toxicities of different PCBs,
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MEMO
SUBJECT: ~.
From:lfuru/?
North Carolina Department of Environment,
Health, and Natural Resources @ PrintedonRecycledPaper
PCB LANDFILL STATUS
BRIEF BACKGROUND
In 1993, Governor Hunt was briefed by state officials on the status of the PCB
landfill in Warren County. He was told that the contents of the landfill had not been
sampled since construction, and that there was water in the landfill that needed to be
tested and removed. The PCB landfill was constructed to be a dry facility. At the
direction of the Governor, state officials met with Warren County officials in a public
meeting to determine what to do about the water. The intent of that meeting was to
get concurrence on extraction of the water. Several citizens demanded that
detoxification be considered as a prerequisite to dewatering or done simultaneously
with dewatering of the landfill. They also cited the commitment that Governor Hunt
made in a 1982 letter to the citizens of Warren County to detoxify the landfill when
feasible. As a result, DEHNR set up a 16-member working group composed of Warren
County citizens, environmentalists, and state officials to make recommendations to the
Governor about the future management of the PCB landfill.
The working group met for the first time in January 1994. Upon the group's
recommendation, a contract was entered into with Pauline Ewald, head of
Environmental Compliance Organization, on May 1, 1994 for $82,950 (:~noney came
from DEHNR) to serve as the group's science advisor for one year. Her duties were to
recommend site evaluation procedures, a methodology for water removal, a
detoxification technology, and long-term controls for the PCB landfill.
In July 1994, a sampling event was conducted at the landfill by Ms. Ewald's
company and the state. No PCBs were found outside of the landfill. However, the
laboratory that analyzed the state's samples detected some dioxin at the ppq (parts per
quadrillion) level in three of the monitoring wells around the landfill. Opinions varied
as to where the dioxin originated. Despite the fact that Ms. Ewald tried to discredit the
state's findings, she used those findings to conclude in her report that "In the absence
of other likely sources of chlorinated contamination, it is likely that the PCB landfill is
the source for the dioxin and furan contamination noted at the site." The report
prepared by Ms. Ewald was not acceptable to the state. It was peer-reviewed by several
outside sources who were also critical of her report.
The state recommended that the landfill be resampled. The working group
opposed both resampling and removal of the water from the landfill. Ms. Ewald's
report convinced several members of the working group that the landfill was leaking.
Even though several members of the working group acknowledged that the presence of
water in the landfill presented a potential risk, they did not want the water removed.
They have repeatedly expressed concern that if the landfill were made safe by removing
the threat of the water that the state would not proceed with any detoxification effort.
Ms. Ewald recommended that a technology known as base catalyzed
dechlorination (BCD) be used to detoxify the landfill. The state advised the working
group that at least three methods should be considered and that the General Assembly
would want information about various technologies available for detoxification, why
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certain technologies were approved/rejected, and costs. The working group felt that
the BCD process was a suitable technology and would be acceptable to the community
because it could be done on site. The state and the working group went through the
process of selecting vendors to conduct pilot projects at the landfill using BCD
methods. Two vendors even went through the EPA process for approval. Both
eventually received approval by EPA. Pilot-scale proposals by the vendors included a
cost ranging from approximately $700,000 to $800,000 for on-site testing of
technologies.
Ms. Ewald's contract expired in May 1995.
CURRENT STATUS (July 1, 1995-present)
Membership
The original working group was composed of 16 members. At the working
group's request, the membership was raised to 24 in September 1994. Presently,
there are 21 people on the working group, with Senator Frank Balance serving as an
ex-officio member and Mr. Bill Meyer, director of the Division of Waste Management,
serving as staff. Three positions are vacant (one public safety and two youth).
Approximately 10-12 members show up for meetings on a regular basis, and they are
the decision-makers. The others attend meetings sporadically or never attend. There
are only two elected officials on the working group. County Commissioner Lucius
Hawkins' attendance is sporadic. He was defeated in the spring primary. Ms. Dollie
Burwell, the Register of Deeds for Warren County, is one of the co-chairs and a regular
attendee. She also was defeated in the spring primary.
The credentials of the working groups members, other than the three state
representatives, are basically unknown. The working group very heavily relies on the
state for staff, technical expertise, and support. Yet members have repeatedly said
they do not trust the state.
Expenditures
In March 1994, Warren County was awarded $100,000 from the Solid Waste
Grants Program to be used for capital improvements on the PCB Landfill.
During the 1995 session of the General Assembly, the legislature appropriated
$1 million from the Highway Fund for pilot projects to determine the most appropriate
technology for cleanup of the landfill.
The working group members decided they needed the services of another science
advisor as well as support staff. On March 7, 1996, Mr. Joel Hirschhorn (Maryland)
and Mr. Patrick Barnes (Florida) were hired as science advisors for the working group.
On March 18, 1996, Ms. Doris Fleetwood was hired as a part-time secretary for the
working group. A joint agreement was made between the DEHNR and the Warren
County Board of Commissioners to provide office space, furniture, equipment,
supplies, conference room, kitchen, restroom facilities and parking for the secretary
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and the two science advisors. The working group's office opened on March 25, 1996, in
the CP&L Building in Warrenton, NC. The $1 million appropriated by the General
Assembly is being used to pay the science advisors, the secretary, and office rent. The
science advisors are each paid at the rate of $100 per hour of work. The cost for the
half-time secretary and office space is $25,000 for one year. As of September 1996,
$60,252 has been expended from that fund, of which $31,809 has gone to the science
advisors.
In the fall of 1995, the Division of Waste Management began working with CP&L
to provide electrical service to the landfill for pilot projects or any full-scale
detoxification effort. CP&L was paid $64,384 for this service from the capital
improvements account. Poles and lines for electrical service are in place, and
transformers will be added when the specific electrical demands are known. This
provides a permanent source of power for detoxification efforts or dewatering the
landfill, as well as other activities that may require electricity.
Master Plan
After talking with the working group and reviewing files and documents related
to working group activities and the PCB Landfill, the science advisors developed a
master plan. This master plan stated why the working group should change its
current strategy and offered an alternative strategy. The working group approved the
master plan at their April 25, 1996 meeting.
The science advisors offered several reasons for changing the current strategy of
the working group. Briefly, the science advisors stated that it would be just as
effective, and less expensive, to invite a few companies to conduct off-site, bench-scale
tests on the landfill's contents rather than pilot-scale projects. This would also mean
that less material would have to be removed from the landfill for the studies. The
science advisors stated that other detoxification technologies must be thoroughly
examined. They also said that a much stronger case for funding from the General
Assembly could be made by spending money on a more thorough site investigation and
remedy design.
The science advisors recommended several key steps in the alternative strategy.
They felt that a more detailed evaluation of detoxification technologies and vendors
should be conducted by the science advisors. Mr. Hirschhorn is currently working on
this item. They also suggested that a site investigation be conducted to determine the
current status of the PCB Landfill and the surrounding area. Mr. Barnes and state
officials are currently working on this item, and a plan will soon be presented to the
working group for approval. This investigation, if approved, will include the placement
of additional monitoring wells and a resampling of the landfill and surrounding area.
The site investigation will cost roughly $50,000 (excluding state staff costs), and it will
be funded from the $1 million approved by the General Assembly.
The alternative strategy also calls for several other items:
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-Designing a soil and waste removal plan and selecting a vendor to do
this;
-Issuing a feasibility study report;
-Inviting vendors to conduct bench-scale treatability tests;
-Evaluating test results and selecting/ranking vendors (to be done by
science advisors);
-Finalizing the site investigation report;
-Meeting with working group/highest ranked vendors;
-Selecting best technology vendor (pre-qualified for actual cleanup);
-Hiring best technology vendor as design contractor (under current
funding);
-Selecting a remedy and issuing a remedial design report.
The remedial design report would be used as the basis for the working group and
DEHNR to formally propose the landfill detoxification project to the General Assembly
to obtain funding.
9/24/96
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ROLES, DUTIES AND RESPONSIBILITIES OF THE PCB LANDFILL
WORKING GROUP, THE STATE, AND THE SCIENCE ADVISORS
PCB Workin& Group
• Assess current conditions and safety of landfill and make recommendations
to DEHNR for addressing any unsafe condition identified.
• Assess need to remove rainwater from landfill and recommend to DEHNR
the basis and technology for removal or allowing rainwater to remain in the
landfill.
• Identify and evaluate technologies for detoxification of landfill and make
recommendations to DEHNR on appropriate and feasible technologies for
detoxification.
• Identify and recommend implementation strategy to DEHNR for all
goals/tasks including infrastructure and funding.
The State
• Maintain integrity of PCB Landfill to protect public health and the
environment.
• Serve as staff to the PCB Working Group.
• Implement funded recommendations for long-term maintenance and, if
appropriate, detoxification of the landfill.
The Science Advisors
• Develop PCB Landfill detoxification project master plan.
• Develop proposals and plans for legislative support of detoxification efforts.
• Develop community interaction plan.
• Prepare information on alternatives for detoxification, selection of
alternatives, pros and cons of alternatives, cost of alternatives and basis for
selection of specific alternative.
• Perform additional tasks or delete tasks as directed by the PCB Working
Group.
MEMO
DATE: _______ _
TO: __________ _ SUBJECT: ______ _
From: __________ _
North Carolina Department of Environment,
Health, and Natural Resources @ Printedon RecycledPape,
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