NCD980602163_19961018_Warren County PCB Landfill_SERB C_PCB Meeting-OCR

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MASTER PLANNING PROJECT -PCB LANDFILL IMPACT
ASSESSMENT AND DETOXIFICATION MASTER PLAN
TASK 4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
TECHNICAL BACKGROUND
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Spill/Excavation ~ 2,oD
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During July and August 1978, approximately 3~!!.o~~of P contaminated
transflrmer oil was ille~ d}scharged onto more than --z es of road shoulder in 14
North Carolina counti~tivated charcoal and a liquid asphalt tack solution was
applied to the spills to absorb the PCB and minimize migration in the environme 2-
From September 15, 1982 until November 1, 1982, approximately 40,000 cubic
of PCB contaminated soil were excavated, a 24-30" width by 3-1/2 inch deep spill , rom ... J
the road shoulders. The contaminated soil were placed in a USEPA permitted (Title 40 ~J (:j'.
Code of Federal Regulations, Part 761) Ioxic Substance .Control Act Chemical Wa~;J~ ,:;:-'~
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Landfill Design
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The PCB ,l~ndfill consists of a single cell approximately J:&1lcres '260' wiatk by~ 1,)
MHigth) ~Containment systems, including clay and PVC liners, were constructed . An
internal leachate collection and removal system allows removal of water followed by o_i:ii--
site treatment with sand and carbon filter~ with irrigation over the landfill surface..a-t§JAn
external holding pond or sedimentation basis (0.35 acre, 120' by 120') with a storage
capacity of !}yo and one half acre feet was constructed immediately North East of the
landfill eel~ Final grade consisted of a crown along the center line of the cell with 10
percent side scopes~~ A chain link fen,9_~ .. ~as constructed along the encloses an area of
approximately ll acres (555' by 30~ A four inch PVC air vent was installed in the
approximate center of the cell for release of gase£~ Four groundwater monitoring wells
were installed, one each North, monitoring well #2, South, monitoring well #3, East,
monitoring well #1 , and West, monitoring well #3 of the landfill cell ~ Surface water
sampling points were located upstream and downstream on Rich Neck Creek, North of
the site and an unnamed tributary to Rich Neck Creek South and East of the site. €'1~ 11 c-7 ( +ilM L)
Physical and Chemical Characteristics of PCB Landfill Contents
The 40,000 cubic yards of road shoulder materials consist of organic matter, primarily
grass stems and ro°l_s, ~~d mineral soils. The soils are classified as silty or clayey sands.
(AASHTO A--2--4)~he weight of the soils are approximately 59.9 lbs per cubic foot
1 ,0. The soils contain less than 30 percent fine materials, the liquid limit and plasiticty . '1 ,ff)
index is 8.5 and 8 respectively. Total organic matter is less than 2% on a weight basis <tn;.!,J
· Contaminated soils have an average PCB concentration of approximately 3 50 ppm with a
range of 150 to almost 900 ppm.C.~
The PCB is a mixture of congeners with approximately 'l!-n feight percent ~?.rochlor 1260,
27 wt% 9'arochlor 1254, and 12 wt% arochlor 1242)il'(l.-'<:)ther organic constituents include
chlorinated benzenes, furans and dioxins at pp-1:or ppq concentrations <~JI) 'j
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significant technological processes for detoxification and analytical capability.
The State reaffirmed the commitment for detoxification and ensuring the safety of the
landfill. In March 1994, a Joint Warren County & State PCB Landfill Detoxification
Working Group was established. An independent Science Advisor was hired to assist the
Working Group. The major focus of the Working Group was evaluation of the safety of
the landfill and identifying appropriate and feasible PCB detoxification technology. In July
1994, under the direction of the Science Advisor, the Working Group performed a
comprehensive sampling and analysis of the landfill environment and selected a technology
(Base Catalyzed Dechlorination (BCD), and vendors for detoxification of the landfill. The
Working Group also developed a process for implementing Pilot Scale on-site studies of
PCB detoxification technologies.
The Science Advisor contract ended in May 1995. The General Assembly appropriated
$1 million to fund pilot projects to identify and select a technology for detoxification and
remediation of the PCB landfill. Two new Science Advisors were hired to continue the
detoxification efforts.
The new Science Advisors developed a Master Project Plan <30>. The plan directs new
strategies for development of feasbilility and remedy selection for detoxification and
development of a comprehensive site investigation. These efforts can proceed
independently; however, there is a significant degree of dependance between the two
efforts for final recommendations on detoxification. Dependance is primarily based upon
the form of materials, solids and liquids, and the quantity of materials to be detoxified.
Both the type of technology and scale or size of the detoxification effort is dependant
upon form and quantity of materials to be treated. In order to accurately determine these
factors, a comprehensive site investigation is required for providing information relative to
technology and scale.
Existing Site Information
The 1994 Comprehensive site investigation included sampling of all surface water,
sediment, groundwater, landfill contents and land surface features associated with the
landfill . Dioxin 8{, furans at part per quadrillion (ppq) levels as well as metals, PCB,
VOCs, base N~ acid extractable organics were analyzed <31>. At best, the date is
inconclusive with respect to dioxin and furans. Comparisons between landfill content and
monitoring wells #2, #3, and #4 indicate different dioxin isomers which tends not to
fingerprint dioxin well sources as associated with the landfill. Dioxin concentrations in
monitoring wells were higher than landfill leachate which is not consistent with ...... .
sources of contribution of dioxins. In addition, the adequatecy of the groundwater
monitoring wells is also a concern <32>. Analyzing hydrographs and variation of flow and
gradient over time incidates that the wells may not be intercepting groundwater flow from
the landfill cell. Monitoring well number one is east of the site hydrographs indicate
fluctuations in the magnitude of groundwater elevations are not consistent with the other
three wells. The quantity of change is lower than other wells.
Some phenomena is resulting in reduced hydraulic conductivity which may not reflect
actual natural groundwater flow conditions into the well. Monitoring well #2 is a
hydraulic down gradient well, but due to seasonal fluctuations or variations in flow
patterns, it appears that this well only intercepts flow from the landfill 25 percent of the
year. Monitoring well #3 is in an apparent side gradien, parallel rather than perpendicular,
to groundwater flow from the landfill and does not accurately reflect or capture releases
from the landfill. Monitoring well #4 is suspected to be located near a groundwater
divider that runs in a N -S direction. If a divide exists between the landfill and the well,
then well #4 is not hydraulically connected to the landfill and does not serve to monitor
the landfill. In addition to concerns with the adequacy of monitoring releases from the
landfill, the construction of the monitoring wells is of conern. The wells were cnstructed
in 1982 using 1982 standards. These standards are not suitable or acceptable for 1996
analytical methods <33>_ These wells would not be acceptable for monitoring trace levels of
organic contaminants if installed in 1996.
Recommendations
Proposed plan to install additional monitoring wells. Proposed plan to sample and analyze
monitoring stations.
Purpose
To determine extend and degree of contamination for selection of detoxification
technology and scale of selected technology.
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Joint Warren County/State PCB Landfill Technical Committee
draft September 12, 1996 Meeting Minutes
b The September 12, 1996 Technical Committee Meeting was facilitated by Ms. Deborah Ferruccio.
The meeting began at 1 :Z5 P. M. In.attendance were Ms. Daria Holcornp[f\fr. Patrick Barnes, Sc,tUllL Mv1ii:.Z.1
,/ '?O.e1-lU. /tJ vl"YD(} ~ _.
Mr. Joel Hirschhorn.~-Bobbie RiJ.ec7~nd Ms. Nan Freeland.
Ms. Ferruccio began the discussio,sa.ying that the State is liable for this landfill and a3ked if the
'
Federal Government could put pressure on the State to get them to clean up the landfill. Mr.
Hirschhorn said that the grievance aspect i§1hat the St1.t.te does not meet TSC.A: rnqyirements,
The State was given pennils that impo:sc legal reg_yirements on the State as the owner o.peratac Qf
;,t.
.llhe landfill and:tln;y-lmve not met those ceqnicemeots. This is not a matter of th8 EPA coming to
the re!l~.:ue to this community. Mr. Hirschhom said that this would not have happened if the State
'l . --1(1,l5 . _
had some reasonable enforcement. Mr. Barnes said that there j5 any excuse for not doing the L~-<t11-lt.-{_iCC·
i'T1:;..f'.(<;
compliance testing. Ms. Riley asked if the blame for the State not hein:; :::, r.ompliance could
somehow fall in the lap of the Working Group. The Science Advisors agreed th.at may happen,
hut would have no validity. Mr, Barnes asked if anyone had inspected the PCB landfill since the
hurricaM and advised it not that Mr. Meyer should send someone as soon. ss possible and ha.v11;:
them take ground-water level samples. He advised that the Technk:ctl Conunittee contact Mr.
Meyer and request that the landfill be inspected and advised that he would fox Mr. Meyer with his
concerns.
Post-It~ Fax Note 7671
RECOMA1ENDATIONS
___ ,.... _________ _ -------
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Mr. Hirschhorn ~~,sJ}f e advised that the Technical Committee and the . ¾ti ioeiklrtij ,
Working Group use more formal means of communication with the State. He suggested that -~ E, r..flLfJ / . /i -0 vi,l (.c?{
prepare written communication; ~at Verbal requests are not adequate unless they are et (yr r
follow ed with a written document. He advised)( the Working Group was to adopt a standard
procedure for making decisio ns. His recommended process is:
\. tfw
/, D•f\!/ er
1) jii'c Science Adviso&ax an action memo for the Technioal Committee to the Working Group
office for immediate distribution by fax to the members and the other Science Advisor.
2) The office arranges for a phone conference call within 24-48 hours for the Technical
Committee to discuss and make decisions on recommended actions.
3) During that call with the Science Advisors, the Technical Committee as'1,.. questions and
discussY( action recommendations and~~ make decision (s) on action item(s), allowing follow-
ctoh on .. · wi II
up activities by Science Advisor(s), or some other d0Gi&IDn-is--made. Secretarfhtaintain$ minutes
ctlL--
of ;uth calls.
4) Within 24-48 hours:
-t l\J id
a) As appropriate, the Scicmce Advisor~ fax~ a work product to office for distribution
to Technical Committee (unless instructed to take other action directly, such as sending a.
memo or making a call to some party on behalf of the Technical Committee or Working
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Group) to facilitate the Technical Committee or Working Group implementing the
decision. tr,
1.vi il
b) The Technical Committee or Working Group takes final action. Secrctai/4ecpi a
record of exactly what is crene: o.ct(on 1 ,,;· -~ ztt.en .
FEDERAL STRATEGY
Mr. Hirschhorn advised that the State is in legal violation of EPA pennits since Feder~Uw
were used for constructing the landfill facility. He said that it is not normal to construct a new
pemument facility just for clean up waste and that this probably had never happened before.
Mr. Hirschhorn said that if the Working Group had correct political advice before the landfill was
built, tha the landfill could have been stopped because it did not comply with what is in the
cJ~td~e... --,..,WJaie Therefore, the Working Group could have tried to stop the Federal funding. He advised
that when TSCA has a super.fund site no permits are requir&1ce the landfill was not done as a
superfund sit:l permit should have been required. Mr. Hirschhorn, as described in his
recommendations to the Technical Committee, advised to "initiate steps to build a cn.<Je for federal
interv.ention and action that support/ the goal ofdetoxification of the landfill. h These action
recommendations are ;
1) The Working Group should submit a written request to the state fo r a _compliance
audit and summary report given to the Working Group within 30 days. The Working
Group would ask very specific, carefully crafted questions, based largely on various
00CH-lSC:-6 T6: XP.:J dn□cJ9 9NI>lcJOfll 8Jd
federal requirements that the state was required to satisfy;
2) The Working Group could submit a written request to the EPA Region IV
Administrator to conduct an official EPA compliance investigation w1der TSCA for the
landfill, based on EPA examination of its records, and a facility inspection if necessary.
The need for~ expedient implementation would be made. S~ific concerns would be
identified; and
lto -1eie./ -w.
)) The Working Group would submit • written request I' Assi,tant Administrat5 illiott
Laws at BP A Headquarters for his office t(? exartline specific policy issues under
lf.<Sf?)
CERCLA/National Contingency Plan i,y asking key question affectiug potential cleanup of
the landfill. The letter would cite the details of the agreement behveen the EPA and the
State.pin the form of a cooperative agreement that was funded under CERCLA/Superfund.
Specific policy determinations would be requested on specific issues, such as whether the
jurrent form of the NCP applies to the landfill, and whether the statutory requirement
for review of the remedy every five years applies.
j1'){1,,L/
Mr. Hirschhorn advised that when this is presented to the full Working Group that the:re weuldlbe
some opposition, because this will forc e..the Swe to beqpm; '1~wplianL_
STRATEGY FOR RF'P FOR OBTAINING A TEC'HNOLOGY VENDOR
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Mr_ Hirschhorn advised that to streamline the process the compnance testing and site
investigation should be handled in one RFP. He explained that his idea is that the first set of
activities would be:
d1ocoe,,
1) to·-ehuiC'e companies that will conduct the bench-scale test and dependittg--etrthe-reso.lts--
; d-epclu~.t' rlOx lt-(1 +e t,l/ '
that these companies would be prequalified of prefoninary desigrlind u ( t SLtt:f.;:; c),f--
2) the selection of one company to work on the preliminary design of the ~ale
detoxification.
,t,
Mr_ Barnes ~d that before any company can be chosen for the bench-scale test that t~ must
i-C, .
show that ~ can do both the bench-scale and the design.
Mr. Hirschhom's key components to the proposal are:
1) The RFP would be described as the solicitation of a contractor that after completing a
or-p,Gc+-.
successful hen€""~ scale test of detox.ifkation technology will provide professional
services in developing a conceptual engineering design of the full remedial action at the
landfill, including an onsite demonstration Jl~rior to n€:cale use of the selected
detoxification technology,
2) The RFP would define the following steps for interested parties:
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A) Based on information given in the RFP (including site background, and scope
of work for test) one (1) to three (3) vendors will be selected on the basis of
submitted proposals to conduct a benc@r pil©cale test at their own facility on
landfill materials provided to them,J1' ~
B) After the selected companies submit the required reports on test results and
pwvide any additional information required, one company shall be selected to
infonnation provided, and the bids in the company's proposal. ·7 C_JJ'{\
3) The RFP would ask for proposals that must contain certain types of infonnation,, includins bids
for the initial testing and, ~d,.for--the-tkIB~ based on scopes of work for the two
phases given in the RFP:iz"echnology companies would be u~to select a
subcontractor {such a.s an environmental design and enginC(':ring firm) that has the capabilities to
contribute to the conceptual design of the total remedial action based on but not limited to the
detoxification technology.
4) The state would enter into an irutial contract with the companies selected for the benc@r pilt)
tests. This contract would contain a provision stipulating that the company is being pre-qualified
or short-listed by vu tue of being selected to conduct the test for final selection as the provider to
the design services and that not other RFP will be issued by the state. Subsequently, after one
company is selected, the state would enter into the final contract for the provision of the design
90'd OOOT-lSc-616 :X~J
services.
Mr. Hirschhorn advised that what the Technical Committee needs to do now is get the Working
Group to approve these actions. Next, write a letter to Mr. Meyer and advise that this is how the
Working Group would like to proceed; tell us if this is feasible and give him five (5) to ten (10)
days to respond. The letter should be ready for the Working Group to sign at the next meeting.
DETOXIFICA110N CLEANUP GOALS
Mr. Hirschhorn advised that he: has put together a budget ( see appendix l) which shows realistic
cost projections. He advised that there will be three companies to do bench-scale test and they
would give two prices. One price will be for the bench-scale test D.nd one price will be to
participate in remedial design. Then the State would enter into an agreement with these
companies. Mr. Hirschhorn said that must tell the companies interested in bench-scale, that they
must give a target level of detoxification they can perform. He advised that for PCB and dioxins
the typical number is one (1) or two (2) parts per million. Ms. Ferruccio asked if aft-er the bench-
scale test will have enough infonnation to get money for the clean up or will the State say that a
pilot study is needed. Mr. Barnes said that the three (3) technologies selected will factor in full
scale operatio11; before they are selected. Ms. Ferruccio asked if at some point an on-site study to
get enough information to get funding for the clean up. Mr. Hirschhorn replied only if someone
wants to delay the project and it depends on what results are gonen from the bench-scale tel11.
Mr. Hirschhorn said that a lot depends on if the landfill still has integrity and has not seriously
contaminated the environment or whether Jt is leaking and has seriously contaminated the
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environment He advised that if we get involved with CERCLA will go through another ·process.
and all of the work done, would be useless. He also advised not to seriously consider TSCA and
Superfund. Mr. Barnes advised that since this is a site investigation at the facility that it could be
Superfund site. Mr. Hirschhorn advised that it is unlikely that the landfill would be a superfund
site.
INFORMATION ON WATER IN LANDFJU
Mr. Barnes said that he does not have the elevation form of where measurement where taken
from. He was given a depth to, but needs the elevation of Mr. Barnes advised that he is looking
at the water in the landfill from a hydrological standpoint is there a leak or not, either from the
top or bottom? He said that the chart he was given shows much fluctuation and there should not
be that much fluctuation. He noted that the water levels have an upward trend (see chart
numbered 3).
Mr. IBrschhom advised that the Eco Logic Process is very good with water and that is the only
technology viable with water. He advised that this process was designed td',deal with wet
sediment, however, this process has not had to deal with dioxins. The BCD process produce!? by
products and Eco Logic has less by products and is better for air emissions. Mr. Hirschhorn
advised that talking with 2 BCD companies1 Eco Logic and possibly three or four other BCD
companies.
BJOREM.EDIATION
t I
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Mr. Hirschhorn recommended that the Working Group formally request that the State stop all
activities related to· bioremediation, since the Working Group has ruled it out. He feels that no
form ofbioremediation would be successful with this landfill. He also advised that there is a
political problem because there are two (2) bioremediation companies in North Carolina who
want this clean up. Mr. Hirschhorn said that he believes that the State is pursuing bioremediation
because they feel that it is unlikely that the Working Group will get $25,ooo;ooo.oo to
$50,000,000.00 for this cleanup. He feels that the Working Group may have to look at opinions
that they have ruled out like: off*site disposal or treatment> c;onta.inment, separation technologies,
and incineration.
BUDGET
M'.r. Hirschhorn prepared a budget of what each activity should cost. He advised the Technology
)~:,.+-/ ! n'ltttl
Committee present it to Working Group and ask :Mr. Meyer ifhe feels it is adequate. (See figure--
h~-d~ ci > _,_1,) J
ACTION I'JEMS
The Technology Committee will write a letter to Mr. Meyer to advise his office to proceed with
the sampling plan without the off-site wells, if they are holding up the process; to advise the status
of the Project Director; and to send someone to inspect the landfill> if that has not been done.
The Technology Committee will recommend to the Working Group at thdr next meeting:
60'd OOOT.-lSZ-616 :XP.:J dnOd9 9N DldOrl 8Jd
1) to implement the strategy that Mr. Hirschhorn hi\S recommended,
2) that the Working Group write to the EPA to inquire about pennits needed for the
extraction of soil from the landfill, and
3) that a letter be sent to Secretary Howes and to Governor Hunt to see if their offices can
help facilitate the process.
OTHER INFORMATION
Mr. Ba.rues advised that instead of drilling, that we might want to consider the push method of
well installation. With this method one would use a piping wire with a screen, you would go into
the casting and remove just what material is needed and would not have the problem of storage.
The Tecbnolgy Committee advised that this method should be suggested to the State.
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WATER LEVEL
Page 1
OOOT-lSG-616 :X~j dn□2!9 9N Dl2J0Pl 8Jd
ESTIMATED BUDGET
Science Advisors ................................................................................. $200.000.00
Extraction ............................................................................................ 100,000.00
Site Investigation................................................................................. 250,000.00
Bench Scale Tests (3) .......................................................................... 225,000.00
Design................................................................................................. 100,000.00
Office, Miscellaneous.......................................................................... 50,000.00
Contirigency ..................................................................................... ,.. 75 .000.00
$1,000,000.00
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