NCD980602163_19961218_Warren County PCB Landfill_SERB C_Joint Warren County and State PCB Working Group, 1996-OCR

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
MEMORANDUM
TO: Luanne Williams
FROM: Bill Meyer~
DATE: December 18, 1996
SUBJECT: PCB -Air Sampling Results
Thanks for your 12/9/96 response.
Section 3 -1st sentence -"typical background"
AVA
DEHNR
I would delete this sentence since Section 5.4-lofthe attachment states, "levels
from one location cannot be compared with levels from another because of
differing emission sources".
With regard to your voice mail of 12/16 with the new/latest EPA report on
tox. equivalent of PCB's. There are two issues here:
(I) source of PCB's (fingerprint) unless the separate AROCLOR(s) is identified,
or ratios determined it will not allow identification of source( s) ( or elimination of
sources) and we could end up making the wrong decision. This issue is not a
health issue but one of common sense and we will continue to identify PCB' s by
specific AROCLORs and use totals for exposure determinations, if that is the
standard;
(2) if totals (PCB's) only are used for health determinations, I assume
that all the AROCLORs would still be determined (since they occur as different
peaks) and then totaled? It is also interesting that toxicity of all AROCLORs
would be considered equivalent since 1260 can be biologically degraded
anaerobically but not aerobically and the reverse is true for the lower chlorine
saturated PCBs. Even bug physiology tells us they are different. Then we might
not be as smart as the bugs.
C:wpfiles/pcblf/1-willia.mem
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
F'CB l.1.IDF:f< I (\li3 l3F:DUF· Fax:[phone] Dec 18 '96 15:19 F·. 01
.JOINT WARREN COUNTY /ST A TE PCB LANDFILL WORK.ING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Office [phone] -Fax [phone]
Fax Cover Sheet
TO: Monica Porter 733-2120
tL ~~ Laura Butler 733-5317
-~Cline 733-1431 ~ ??t\Y . ] Meyer 715-3605
Ron Nixon 419-8315
Dennis Retzlaff 257-2897
Nan Freeland 832-9100
Jim Warren 493-6614
FROM: Doris Fleetwood
DATE: December 18, 1996
RE: Working Group Meeting Date
Number of Pages, including cover sheet: 2
Fax:919-:257-1000 Dec 18 '96 15 :19 P.02
~ MEETING ANNOUNCEMENT
The Joint Warren County/State PCB
Working Group will meet
Friday,
January 3, 199,((7
at 4:00 p.m.
at the Warren County Office.
.,, •• ,, • ..,.j QU ..J ;,vLJ.V wH.:iotc. VlV
'
t9te ,Of N~t CarP,llna l $P r,tme of Enylr nment, i ~a,?h an · atural ~esources
!vision of Solld Waste Monogement i
J mes B. Hurit, Jr., Governor
J nothcm B. Howes, Sebretory
Wllllom L Meyer. Director l .
~IEMQRANQUM
I i
December 18, 1996
l
~O:
$OM:
Joel Hirschhorn, Science~
I
Mike Kelly, State S
S~BJECT: VENDOR CONTRACT -~· . VERIFIC
: I i
j On November 22, · 1996, I sent a ~emo to you ( copy aJched) reque ting information on
~e proposed vendors and processes for t~e bench scale detoxi~cation atudi . As of today. I still
htve not received that information. i . i
' . ' I
~
. I will not be in the office during ~e holidays, ie after th~ 20th until e 2nd of January,
d had hoped to aet that RFP out the dopr prior to my departure. Patrick attets of my staff
I be here some during the holidays and will work on gettini tJ,e RFP pre once tho
onnatJon is re0eived. · . 1 . i
' , I
1 In regards to the question of a twJ phaso approach, we 1've been ad sed by Purchasing
a. d Contracts that we can lake this appro~ch on tho RFP as lo~ as it ls cle y spelled out in the
P what our intentions are. They were ~nccmed u to wheth~r or not the endor would have
e ugh information to adequately prepar~ a Phase II, or do they:need the res Its from the pilot to
p pare an accurate proposal, The ooncetp would al10 be one ot "high pricl " on a Phase 11,
polslbly low balling the Phase I to help get the busi~ess. Anothqr question is given the results of
th Phase J. if the others originally biddl~ were allowed to bid ~n the Phase I using the
te hnology picked, would lt be more price compeUtlve? I comhiented that companies should
kn. w their technologies and be in a position to predict tho resui' and that o recommendations wtld be based on the enti~ package and: that if they know our ~ntentions to o straight into a
P e II contract they should be competit~ve up front. ,
I . !
1 Please submit the information as s~n as possible so that1we can get ls RFP out the d1r. Refer to the "Part JI, Scope of Worr outline in one ofthe'.othor RFP's OU have to sco
w t infonnation 1hould be covered .. We need to ho sure that wp can clearly cparate the two
ph ses and that it ts understood that we w~ll pick more than on, f hase I, but nly one Phase II.
I Feel free to call Patrick Watters or'.me at 919-733-4996, ➔xtenslon 20 should you have any questions. 1 :
I , : . I
Cory: B. Meyer, P. Barnes, P. Watten, Tfchnical Committee
1
P.0.80)(27687. , 14
~al lgh, North Coronna 27611•7687 ·~
Voice 919-7 3-4996
9-715-3605
fflrmattve Action Employer
post-coosumet paper
• FROM 9197153605 SOLID WASTE DIU .. •I ,.._ 12.18.199€, 10:30 p. :;
. '
,...,u, 11 11~1r or tnvironment, ealth an ~aturol_ Resources
/vision of aate Management
I
omea B. Hur,t, Jr., Govemor
onathpn B. !HPw•1, S♦cretory lllam L. Meyer, Dlrec:tor
~EMORANDUM
I
OM: Stato Staff
' I
. l . i
: i I I
· I
I I . i
!November 22, 1996 · I
;
Vendor Contracts for B~nch Scale Veriflcatlon'studies
1
In order for the State to develo~ contract, for vondora 'for bench sc le det.oxification
tudies, the fotlowins infbnnation Js req~ested: · ·
I •
· I. Names, t~hnoJogies,!and qualiflcationa of p~tential ~end rs,
2. Scope of work for detoxification studies ineluding standa ds and deiiveri4ble1. :
· 3. Propo•ed schedule j_ :
4. Extent :ancl degree of rteraction with EPA ~th reapect t
pennit.,,,approvaJs in ~ccordanco with TSCA;regulations.
! ,
I ' Enclosed i• tho RFP for the prev~ous vendor effort for ,QCD Techno gy. Also enclosed is
,
1
copy of the EPA TSCA approVll docu!nent for the Solltcch f 1> propo1
, If you need aHistance or have any question,, please COl\ltc:t Mike K ly at 919~ 73 3-4 996 elct. 203. . : . !
I ' l l I . : l ! erclosures .
c+ Patrick Bamea
l l
j P.O. 80)( 27687,
Rqlelgh, North Coro,no 27611-76a7
Voice 919-733-4996 ·
.,,
. '
i
AnE
19-715-3605
Arnrmohve Aetl-,n Emplo>1er
post-consumer poper
MEMORANDUM Bf A #95 --0.17
TO : Working Group
FROM: Patrick A. Barnes, Science Advisor
DATE: December 17, 1996
SUBJECT: Status of Litensure
As yuu 11111y know, since November 11, 1996, I have been in regular communication with
representatives of the N.C. Board for Licensing Geologist. The Board's position was that the
vrofessional services I have provided constituted the practice of geologi{;al se1vices for which I
~hould be licensed. Needless to uy, I was unaw3re of that necessity, especially given the premise
under which I was hired, that of technical independence.
The necessity to be licensed by the State to perform the services outlined in the Science Advisor
tu1\lnu;l is therefore, somewhat contrary to the guiding pnnc1ple or independent advice .
Ne, crthcless, a§ a. Florida lke11~c::J prufos~iunal geologist, I recognize the imponance of having
qualified/ljcensed individuals performing t.er.hnir.fll services; therefore, during the week of
December 8th, 1996, I made application to the State for both an individual and corpornte
geological license and attended the quarterly meeting Qf the N.C. Board for Licen:;ing (knlngiM.~
(Friday, December 13th). The meeting was very interactive and I was given the opportunity to
provicic fi.lrther support to the conclusions we have reached concerning the status/integrity of tht':
PCB Landfill. By the way, the Board members were already very much aware of these
conclusions.
This morning in a conversation with the Board, I was ~nfonned that I will be granted II pmvisinn;,I
license, conditioned upon the receipt of professional references and a college transcript Receipt
of this license will in no way change my commitment to provide independent technical advice to
the Working Group.
The Hollister Buildtng • 3535 Lewton Road• Suite 111 • Orlando, Florida 32B03
Office [phone] • Fax [phone]
DATE:
JOINT WARREN COUNTY /STATE PCB LANDFILL
WORKING GROUP AGENDA
DECEMBER 17, 1996
I. Welcome
II. Approval of Minutes
III. Unfmished Business
1) Status Reports
a) Monitoring Wells ...................................... Tommy Cline
Bill Meyer
b) Any Other Status Reports ........................... Bill Meyer
2) Technical Committee Report
a) Letter to Governor Hunt about a visit to Warren County
b) Letter to Secretary Howes about the filtration system
c) Science Advisors Report and Recommendation on Air Quality
IV. New Business
Proposal by co-chairs on issue of structure of the Working Group
V. Other Business
VI. Adjournment
December 16, 1996 .............................................................. by FAX (5 pages)
To: Technical Committee
From: Joel Hirschhorn
Through: Doris (for distribution prior to WG meeting as much as possible, and to all Working
Group roe1nbers at meeting of Dec. 17)
Subject: Review of orieinal EPA contractor report on PCB 1k emissioru'.
Jn response to my request, I received the Final Report on Ambient Mouito:ling For PCBs At The
Warren Cowity (North Carolina) Landfill by Battelle from Dr. Lewis and have pl'epared the
following comments on it so that the Working Group can better understand the situation. ln
general I have found even more problems and reasons to be concerned about the entire history of
this situation .
. M.v latest review, analysis and conclusion~ strongly support the position of the Iechnir.;11
Committee in its rec;_Qg.r)ition that it is imperatixe that full disclosure of the dan:ct.t.s..~thi
landfl.11 be openly communicated to the public and the state 1overnrnent tru:.o_qg_li.Jllwther
press con&r~oce, letters to the Governor and Secretao How~ttions bein..g
taken by the state uuch as carbon filter installation and new monitoring), an<la »·ell
planned community meetinc that the GQvernor is invited to participate in. Lwapj..1.Q
~nphasize that the most important recommendation presented by t;.rA 's contrac .. w.r i.n
1983, calling for future periodic monitorine fot PCB air releases. was NOT implemevJed..b.):
th~ state or EPA. In my profeuional opinion this was a ulloos and scientifitAlb:'. .. M..filmll..d
decisio11 by the state and EPA that sas:riliced protection of public health to deviou.1
concerns, like wantine to avoid eettin,: data that would conclusively demonat,.:mJ.si
\Varro County residents and the broader public that the Warren County FCB....LJ.rultlJJ
was dangerous. unsafe, and a source of uncontrolled environmental rel~,.._..I..~
recommendalion for future periodic monitorin1 and the test results from 1983 SM.Uld h~ye
Jof:i,cally resulted in the state lakiax: the proper precautionary step of instalJing carbon
filters on aJI landfill vents. Thi~ matter de,llerves the dron1e.d pouible action t,_y th~
~Working Group to safeu,a,d the interests of Warren County nsidentLtt..tbat effectiv~
detoxification of the laodfiU is actually accomplished as soon as possible, The Goveriw.
should be requested to determine why the recommendation of EPA's; contractor to cond.~
future monitorine for PCB emissions JHII not implemented,
The l'eport was dated August l6, 1983,.indicatjng that complete data were available to EPA
relatively soou after tbe onsite testing had been done iu January and February l 983. Of the 40+
page report, only page 2, Section 2, Conclusions had been found in the state .files provid~d me,
and which I previously commented on.
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Page 3 of the report was Secµ.on. 3 Recommendations and included the following: "In the future,
i..l.il recommended that periodic; monitoring be performed to determine the trend in PCB
emission rates from the gas vents and le1L~hate access ports on the landfiJJ site .. " ( emphasis
added) The single paragraph also included a recommendation to use somewhat different sampling
technology, called high volume PCB sarop.1ers, because they offered ''significantly lower detet,iion
limits." It appears that these recommendations were never implemented by eithe.r EPA or the
state. The recommendation for future testing is particularly significant because there were
relatively few positive detections of PCBs in. ambient air, indicatmg that the contractor recognized
that in later times PCB emissions and releases offsite were plausibl(:1. In other words, the
contractor was correct in recognizing the appropriateness of experimentally, through further field
testing, deter:miumg the "trend" of PCB emissions. This implicitly recognized the positive
detections of PCBs in vents an.d ports, as sources of environmental releases, as well as initial
detections of PCBs in ambient ai.r. lt also recognized the reasons why the study had been
conducted.
The contractor report contwned no information on the design or construction of the landfill,
which the published paper had presented. But the contractor repo.rt did note that: "Local
residents and the Warren County Health Department have expressed concem about the possibility
of airborne PCB emissions from the landfill being transported to neighboring areas, thus
threatening the public welfare. 11 It also noted that "The study was performed at the request of
the North Carolina Division of Health Services ... 11 1bis makes it even more questionable why the
full contractor report was not found in state files. Five specific study objectives were presented,
including dete.rmining if PCBs were present at the house approximately one-halfmile away. Of 42
specific measurements in ambient air, however, only two were for the nearby house.
Th.ere is absolutely no statement iu th.e entire .report that in any way supports the contention
recently communicated by EPA that the positive findings of PCB air emissions were false
positives.
There js a discrepancy between the details of the positive findings as preseuted .in the published
paper versus the contractor repo.rt. The pubJished paper indicated four positive detections in
ambient air and clearly gave the locations oftluee of the.mas: beside main vent, fence line
downwind, and nearby house. The contractor report gave: beside main vent, two for fence line
downwind, aud onsite upwind of main vent. The footnote in the published paper iudicatitlg that
one of six measurements at the nearby house was above detection limit is mconsistellt with data in
the repo.rt that indicates that only two measurements were 1aken at tbe nearby house. What is
most perplexing at this time is, therefore, that the published paper showed a positive finding of
PCBs at th.e .nearby house, while the contractor report showed all .findings as less than the
detectio.n limits. But the procedure used by the contractor was to consider less than dctectiou
limit findings as equal to the detection limit. Following the contractor~s procedure the average
concentration for Aroclor 1242 and 1260 for the nearby house would be 6 and l 0 ng/cn\
respectively. In my previous comments I used what was reported in the published paper, namely
a positive finding of IO ng/cm for 1260, which is still supported by the actual findings in the
2
P.2
5-17-1996 2:23AM FROM ...
contractor report. Let me emphasize that the contractor's methodology of assuming a finding of
less than the detection Jimit is equal to the detection limit is far more appropriate than assuming
that such a nondetect .finding is equal to zero, which seems to be EPA's position. Nevertheless,
there remains a discrepancy between the published paper's clear notation that a positive .finding of
Aroclor J 260 was found at the nearby house versus the contractor report that indicates that all
four readings on the two days of testing for the two Arodors were nondetects. What deserves
attention by .EPA is why it reported, in the published paper, the positive finding of PCB at the
nearby house.
The variatio.n. in detection limits was made understandable in the contractor report, because the
data given showed that sampling times and, hence, sample volumes varied somewhat, with
unanticipated lower volumes resulting in higher detection limits in some cases. In all cases, where
positive detection.s in ambient air were found, the detection limits were the lowest, making the
findings more reliable.
Although the published paper presented key PCB data in terms of ranges and averages, the data
pre~entation in the contractor report was different and, in my opinion, more useful and
infonnative. One problem in the published paper is that some data were reported as "ND" which
is standard notation for non-detected, while other data were reported as"<" meaning less than the
following numerical number which normally would be the actual detection limit (DL ). In fact,
there was no reason to report NDs at all in the published paper, and in the contractor report data
were reported either as positive detects or as <DL for .PCB concentrations. The point is the NDs
represented a specific test in which no reliable data were obtained. But the published paper said
that ND represented "n.ondetectable." Ibis definition misrepresented the actual meaning of some
data. For example, for the lower leachate access port, the published paper indicated the low end
of the two ranges were ND, but this actually referred to a test where the data were not usable.
The inference was that a ND low end represented a zero level rather than no reliable data. The
published paper reported averages of0.04 and 0.05 ug/cm for 1242 and 1260, respectively, which
we.re calculated by assuming that ND = 0 and that <DL = DL. But using the a.ctual data in the
report, and eliminating the ND values results in the averages being .06 and .08 ug/cm,
respectively. Clearly, the corrected averages portray a significantly higher level of PCBs from the
lower leachate access port.
Another systematic source or widerreporting PCB levels was the unusual procedure of not
rounding off numbers following the normal practice that if a digit is 5 or greater, than the
preceding digit is increased by one. For example •. 056 should become .06. But in the published
paper, some averages and other figures are too low, because rounding was not done properly.
For example, the average PCB levels for small vent E were reported as 0.24 and 0.4, hut should
be 0.24 and 0.5.
There is an important lack of details about the weather conditions existing at the time of sampling.
For example, for Jan. 30 the notation was ''no sampling due to weather c~ditions," \\ithout,
however~ explaining what the weather conditions were. The relative humidity for the follo""11lg
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two days on which testing was done indicated very high level~ ~1lggesting that perhaps rain or
snow was a factor during the testing period. In general, the collection of meteorological data was
incomplete, and tbe report presented no detailed analysis of bow weather conditio.us n1ight have
affected the testing results, both positive and negative detections. .Io my opinion, the weather
conditions were probably not the most conducive for transporting PCBs offsite which could exist
at other times. This supponed the study's recommendation for additional future testing. For both
periods during which monitoring was done for the nearby house the Wlll.d was .not bJovving from
the landfill in the direction of the house. This fact and the very limited number of measurements
taken at the h.ouse indicate, in my ophlion, poor study design.
The contractor report made an important observation about the fm.c:ling of Aroclor 1260 but not
1242 in. ambient air: "It is puuling that Aroclor 1242, the major component of the vent emi.ssions,
was not also detected m these samplei." 1his is the issue nused recently by EPA However, the
colltractor does not attempt to explain why the noted observation occurred or how it can be
explained, and certainly never raises the possibility of false positives.
In eight cases reliable data was not obtained because sample pumps malfunctioned, wid, the only
reason gjven as "due to the low temperature and hlgh humidity conditions that prevailed during
the sampling period." This supported monitoring at a later time under different climatic
conditions.
The published paper did not note that the two highest ambient air detections were for the same
location at the same time, but for two heights of 4 aud 15 feet, with 71 and 50 ng/scm,
respectively. The Jevel of PCBs at the higher height is siguificmt.
The contractor report made it clear that gas flow rates from vents and leachate access ports were
measured by EPA _personnel on ''March 2, .I 982." Preswnahly this was an enor (not caught in
peer review), and was really in 1983, but it was definitely after the contractor performed the
major portion of the work. And while the published paper some data on the gas tlow from the
maiu vent, it did not p1esent the detailed data in the most understandable and sign.ificant way. The
contractor report's presentation of the data showed that gas flow rates increased sigruficaotly
from 9:45 AM to 3:00 PM, with a 32% increase over that period. This would logjcally suggest
that gas flow increased as temperature in.creased (no climatic data was given for this day in the
report), supporting my contention. that air releases of PCBs increase with increasing temperature
and also supports the report's recommendatio.n for subsequent monitoring at the landfill. The
modelin.g work by the co.o.tracto.r cited by EPA only used the average of the data obtained for
different times, which does not, th.erefore, produce results indicative of maximum PCB release
rates.
The study design was deficient because the sample volumes for the small vents and the .leachate
access ports was the same as for the main vent, which resulted in higher detection limits for the
fonnet versus the latter, because the quantities of PCBs in the former were substantially smaUer.
Such a situation could have been predicted, and at the very least this problem would have been
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corrected in subsequent monitoring by increasing the sampling rate and volume (as was do.ne for
th.e ambient monitoring).
I found it unusual that several significant statements made in the Conclusions sec6on were not
contained in any form within the body of the report, particularly Section S Results and Discussion.
This is highly unusual, because normally there is a more extended discussion in the body of the
report that supports surollll1}' conclusions. For example, the comments .u1 the conclusions about
PCB emission rates being reduced in the future are not supported by any information or analysis
given in the body of the report. Nor are the comments completely consistent with the report's
major recommendation for future periodic monito1ing. Other statements in the conc.lusions are
inconsistent with the details given in the report, namely that ambient PCB Jevels were only found
"at or below mininwm detection limits'' while, in fact, the report's data showed positive detections
as high as seven tim.es the detection limit. Based on .my professional experience, tb.ese kinds of
unsupported and inconsistent statements in conclusio.ns result from the contractor's dient (EPA)
making changes during a final review of the draft report in order to protect or serve its o~n
interests.
As to peer review that Dr. Lewis has claimed is so significant, I want to point out that the peer
review process has many limitations, including the fact that a primary report that forms the basis
for a published paper is not provided peer reviewers, so that soroe shortcomings in the paper
cannot be properly assessed.
5
., .. State of North Carolina
Department of Environment.
Health and Natural Resources
Division of Air Quality
James B. Hunt, Jr,, Governor
Jonathon B. Howes, Secretary
Alan W. Klimek, P E .. Director
December 16, 1996
MEMORANDUM
TO :
THROUGH:
FROM:
SUBJECT:
Bi ll Pate
Division of Epidemiolog~/ /
Alan Klimek, Director lY
Division of Air Quality
Laura S. 6utler. P,E .. ~tJiyf J}r_
Air Permits Section
PCB J\ir Emie;sions
V\Jarron County PC!i L::indfill
Warren County
f-'.Ul /04
We have received a report concerning air emissions from the Warren County PCB
Landfill. The Warren County PCB Landfill Working Group is concerned about potential
human health effects and environmental impacts !from PCB emissions. By way of this
mernonmdum I am requesting your guidance and input on these i.%1.IA5. CnriP.s nf f hP.
following documents are attached:
1. Final Rsport On Ambient Monitoring for PCB's at the Warren County (Norih
Carolina) Landfill, D.L. Sgontz, W.E. Bresler, LA. Winker and J.E. Howes. Jr .
Battelle Columbus Laboratories, August 16, 1983.
2. Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls from
Hazardous Waste Landfills, Robert G. Lewis and Barry E. Martin, Environ. Sci.
Technol., Vol. 19, No . 10, 1985.
3. PCB Air Emissions and Health Risks from the Warren County PCB Landfill, Joel
Hirschhorn, Warren County PCB Landfill Working Group, November 27, 1996
4. Air Emissions of PCB and Associated Health Risks, Patrick Barnes and Joel 0 .
Kimrey, December 2, 1996.
P.O. Box 29580. Ra1e1gn, Nonn t.:;oronno 276~6-Uo!iU
Vole~ (9i9) 715-6235 FAX [phone]
· Post-It" Fax Note
To
Co.
7671
From 1 1 t-· .
I"'. Ui/Ull
5. Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G Lewis , December
3, 1996.
6. Oiiper,ion Modeling for We1m~n County Pr.R I ;:tnrlfill . Tnm AnrlAr,"nn , nAr.AmhAr
10, 1996.
C: Willieim Meyr--r -ni\liRinn nf '11/nr.tn Mnn:iornmmt (w/n ;1ll;11;l11rn-rnl~;)
Ernie Fuller -Regional Air Quality Supervisor (w/o attachments)
Lee A. Deiniel (w/o ettechments)
George Murray (w/o attachments)
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Air Quality
James 8. Hunt, Jr,, Governor
Jonothan B. Howes, S~cretary
Alan W. Klimek, P.E., Director
MEMORANDUM
December 16, 1996
TO: Lee A Daniel, Chief
Technical Services Section
George Murray, Chief
Ambient Monitoring Section
THROUGH: Alan Klimek, Director ~
Division of Air Quality
FROM: Laura S. Butler, Chief .~-
Air Permits Section
SUBJECT: PCB Air Emissions
Warren County PCB Landfill
Wmrnn r.rnmty
On December 2, 1996, I sent you snd Lori Cherry ;;i r,nr,y nf thA rnpnrt Pf.A Air
tm1ss1ons and Health Risks from the Warren County PCB Landfill for your review and
comment (copy ottochod). /\ddition::tl reportE; have been received and are attached for
your review and comment. Please advise me on your opinion of the necessity for
performing air monitoring for PCB's at the Warren County PCB Landfill.
The Warrf:'n County PCB Landfill V1/nrkino Grrn lfl i~ r.nnr,ArnArl ~hrn 1t notP.ntiRI h11mnn
health effects cmd ~nvirurmu:ml~I ir11!J~c.;ls f1u111 PCB e111i:s:siu11~-Yuu, ~,:uli~::,l ,ievi~w i:::.
requested.
C: Bill Pate -Division of Epidemiology (w/o attachments)
William Meyer (w/o attachments)
Ernie Fuller (w attachments)
Lori Cherry (w/attachments)
Attachments. (6)
P.O. Box 29580. Ra1e1gn, Nortn L.;uro11na "Lto:to~
Voice [phone] FAX (919) 7~3-5317
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I U.A • .;;/ .L ;,, I VV ...IV .L I uc:;1., .lV :JV .lV • .lL
r;, 1141 n ....... ,,...-1 01, ,n,1,,i.i,~\ M•I,itHiMl fu nc □·• •• ·~· tn.ro,.Jlon Counh,1 (l'llortn
Carolina) Landnll, D.L. Sgontz, W .F!.. e,~~1~,. L.A. Wirik~, dllU J.E Huwt::l~, J1 .,
Bc1lldl'=' C, tl,111',hti.., I ~hi■rr/1\tr.ri,i;,..,_ A11a11~t 1G, 180;1
2. Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls frorn
Hazardous Waste Landfills, Robert G. Lewis and Barry E. Martin, Environ. Sci.
Technol., Vol. 19, No. 10, 1985.
3. PCB Air Emissions and He~lth Risks from the Warren Ccunty PCB Landfill, Joel
Hir~d1'1u111, Wd11811 County PCB Landfill Working Group, November 27 , 1996
4. Air Emissions of PCB and Associated Health Risks, Patrick Barnes and Joel 0 .
Kimrey, December 2, 1996.
5. Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G Lewis, December
3, 1996.
6. Dispersion Modeling for Warren County PCB Landfill, Tom Anderson. December
10, 1996.
1 2/13/1995 15:59
,. , . '\
9192572584
December 13, 1996
CHAPELSOUTHERNLIGHTS
REVISED COPY
To: PCB Working Group and Science Advisors
From : Ken Ferruccio ~~
SubJect: Flnel Recommendation •• Co-chair
It is my final recommendation as a co-chair that the most serious concerns of the
Science Advisors and Technical Committee be addressed first at the upcoming
Dec;ember 17th PCB Working Group meeting.
To be responsible to the citizens of Warren County, it is imperative that these serious
concerns are given first priority on the agenda and that other process-related concams
follow.
l~/13/1936 16:31 91925726El4 Q-iiOPELSOJTHERl-l..lEriTS
December 13, 1996
To: PCB Working Grot,p and Science Advisors
From : Ken Ferruccio ~~
I am convinced that I can now most effectively serve the citizens of Warren County by
stepping down as a co-chair of the PCB Working Group. Therefore, I am submitting my
resignation effective immediately.
I will work as a regular member of the PCB Working Group as long as I believe that
the Workino rirnup serves the best interectc of Warren Ceumyrs citi2:61"16.
Please regard this memo as an official statement of my resignation as a co-chair.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Dr. Terry F. Bidleman
ARQP
Environment Canada
4905 Dufferin Street
Downsville, Ont., Canada M3H 5T4
Prof Ronald A. Hites
NA
DEHNR
December 12, 1996
School of Public Health & Environmental Affairs
Indiana University
I 0th & Fee Lane
Bloomington, IN 47405
Dear Prof Hites and Dr. Bidleman:
It has been brought to my attention that you are an expert on PCB air monitoring and
familiar with the work of Dr. Robert G. Lewis. Dr. Lewis authored an article published in
Environmental Science and Technology, October, 1985, pp. 986-991, titled: Measurement of
Fugitive Atmospheric Emissions of Po/ychlorinated Bipheny/s from Hazardous Waste Landfills.
The quality and scientific interpretations of the monitoring study have recently been questioned. I
would like to respectfully request your review of both the article and recent responses to
questions concerning the quality and conclusions by Dr. Lewis and Dr. Joel Hirschhorn. Your
response to this request is appreciated and will be presented to a Joint Warren County/State PCB
Landfill Working Group established for detoxification of the landfill.
Thank you for considering this request on our behalf and assisting our efforts to address
complex scientific and technical issues as we make progress toward ultimate detoxification of the
PCB Landfill.
If you need clarifications, information or assistance please contact me at 919-733-4996,
ext. 202.
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
Sincerely,
~cf~~
William L. Meyer, Director
f t!ffliJlk$Mtl
FAX [phone]
An Equal Opportuni1y Affirmative Action Employer
50% recycled/10"/o post-consumer paper
Enclosures:
Measurement of Fugitive Atmospheric Emissions of PolycWorinated Biphenyls from Hazardous
Waste Landfills, Robert G. Lewis and Barry E. Martin, Environmental Science and Technology,
October 1985, pp. 986-991.
Draft Final Report on Ambient Monitoring for PCB's at the Warren County (North Carolina)
Landfill, D. L. Sgontz, et.al., Battelle Columbus Laboratories, April 8, 1983.
PCB Air Emissions and Health Risks From the Warren County PCB Landfill, Dr. Joel Hirshhorn,
November 27, 1996.
Air Emissions of PCB and Associated Health Risk, Patrick Barnes, December 2, 1996.
Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G. Lewis, December 3, 1996.
Response to EPA letter of 3 December, previously provided; Dr. Joel Hirschhorn, December 10,
1996.
Response to Hirschhorn's latest comments, Dr. Robert G. Lewis, December 11, 1996.
copy without enclosures:
Joel Hirschhorn, Science Advisor to PCB Working Group
Py.trick Barnes, Science Advisor to PCB Working Group
~oris Fleetwood, Joint Warren County/State PCB Landfill Working Group
Dr. Robert G. Lewis
c:wpfiles/pcblDbid-hite.ltr
Date: Wednesday, December 11, 1996
To: Ms. Doris Fleetwood
PCB WORKING GROUP
Fax: [phone]
Voice:
Comments:
Time: 1:51 :01 PM
From: Dennis W. Retzlaff
Fax: [phone]
Voice: 919-257-1092
Doris, I will not be able to join the 3:00 P.M . Technical Committee
Conference Call. Please relay the following message to the Committee.
Mr. Bill Meyer indicated that his staff is responding to the concerns
expressed related to possible PCB emissions from the Warren County PCB
Landfill. Plans for placing a carbon filter have been in the works since
concerns were raised to reduce fears of those who may be concerned.
Filter may be in place by this Friday. Dennis
1 Pages
I , _.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt. Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
To:
From:
Date:
Mike Kell
December 10, 1996
AVA
DEHNR
CONFIDENllAL
Subject: Bid Clarification for the Excavation, Handling, and Storage of PCB Contaminated
Soils from the Warren County PCB Landfill dated 11/8/96.
Four bid proposals were received by the Division of Waste Management for the subject RFP. A
Pre-Bid conference was held on February 16, 1996. All of the respondents to the RFP attended
the pre-bid conference. All of the technical and cost proposals for this RFP were reviewed versus
the criteria in the RFP with the following conclusions and recommendations.
As far as the methane potential is concerned, all respondents addressed this as part of their Health
and Safety Plan by using various detectors and monitors. All respondents appeared to adequately
address this concern.
GENERAL
The overall ranking of the four respondents based purely o~ the cost breakdown are as follows:
LINER INTEGRITY EVALUATION
CATEGORY S&ME
Labor $9,191
Equipment $2,815
Sub-cont. $5,015
Misc $ 140
TOTAL $17,091
P.O. Box 27687,
Raleigh. North Carolina 27611-7687
Voice 919-733-4996
BIDDERS
CDM
$10,500
$ 900
$11,500
$ 4,500
$27,400
Triangle Patterson
$ 750 $4,800
$ 775 $ 0
$1,075 $ 800
$ .600 $2,175
$3,200 $7,775
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
BOREHOLE/ EXCAVATION/ WELL INSTALLATION
BIDDERS
CATEGORY S&ME COM Triangle Patterson
Labor $14,422 $30,425 $14,000 $13,500
Equipment $ 5,973 $ 1,100 $ 200 $14,000
Sub-cont. $ 915 $20,000 $ 8,700 $16,500
Misc $ 175 $ 4,475 $ 2,600 $ 1,500
TOTAL l . , ,
I ' I $21,485 $56,000 $25,500 $45,500
·. ! i
GRAND TOTAL $38,576 $83,400 $28,700 $53,275
CONCLUSIONS
From a pure cost perspective Triangle Environmental Inc. and S&ME were the lowest. From a
technical perspective however, S&ME had the better proposal for the following reasons.
-S&ME has had orders of magnitude more experience dealing with landfills than Triangle.
S&ME cite 53 different landfill related projects. Triangle cited only two landfill examples.
-S&ME cited specific PCB experience whereas Triangle did not.
-S&ME proposed both sampling and new survey data to assure that the bottom liner integrity is
maintained. Triangle plans to rely on existing survey data with periodic sampling. Maintaining
the integrity of the bottom liner is a very key element ofthis project. The State will have to be
authorized by the EPA to conduct this work and liner integrity is one of the most important
aspects of this project.
-The descriptions of the services in the S&ME proposal is far superior to that of the Triangle
proposal. S&ME provides more detail and illustrations on the scope of work and methodology
they will use than Triangle.
-The S&ME proposal provides information on the qualifications of key staff members whereas
the Triangle proposal does not.
S&ME will not need to subcontract any of this work whereas Triangle will use a drilling
subcontractor.
-S&ME will use a more sophisticated steel pan system to contain the drill cuttings.
Therefore as a result, and following lengthy discussions with staff and the science advisors, we
recommend that S&ME be awarded the contract for this RFP.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
To: Doris Strickland
From: Mike Kelly
Subject:
Date:
Monitoring Well Bid Propo
December 10, 1996
NA
DEHNR
Eleven bid proposals were received by the Division of Waste Management for the Monitoring
Well RFP issued on November 5, 1996. A Pre-Bid Conference was held on November 18, 1996.
All of the respondents to the RFP attended the Pre-Bid Conference.
Monitorioi Well Proposals Ranked by Cost
1 -SGI Associates
2 -BP A Environmental and Engineering
3 -Aqua Drill Incorporated
4 -Flour Daniel GTI
5 -National Environmental Technologies
6 -Dames & Moore
7 -Groundwater Management Associates
8 -Handex
9-S&ME
IO -Engineering Tectonics, P.A.
11 -Environmental Investigations
$175,598.00
$104,877.00
$ 97,890.00
$ 96,543.00
$ 94,490.00
$ 91,494 .75
$ 79,027.00
$ 78,664.80
$ 72,836.00
$ 69,649.00
$ 69,615.00
Based on an in house review of the submitted bids and discussions with the science advisors for
the Warren County PCB landfill it was determined that Engineering Tectonics, P.A. has the best
proposal in terms of cost and services they will provide. Specific reasons for this selection are as
follows:
-They had the second lowest cost estimate
-They had the best landfill related experience.
-They are not planning to use sub-contractors.
-The cost difference between Engineering Tectonics and the lowest bid by Environmental
Investigations was only $34. The proposal by Environmental Investigations did not show the
detail or the level of landfill experience that Engineering Tectonics, P. A. had. Therefore, after
consulting staff and the Science Advisors, we recommend that Engineering Tectonics, P.A. be
awarded the contract for this RFP.
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
To: From: Subject: Date: ,. . ., MikeKelly1 Dioxin/Furan Bid Proposals for the Warren County PCB Landfill December 10, 1996 We received bid proposals for this RFP from five different companies for this RFP. I have summarized my review in the following tables. COST SUMMARY TABLE LAB NAME OVERALL COST STD QUICK ON SITE OVERNIGHT COST' PERSAMP TAT2 TATS PERSONS DEL. COST 1 -Triangle Labs $37,356.00 $849.00 30d 14 day: +10% $150/trip + No 7 day: +50% $60/hr/person Quote 2 -Midwest Research Institute $36,300.00 $825.00 45d 14 day: +27% $500/pickup No 7 day: +52% Quote 3 -Southwest Research Institute $32,912.00 $748.00 30d 14 day: +17% 1 person-2 days No 7 day: +40% $3,200 Quote 4-Maxim $28,820.00 $655.00 30d 14 day: +45% Cannot No 7 day: +133% Provide Quote ~ -Southwest Labs of Oklahoma $28,560.00 $630.00 (liq) 21d 14 day: +50% $3 8/hr/person + $15 $700.00 (soil) 7 day: +75% + $0.28/mile per (()LJ e__ (le cc<YYn~ d e d -48 hours:+ 100% from Raleigh sample 1 Assumed 44 total samples; 2 TAT= Tum Around Time
.. MISCELLANEOUS INFORMATION LAB NAME REFERENCES LEAD TIME CONTAINERS REPORTING NEEDED SIDPPING $ FORMAT 1 -Triangle Labs 6 provided 7 days Included in quote Example included w/ raw data 2 -Midwest Research Institute 5 provided Did not state Did not indicate Table summary format only 3 -Southwest Research Institute 81 provided Did not state Did not indicate Did not supply report example 4-Maxim 6 provided 7 days Included in quote Example included w/ raw data 5 -Southwest Labs of Oklahoma 5 Provided 7 days Included in quote Example included w/ raw data + confidential refs. Southwest Labs of Oklahoma provided the best overall proposal and the lowest cost. They had the most extensive reporting format and were the only one that was certified by North Carolina DEHNR (Lab # 404) and EPA (CLP). They were also able to supply on-site personnel during the sampling and had the best analytical results tum around time. Therefore, after extensive discussions with staff and the Science Advisors, we recommend that Southwest Labs of Oklahoma be awarded the contract for this RFP. •.
CO-CHAIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLLIE B. BURWELL
KEN FERRUCCIO
HENRY LANCASTER
December 6, 1996
Dear Governor Hunt:
The Joint Warren County/State PCB Landfill Working Group finds it necessary to inform you
about the number of very serious new circumstances. You personally have played a key role in
assuring the citizens of Warren County that the PCB Landfill would be safe and secure, a state-of-
the-art facility, and would be detoxified when feasible technology became available. We are
concerned that the normal bureaucratic channels of providing information to your office may not
have effectively communicated the importance of new information that the Working Group has
received from its two highly qualified Science Advisors.
The purpose of this letter is two fold. First, to inform you in general terms about the new
circumstance, and second to request your attendance at a community meeting in Warrenton
sometime in January 1997 so that you can personally hear the new facts abut the landfill and the
concerns of Warren County citizens.
As to the new circumstance, our Science Advisors have made it clear that the landfill did not have
the best technology installed, which is why the critically important leachate collection system is
not functioning as it must and why there is an enormous amount of water in the landfill. Our
Advisors believe that the landfill is leaking. Our Advisors have also concluded that there was
evidence in 1983 the uncontrolled PCB air emissions were significant, but that the State never
installed low cost carbon adsorption filters at air vents. At this time, our Working Group
members and the larger Warren County community have become convinced that the Warren
County PCB Landfill is not safe or secure and very likely has posed some threat to public health
for many years. Moreover, our Advisors have also informed us that detoxification technology has
become commercially available.
At this critical time, therefore, there is a critical need for you to assure Warren County residents
that you remain committed to protecting their health, environment and well-being by taking
measures to assure the safest possible condition of the present landfill and by committing to do
everything necessary to provide the State funds for total detoxification of the landfill as you
originally promised in 1982, and which our Advisors say will cost at least $25 million. The
Working Group has already requested Secretary Howes to immediately install carbon filters at any
open vents from the landfill as a necessary, temporary safety measure until detoxification can be
implemented. At the public meeting we also want to discuss with you the need for the State to
take other actions, including a health effects survey of residents living relatively close to the
landfill and possible testing of body tissues for residual PCB levels.
Governor Hunt, would you please have your office inform us what dates in January 1997 you
would be available to personally attend an evening community meeting in Warrenton. If you
provide two or three available dates within the next few days, we will quickly ascertain which date
can maximize attendance by our members, our Advisors, and Warren County citizens and confirm
a date with your office.
Sincerely,
Dollie B. Burwell, Co-chair
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
720 RIDGEWAY STREET-WARRENTON, N. C. 27589
PHONE [phone] -FAX [phone]
CO-CHAIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOUIE B. BURWELL
KEN FERRUCCIO
HENRY LANCASTER
Mr. Jonathan B. Howes, Secretary
State of North Carolina
Department of Environment, Health and Natural Resources
P. 0. Box 27687
Raleigh, N. C. 27611-7687
December 9, 1996
SUBJECT: Need to Install Filtration System on the PCB Landfill Main Gas Vent
Dear Secretary Howes:
It has recently come to the attention of this Working Group and citizens of Afton that gas
emission containing PCBs has been emanating from the main vent at the PCB Landfill in
Warrenton. This data was obtained by our Science Advisors from information contained in the
State's files. In particular, from a study performed by the EPA directly after the facility was
constructed some 14 years ago. The citizens are extremely concerned about this information and
demand that immediate action be taken to prevent further potential discharges of PCB to the
environment.
It is our understanding that the vent system opening, which is comprised of a single four-inch
diameter pipe, can be easily and inexpensively fitted with a filtration system. The Working Group
is willing to do all we can to expedite this matter including the allocation of the necessary funds
from our operational budget.
Because the gas vent is a direct connection between the PCB wastes and the environment, and
because it has been shown in the past to be a source of PCB gas emissions, we request that an
appropriate filtration system be placed at the mouth of the vent immediately. We believe that this
is the only prudent course of action concerning this matter.
Sincerely,
Dollie B. Burwell, Co-chair
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
cc: Dennis Retzlaff, Warren County Health Director
' , .... t· Orn " ·-c:. '-v //' ·-
N. C. ENVIRONMENTAL CAUCUS , kv,i
To: ENVIRONMENTAL CAUCUS
From: John Runkle
RE: NEXT MEETING IS TUESDAY, JANUARY 14, AT 2 P.M.
facilitated by John Runkle
P.O. Box 3793
Chapel Hill, N.C. 27SIS
919-942-0600 (o&.f)
[e-mail]
December 1 7, 1996
The next meeting of the Caucus is Tuesday, January 14, from 2 -

5

p.m., at the office of the
Wildlife Federation, 1024 Washington St., Raleigh. Call 919-833-1923 for directions. The
agende items for the 1 /14 meeting are the environmental agenda and Green Budget for 1997
session.
We are starting at 2 p.m. for a presentation by representatives of Wildlife Reeol.!rces
Commission and Division of Water Quality on critical habitat and endangered species (where
are we, were do we need to be); contact Jane Preyer, EDF, 919-821-7793.
From the 12/12 meeting:
The Institute for Southern Studies has created Democracy South for education on campaign
rntorrn and related issues. --The Alliance for Democracy has sent letters to Gov. Hunt and
Speaker Brubaker to remove Pearce (Gov. 's campaign advisor) and Shumaker (Brubaker and
Republican Party's PR consultant) from providing PR services for Farmers for Fairness, a hog
industry group. Pearce has removed himself. Contact Pete MacDowell, 919-967-1699.
NC Health and Environment Community Center by Environmental Resource Program (attached).
--The Z. Smith Reynolds Foundation has issued a request for proposals for "electronic
networking alliances" for direct on-site and on-call periodic technical support plus $5,000
grants for equipment, software and related staff costs. Deadline: February 15. Contact
Andrew Foster Connors, 919-932-4743 or [e-mail]. --=========================-------------------------The Science Advisory Board in Warren County has found that State agency staff falsified
d~ at the PCB landfill, did not install required leachate collection systems, and
routinely vents PCB to the air. More on this soon in a media outlet near you .
-------. ---. --. --.. _______________ ___
Dayne Brown is retiring from Radiation Protection Division; he has been an open and unbiased
regulator who would not let the licensing decision on the rad dump be a political one. --LLRW
Authority has enough funds until June; rad dump has cost $93.2 million already and may
require generators to fund the remaining at least $80 million required to finish licensing. --
Several groups are complaining to the Southeast Compact about its new "stakeholders" group
made up of utilities and regulators (i.e., no citizens). Contact Mary MacDowell, 919-542-
4878.
The NC Environment.al Caucus ls sponsored by the NC Solar Energy Association and funded by the Beldon Fund.
Recommendations are being made for Steve Levitas's replacement. Contact Raine Lee, 919-
933-7575.
VICTORY ON DURALEIGH --Governor Hunt finally made the decision to stop the road running
through Schenk Forest next to Umstead State Park. Now we need to make sure it is
eliminated from DOT's plans and budgets.
The Audubon Society is opening up the NC office of the national group; will focus on stream,
wetland and forest habitats. Contact Henry Hammond, 919-834-9573.
BREDL reported on the widening of Rt 16 through Glendale Springs; the BREMCO power line
over 3-Top Mountain in Ashe County, and the citizen campaign against the timber sale on Bluff
Mountain (Madison County). Contact Janet or Lou Zeller, 910-982-2691.
Erick Umstead reported on the victory before the Pesticide Board on groundwater report; for
regulators, "the truth is a slippery slope!"
Legjs!atjye issues --Bill Holman distributed the draft of the Sierra Club/CCNC agenda, to be
finalized in late January. Highlights (and lowlights) are Transit 2001, marine fisheries,
backlash on wetland rules and Neuse buffers, local zoning of hog operations, utility
restructuring, attack on groundwater through "risk analysis," our response to hurricane, return
of audit privilege, attack on third-party appeals, campaign finance reform, repeal of tax credit
for chip mills, repeal of Administrative Rule Review Commission, attack on watershed
protection act. Contact Bill at 919-755-1329 for a copy.
John Runkle presented early draft of green budget/green scissors. Several groups have
submitted recommendations on park staff funding, Transit 2001, saltwater fishing licenses,
plant protection and non-game species, and sustainable agriculture practices. Scissor items
are LLRW Authority, the hog slaughterhouse at NCSU, the beaver control program, DOT
boondoggles (Duraleigh Road will save $52 million),, the chip mill tax credit, Randleman Dam,
and the Administrative Rules Review Committee. A draft should be ready by next Caucus
meeting. KEEP THOSE SUGGESTIONS COMING IN.
NC RISK ANALYSIS FRAMEWORK ISSUES FORUM will be held January 22 at NIEHS in the
Research Triangle Park. The risk analysis framework is expected to be used in all soil and
water cleanups, including UST and brownfields. While attendance is by invitation only, John
Runkle was given 1 2 invitations for the environmental community. Please contact John if you
are interested in attending. For a copy of the Draft Framework or info about the Forum,
contact Sharron Rogers at 919-733-2178x222 or [e-mail]
To: ENVIRONMENTAL CAUCUS
From: John Runkle
RE: NEXT MEETING IS TUESDAY, JANUARY 14, AT 2 P.M.
~ · .. -=-~-:~ , ... ,.
facilitated by John Runkle
P.O. Box 3793
Chapel Hill, N.C. 27515
919-942-0600 (o&f)
[e-mail]
December 17, 1996
The next meeting of the Caucus is Tuesday, January 14, from 2 - 5 p.m., at the office of the
Wildlife Federation, 1024 Washington St., Raleigh. Call 919-833-1923 for directions. The
agend?. items for the 1 /14 meeting are the environmental agenda and Green Budget for 1997
session.
We are starting at 2 p.m. for a presentation by representatives of Wildlife P.eso~rces
Commission and Division of Water Quality on critical habitat and endangered species (where
are we, were do we need to be); contact Jane Preyer, EDF, 919-821-7793.
From the 12/12 meeting:
The Institute for Southern Studies has created Democracy South for education on campaign
rntorrn and related issues. --The Alliance for Democracy has sent letters to Gov. Hunt and
Speaker Brubaker to remove Pearce (Gov. 's campaign advisor) and Shumaker (Brubaker and
Republican Party's PR consultant) from providing PR services for Farmers for Fairness, a hog
industry group. Pearce has removed himself. Contact Pete MacDowell, 919-967-1699.
NC Health and Environment Community Center by Environmental Resource Program (attached).
--The Z. Smith Reynolds Foundation has issued a request for proposals for "electronic
networking alliances" for direct on-site and on-call periodic technical support plus $5,000
grants for equipment, software and related staff costs. Deadline: February 15. Contact
Andrew Foster Connors, 919-932-4743 or [e-mail].
The Science Advisory Board in Warren County has found that State agency staff falsified
~ at the PCB landfill, did not install required leachate collection systems, and
\_ routinely vents PCB to the air. More on this soon in a media outlet near you.
Dayne Brown is retiring from Radiation Protection Division; he has been an open and unbiased
regulator who would not let the licensing decision on the rad dump be a political one. --LLRW
Authority has enough funds until June; rad dump has cost $93.2 million already and may
require generators to fund the remaining at least $80 million required to finish licensing. --
Several groups are complaining to the Southeast Compact about its new "stakeholders" group
made up of utilities and regulators (i.e., no citizens). Contact Mary MacDowell, 919-542-
4878.
The NC Environmental Caucus is sponsored by the NC Solar Energy Association and funded by the Beldon Fund.
State of North Carolina Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
MEMORANDUM
AVA
DEHNR
TO: Members of Joint Warren County/State PCB Landfill Working Group
FROM: Division of Waste Management Staff to Working Group
DATE: December 17, 1996
SUBJECT: Removal, treatment, irrigation of water in PCB Landfill
The Division of Waste Management Staff offers a motion to the Working Group
for enhancing safety and detoxification of the PCB Landfill.
The Division of Waste Management Staff moves that the staff immediately initiate
extraction, on-site treatment, and on-site land application of water contained in the landfill. These
activities shall be in accordance with the approval/permit conditions of the landfill.
sh
c:wpfiles/pcblf712-l 7.mem
P.O. Box 27687,
Raleigh, North Carolina 27 611-7 687
Voice 919-733-4996
N'k,.C . ~ .·~ An Equal Opportunity Affirmative Action Employer
FAX [phone]
50% recycled/10% post-consumer paper ISPA'i4M€i p
To: ENVIRONMENTAL CAUCUS
From: John Runkle
RE: NEXT MEETING IS TUESDAY, JANUARY 14, AT 2 P.M.
~
·:-=--~-r~ r:\-' ·.
facilitated by John Runkle
P.O. Box 3793
Chapel Hill, N.C. 27S1S
919-942-0600 (o&..t)
[e-mail]
December 1 7, 1 996
The next meeting of the Caucus is Tuesday, January 14, from 2 - 5 p.m., at the office of the
Wildlife Federation, 1024 Washington St., Raleigh. Call 919-833-1923 for directions. The
agendc items for the 1 /14 meeting are the environmental agenda and Green Budget for 1997
session.
We are starting at 2 p.m. for a presentation by representatives of Wildlife Re:::oL!rces
Commission and Division of Water Quality on critical habitat and endangered species (where
are we, were do we need to be); contact Jane Preyer, EDF, 919-821-7793.
From the 12/12 meeting:
The Institute for Southern Studies has created Democracy South for education on campaign
reform and related issues. --The Alliance for Democracy has sent letters to Gov. Hunt and
Speaker Brubaker to remove Pearce (Gov. 's campaign advisor) and Shumaker (Brubaker and
Republican Party's PR consultant) from providing PR services for Farmers for Fairness, a hog
industry group. Pearce has removed himself. Contact Pete MacDowell, 919-967-1699.
NC Health and Environment Community Center by Environmental Resource Program (attached).
--The Z. Smith Reynolds Foundation has issued a request for proposals for "electronic
networking alliances" for direct on-site and on-call periodic technical support plus $5,000
grants for equipment, software and related staff costs. Deadline: February 15. Contact
Andrew Foster Connors, 919-932-4 743 or [e-mail].
The Science Advisory Board in Warren County has found that State agency staff falsified
d~ at the PCB landfill, did not install required leachate collection systems, and
routinely vents PCB to the air. More on this soon in a media outlet near you.
Dayne Brown is retiring from Radiation Protection Division; he has been an open and unbiased
regulator who would not let the licensing decision on the rad dump be a political one. --LLRW
Authority has enough funds until June; rad dump has cost $93.2 million already and may
require generators to fund the remaining at least $80 million required to finish licensing. --
Several groups are complaining to the Southeast Compact about its new "stakeholders" group
made up of utilities and regulators (i.e., no citizens). Contact Mary MacDowell, 919-542-
4878.
The NC Environmental Caucus ls sponsored by the NC Solar Energy Association and funded by the Beldon Fund.
.,,. "
State of North Carolina
Department of Environment,
Health and Natural Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Henry M. Lancaster, II, Assistant Secretary
for Natural Resources
MEMORANDUM
.AVA
DEHNR
TO:
FROM:
Joint Warren County/State PCB Landfill Working Group
Henry M Lancaster 11, Co-chair ~~
RE: Proposal -Working Group Membership Restructuring
DATE: December I 7, I 996
The Working Group Co-chairs propose for consideration and action the following
membership restructuring plan. It is intended that a new membership plan be presented to
Secretary Jonathan Howes as a follow-up to the earlier communication encouraging him to
continue the landfill detoxification effort via a joint state/citizen structure.
RECOMMENDATIONS
1. NEW MEMBERSHIPS
Office of the Governor
Office of the Secretary, EHNR
Office of the Secretary Administration
Warren County Government
Health Department
Grass Roots Environmental Community
Religious Community
Private Citizens
TOTAL
P.O. Box 27687 ,
Raleigh, North Carolina 27611-7687
Voice 919-733-4984
I
1
I
I
2
I
4
11
Appointee
Governor
Secretary
Secretary
County Commission
Working Group/Secretary
Working Group
Working Group
FAX [phone]
An Equal Opportunity/ Affirmative Action Employer
50% recycled/10% post-consumer paper
Joint Warren County/State PCB Landfill Working Group
Page2
December 17, 1996
2. The group should be led by one Chair selected by the majority of the membership.
3. A Vice-Chair should be selected to act in the absence of the chair.
4. The regular meeting should be no more than two hours in duration and open with a one
hour public comment period followed by a one hour business meeting.
December 16, 1996 ............................................................. by FAX (5 pages)
To : Technical Committee
From: Joel Hirschhorn
Through: Doris (for distribution p.rior to WG meeting as muc.h as possible, and to all Working
Group members at meeting ofDec. 17)
Subject: Review or ori&inal EPA contractor report on PCB air embsiow
lo response to my request, I received the Final Report on Ambient Monito,:ing For PCBs At The
Warren CoW1ty (North Carolina) Landfill by Battelle from Dr. Lewis and have prepared the
following comments on it so that the Working Group can better understand the situation. In
general I have found even more problems and reasons to be concerned about the entire histor1 of
this situation.
~tv latest review, analysis and condusiops strongly support the position of the Icd1ni¾1!
Committ«.in its rec;_Qgnition that it is imperath:.e that fuU disclosure of tht dan2t-r.LQf.the
landfill be openly communicated to the public and the state government th~ another
press conference, letters to the Governor and SecretaQ' Bowc~ttions being
taken by the state (:ivs.h..as carbon filter installation and new monitoring). anrl...a well
planned community meetin.~ that the Governor is invited to participate in. I wanJ-1Q
.emphasize that the most important recommendation presented by t.l.A 's confn1c1<1.r i!!
1283, calling (or future periodic monitorine for PCB air releases. was NOT i,mptcmente.d.b
.tbe state or EPA, In my professional opinion this was a ullous and scientifit;1ll):·_M.filtl.M1-d
decisio11 by the state and EPA that sas:rificed protection of public health to derl2Y1
um.cerns, like wantine to avoid eettine data that would conclusively demo.m.t1.:.a.i.Uj!
\Varrui County residents and the broader public that .thLWan:en County FCJ.!.LAruifW
was dangerous. un5afe. and a source of uncontrolled environmental rd~!..JJte
recommend;tgo.n for future periodic monitoring and the test results from J 983~~t
lo~ally resuUed in the state takipg the proper precautionary step of instalJing ~JJ~
filters on aJJ landfill vent1, Thi~ matter de..1uve~ the drongest pos5ihle action l)~y th~
\Vorking Group to urew.ard the interests of Warren County resident~..fillihat effutivs
.d..tluxificatfon of the landfiU is .M1u3Uy accomplished III soon as possible, The Gover!!.Q!
should be •·equested to detecn.ilile why the recommendation of EPA's: contractor to cond~·Kt
hnY.c.e..monitor;oe for PCB emission~ wa, not implemented,
The report was dated August 16, 1983,.indicating that complete data were available to EPA
relatively soou after the onsite testing had been done in January and February 1983. Of tb.e 40+
page report, only page 2, Section 2, Conclusions had been found :in the state files provid~d me,
and which I previously commented on.
l
r ..
Page 3 of the report was SeC1,ion 3 Recommendations and included the following: "In tbc futm·e,
il is recommended that periodic monitoring be performed to determine the trend in PCB
emission rates from the gas vents and lea,hate access ports on the landfill site .. " (emphasis
added) The single paragraph also included a recommendation to use somewhat different sampling
technology, called high volume PCB samplers, because they offered ''significantly lower dete1.,"tion
limits." It appears that these recommendations were never implemented by either EPA or the
state. The recommendation for .future testing is particulady significant because there were
relatively few positive detections of PCBs in ambient air, indicating that the contractor recognized
that in later ti.mes PCB emissions and .releases offsite were plausibl~. In other words, the
contractor ,vas correct in recognizing the appropriateness of experimentally, through further field
testing, deten:nm.ing the "trend" of PCB emissions. Tiris implicitly recognized the positive
detections of PCBs in vents an.d ports, as sources of environmental releases, as well as initial
detections of PCBs in ambient air. It also recognized the reasons why the study had been
conducted.
The contractor report contained no information on the design or construction of the landfill,
which the published paper had presented. But the contractor report did note that: "Local
residents and the Warren County Health Department have expressed concern about the possibility
of airborne PCB emissions from the lilDdfill being transported to neighboring areas, thus
threatening the public welfare." It also noted that "The study was performed at the request of
the North Carolina Division of Health Services ... 11 This nukes it even more questionable why the
full coJ.1tractor report was not found in state files. Five specific study objectives were presented,
including determining if PCBs were present at the house approximately one-half mile away. Of42
specific measurements in ambient air, however, only two were for the nearby house.
There is absolutely no statement iu tb.e entire report that in any way supports the contention
recently communicated by EPA that the positive findings of PCB air emissions were false
positives.
There is a discrepancy between the details of the positive findings as preseuted ill the published
paper versus the contractor report. The published paper indicated four positive detections in
ambient air and clearly gave the locations of tluee of the.OJ as: beside main vent, fence line
downwind, and nearby house. The contractor report gave: beside main vent, two for fence line
downwind, aud onsite upwind of main vent. The footnote in the published paper iudicatiug that
one of six measurements at the nearby house was above detection limit is inconsistent with data in
the report that indicates that only two measurements were taken at the nearby house_ What is
most perplexin.g at this time is, therefore, that the published paper showed a positive finding of
PCBs at the nearby house, while the contractor report showed all findings as less than the
detection limits. But the procedure used by the contractor was to consider less than dctectiou
limit findings as equal to the detection limit. Following the contractor~s procedure the average
concentration for Aroclor 1242 and 1260 for the nearby house would be 6 and l 0 ng/cm.
respectively. In my previous comments I used what was reported in the published paper, namely
a positive fillding of 10 ng/cm for .1260, which is still supported by the actual findings in the
2
contractor .report. Let me emphasize that the contractor's methodology of assuming a finding of
Jess than the detectfou limit is equal to the detection limit is far more appropriate than assuming
that such a nondetect finding is equal to zero, which seems to be EPA's position. Nevertheless,
there remains a discrepancy between the published paper's clear notation that a positive .finding of
Aroclor 1260 was found at the nearby house versus the contractor report that indfoates that all
four readings on the two days of testing for the two Arodors were nondetects. \\'hat deserves
attention by .EPA is why it reported, in the published paper, the positive finding of PCB at the
nearby house.
The variation in detection limits was made understandable in the contractor report, because the
data given showed that sampling times and, hence, sample volumes varied somewhat, with
unanticipated lower volumes resulting in higher detection limits in some cases. In all cases, where
positive detections in ambient air were found, the detection limits we.re the lowest, making the
findings more reliable.
Although the published paper presented key PCB data in terms of ranges and averages, the data
presentation in the contractor report was different and, in my opinion, more useful and
informative. One problem in the published paper is that some data were reported as "ND" which
is standard notation for non-detected, while other data were reported as "<" meaning less than the
follo'"1ing uu.merical number which normally would be the actual detection limit (DL). ln fact,
there was no reason to .report NDs at all in the publish.ed paper, and in the contractor report data
were reported either as positive detects or as <D.L for PCB concentrations. The point is the NDs
represented a spt!cific test in which no reliable data were obtained. But the published paper said
that ND represented "nondetectable." Ibis definition misrepresented the actual meaning of some
data. For example, for the lower leachate access port, the published paper indicated the low end
of the two ranges were ND, but this actually referred to a test where the data were not usable.
The inference was that a ND low end represented a zero level rather than no reliable data. The
published paper reported ave.rages of 0.04 and 0.05 ug/cm for 1242 and 1260, respectively, \.vhich
were calculated by assuming that ND = 0 and that <DL = DL. But using the a.ctual data in the
report, and eliminating the ND values results in the averages being .06 and .08 ug/cm,
respectively. Clearly, the corrected averages portray a significantly higher level of PCBs from the
lower leachate access port.
Au other systematic source or wideneportjng PCB levels was the unusuaJ procedure of not
rounding off numbers following the normal practice that if a digit is 5 or greater, than the
preceding digit is increased by one. For example, .056 should become .06. But in the published
paper, some averages and other figures are too low, because rounding was not done p.roperly.
For example, the average PCB levels for smaU veut E were reported as 0.24 and 0.4, liut should
be 0.24 and 0.5.
There is an important lack of details about the weather conditions existing at the time of sampling.
For example, for Jan. 30 the notation was ''no sampling due to weather c~ditions," \\i.thout,
however, explaining what the weather conditions were. The relative humidity for the follo\\ing
3
two days on which testing was done indicated very high levels, suggesting that perhaps rain or
snow was a factor during the testing period. In general, the collection of meteorological data was
incomplete, and th~ report presented no detailed analysis of bow weather conditio.ns might have
affected the testing results, both positive and negative detections. In my opinion, the weather
conditions were probably not the most conducive for transporting PCBs offsite which could exist
at other times. This supported the study's recommendation for additional future testin.g. For both
periods during which monitoring was done for the nearby house the Wllld was .not blowing from
the landfill in the direction of the house. This fact and the very limited number of measurements
taken at the house indicate, in my opinion, poor study design.
The contractor report made an important observation about the finding of Aroclor 1260 but not
1242 in ambient air: "It is puzzling that Aroclor 1242, the major component of the vent emissions,
was not also detected in these samples." This is the issue raised recently by EPA However, the
cot1tractor does not attempt to explain why the noted observation occw-red or how it can be
explained, and certainly never raises the possibility of false positives.
In eight cases reliable data was not obtained because sample pumps malfunctioned, wjtJ1 the only
reason given as "due to the low temperature and hlgh. humidity conditions that prevailed during
the sampling period. 11 This supported monitoring at a later time under different climatic
conditions.
Tue published paper did not note that the two .highest ambient air detections were for the same
location at the same time, but for two heights of 4 aud 15 feet, with 71 and 50 ng/scm,
respectively. The level of PCBs at the higher height is significmt.
The contractor report made it clear that gas flow rates from vents and leachate access ports were
measured by EPA personnel on "March 2, 1982." Pre&tUn.1blythis was an enor (not caught in
peer review), and was really in 1983, but it was definitely after the contractor performed the
major portion of the "vork. And while the published paper some data on the gas flow from the
maiu vent, it did not present the detailed data in the most understandable and significallt way. The
contractor report's presentation of the data showed that gas flow rates increased siguHicautly
from 9:45 AM to 3:00 PM, with. a 32% increase over that period. This would logically suggest
that gas flow increased as temperature in.creased (no climatic data was given for this day in the
report)~ supporting my contention. that air releases of PCBs increase with increasing temperature
and also supports the repon's recommeudatio.n for subsequent monitoring at the lan.dfill. The
modeling work by the coo.tractor cited by EPA Ollly used the average of the data obtained for
different times, which does not, therefore, produce results indicative of maximum. PCB release
rates.
The study design. was deficient because the sample volumes for the small vents and the leachate
access ports was the same as for the main vent, which resulted in hlgher detection limits f01 the
fonnet versus the latter, because the quantities of PCBs in the former were substautially smaller.
Such a situation could have been predicted, and at the very least this problem \\-ould have beeu
4
corrected in subsequent monitoring by increasing the sampling rate and volume (as was done for
tb.e ambient monitoring).
I found it unusual that several significant statements made in the Conclusions sec6oo ""ere not
contained in any form v.ithin the body of the report, particularly Section S Results and Discussion.
This is highly unusual. because normally there is a more extended discussion in the body of the
report that supports summary conclusions. For example, the comments in the conclusions about
PCB emission rates being reduced in the future are not supported by any informatio.n or analysis
given in the body of the report. Nor are the comments completely consistent with the report's
major recommendation for future periodic monitoring. Other statements in the conclusions are
inconsistent with the details given in the report, umely that ambient PCB levels were only found
"at or below minimum detection limits'' while, in fact, the report's data showed positive detections
as high as seven tim.es the detection limit. Based on my professional experience, these kinds of
unsupported and inconsistent statements in conclusions result .from the contractor's client (EPA)
making changes during a final review of the draft report m order to protect or serve its O'-'in
interests.
As to peer review that Dr. Lewis has claimed is so significant, I want to point out that the peer
review process has many limitations, including the fact that a primary report that forms the basis
for a published paper is not provided peer reviewers, so that some shortcomings in the paper
cannot be properly assessed.
5
• • A
, . \
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Air Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Alan W. Klimek, P.E., Director
MEMORANDUM
December 16, 1996
TO: Lee A Daniel, Chief
Technical Services Section
George Murray, Chief
Ambient Monitoring Section
THROUGH: Alan Klimek, Director ~
Division of Air Quality
FROM: Laura S. Butler, Chief ~
Air Permits Section
SUBJECT: PCB Air Emissions
Warren County PCB Landfill
Warren County
NA
DEHNR
,_,. ;.::,
--.J :r
J,-.-\ :·-er;::,
Ct:-o c
On December 2, 1996, I sent you and Lori Cherry a copy of the report PCB Air
Emissions and Health Risks from the Warren County PCB Landfill for your review and
comment (copy attached). Additional reports have been received and are attached for
your review and comment. Please advise me on your opinion of the necessity for
performing air monitoring for PCB's at the Warren County PCB Landfill.
The Warren County PCB Landfill Working Group is concerned about potential human
health effects and environmental impacts from PCB emissions. Your earliest review is
requested.
C: Bill Pate -Division of Epidemiology (w/o attachments)
illiam Meyer (w/o attachments)
Ernie Fuller (w attachments)
Lori Cherry (w/attachments)
Attachments: (6)
P.O. Box 29580, Raleigh. North Carolina 27626-0580
Voice [phone] FAX [phone]
An Equal Opportunity/ Affirmative Action Employer
50°1o recycles/ l 0"/4 post-consumer paper
1. Final Report On Ambient Monitoring for PCB's at the Warren County (North
Carolina) Landfill, D.L. Sgontz, W.E. Bresler, L.A. Winker and J.E. Howes, Jr.,
Battelle Columbus Laboratories, August 16, 1983.
2. Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls from
Hazardous Waste Landfills, Robert G. Lewis and Barry E. Martin, Environ. Sci.
Technol., Vol. 19, No. 10, 1985.
3. PCB Air Emissions and He9Ith Risks from the Warren County PCB Landfill , Joel
Hirschhorn, Warren County PCB Landfill Working Group, November 27, 1996.
4. Air Emissions of PCB and Associated Health Risks, Patrick Barnes and Joel 0 .
Kimrey, December 2, 1996.
5. Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G. Lewis, December
3, 1996.
6. Dispersion Modeling for Warren County PCB Landfill, Tom Anderson, December
10, 1996.
Date: Wednesday, December 11, 1996
To: Ms. Doris Fleetwood
PCB WORKING GROUP
Fax: [phone]
Voice:
Comments:
Time: 1 :51 :01 PM
From: Dennis W. Retzlaff
Fax: [phone]
Voice: 919-257-1092
Doris, I will not be able to join the 3:00 P.M. Technical Committee
Conference Call. Please relay the following message to the Committee.
Mr. Bill Meyer indicated that his staff is responding to the concerns
expressed related to possible PCB emissions from the Warren County PCB
Landfill. Plans for placing a carbon filter have been in the works since
concerns were raised to reduce fears of those who may be concerned.
Filter may be in place by this Friday. Dennis
1 Pages
Fax :[phone]
MEMORANDUM
TO: Bill Pate
Di vision of Epidemiology
THROUGH: Alan Kli mek, Director
Division of Air Quality
DRAFT
FROM: Laura S Butler, P.E , Chief
Air Permits Section
SUBJECT: PCB Air Emissions
Warren County PCB Landfill
Warren County
Dec 13 '96 14 :26
f ' I,,! t •~ 'I
F·. 01/03
We have received a report concerning air emissions from thEi Warren County PCB
Landfill. The Warren County PCB Landfill Working Group is concerned about potential
human health effects and environmental impacts from PCB emissions. By way of this
memorandum I am requesting your guidance and input on these issues. Copies of the
following documents are attached:
1. Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls from
Hazardous Waste Landfills, Robert G. Lewis and Barry E. Martin, Environ Sci
Technol., Vol. 19, No. 10, 1985.
2. PCB Air Emissions and Health Risks from the Warren County PCB Landfill , Joel
Hirschhorn, Warren County PCB Landfill Working Group.
3. Air Emissions of PCB and Associated Health Risks, Patrick Barnes and Joel 0 .
Kimsey, December 2, 1996.
4. Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G . lewis, December
3, 1996.
5 Dispersion Modeling for Warren County PCB Landfill, Jim Roller, December 10,
1996.
C: William Meyer -Division of Waste Management
Ernie Fuller -Regional Ai r Quality Supervisor
Lee A Daniel
George Murray PosHt Fax Note 767 1 D;t\i, /) /. I J1~Ls ► ,
,...To_/.;..~ c-. ,.,....; !.,.---i ..,..,· '"'"!-c-,,-. ,:-, ---+-Fr-om~' ~1 ._..;-,I--'-,.-.-/ -1. -_---'-----1
Co/D~r,1. Co.
c.;WPWII\J\eil\R~\FM,s.PATE PC8 Phone /I
Fax II j Ir..:-
. I "\
Fax II
Fax:[phone]
DRAFT 3
MEMORANDUM
TO . Lee A. Daniel, Chief
Technical Services Section
George Murray, Chief
Ambient Monitoring Section
THROUGH: Alan Klimek, Director
Division of Air Quality
FROM La1.1ra S. Butler, Chief
Air Permits Section
SUBJECT: PCl3 Air Emissions
Warren County PCB Landfill
Warren County
Dec 13 '96 14=26 F'. 02/03
On December 2, 1996, I sent you and Lori Cherry a copy of the report PCB Air
Emissions and Health Risks from the Warren County PCB Landfill for your review and
comment (copy attached). Additional reports have been received and are attached for
your review and comment. Please advise me on your opinion of the necessity for
performing air monitoring for PCB's at the Warren County PCB Landfill
The Warren County PCB Landfill Working Group is concerned about potential human
health effects and environmental impacts from PCB emissions. Your earliest review is
requested.
C Bill Pate -Division of Epidemiology
William Meyer
Ernie Fuller
Attachments: (5)
Fax:[phone] Dec 13 '96 14 =27 F·. Cl3,lCJ3 -. .
i. Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls from
Hazardous Waste Landfills , Robert G. Lewis and Barry E. Martin, Environ. Sci.
Technol., Vol. 19, No 10, 1985.
2. PCB Air Emissions and Health Ris ks from the Warren Cou nty PCB l andfill , Joel
Hirschhorn, Warren County PCB Landfill Working Group.
3. A ir Em issions of PCB and Associated Health Risks, Patrick Ba rnes and Joel 0.
Kimsey, December 2, 1996.
4. Hirschhorn Report on Warren County PCB Landfill, Dr. Robert G. Lewis, December
3, 1996.
5. Dispersion Modeling for Warren County PCB Landfill, Jim Roller, December 10 ,
1996.
MEMO FROM: Linda Rimer Assistant Secretary for Environmental Protection TO~r) \ (f\o.,, a.-\ \ i \-\-. le.,,(.(~~ ~•oSf. !Jfc ·1 R 1886 D~J¼' l ~, f) ,, SUBJECT, Pc £s (k.; & . if ~.\\-¼ memo rt'"' 1--i,rr\'w-\ s, ~ ~ro ~L. \, r'l(f -\__, C'/Y'\ c:{g 1--, (\ ~ -b s--+A,-0 m 'C. l><,t 1 -1 be I 1e0--ulU\ dJ.~CJJ.fr't OA u.-.-S-'T'f> 0~ l s~c_o //}ClA~41f [PA-~ ~ 0A c~ MA DEHNA NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES ___ P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone]_140 __ _.
MEM® 1996 PROM: Lin?a Rimer •!t ·~ DATE:~ l ~1 '3 l Ct l "~ ~. •" Assistant Secretary for . :~ rn,f ~ · ~ Environmental Protection TO:_\:tet\ti-Lc(l(cs'I&<.. SUBJECT: uJ A<4>~ U)v-,'i] 7-R< )JE' s fl'"\ IT t-\ -f (__ ~ (__ Cn Q 6 ' l I ~MS\Ur--¼:ow()./1,J ;F· rn \u {(l uSc.((, ~\~ .... ~LIi"'(\~\<::_ {Af l) I e,L,-0 ~C (l)'f.J me rr1~ rn~C,,\ -~,\ I hC/J me~ Q~u,Q_Q_ 'f" ~,\I scu,.QJ..,c9 AfUJrnmetiQ~~~r ~ (J.AJ \ ~+--' -\-1 me l\ Oi 1 CQJ1fr.,,,, s l v"" vl ~ v'\QSOMA LI I ~ U u'f"J,l,S. T' 1 ,.,-k,,J ~ --l.9-t CJ{? V /ne-clt0 W ~ '--( <>-~ CJl~c.uS' GV"lQ ~L.CrY\ O f\a-Sf ~ .RA DEH~ -ENVIRO~~~~ ~~~NA DEPARTMENT OF P.O. Box 27687. Raleigh. ~orth Caroll~~~ ~7';a~RALT RESOURCES elephone 919-715-4140
Forwarded by:
Forwarded to: ·
Date forwarded:
From:
Organization:
To:
Date sent:
Subject:
Copies to:
Priority:
[e-mail]
[e-mail]
Fri, 13 Dec 9612:40:17 +1100
"ALAN KLI.l.\1EK" <alan [e-mail]>
EHNR/AQ -
"Linda Rimer" < linda [e-mail] >
Fri, 13 Dec 1996 12:40:14 EST
Warren Co pcb landfill issue
Henry [e-mail]. us, [e-mail]
Bill_ [e-mail], laura_ [e-mail]
normal
Laura Butler has been the DEM (now DAQ) apointment to the Warren Co
PCB Landfill Workgroup established by the Gen Assembly. Events seem
to be heating up a bit of late, and we are unsure as to the direction
and effort that the Dept would like DAQ to go on this. I myself have
only cursory knowledge of ongoing events. In response to recent
requests, we are proposing to have our toxic group review certain
materials for AQ concerns, and are also planning to forward them to
Bpi for their assistance. Please let me know if you have specific
guidance wrt this issue.
Forwarded by:
Forwarded to:
Date forwarded:
Date sent:
From:
To:
Copies to:
Subject:
[e-mail]
nlnwOl [e-mail]
Fri, 13 Dec 96 18:47:11 + 1100
Fri, 13 Dec 96 18:44:28 EST
"Linda Rimer" < linda [e-mail] >
"ALAN KLIMEK" < aian klimek@aq .ehnr .state.nc.us >
Bill [e-mail] .state:iic. us, [e-mail]
[e-mail], laura [e-mail] .stat
Re: Warren Co pcb landfill issue -
A timely request Alan.
In my mail today I discovered a request from Bill Meyer to establish
an internal work group to assess where we are and where we need to go.
I intend to work with Henry Lancaster (who has been the rep from the
14th floor -to set up a meeting with affected Division Directors. I
suggest that you get briefed by laura. We will need to get this
meeting set up early in January.
=--=,-,----==-=----=---=---:---=-=-=-,-----,--Reply Separator __________ _
Subject: Warren Co pcb landfill issue
Author: "ALAN KLIMEK" <alan [e-mail]> at Internet
Date: 12/13/96 12:41 PM -
Laura Butler has been the DEM (now DAQ) apointment to the Warren Co
PCB Landfill W orkgroup established by the Gen Assembly. Events seem
to be heating up a bit of late, and we are unsure as to the direction
and effort that the Dept would like DAQ to go on this. I myself have
only cursory knowledge of ongoing events. In response to recent
requests, we are proposing to have our toxic group review certain
materials for AQ concerns, and are also planning to forward them to
Epi for their assistance. Please let me know if you have specific
guidance wrt this issue.
REVISED COPY
December 13. 1996
To: PCB Working Group and Science Advisors
From : Ken Ferruccio ~~
Subject: Flnal Recommendation as Co-chair
It is my final recommendation as a co-chair that the most serious concerns of the
Science Advisors and Technical Comminee be addressed first at the upcoming
December 17th PCB Working Group meeting.
l H '•-~L_ U..L
To be responsible to the citizens of Warren County, it is imperative that these serious
concerns are given first priority on the agenda and that other process-related concerns
follow.
=1.1. =1 .,:_:_1 1' LQt.:.J'-t
December 13, 1996
To : PCB Working Group and Science Advisors
From : Ken Ferruccio cJ/ '-1 ~~
~--t--,A.•vc~./
I am convinced that I can now most effectively serve the citizens of Warren County by
stepping down as a co-chair of the PCB Working Group. Therefore, I am submitting my
resignation effective Immediately.
I will work as a regular member of the PCB Working Group as long as I believe that
the Working Group serves the best interests of Warren County's citizens.
Please regard this memo as an official statement of my resignation as a co-chair.
PCB ~JRKING GRC~P Fax:[phone]]0 Dec 13 •~5 11 :44 F·. 01
JOINT WARREN COUNTY/STATE PCB LANDFILL WORKING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Office [phone] -Fu [phone]
Fax Cover Sheet
TO:
FROM
DATE:
RE:
Laura Butler
Tommy Cline
Bill Meyer
Ron Nixon
Dennis Retzlaff
Nan Freeland
Jim Warren
Doris Fleetwood
December 13, 1996
733-5317
733-1431
715-3605
419-8315
257-2897
832-9100
493-6614
Working Group Meeting Date and Agenda
Number of Pages, including cover sheet : 2
Dear Working Group Members:
The co-chairs met yesterday and have informed me that the Technical Committee cannot cancel a
Working Group meeting. Therefore, the meeting scheduled for Tuesday, December 17, 1996 at
4:00 p.m will take place as originally scheduled. I apologize for any inconvenience.
Thank You.
... F'CB l.dCIF:f< I r·.J(; 13PCIUF' Fax : 91':::l-257-1000 Dec 13 '96 11:44
JOINT WAR.REN COUNTY /STA TE PCB LANDFILL
WORKING GROUP AGENDA
DATE: DECEMBER 17, 1996
I. Welcome
IL Approval of Minutes
Ill. Unfinished Business
1) Status Reports
F'.02
a) Monitoring Wells ...................................... Tommy Cline
Bill Meyer
b) Any Other Status Reports ........................... Bill Meyer
2) Technical Committee Report
a) Letter to Governor Hunt about a visit to Wanen County
b) Letter to Secretary Howes about the filtration system
c) Science Advisors Report and Recommendation on Air Quality
IV. New Business
Proposal by co-chairs on issue of structure of the Working Group
V. Other Business
VI. Adjournment
PCB WORKING GROUP Fax:[phone] Dec 12 '96 13:00 P.01
JOINT \VARREN COUNTY /STATE PCB LANDFILL WORKING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Office [phone] -Fax [phone]
Fax Cover Sheet
TO :
FROM :
DATE:
RE:
Laura Butler
Tommy Cline
Bill Meyer
Ron Nixon
DeMis Retzlaff
Nan Freeland
Jim Warren
Doris Fleetwood
December 12, 1996
733-53 J 7
733-1431
715-3605
419-8315
257-2897
832-9100
493-6614
Working Group Meeting Date
Number of Pages, including cover sheet: 1
Dear Working Group Members:
The Technical Committee met again yesterday, and still feels that there are some issues that need to be
resolved with the local members of the Working Group before a full Working Group meeting is held.
Therefore, this is to notify you that the meeting scheduled for December 17, 1996 will not take place.
The co-chairs will be meeting here today at 5:00 p.m .. One item that will be discussed is possibly
changing the structure of the Working Group. Please fax any ideas that you want the co-chairs to
consider to the office before 5:00 p.m. today.
Thank You.
Dear Working Group Member:
The members of the Technical Committee and the Science Advisors had a conference call this morning
and have asked that I poll you on several items, so that they may be expedited.
1) The date of the next Working Group meeting. The Science Advisors have informed the
Technical Committee that they cannot attend a meeting on the 17/18 December.
They have suggested the December 16. Please advi~e if this date is convenient for you.
2) The Technical Committee has proposed that the Working Group inform that State that if
necessary the cost of the filters needed at the landfill could be taken from the $100,000.00
that the County has for improvements to the landfill.
3) The Technical Committee has suggested that the Working Group hold another press
conterence, December I 6, 1996 at 11 : 00 a. m.. The press conference will deal with the
Working Group's request that filters be placed on the vents in the landfill to address health
care issues The Governor corning to Warren County to address citizens' concerns will be
the other issue discussed.
4) The Technical Committee has suggested that two letters be written. One, to the Governor
informing him of the request that filters be put on the vents and to ask him to come to the
County to address citizens concerns. A copy of this letter will be sent to the media. The
second letter is to Secretary Howes to reqnest that the State put filters on the vents. A copy
of this letter will be sent to Dennis Retzlail: Warren County Health Director.
I spoke with Dollie Burwell this morning and advised her of the above. She wanted me to include that
she is for sending the letter to Secretary Howes, and the Governor. However, she feels that the letter to
the Governor should not be sent to the media. She feels that the Governor should be given time to
respond to the letter. The media should be notified only it: after about a week, the Governor has not
responded.
Please respond by Monday, December 9, 1996 at noon. Additional commits or suggestions are
welcomed.
Thank You.
I) yes
3) yes
{ }
{ }
no
no
{ }
{ }
Place for Press Conference: Warrenton { }
December 16 for Working Group meeting yes
2) yes
4) yes
{ }
{ }
Raleigh { }
no { }
no { }
{ } no { }
720 Ridgeway Street. Warrenton, N. C. 27589
Office [phone] • Fax [phone]
t-1-<UM
December 12, 1996
To: Technical Committee
From: Joel Hirschhorn
Subject: Latest letter from EPA to Bill Meyer
Bill Meyer faxed a two page response dated Dec. 11 from Robert Lewis of EPA that was
described as the "Response to Hirschhom's Latest Comments. 11 See attach.ment.
The first question I asked myself was bow did EPA get a copy ofmy comments on their initial
responses to my report o.n PCB air emissions, because I first thought it was only distributed to the
Tecluucal Committee, but than I realized (with Doris' heip) that my comments were faxed to
Dennis on the afternoon of Dec. 10. So clearly Deimis sent it to Bill who immediately sent it to
EPA to get another response.
As to the substance of the latest EPA comments, there is none.
Dr. Lewis has chosen to take my comments personally.
Although he talks in terms of an ''attack on the quality of the EPA monitoring study" and on his
"scientific interpretations," he has provided no technical, detailed, professional statements.
All Dr. Lewis has done is to defend EPA and himself by citing his personal, professional
credentials, which, of course, I never attacked or questioned. Jndeed, Dr. Lewis has distinguished
credentials.
But that really is beside the. point. As most astute Aroerican.s have surely learned over past years,
even people with the best of professional credentials get involved with government actions and
decisions that do not serve the public interest. Some of this surely is a result of different
judgments and technical opjnions, and not necessarily, merely or solely bad intentions. But it
happens.
As l have already told the Technical Committee, Bill Meyer's style has become abundantly clear.
His office rarely h.as dealt with complex and contentious technical issues and public concems in a
straightfotward manner in writing by providing detailed well reasoned technical arg:uroeuts and
information. Instead, he likes "peer review" and involving other parties in fighting what sh.ould be
the state's battles. Neither am I attacking Bill Meyer personally or his motive.s or credentials.
I stand by all my conclusions and discussions.
FROH 9 197153605 SOL ID WASTE DlU 12.12.1996 09:11
DATE:
TO:
FR()M:
SUBJECT:
u. s. ENVIR~NMENTAL PRPTECTI N AGENCY
NATlON~L EXPOSURE RESEARCH LA ORATORY
A~ MEASUREfylENTS RESEARCH ~lVISION MAIL DROP 44)
RESEARCH tR.IANOL.f! PARK_ NbRTH CAR LINA 2 7711
TELBPHONB 9l!M41-306S FACSIMILE 919-41-352'1 E-MAIL [e-mail]
I : I .
1FAXMESSAGB
J I December 1996 NUMBER OF P GES: 2
Bill Meyers
Dr. Robert G. Lewi11 1
USBPA (MP-44) di
Research Tr1angl! Park, N . 27711-2055
I
I
Response to · Hirschhorn' e ~ateat Comments
' Fax No,: 71 S '.3605
Telephone:
M~SSAGE: i
F' "'
~OCJ/00i1
i . I will not dignify Dr. Hirschhorn~y responding to his l~test attack n the quality of the EPA
mo11itoring stlldy at_ the Warren Collnty lan 11 and n:iy scientific int~rpretations. It is obvious that nothing will persuade him to abandon the faulty re soning that he has committed hims If to in order to convince
1.he citi:ten.s of Warren County that they ar~ at risk. ·
; J will, howover, pl'ovide you with m~ biographical sketch i~ support of y credentials and suggest
that you a&k him to do the' same. I can s~nd you my full C.V. (iS pp), jf yo wish. I believe that I am
widely recogniied throughout the world as an expert in environm~ntal monito ng, especially for organ,c
coipounds in a.it. I wrote the defining chaoter on SBnlpling for organic cheJllJC ls in air for the American
Ch tnical Society's Professional Reference :Book, Princtplt.s of Environmenta · Sampling (L. Keith, ed .),
an 101 currently writing a book on the s~bjoot for the ACS. I have also aut ored or coauthored eight
A TM standards and two ISO standards on monitoring methods, including one on the methodology
(u~dated) used in Warren County (ASTM ~ 4861). l4urthennore; Battelle Me orial Institute, which did
the'.fleld v:ork e.t the le.ndfillforus, i& one oftbe leadins environmental researc institutions in the U.S . I
would sug9est that you get the opinions of two of the world's leading PCB 11· monitoring experts as to
the. validity of our conclusions and Dr. Hirsc~om'a argumeota. Th~y are both v ry fanuliar with my work.
Drl Terry F. Bidleman : Tel. 416-73~•5730
A}\QP i Pax. 416 .. 739-S708
Enyironment Canada l B-mail: tbid,oman@dow. n.doe.ca
490S Dufferin Street . I
Do~nsville, Ont., Canada M3H 5T4
and ; -I
Pr¢f. Ronald A, Hites ( curtent editor of E$&1)
School of Public Health and Bnvironmonuil Aff'ain
Indiana University i
10th. & Fee Lane
Bloominaton, IN 4 740S
. I
!
Toi. 812·8Sf-0193
Pax. 812-BS.5-1076
B-mail: hit~[e-mail]. u
. , ...
FROM 9197153605 SOLID WASTE DIU 12.12.1996 09: 13
~ ._. .
•· I
i
'
Blographl~al Sketch of Robert G, Lewis
I i 't••.J ,\:,,,.,, ... ,,.1,,• ........ ,.· ,, 1,. . -: .
I I . I .
R.OBEl(T 0. LEWIS is a Senior s{ientist in EPA's Natlonal E>tpo re Regearch Exposure
'Laboratpry, Research Triangle Park, North Carolina, He i1 :responsible or overseeing research
focused ; on new sampling and anal~ical methods for pesticides, PCB , dioxioR and related
semivol~tile organic chemicals and for ~heir application io total human exp sure assessment.
! : •
Dr, Le~ls received his Bachelor of Sc~ence in Chemistry froin the Unive ity of North Carolina,
Chapel ¥111, North Carolina in t 960 an~ his Ph.D. in Physical-Organic Ch istry in 1964 from the
Universi~ of Wisconsin, Madison, '1ore he wu a National Science Fo ndation Fellow and a
National: Institutes of Health Fellow. I :
I '
Followinh six years with industty, Dr. ~a joined the EPA in 19.71 and held e positions of Section
Chief rrofn 1971 to 1978 and Branch Chief from 1978 to 1993. He has done ubstantial re;earcb on
tnonitori~g and exposure assessment mJthods for organic che~icals in air a d other environmental
tnedia ,m~ in human and blological tissuei and fluid;. He establi~hed and hea ed for 12 years BP A's
~rst ambi~nt air methods development pr gram. He was a membtr ofEPA's st task force Oh PCBs
in 1972 ~d in 1983 wa~ appointed by he Oovemor of North Carolin!\ to the lntergovommental
Working, Group on PCB !DotoKification.! ; '· : .' i ;
Dr. Lew~s has authored :or co-authored \more than 200 journal; articles, boo a, book chapters, and
Other sci~ntific article& ~d reports on various matters of en~ironmental oncem. He bas been
4warded '1ie BP A Bronze medal for Comrbendable Service twice !lDd has recei ed four Scientific end
technoldgical Achievement Awards for\ouutandi~journal articles.
~r. Le. '\'is a member oftbe American 1' emical Society (since 19S8), Air a d Waste Managtme~t .
Associ~n, American Aseociation for A osol Research, Americln Society o Testins and Materials
(Fellow),! International Standards Ors ution, Phi Beta Kappa, Sigma ·, Alpha Chi Sigma
(Chemist~), Pbi Lambda Upsilon (Chem~· try) and Delta Phi Alpha (German) He has been listed in
American!Men and Women of Science sin 1966. He has stned on numerous committees and work
groups oo~cemed with environmental mo 'toring, exposure asseaiment, and t chemical profession.
}ie is cu~ently chairman of ASTM 22.05.02 on Oraa.nie Chemical; n Indoor Air, U. s.
ltepresen ative to ISO 01:1 Indoor Air, Research Area Mana~$' for Enviro mental Meuurament
Methods r! the EPA Residential Pesticid~s Exposure ReaearchPrograrn and n advisor. to the EPA
National ttuma.n Exposure Asaessment $tudy (Nf{SXAS), NCIJBPAINIE S Agricultural Health
Study, the· Lower No Grande Valley Bnvir,onmental Study (NAFTA), the Great Lakes Air Deposition
Project and the Pesticide Spray Drift ru)c Force. · .
I '
PCB WORKING GROUP Fax:[phone]
Data: Wednesday, December 11 , 1996
To: Ms. Doris Fleetwood
PCB WORKING GROUP
Fax: [phone]
Voice:
Comments:
Dec 12 '96 12 :49
Thna: 1 :51 :01 PM
From: Dennis W . Retzlaff
Fax: [phone]
Voice: 919-257-1092
Doris, I will not be able to join the 3:00 P.M. Technical Committee
Conference Call. Please relay the following message to the Committee.
Mr. Bill Meyer indicated that his staff is responding to the concerns
expressed related to possible PCB em issions from the Warren County PCB
landfill. Plans for placing a carbon filter have been in the works since
concerns were raised to reduce fears of those who may be concerned.
Filter may be in place by this Friday. Dennis
Post-it" Fax Note 7671
F·. 01
1 Pages
Forwarded by:
Forwarded to:
Date forwarded:
From:
Organization:
To:
Date sent:
Subject:
Send reply to:
Copies to:
Priority:
ME TOO!!!
[e-mail]
[e-mail]
Wed, 11 Dec 96 11:58:50 + 1100
"Preston Howard" < [e-mail] >
DEM Water Quality
"Linda Rimer" < linda [e-mail] > ,
"ALAN KLIMEK" <[e-mail]>
Wed, 11 Dec 1996 12:51:52 EST
Re: env consultant reg
[e-mail]
[e-mail], [e-mail],
[e-mail], [e-mail] .state.n
normal
From: "ALAN KLIMEK" <[e-mail]>
Organization: EHNR/ AQ
To: "Linda Rimer" < linda [e-mail] >
Date: Tue, 10 Dec 1996 18:19:06 EST
Subject: env consultant reg
Cc: [e-mail], [e-mail],
[e-mail]. us
Priority normal
You sent out a cc of a letter from Bolich of Geo-Solutions on a
proposed registration for env consultants and asked for comments by
12/16. Could we discuss at a staff so I understand what is being
asked in this letter? I confess to a slight eng bias and have been
somewhat cool to the concept of registering env consultants.
Forwarded by:
Forwarded to:
Date forwarded:
Date sent:
To:
From:
Subject:
Bill:
[e-mail]
[e-mail]
Tue, 10 Dec 96 16:11:32 + 1100
Tue, 10 Dec 1996 16:12:28 -0500
[e-mail]
[e-mail] (Cook)
Bob Neal Contact
Per your inquiry today Bob Neal's home address and phone are as follows:
104 Brighton Close
Nashville, TN 37205
615-297-8230
I hope he can help out!
Regards,
JLC
Lindsay Cook, CIH, CSP
Manager, Facilities, Health, Safety & Environment
Chemical Industry Institute Of Toxicology
P. 0. Box 12137
RTP, NC 27709
[e-mail] Phone:[phone] Fax: [phone]
December 10, 1996 .............................................................................. by FAX (five pages)
To: Technical Committee
From: Joel Hirschhorn
Subject: Responses to EPA letter of 3 December, previously provided
.In examining the EPA letter to Bill Meyer I focused on the main pomts and I have
concluded tha.t l have no reason to abandon or change my original .findings and conclusions. I
have faxed a request to the author of the EPA letter for a copy of the original contractor (Battelle
Memorial Institute) report, which, if provided, may reveal other interesting information It is
important to emphasize that only two documents have surfaced regarding the original 1983
measurements by EPA, the published paper from 1985 and one page of conclusions fro.m what
EPA now says was a contractor report prepared for it. Only the latter would have the testing
details allowing the most complete analysis of what actually happened dwing the testing.
EPA has said that "our statements that PCB emissions from the landfill were negligible at
the time of the study were supported by the highest level of tecb.nical review." The problem is
thnl the paper itself, as I noted previously had a logical inconsistency between. two of its
statements, one saying the emissions were negligible and the other that the emissions were at low
levels. Clearly, PCB emissions were measured and reported in the paper. Any reviewer of the
paper, however, may have missed the importance of the two statements and, moreover, may have
interpreted the statement about ernission.s from tb.e Warren. County landfill being negligible as not
nec.essarily related to health effects. In fact, the paper presented no information about PCB levels
and health effects. The paper was about PCB emissions from different land disposal situations,
not potential health impacts.
EPA is now defending itself by saying that the actual measurements of PCBs "were likely
false-positive results." This is a .remarkable statement. It was o.ot made in the original paper, u.or
is th ere auy evidence to support this contention. Now, EPA claims that "It would be dear to auy
analytical chemist or anyone with environmental monitoring expertise that these were likely false-
positive results." Notice the qualifier "likely." If scientists have a very sound technical reason for
beliC'-'ing that e,q,eri.Jnental data are false-positive results (i.e., a finding of a chemical when none
is really present}, they either would not report the data in a publication or they would clearly
articulate why the data should be viewed as false positives. Any objective analysis of the EPA
published paper "'-ill &how that there is no suggestion or proof that the reported ambient air PCB
levels were fulse-positives. For EPA to now claim that jts data were likely false-positives is
disingenuous at best, and for it to attempt to create explanations now but not in the published
paper is not normal professional conduct.
A part of the current contention about false-positives is that if the data were "real" --and
1
HOcL::l HdL0 0l 966l -0 L-S
they certainly were real enough for the EPA persons to report and publish them.•· then the more
volatile Aroclor 1242 rather than the measured 1260 would have been measured. But there are
various possible explanations of why the less volatile and not the more volatile Aroclor could be
found in ambient air monitoring. These possible reasons include: variable types of PCB emissions
from the landfill at different times, making a small number of measurements in ambient air not
reflective of the cumulative types of emissions over time; a greater loss of the more volatile
Aroclol" prior to the time of the measurement, especially because of the many months that the
wastes were exposed to the atmosphere when they were first dumped on the roads and contjuuing
through their disposal in the open pit; different environmental interactions during the ak transport
of the vapors, leading to different variations of the PCBs reaching a given point of me~sUTement;
the greater water solubility of 1242 versus 1260, by a factor of about JOO, that jn th.every wet
materials inside the landfill could explain why considerable 1242 could be trapped in the water and
not released to the air (i.e., the difference in water solubility is nmch greater than the difference in
vapor pres~ure); more of the 1242 may have been biodegraded over the entire time the wastes
existed prior to the gas vaporization.
The letter from EPA notes that the more normal higher level of 1242 over 1260 was found
in the main. and upper leachate ven.t pipes. But of course it does not note that the relationship
between the two Aroclors was not tb.e normal t}pe in three other categories reported iu the
original published paper (lower leachate port and two small vents). Most interestingly, for
example, one of the small vents (E) had Aroclor 1260 levels twice that of 1242, and at levels that
the detection issue is irrelevant. Clearly these are emissions measured in the small vent where a
bubble had fon:ned in the top plastic liner. If more 1260 than 1242 clearly came from tbjs source
oflandfilJ gas, then why does EPA make such an issue of finding more 1260 than 1242 at any
offsite location? EPA also makes the mistake of assuming that a non-detect finding is equal to
zero concentration, when in fact that is a scienilii.cally incorrect and improper assumption to
m,1ke. At all the other ambient testing locations where no positive levels of PCBs were reported,
the values may inf.act be something less thBn the detection limit.
The letter from EPA also attempts to make a point that the ambient air levels found "did
not appear conelate (sic) with proximity to the vents." In actual fact, there is problem in EPA's
interpretation because immediately after the statement cited, the paper also said "The two
maxnnum )e'/els were found 98 m downwind of the main vent. 11 In other words, of the four
positn·e findings of PCBs in ambient air reported as "11, 12, 50, and 71 ng/m3'', according to EPA
the readings of 50 and 71 (now claimed as not real, but ana1yud nevertheless by EPA) were not
at the house, which was, according to the paper, some 1000 m away. According to the paper, the
highest level measured was at the fenceline and logically so was the second highest level found .
Tiiat leaves two very similar but lower PCB levels foun.d at two 0th.er locations, which according
to Table Il of the paper were at the nearby house and beside the mam vent. The only
measurement, therefore, that is somewhat .irregular is the lower level foUlld beside the main vent,
because it seems much too low (i.e., if there are a sufficiently large number of measurements one
expects to find the highest concentrations at the source, with steadily lower concentrations at
increasing distances away from the source). But the anomaly is the very low reading next to tbe
2
~Oc!.:I HdL0 : 0 l 966 l -0 l -S
main vent, especially because much higher levels were measured inside the main vent and EPA
said that there was a positive gas flow \\-ith PCBs being emitted from the main vent. However,
sucb. low readin.gs wbere higher levels are expected can be explained by, for example, variable
emission rates, variable wind conditions, and possibly different times of measurements at different
locations.
Indeed, EPA has a big problem trying to explain why the high levels found inside the main
vent did not translate into much higher levels "beside main vent" which presumably was,
according to the figure sh.owing tb.e sampling locations, only I m away. The problem of cotuse is
that variable \.\'llld conditions will lead to vastly different levels measured at any given location,
unless many more measuremeots are taken over time. The original paper noted that wind speed
varied rrom 0.04 to 6.6 mis, and that the ambient air monitoring was not done on the same days
that testing took place in the vents. The latter fact suggests that highly variable emissions from
the land.fill were occurring, explaining why a very low reading might obtained near the main vent.
Al~o. the paper indicates that the ambient air monitoring occurred on different days, explaining
\.Vhy PCB levels would change significantly for dilfcrent locations.
The original EPA paper said that ambient air data were given in its Table 11 and that "only
fonr of the 39 ambient air samples analyzed contained detectable quantities of PCB11 and that
"three ~amples were positive for Aroclor 1260 only (at 11, 12, 50, and 70 ng/m3)." The problem
is that in Table 11 there are three footnotes for each of the three data sho~ing po&1tive levels of
PCBs detected., as follows:
beside main vent: 11• One of six measurements above detection limit."
fence line, downwind: uh Two of 13 measurements above detection limit (0.05 and 0.07
ug/m3).''
neaJby house: IIQ One of six measurements above detection limit."
TI1ere is a discrepancy between these footnotes and the body of the paper's text. Th.e total
number of measurement seems like 25, not 39. Another problem is that the tabulated data
indicate that the detection limit was IO ng/m3, but the second footnote indicates that the detection
limit was from 50 to 70 ng/m3, and both th.e original paper and the recent EPA letter said that the
detect.ion fa.nits were from 10 to 20 ng/m3• while the page of conclusions from EPA's contractor
report said the detection limits were 6 to 10 ng/m1• Only close examination of the original
laboratory data sheets that might be in the Battelle contractor report could resolve these
discrepancies.
EPA's letter claims that "the vent pipes were not the source of the PCBs detected in air,
even if the measured air values were real. 11 First, EPA .is acknowledging that the data may
actually be accurate positives and, second, EPA is speculating that some other source of PCBs
existed around the landfill. In fact, in its original published paper, EPA said that "air levels were
at or near background" at the Warren County landfill, which scientifically is a very different
argument than its present one based on claiming that the findings were false-positives. In other
3
Hd90'01 9661-01-S
words, originally EPA disregarded the levels of PCBs it measured in ambient air by arguing they
were "at or near background" and now by arguing that they were not really positive findings. But
in fact, even the EPA argument that the measured (real) PCB levels were only backgrowid does
not stctnd up wider close scrutiny.
EPA cites the general data for the U.S. about highly variable ambient air leveJs of PCBs,
with the maximum being 10 ng/m', which is actually less than all four positive findings reported in
the paper (11, 12, 50 and 71 ng/m3). More importantly, the range given in EPA's letter (and
given originally in EPA's contractor report, but not the published paper) does not distinguish the
types of locations at which PCBs have been measured. In fact, the higher levels of ambient PCB
levels correspond to more industrial and urban areas, and areas near any type of incineration of
waste, not the rusal area at whic.h the Wmen Cowity landfill is located. Logically, the low end of
tht range repoited, namely 5 ng/m3, might be appropriate for such a rural location, but the correct
scientific methcd in such an investigation is actually to take measurements at a substantial distance
from the likely pojnt source (i.e., the landfill) but within. the local geographic area. Then, this
experimental background level appropriate for the study should be used. But ·assuming th.at the
low end of the national range may be appropriate, the four positive findings are significantly
higher, undermining EPA' s argument.
The l.etter from EPA claims that the "The Warren County site was brand new and should
have been emitting at a ma~imum rate." This is sheer nonsense and perhaps more than any other
EPA statement demonstrates that EPA persons are trying very hard to cover up the truth. Why?
There a.re various sound, scientific reasons why landfill emission rates were not necessarily the
highest at the time of the EPA measurements, including: the temperature at the time was low (-1
to + l 411C) relative to summer periods when high emission rates would occur; the complex mixture
of materials actually placed in the landfill and the disposal process necessarily traps PCB vapors
that take time to find transport pathways; the btge amount of water present in the materials
buried in the landfill from heavy rainfalls would slowly sink and accumulate to the bottom of the
landfill and the internal drying process (for some of the buried waste) would more easily allow
PCB vapors to escape over time.
Lastly, EPA is arguing that its computer modeling (the details of which were not given in
the published paper. but way be iu the contuctor report) sh.owed that calculated (not measured)
levels of PCDs at some distance away from the landfill would be "far below the detection
capability of the sampler employed." But such dispersion modeling is based on many technical
:lssump'f.ions about the source of emissions and many climatic conditions that cannot be assessed
at this point. Implicitly, in its original published paper, EPA was arguing that the theoretical
modcliog sh.owed data below the PCB levels actually 111eas11,ed at distances away from the
faudfill. But EPA did not actually say in its published paper that the modeled data were below
background levels. More importantly, the core basis for EPA's modeling were only three
measurements r:>fthe gas flow from the main vent md some un~tated data for what was measured
in the main vent, lea.ding to what EPA described as an average gaseous PCB emission rate. The
ptoblcm., of course, is that there were only a small number of measurements dwing a winter
4
Hd60 '0l 966 l-0l -S
s ·d
period, reducing the reliability of the specific figure used by EPA in its modeling and undermining
any objective confidence in the results of the modeling. In tntly objective and fair work, field
measmements of air levels of a toxic substance ne used to evaluate whether the modeling is
accurate and reliable. But in. this case, there was not even an explicit analysis by EPA ofits own
positive measurements and its modeling results.
-~_g_nclusionJht important deficiency of the EPA work was that they never
decided that there was sufficient reason to perform much more complete testing for PCB
~IJl.issions from the \:Yarren Count~ landfill, EPA. of course, had a conflict of interest,
~'!SC it ,had approved the Warren County PCB landfill and the objective of the t 9~
study seems to have been to prove that government sanctioned PCB landfills were "safe"
r~lfilive to unco..ru.rolled to,;ic wast, sites with PCBs that required cleanup, Sinc;e the
1V..a..r:r_tn_Cmmiy PCQ landfill was the cleanup [or the ori2io1l PCB road dnmpinr situation
.thAt:F.PA 11u,rnred and funded, it clearly was not in EPA's interest to re,port s.;:nificant
1nd potentialll'.. dangerous levels of PCB air emissions from its controlled landfdl, Also.
EPA 's -PJ1.h•uh~d paper, submitted for publication in December 1984, about two years after
the laQdfill...w~ostructed, described the Warren County landfill has having the
p_c.rforatcd pipe system that we now know was not installed, EPA 's description of the
lan.dfili _as state-of-the-art was eonsistent with what EPA wanted to portray, namely a
~kQlled landfill that.h)'. comparison would show how bad the uncontrolled Indi.11na PCJI
sites wer.~.L..Ibd_EPA's description was ina~~w:ate and, 11~rbaps, !ntcutiQnall.y so it as the
mte_rw..w daim~, EPA itsf!f..approved a change in the design of the Warren County landr.Jl
that would have had to occur in 198l and that allowed the state to omit usini the
perforated leachate collection pipe system at the bottom of the landfill,
~d0l '01 9 66 L-O l-S
• State of North Carolina AVA £C l, ~/:.
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Michael Moser, M.D., M.P.H. DEHNR '
December 10, 1996
MEMORANDUM
TO: Bill Meyer, Director
THROUGH:
Division of Waste Management ~
Stanley Music, M.D., DTPH (LOND.), Chief
Occupational and Environmental Epidemiology Sectio
William J. Pate, Head
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
• JI --ti FROM: Luanne K. Williams, Pharm.D., Toxicologistt7\ f.. ().;'
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Review of Dioxin Cleanup Levels for the Warren County PCB Landfill
Proposed by Hirschhorn & Associates
I have reviewed the document prepared by Dr. Joel Hirschhorn titled "Cleanup Levels
for Dioxin Contaminated Soils." My recommendations with regard to the derivation of
cleanup levels for dioxins and furans and sampling are as follows:
1. Dr. Hirschhorn has proposed 2 to 4 parts per trillion (ppt) as the residential cleanup level
based upon a target excess cancer risk of 1 x 10-s (one in a million). The recommended
target cleanup level for dioxin will be dependent upon the current or future use of the
site, use of the groundwater, and background concentrations. Guidance for determining
the target cleanup level for 2,3,7,8-TCDD (dioxin) is provided as follows:
RESIDENTIAL SOIL CLEANUP LEVEL
If the site is , or may be in the future, a residential area or in an area where activities of
sensitive human receptor populations occur (e .g., schools, day-care facilities, and
retirement centers), then the soil target concentration should be based on residential
exposure. The recommended soil cleanup level for 2,3,7,8-TCDD in a residential area is
4 ppt (USEPA Region Ill Risk-Based Concentration Table, April 1996). The oral slope
factor used to calculate 4 ppt was obtained from the USEPA 1995 Health Effects
Assessment Summary Tables. The oral slope factor was determined by USEPA based
P.O. Box 27687, Raleigh,
North Carolina 27611-7687 ,,., ..• An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
Bill Meyer
December 10, 1996
Page Two
upon the 1984, 1985, and 1989 review of the study Kociba RJ, Keyes DG, Bower JW et
al., 1978. "Results of a Two-year Chronic Toxicity and Oncogenicity Study of 2,3,7,8-
Tetrachlorodibenzo-p-dioxin in Rats." Toxicol Appl Pharmacol. 46(2):279-303.
In 1984, the Centers for Disease Control (CDC) staff released a paper that contained
recommendations of 1 ppb or 1000 ppt as a level that would not likely result in adverse
effects in a residential area and according to CDC would correspond to an excess
cancer risk of 1x10-6. Using the oral slope factor in the USEPA 1995 HEAST, a
residential soil dioxin concentration of 1000 ppt would correspond to a 2.5 x 10-4 excess
cancer risk. It is recommended to use 4 ppt instead of 1000 ppt as a cleanup level in a
residential area.
INDUSTRIAL/COMMERCIAL SOIL CLEANUP LEVEL
If the site is, or may be in the future, an area where adult worker exposure occurs, then
the soil cleanup level should be based on industrial/commercial exposure. The
recommended soil cleanup level for 2,3,7,8-TCDD in an industrial/commercial area is 40
ppt (USEPA Region Ill Risk-Based Concentration Table , April 1996).
SOIL-TO-GROUNDWATER CLEANUP LEVEL
If the groundwater in this area is being used for drinking, then transport modeling may
be necessary to determine the maximum allowable dioxin soil concentration that would
not result in exceedance of the dioxin groundwater quality standard. If groundwater is
being used for drinking, then the soil cleanup level would be the lowest of the soil-to-
groundwater cleanup level; or the residential or industrial/commercial cleanup level
(whichever is applicable).
SOIL BACKGROUND CONCENTRATIONS
If the TCDD soil cleanup level is determined to be less than the soil background
concentrations, then it is recommended to use the soil background concentration as the
TCDD soil cleanup level. I have enclosed guidance for collecting background samples
which was obtained from USEPA 1989 Risk Assessment Guidance for Superfund
Volume I Human Health Evaluation Manual {Part A) (EPA/540/1-89/002).
2. Dr. Hirschhorn & Associates are proposing higher toxicity equivalents factors (TEFs)
than those recommended by EPA for chlorinated dioxin and furan congeners. This
would result in lower cleanup levels. Higher TEFs are proposed to be used because of
the likelihood of synergistic effects from exposure to dioxins and polychlorinated
biphenyls (PCBs). I caution the use of higher TEFs because of the uncertainty in
synergism between dioxins/furans and PCBs. Also, I caution the use of higher TEFs
because conservative assumptions have already been considered in deriving the TCDD
carcinogenic slope factor and in deriving the exposure parameter values used to
Bill Meyer
December 10, 1996
Page Three
generate the TCDD cleanup level. The TEFs recommended by EPA and other state
should be used to determine cleanup levels for dioxin and furan congeners. A list of the
TEFs recommended by EPA is provided in Table 1 (USEPA 1995 Supplemental
Guidance to RAGS: Region 4 Bulletins Human Health Risk Assessment).
The soil cleanup level for each dioxin and furan congener found at the site can be
calculated by dividing the cleanup level for 2,3,7 ,8-TCDD by the appropriate TEF. If Dr.
Hirschhorn has scientific evidence to support different TEFs, then I would like the
opportunity to review it.
Table 1. Toxicity Equivalents Factors (TEF) for CDDs and CDFs*
Dioxin Compound TEF Furan Compound TEF
2,3,7,8-TCDD 1 2,3 ,7,8-TCDF 0.1
2,3,7,8-PeCDD 0.5 1,2,3 ,7,8-PeCDF 0.05**
2,3,7,8-HxCDD 0.1 2,3,4,7,8-PeCDF 0.5**
2,3,7,8-HpCDD 0.01 2,3,7,8-HxCDF 0.1
OCDD 0.001 2,3,7,8-HpCDF 0.01
Other CDDs 0 OCDF 0.001
Other CDFs 0
* Source: EPA, 1995. Supplemental Guidance to RAGS: Region 4 Bulletins Human Health Risk Assessment.
** Correction noted per telephone conversation with EPA Region 4 on November 27, 1996.
3. I have discussed the issues pertaining to this site with Dr. Renate Kimbrough with the
Institute for Evaluating Health Risks in Washington, D.C. She has expressed an interest
in reviewing the sampling protocol. She can be reached by phone at 202-289-8721 or
fax [phone]. Her address is as follows: Institute for Evaluating Health Risks , Suite
402, 1629 K Street N.W., Washington, D.C. 20006.
Please feel free to call me at any time. I can be reached at 715-6429. Thank you for
the opportunity to review the report.
LKW:lp
Enclosures
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1.
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1·:
' ;
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OEPA --
United States ·. ' .·
Environmental Protection·
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
EPA154zyt-89/002
December 1989 .. , ,,-w;
Superfund PB9 0..:£5·5"'5
Risk A-sse·ssment ·':1}x1
Guidal1Ce fbf'-SuperfunClt"
Volume I :t~~
Human Health ·
Evaluation _ Manual
{P~-rt :A)
REPRODUCED BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL TECHNICAL
INFORMATION SERVICE
SPRINGFIELD, VA 22161
E
'·f;:~f.\
If available, LSI (or ESI) data are especially useful
because they represent fairly extensive site studies.
,!3ased on a r~ew--of the-~ting _data, ~h.~
~S~..9.l ~hQ11ld formulate a conceptual model
of the site that identifies all pcnerii1af"or suspected
s_ources of contamination, types and con~~tfatioris
of contaminants detected _at _the_.s.ite, potentially
contaminated med_ia, and potential ·exposure
paihways·,-·~ci~ding receptors (~ee Exhfbit 4~1):
As discilssed previously, identification of potential
exposure pathways, especially the exposure points,
is a key element in the determination of data
needs for the risk assessment. Details concerning
development of a conceptual model for a site are
provided in the DQO guidance (EPA 1987a,b) and
the RI/FS guidance (EPA 1988a ).
In most cases, site information available at
the start of the RI/FS is insufficient to fully
characterize . the site and the potential exposure
pathways. The conceptual model developed at this
stage should be adequate to determine the
remaining data needs. The remainder of this
chapter addresses risk assessment data needs in
detail.
4.3 ADDRESSING MODELING
PARAMETER NEEDS
As discussed in detail in Chapter 6,
contaminant release, transpon, and fate models
are often needed to supplement monitoring data
when estimating exposure concentrations.
Therefore, a preliminary site modeling strategy
should be developed during RI/FS scoping to
allow model input data requirements to be
incorporated into the data collection requirements.
This preliminary identification of models and
other related data requirements will ensure that
data for model calibration and validation are
collected along with other physical and chemical
data at the site. Exhibit 4-2 lists (by medium)
several site-specific parameters often needed to
incorporate fate and transport models in risk
assessments.
Although default values for some modeling
parameters are available, it is preferable to obtain
site-specific values for as many input parameters
as is feasible. If the model is not sensitive to a
Page 4-5
particular parameter for which a default value is
available, then a default value may be used.
Similarly, default values may be used if obtaining
the site-specific model parameter would be too
time consuming or expensive. For example,
certain airborne dust emission models use a
default value for the average wind speed at the
site; this is done because representative
measurements of wind speed at the site would
involve significant amounts of time (i.e., samples
would have to be collected over a large part of
the year).
Some model parameters are needed only if
the sampling conducted at a site is sufficient to
support complex models. Such model parameters
may not be necessary if only simple fate and
transport models are used in the risk assessment.
4.4 DEFINING BACKGROUND
SAMPLING NEEDS
Background sampling is conducted to
distinguish site-related contamination from
naturally occurring or other non-site-related levels
of chemicals. The following subsections define the
types of background contamination and provide
guidance on the appropriate location and number
of background samples.
4.4.1 TYPFS OF BACKGROUND
There are two different types of background
levels of chemicals:
(1) naturally occurring levels, which are
ambient concentrations of chemicals
present in the environment that have not
been influenced by humans ( e.g.,
aluminum, manganese); and
(2) anthropogenic levels, which are
ooncentrations of chemicals that are
present in the environment due to
human-made, non-site sources ( e.g.,
industry, automobiles).
Background can range from localized to
ubiquitous. For example, pesticides -most of
which are not naturally occurring (anthropogenic)
-may be · ubiquitous in certain areas ( e.g.,
-6
EXHIBIT 4-1
ELEMENTS OF A CONCEPTUAL EVALUATION MODEL
SOURCES
RECEPTORS
SOURCE: EPA 1987a
VARIABLES
• CONTAMINANTS
• CONCENTRATIONS
•TIME
• LOCATIONS
• MEDIA
• RATES OF MIGRATION
•TIME
• LOSS AND GAIN FUNCTIONS
• TYPES
• SENSITIVITIES
•TIME
• CONCENTRATIONS
• NUMBERS
HYPOTHESES TO
BE TESTED
• SOURCE EXISTS
• SOURCE CAN BE CONTAINED
• SOURCE CAN BE REMOVED
AND DISPOSED
• SOURCE CAN BE TREATED
• PATHWAY EXISTS
• PATHWAY CAN BE
INTERRUPTED
• PATHWAY CAN BE
ELIMINATED
• RECEPTOR IS NOT.
IMPACTED BY MIGRATION
OF CONTAMINANTS
• RECEPTOR CAN BE
RELOCATED
• INSTITUTIONAL CONTROLS
CAN BE APPLIED
• RECEPTOR CAN BE
PROTECTED
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Page 4-7
EXHIBIT 4-2
EXAMPLES OF MODELING PARAMETERS FOR WIIlCH
INFORMATION MAY NEED TO BE OBTAINED DURING
A SITE SAMPLING INVESTIGATION
Type of Modeling
Source Characteristics
Soil
Ground-water
Air
Surface Water
Sediment
Biota
Modeling Parameters0
Geometry, physical/chemical conditions, emission rate, emission
strength, geography
Particle size, dry weight, pH, redox potential, mineral class, organic
carbon and clay content, bulk density, soil porosity
Head measurements, hydraulic conductivity (pump and slug test
results), saturated thickness of aquifer, hydraulic gradient, pH,
redox potential, soil-water partitioning
Prevailing wind direction, wind speeds, stability class, topography,
depth of waste, contaminant concentration in soil and soil gas,
fraction organic content of soils, silt content of soils, percent
vegetation, bulk density of soil, soil porosity
Hardness, pH, redox potential, dissolved oxygen, salinity,
temperature, conductivity, total suspended solids, flow rates
and depths for rivers/streams, estuary and embayment
parameters such as tidal cycle, saltwater incursion extent,
depth and area, lake parameters such as area, volume, depth,
depth to therrnocline
Particle size distribution, organic content, pH, benthic oxygen
conditions, water content
Dry weight, whole body, specific organ, and/or edible portion
chemical concentrations, percent moisture, lipid content,
size/age, life history stage
0 These parameters are not necessarily limited to the type of modeling with which they are
associated in this exhibit. For example, many of the parameters listed for surface water are also
appropriate for sediments.
Page 4-8
agricultural areas); salt runoff from roads during
periods of snow may contribute high ubiquitous
levels of sodium. Polycyclic aromatic
hydrocarbons (P AHs) and lead are other examples
of anthropogenic, ubiquitous chemicals, although
these chemicals also may be present at naturally
occurring levels in the environment due to natural
sources (e.g., forest fires may be a source of
P AHs, and lead is a natural component of soils in
some areas).
4.4.2 BACKGROUND SAMPLING
WCATIONS
Background samples are collected at or near
the haz.ardous waste site in areas not influenced
by site contamination. They are collected from
each medium of concern in these offsite areas.
That is, the locations of background samples must
be areas that could not have received
contamination from the site, but that do have the
same basic characteristics as the medium of
concern at the site.
Identifying background location requires
knowing which direction is upgradient/upwind/
upstream. In general, the direction of water flow
tends to be relatively constant, whereas the
direction of air flow is constantly changing.
Therefore, the determination ~f background
locations for air monitoring requires constant and
concurrent monitoring of factors such as wind
direction.
-4.4.3 BACKGROUND SAMPLE SIZE
In appropriate circumstances, statistics may
be used to evaluate background sample data.
Because the number of background samples
collected is important for statistical hypothesis
testing, at some sites a statistician should be
consulted when determining background sample
size. At all sites, the RPM should decide the
level of statistical analysis applicable to a
panicular situation.
Often, rigorous statistical analyses are
unnecessary because site-and non-site-related
contamination clearly differ. For most sites, the
issue will not be whether a difference in chemical
concentrations can be demonstrated between
contaminated and background areas, but rather
that of establishing a reliable representation of the
extent (in three dimensions) of a contaminated
area. However, statistical analyses are required
at some sites, making a basic understanding of
statistics necessary. The following discussion
outlines some basic statistical concepts in the
context of background data evaluation for risk
assessment. (A general statistics textbook should
be reviewed for additional detail. Also, the box
below lists EPA guidance that might be useful.)
. :• )STATISTICAL:METHODS
;,::i;;,f.;~v:ttt:.a~t;]ij '/:~;1;~: 19~" ... :J,\
?;!LiJW{can'at ,E11t&gency ·I>ecllirano"n Atiz \
., Habitability Study (EPA 1988d) · ...
Soils Sa~;lingQuali~ Assurance Guide (EPA ;\
J989b)\ :·· ·· . . .
A statistical test of a hypothesis is a rule
used for deciding whether or not a statement (i.e.,
the null hypothesis) should be rejected in favor of
a specified alternative statement (i.e., the
alternative hypothesis). In the context of
background contamination at hazardous waste
sites, the null hypothesis can be expressed as
"there is no difference between contaminant
concentrations in background areas and onsite,"
and the alternative hypothesis can be expressed as
"concentrations are higher onsite." This expression
of the alternative hypothesis implies a one-tailed
test of significance.
The number of background samples collected
at a site should be sufficient to accept or reject
the null hypothesis with a specified likelihood of
error. In statistical hypothesis testing there are
two types of error. The null hypothesis may be
rejected when it is true (i.e., a Type I error), or
not rejected when it is false (i.e., a Type II error).
An example of a Type I error at a hazardous
waste site would be to conclude that contaminant
concentrations in onsite soil are higher than
background soil concentrations when in fact they
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are not. The corresponding Type II error would
be to conclude 'that onsite contaminant
concentrations are not higher than background
concentrations when in fact they are. A Type I
error could result in unnecessary remediation,
while a Type II error could result in a failure to
clean up a site when such an action is necessary.
In customary notations, a (alpha) denotes the
probability that a Type I error will occur, and f3
(beta) denotes the probability that a Type II error
will occur. Most statistical comparisons refer to
a, also known as the level of significance of the
test. If a = 0.05, there is a 5 percent (i.e., 1 in
20) chance that we will conclude that
concentrations of contaminants are higher than
background when they actually are not.
Equally critical considerations in determining
the number of background samples are /J and a
concept called· "power." The power of a statistical
test has the value 1 -/J and is defined as the
likelihood that the test procedure detects a false
null hypothesis. Power functions for commonly
used statistical tests can be found in most general
statistical textbooks. Power curves are a function
of a (which normally is fixed at 0.05), sample size
(i.e., the number of background and/or onsite
samples), and the amount of variability in the
data. Thus, if a 15 percent likelihood of failing
to detect a false null hypothesis is desired (i.e., /J
= 0.15), enough background samples must be
collected to ensure that the power of the test is
at least 0.85.
A small number of background samples
increases the likelihood of a Type II error. If an
insufficient number of background samples is
collected, fairly large differences between site and
background concentrations may not be statistically
significant, even though concentrations in the
many site samples are higher than the few
background samples. To guard against this
situation, the statistical power associated with the
comparison of background samples with site
samples should be evaluated.
In general, when trying to detect small
differences as statistically significant, the number
of background samples should be similar to the
number of onsite samples that will be used for the
comparison(s) (e.g., the number of samples taken
from one well). (Note that this does not mean
Page 4-9
that the background sample size must equal the
total number of onsite samples.) Due to the
inherent variability of air concentrations (see
Section 4.6), background sample size for air needs
to be relatively large.
4.4.4 COMPARING BACKGROUND
SAMPLES TO SITE-RELATED
CONTAMINATION
The medium sampled influences the kind of
statistical comparisons that can be made with
background data. For example, air monitoring
stations and ground-water wells are normally
positioned based on onsite factors and gradient
considerations. Because of this purposive
placement (see Section 4.6.1), several wells or
monitors cannot be assumed to be a random
sample from a single population and hence cannot
be evaluated collectively (i.e., the sampling results
cannot be combined). Therefore, the information
from each well or air monitor should be compared
individually with background.
Because there typically are many site-related,
media-specific sampling location data to compare
with background, there usually is a "multiple
comparison problem• that must be addressed. In
general, the probability of experiencing a Type I
error in the entire set of sta.tistical tests increases
with the number of comparisons being made. If
a = 0.05, there is a 1 in 20 chance of a Type I
error in any single test. If 20 comparisons are
being made, it therefore is likely that at least one
Type I error will occur among all 20 tests.
Statistical Analysis of Ground-water Monitoring
Data at RCRA Facilities (EPA 1989c) is useful
for designing sampling plans for comparing
information from many fixed locations with
background.
It may be useful at times to look at
comparisons other than onsite versus background.
For example, upgradient wells can be compared
with downgradient wells. Also, there may be
several areas · within the site that should be
compared for differences in site-related
contaminant concentration. These areas of
concern should be established before sampling
takes place. If a more complicated comparison
scheme is planned, a statistician should be
consulted frequently to help distribute the
sampling effort and design the analysis.
Page 4-10
A statistically significant difference between
background samples and site-related contamination
should not, by itself, trigger a cleanup action. The
remainder of this manual still must be applied so
that the toxicological --rather than simply the
statistical --significance of the contamination can
be ascertained.
4.5 PRELIMINARY IDENTIFI-
CATION OF POTENTIAL
HUMAN EXPOSURE
A preliminary identification of potential
human exposure provides much needed
information for the SAP. _I!lis a~\'.iJ:y_.involves
the identification of 11) .. media---Qf concern,_ (2)
areas of conce~_(i.e.-;eneral locations of the
media.to be-sample<!), __ (3) types o_f ~hepticals
expected at ·the site, and ( 4) potential routes of
contaminant transport through _the_enyironment
(e.g., inter-media transfer, food-chainf -lliis
section provides general information on the
preliminary identification of potential human
exposure pathways, as well as specific information
on the various media. (Also, see Chapter 6 for
a detailed discussion of exposure assessmenL)
4.5.1 GENERAL INFORMATION
Prior to discussing various specific exposure
media, general information on the following is
provided: media, types of chemicals, areas of
concern, and routes of contaminant transport is
addressed.
Media of concern (including biota). For risk
assessment purposes, media of concern at a site
are:
• any currently contaminated media to
which individuals may be exposed or
through which chemicals may be
transported to potential receptors: and
• any currently uncontaminated media that
may become contaminated in the future
due to contaminant transport.
Several medium-specific factors in sampling may
influence the risk assessmenL For example,
limitations in sampling the medium may limit the
detailed evaluation of exposure pathways described
in Chapter 6. To illustrate this, if soil samples
are not collected at the surface of a site, then it
may not be possible to accurately evaluate
potential exposures involving direct contact with
soils or exposures involving the release of
contaminants from soils via wind erosion (with
subsequent inhalation of airborne contaminants by
exposed individuals). Therefore, based on the
conceptual model of the site discussed previously,
the risk assessor should make sure that
appropriate samples are collected from each
medium of concern.
Areas of concern. Areas of concern refer to
the general sampling locations at or near the site.
For large sites, areas of concern may be treated
in the RI/FS as "operable units," and may include
several media. Areas of concern also can be
thought of as the locations of potentially exposed
populations (e.g., nearest residents) or biota (e.g.,
wildlife feeding areas).
Areas of concern should be identified based
on site-specific characteristics. These areas are
chosen purposively by the investigators during the
initial scoping meeting. Areas of concern should
include areas of the site that:
(1) have different chemical types;
(2) have different anticipated concentrations
or hot spots;
(3) are a release source of concern;
(4) differ from each other in terms of the
anticipated spatial or tempc:,ral variability
of contamination;
(5) must be sampled using different
equipment; and/or
(6) are more or less costly to sample.
In some instances, the risk assessor may want
to estimate concentrations that are representative
of the site as a whole, in addition to each area of
concern. In these cases, two conditions generally
should be met in defining areas of concern: (1)
the boundaries of the areas of concern should not
overlap and (2) all of the areas of concern
• • l)
• • •
F'C B l.dCIRk I t·.Jl3 (3R:CIUF· Fax:[phone] Dec 10 '96 10 :39 F'.01
JOINT WARREN COUNTY/STATE PCB LANDFILL WORKING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Office [phone] -Fax [phone]
Fax Cover Sheet
TO:
FROM:
DATE:
RE:
Laura Butler
Tommy Cline
Henry Lancaster
v-William Meyer
Ron Nixon
Monica Porter
Dennis Retzlaff
Doris Fl.eetwood
December 10, 1996
Next meeting date.
733-5317
733-1431
715-3060
715-3605
419-8315
733-2120
257-2897
Number of Pages, including cover sheet: 1
Dear Working Group members:
I have been asked to inform you that after the polling of members the result is that the next Working
Group meeting will be held December 17, 1996 at 4:00 p.m .. I know that this may be inconvenient for
some of you, but none of the co-chairs were available for the :r:neeting on December 16.
ec -YZ:I ttf i>~~
~t /ftY
RJ_
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Michael Moser, M.D., M.P.H.
December 9, 1996
MEMORANDUM
TO: Bill Meyer, Director
Division of Waste Management
THROUGH:
.. --n~~-
Stanley Music, M.D., DTPH (Lond.), Chief (_ _,/
FROM:
Occupational and Environmental Epidemiology Section
Luanne K. Williams, Pharm.D., Toxicologist ;;(J(lv-
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
At your request, I have provided a risk assessment following my review of the air
sampling results of the Warren County PCB Landfill reported in the 1983 USEPA study
"Measurement of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls from Hazardous
Waste Landfills" and the December 3 letter from Dr. Robert G. Lewis, a co-author of the study.
RISK ASSESSMENT
1. The ambient air concentrations reported of 11, 12, 50, and 71 ng/m3 most likely exceed
the actual PCB concentrations present at the site for the following reasons:
(a) the method used is not specific for PCBs but detects all chlorinated compounds
(b) ambient air concentrations were reported to be higher at 98 meters downwind
(50 and 71 ng/m3) than beside the main vent (11 ng/m3) and
(c) aroclor 1260 was the only analyte identified in ambient air even though aroclor
1242 was reported at much higher concentrations in the main vent.
2. It is my opinion that the ambient air concentrations reported are worst-case estimate of
the concentrations that may be present at the site. Therefore, a worst-case risk
estimate is provided based upon the concentrations reported at the following locations:
Locations
beside main vent
nearby house
fence line, downwind
P.O . Box 27687 , Raleigh,
North Carolina 27611-7687
(cone. detected)
11 ng/m3
12 ng/m3
50 and 71 ng/m3
,,., ..•
Excess Cancer Risk
1x10-6
1x10-s
5 to 7x10-6
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
..
Bill Meyer
December 9, 1996
Page Two
If a million people were exposed to the concentrations reported at these three locations
over a lifetime, then one to seven of those individuals could possibly develop cancer as
a result of their exposure to the PCB concentrations reported. This cancer risk is a
worst-case estimate and is in addition to the existing cancer risk rate of 333,333 out of a
million expected cancer cases in a lifetime.
The risk associated with exposure to the concentrations reported at the fenceline does
exceed the acceptable target excess cancer risk of 1x10-5_ However, the actual risk at
the site is most likely lower than 7x10-5 because the PCB concentrations present at the
site are most likely lower than reported. The PCB air concentration associated with a
1x10-5 excess cancer risk (target risk) is 10 ng/m3. The fenceline exceeds this level by
7.
3. The concentrations reported near the PCB landfill exceed typical background
concentrations in rural and urban areas. I have attached background concentrations
reported in the February 20, 1996 ATSDR Tox profile for PCBs. The highest reported
background concentration was 20 ng/m3 in Chicago in 1989-1990.
RECOMMENDATIONS
Contrary to Dr. Lewis' statement in his letter, it is my opinion that it is uncertain as to
whether or not PCBs are present at the site. Because PCBs were detected using a method
that is not specific for PCBs and since the excess cancer risk estimated at the fenceline
exceeds the acceptable target excess cancer risk of 1 x 10-5 , it is recommended to collect
additional vent and ambient air samples and analyze for aroclor 1242 and aroclor 1260 using a
more specific method. A carbon filter may also be used as suggested by BFA Environmental
Consultants to minimize PCB emissions from the landfill.
Please call me if you have any questions at 715-6429.
LKW:lp
Attachments
cc: Dr. Stan Music
Mr. Bill Pate
Draft for Public Comment
"-·--_:-PCBs 242
5. POTENTIAL FOR HUMAN EXPOSURE
degrading organisms or, alternatively, by adding a genetically engineered strain that combines the
activities of mixed cultures (Unterman et al. 1989). Since PCB degradation is a co-metabolic
process, the ,;i.ddition of biphenyl or monochlorobiphenyl s as growth substrates to supply the
nutritional requirements and to induce the catabolic pathway is required to sustain the growth of the
degrader population for biodegradation of PCBs in soil (Guilbeault et al. 1994; Hickey et al. 1993).
In addition, the presence of surface active agents has been shown to increase the bioavailability of
PCBs to the microorganisms. However, enriched cultures were unable to biodegrade PCB
congeners containing five or higher chlorine substitution (Guilbeault et al. 1994). It has been
reported that the mono-, and di-chlorobenzoate, and possibly other higher chlorobenzoates formed
from aerobic degradation of PCBs act as inhibitors towards further degradation of higher chlorinated
PCBs (Guilbeault et al. 1994). Therefore, the efficiency of PCB degradation is not only controlled
by the enzyme substrate selectivity pattern, but also by the metabolite production pattern .
5.4 LEVELS MONITORED OR ESTIMATED IN THE ENVIRONME;NT
5.4.1 Air
The atmospheric concentrations of PCBs in various locations are given in Table 5-2. The range of
atmospheric concentrations of PCBs in urban areas is 1-10 ng/m3 with a mean of 5 ng/m3
(Eisenreich et al. 1992). The atmospheric concentrations of PCBs in two rural areas are in the range
0.2-0.95 ng/m3 with a mean of 0.6 ng/3 and in two remote areas are in the range of 0~02.-0J 8
_:.---·-----"'~-------
ng/m3 with a mean of <0.1 ng/m3 (see Table 5-2). The range and mean atmospheric PCB
concentrations in other locations are as follows: 0.01-0.7 ng/m3 and 0.1 ng/m3, respectively, in
marine/coastal areas; and 0.2-4.0 ~g/m3 and 1.0 ng/m3, re~ec~ively, over the G~eat Lafes ---------
(Eisenre1c e a . 1992). With the available data, it i§ difficult to establi~h the trend in atmospheric
----:--:-------:--:-~:--:-::-· -------·--· . . ..
PeB-cuncenfrations over the last two decades following the cessation of PCB production. This is
because monitoring data indicating the levels of PCBs in air at the same location over this time
period are still lacking (levels from one location cannot be compared with levels from another
because of differing emission sources), and the recent studies (Schreitmueller and Ballschmiter
1994) generally report the atmospheric concentrations of the congeners and not the total PCBs or
Aroclors. On the basis of typical atmospheric concentrations of PCBs in pre-1980 samples
(Eisenreich et al. 1981) and the levels in more recent years (see Table 5-2), it can be concluded the
PCB concentrations in air may have shown a slightly decreasin g trend from the pre-1980 to post-
... DRAFT FOR PUBLIC COMMENT' ..
• • • ' PCBs
• II' ...... 243
i .. · I -l;.
'
of:-
' -'k £. ~l . -.
'~~;
:~· ~--
~~-
i,:,., ·Jr,: ''fl''· ;1:f.
;,t!;;•
;+'f ·?.:&' :~5:~ y~·.
~;-:,.
.;,_ ...... : -~-
~~-,.
5. POTENTIAL FOR HUMAN EXPOSURE
TABLE 5-2. Atmospheric Concentrations of Polychlorinated Biphenyls
Location Year
Boston, MA 1978
Columbia, SC 1978
Columbia, SC 1985
College Station , TX 1979-1980
Newport News, VA 1988
Bloomington, IN 1986-1988
Chicago, IL 1989-1990 ·
Adirondack, NY 1985
Chesapeake Bay 1990-1991
Lake Superior 1986
Rural Ontario, Canada 1988-1989
Antarctica 1981-1982
Arctic 1986-1987
avalues are given as mean concentrations.
bValues at three different sites.
Concentration a
(ng/m3)
7.1
4.4
2.3
0.29
0.11--0.48
0.39
(0.185--0.794)
Summer: 1.74-3.84b
Winter: 0.31--0.62
13.5
(7.55-20.26)
0.95
(0 .339-1 .359)
0.21
(0 .017--0.508)
1.25
0.2
(0 .55--0.823)
(0.02--0.18)
0.02
Reference
Bidleman 1981
Bidleman 1981
Foreman and
Bidleman 1987
Atlas and Giam
1987
Knap and Binkley
1991
Hermanson and
Hites 1989
Holsen et al. 1991
Knap and Binkley
1991
Leister and Baker
1994
Baker and
Eisenreich 1990
Hoff et al. 1992
Tanabe et al. 1983
Baker and
Eisenreich 1990
The ranges are given in parentheses.
···oRAFT FOR PUBLIC COMMENT ...
5 -0 7-1996 1 : 0.3AH FROM
December 6. 1996 .......................................................................... by FAX (5 pages)
To : Technic-al Committee
From: Joel Hirschhorn
Tiuough: Doris
Per our phone conference call this morning, attached is the draft letter for the Governor, and the
three pages I received from Bill Meyer~s office which EPA provided him as a response to my
receut report on PCB air emissions. The attachment to the letter is the page of conclusions that I
described in my report, which I had found in the state files. Apparently it was from a repo,t by
EPA's contractor and not EPA itself, a rninor point, and apparently was given to the state as I
concluded in my report.
As I said this rooming, I do not believe that the statements from EPA invalidate what I and Pat
Baroes have c-oncluded about the threats from PCB air emissions from the landfill. I ",m be
preparing a formaL professional response to the EPA letter next week.
P . l
, . -
CO-CllAIRS:
JOINT WAIUlEN COUNTY/STATE PCB LANDFILL
WOil.l(ING GROUP
DOU.IE lJ. BURWELL
KEN FERRUCCIO
IIENRI' LANCASTER
December 6, 1996
Dear Governor Hunt:
The Joint Warren County/State PCB Landfill Working Group finds it necessary to inform you
about the number of very serious new circumstances. You personally have played a key role in
assuring the citizens of Warren County that the PCB Landfill would be safe and secure, a state-of-
the-art facility, and would be detoxified when feasible technology became available. We are
concerned that the normal bureaucratic channels of providing information to your office may not
have effectively communicated the importance of new information that the Working Group has
received from its two highly qualified Science Advisors.
The purpose of this letter is two fold. First, to inform you in general terms about the new
circumstance, and second to request your attendance at a community meeting in Warrenton
sometime in January 1997 so that you can personally hear the new facts abut the landfill and the
concerns of Warren County citizens.
As lo the new circumstance, our Science Advisors have made it clear that the landfill did not have
the best technology installed, which is why the critically important leachate collection system is
not functioning as it must and why there is an enormous amount of water in the landfill. Our
. Advisors believe that the landfill is leaking. Our Advisors have also concluded that there was
evidence in 1983 the uncontrolled PCB air emissions were significant, but that the State never
installed low cost carbon adsorption filters at air vents. At this time, our Working Group
members and the larger Warren County community have become convinced that the Warren
County PCB Landfill is not safe or secure and very likely has posed some threat to public health
for many years. Moreover, our Advisors have also informed us that detoxification technology has
become commercially available.
At this critical time, therefore, there is a critical need for you to assure Warren County residents
that you remain committed to protecting their health, environment and well-being by taking
measures to assure the safest possible condition of the present landfill and by committing to do
everything necessary to provide the State funds for total detoxification of the landfill as you
originally promised in 1982, and which our Advisors say will cost at least $25 million. The
Working Group has already requested Secretary Howes to immediately install carbon filters at any
open vents from the landfill as a necessary, temporary safety measure until detoxification can be
implemented. At the public meeting we also want to discuss with you the need for the State to
take other actions, including a health effects survey of residents living relatively close to the
landfill and possible testing of body tissues for residual PCB levels.
Governor Hunt, would you please have your office inform us what dates in January 1997 you
would be available to personally attend an evening community meeting in Warrenton. If you
provide two or three available dates within the next few days, we will quickly ascertain which date
can maximize attendance by our members, our Advisors, and Warren County citizens and confirm
a date with your office.
Sincerely,
Dollie B. Burwell, Co-chair ,
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
720 RIDGE\VA Y STREET -WARRENTON, N. C. 27589
PHONE [phone] -FAX [phone]
CO-CJ/AIRS:
JOINT \VAiillEN COUN'fY/STATE PCB LANDFILL
WORl(ING GROUP
DOU.IF. ll. BURWELL
XEN f'EU/WCCIO
IIF.NRJ' IANCAS1"ER
Mr. Jonathan B. Howes, Secretary
State of North Carolina
Department of Environment, Health and Natural Resources
P. 0 . Box 27687
Raleigh, N. C. 27611-7687
Dece1 er 9, 1996
SUBJECT: Need to Install Filtration System on the CB Landfill Main Gas Vent
Dear Secretary Howes:
It has recently come to the attention of this W king Group and citizens of Afton that gas
emission containing PCBs has been emanati from the main vent at the PCB Landfill in '
Warrenton. This data was obtained by our cience Advisors from information contained in the
State's files. In particular, from a study rformed by the EPA directly after the facility was
constructed some 14 years ago. The c· 1zens are extremely concerned about this information and
demand that immediate action be tak n to prevent further potential discharges of PCB to the
environment.
It is our understanding that the ent system opening, which is comprised of a single four-inch
diameter pipe, can be easily a inexpensively fitted with a filtration system. The Working Group
is willing to do all we can to xpedite this matter including the allocation of the necessary funds
from our operational budg .
Because the gas vent is direct connection between the PCB wastes and the environment, and
because it has been sh n in the past to be a source of PCB gas emissions, we request that an
appropriate filtration ystem be placed at the mouth of the vent immediately. We believe that this
is the only prudent ourse of action concerning this matter.
Sincerely,
Dollie B. Burwell, Co-chair
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
cc: Dennis Retzlaff, Warren County Health Director
BF A Environmental Consultants =---= ~ -==-=-7 =-~ == Barnes, Ferland and Associates, Inc.
MEMORANDUM
TO:
FROM:
DATE:
Bill Meyer through PCB Working G~ L.,
Patrick Barnes, Science Advisor ,di'~
December 4, 1996
BFA #95 -01 7
SUBJECT: December 3, 1996 Response to BFA Memo dated December 2, 1996
The statements made i.n the December 2nd memo all stem from the following facts:
l. The main vent has been shown to be a source of PCB emissions.
2. PCBs were present at above detection levels at a house approximately 1000 meters away. Jf
these PCBs are attributable to the landfill vent emissions, then it is possible that sediments at
the same relative distance may also contain PCBs. This is why additional sediment sampling
was recommended.
3. Although a filter could have easily been placed on the vent pipe outlet, that has not yet
occurred.
We believe that the State's assessment of low risks should be based more on analytical data rather
than mathematical modeling.
I apologize for the emotional statement regarding the safety of the Afton citizens; however, it is
our belief that all prudent measures should be taken even if analytical results were to show a low
potential risk. Safety should always c()me first .
f'A.8·j.>sg'12-4.8M.l doc
Post-ltf> Fax Note 7671 D!i.lf:! I z_
FrQm
Co.
~hone II
Fax#
The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando, Florida 32803
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rN/$ ES>'IMAT{ IS FQfl COMPI..ETING rilE JO£! AS Of!;C/l18fO ABOVE ANO IS l!AS[O ON QUR
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.--------•--,--
m1i'.L crtL /!¥,At 'Wt lffl~ ;J}J-~c~ William L. Meyer, Director r Solid Waste Management Division To:Tu . tv\, '(f; tA~ Dak: rd 5 / 9 &, p,,,,,,1ffls '"-' A MW Ull(yb,/, ~>lib r Vf,.,,., b .w-M _ __ Draft a reply for my signature __ For your information See me about attached __ Take appropriate action __ Approve __ Handle and report to me __ Note and return attached material to me Remarks: IVl1K6 6!f Ucf:6J) Pf2£:-Ll c:\Cfil}t!C__~ ~eee,~, ~ ~~ ~,VL~t'-J\\SS1t>~-s oi \/\l~"-l ~o~ f~ ~~~\.,L. "-t¾t:/' ~~CT::: /I AW~ 71) ""f tie---w:f¥l.!ta.J ~ . \Noak ( ~ Csi.~ b~ ·:sntlS ~'ff : .. <;;5PI "'l:'.lr1'JJ '.f-1(,l.c'... ~ut lc0:k /Z££ll l-11 JJs r/1-, l\i81'1" (TH:5-lJ\:::. y~ &It.~) ., ~ ~--t<S-,vl1m"r1w,~CF1br h01-dl1 tie" " &~ ~6fl'il) \W, 'rllE, "SA-\€1r q'-RL C'Jt(~ ~ ~,/olo, ~ ~'IS '12.~Tt, \1\E', ~,. JAl<. 198S' ~a ~ ~<c.. . L~_,._:)\ <;\s-~ ~ \2-\-~ l q ~ ~ N\.t ~~'N-\J~ E.uALu~~'/ll_, 'D~~ ~ ~v\\)E., ~~f::. 01'\. ~clflG-fl ~ ~\tS f\C~ ~ ~su.'2.£ -wtfffl ?ffOW~ \N<0(\D k E:u;\lll~ "\\b~~\i.v ~ ~
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
.AVA
DEHNR
December 3, 1996
MEMORANDUM
TO: Patrick Barnes, Science Advisor
Joint Warren County/State PCB Landfill Working Group
FROM: DWM Staff for the Joint Warren County/State PCB
Landfill Working Group
SUBJECT: BF A 12/2/96 Memorandum Air Emissions of PCB
and Associated Health Risk
Please provide scientific and epidemiological substantiation for BF A's statements that, with
respect to the Warren County PCB Landfill, "so-called landfill represents potentially significant
health risks" and the State's "apparent disregard for the safety of the citizens of Afton". Please
also provide any data on air quality modeling or other technical basis for the statement that the
"PCBs which have been deposited by air emissions may have accumulated in these surface
drainage features and thus may still present a threat to the envir~mment." It would also be helpful
to the staff if BF A submitted the qualifications, expertise and eJiperience of personnel providing
the statements and response to our request.
P.O. Box 27687 ,
Raleigh, North Carolina 27611 -7687
Voice 919-733-4996 f Pffi&llif:ii:MD
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
J2 103 :96 13:01
DATE:
TO:
'0'919 5-!l 3527 NERL: A~IRD : :\IB
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EXPOSURE RESEARCH L/\BORATORY
A.IR }..ffiASUREMENTS RESEARCH Dlv1SION (MAIL DROP 44)
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27il 1
TELEPHONE 91!M41-306S FACSl\ID..E 919-541-3527
E-MAIL lewis. [e-mail]. epa. gov
FAX~SSAGE
3 December 1996 NUMBER OF PAGES: 3
(including cover)
Bill Meyer Fax No.: 715-3605
Telephone:
FROM: Dr. Robert G. Lev.'is
USEPA (MD-44)
Research Triangle Park, NC 27711
SUBJECT: Hirschorn Report on Warren County PCB Landfill
MESSAGE:
[4]001 :003
I was out until today and have just reviewed the above-referenced report that you faxed to
me yesterday. ..
The 1983 EPA paper (on which I was lead author) that Dr. Hirschorn attacked in his
repon was published in Environmental Science & Technology, a peer-reviewed journal widely
recognized as the leading journal in the world on environmental monitoring. Prior to publication,
it underwent rigorous technical review within the EPA and by two or more leading experts
outside the Agency. Therefore, our statements that PCB emissions from the landfill were
negligible at the time of the study were supported by the highest level of technical review.
It is clear from the data presented in Table II of our paper that no significant PCB
concentrations could be measured in the air surrounding the landfill, even at one meter distance
from the main vent pipe. As the paper states, "only four of39 ambient air samples analyzed
contained detectable quantities of PCB." These were positive only for Aroclor 1260 (the least
volatile of the tv.ro Aroclors monitored) and "did not appear to correlate with proximity to the
vents." It would be clear to any analytical chemist or anyone with enVironmental monitoring
expertise that these were likely false-positive results. The levels detected were 0.01 to 0.07
µg!m3, at or very near the method detection limit (0.01 -0.02 µg/m3). Had they been "real," the
more volatile Aroclor 1242 should have been found at much hicller concentrations, as it was in
main and upper leachate vent pipes (see Table I). The la.ck of correlation of the measured ambient
air levels -with proximity to the vent pipes, taken with the fact that Aroclor 1242 was the only
analyte identified in the air even though Aroclor 1260 was at much higher concentrations in the
vent gas, conclusively demonstrates that the vent pipes were not the source of the PCBs detected
in air, !!Ven if the measured air values were real. It should also be noted that PCBs were
12103:96 13:01 '5'919 5-H 352i KERL -' .-DIRD : l[B @002 :1)1)3
ubiquitous in the ambient air in the United States, typically at 0.005 to 0.01 µg/m3, at the time of
the Warren county air monitoring effort.
Our air monitoring results were also consistent '\Vi.th both the air emissions models applied
to the vent measurements. As we stated in the paper, the models predicted that no measurable air
concentrations of PCBs would result at 14 meters from the main vent and beyond.
In his analysis of the data presented in our paper, Dr. Hirshom refers to measurements of
"A.rochlors" (sic) obtained "at" the main vent (120.2 µg/m3 for Aroclor 1242). The vent pipe
measurements shown. in Table I were made within the vent pipes, not in the air at or near tbe
vents. Hence, they cannot be compared '\Vi.th the ambient air measurements made at the
uncontrolled sites in Indiana and reported in our paper. There were other major differences
between the Warren County and Indiana sites. The Warren County site was brand new and
should have been emitting at a maximum rate. The Indiana disposal sites were old (before 1972,
as stated in our paper). The PCB-contaminated soil in Warren County was underground, in the
thermic temperature regime, and should not have been affected by ambient air temperature (i.e.,
emission rates should have been the same whether it was summer or winter at the time of
monitoring). In Indiana, PCB-contaminated surface soil was abundant; thus, emissions were
greate: in summer when the sun heated the soil. As we said in our paper, the PCBs measured in
the vent pipes in Warren County were be transported by metbane from decaying organic matter
(primarily grass excavated along -with the roadside soil) and should hav~ declined greatly once
that matter had decayed. Therefore, Dr. Hirshorn's statement on p. 4 of his report that the "high
levels found at the Warren County Landfill were quite comparable, and perhaps even greater than
the levels found above tbe other three uncontrolled landfills" is absolutely without merit.
As lead aurl:or of tbe ES&T paper, the interpretations of our findings were principally
mine. However, the report provided to EPA by Battelle Memorial Institute, who did the air
monitoring for the Agency under contract, reached the essentially the same conclusions ( see
attachment).
Anachment
i\t.KL: :\}!Kil : .lll:)
SECTION 2
CONCLUSIONS
The conclusions drawn for results of this study are surrrnarized below.
( 1)
( 2)
{3)
(4)
The principal source of emissions from the landfill originate from
the main vent pipe. The average PCB concentrations of Aroc1or 1242
and Aroclor 1260 measured in the main vent emissions during the
study were 123,000 ng/scm (...,100 ppb) and 2,000 ng/scm (,...2 ppb),
respectively. These concentrations are substantially lower than
the current occupational standards for workplace atmospheres which
range from 0.4 to 0.8 ppm .
.A.mbient air PCB levels on and surrounding the landfill site (even
as close as one meter from the main vent) were found to be at or
below minimum detection limits (6 to 10 ng/m3}' for the sampling
method. PCB levels generally present in the atmosphere throughout
the U.S. are in the range of 5 to 10 ng/m3.
Mathematical modeling predicts that ambient air PCB concentrations
on and in the vicinity of landfill resylting from the main vent
pipe emissions may be approximately 106 to 109 times lower than the
detection limits for sampling method used in this study. PCB
contributions to the ambient air from the landfill based on the
model predictions are insignificant when compared to general
ambient air PCB levels in the U.S.
It is anticipated that the low PCB emission rate from the landfill
will be reduced still further as decay of organic matter producing
the methane and other gases emanating from the vents subsides. The
reduction of hydraulic pressure by removal of water from the site
should also reduce ·emission rates substantially.
2
i
l,2 :03 /96 13:01
ft
~
DATE:
TO:
'6'919 541 352i NERL /AMRD /MB
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EXPOSURE RESEARCH LABORATORY
AlR MEASUREMENTS RESEARCH DMSION (MAIL DROP 44)
RESEARCH TRIANGLE PARK, NORTii CAROLINA 27711
m.D'HONE 919-S41•306S FACSIMILE: 919-541-3527
.E-MAIL [e-mail]
FAX l\1ESSAGE
3 December 1996 NUMBEROFPAGES: 3
(including cover)
Bill Meyer Fax No.: 715-3605
Telephone:
FROM: Dr. Robert G. Lewis
USEPA (MD-44)
Research Triangle Park, NC 27711
SUBJECT: Hirschom Report on Warren County PCB Landfill
MESSAGE:
14] 001 :1)1)3
I was out until today and have just reviewed the above-referenced report that you faxed to
me yesterday.
The 1983 EPA paper ( on which I was lead author) that Dr. Hirschom attacked in his
repon. was published in Environmental Science & Technology, a peer-reviewed journal widely
recognized as the leading journal in the world on environmental monitoring. Prior to publication,
it underwent rigorous technical review within the EPA and by two or more leading experts
outside the Agency. Therefore, our statements that PCB emissions from the landfill were
negligible at the time of the study were supported by the highest level of technical review.
It is clear from the data presented in Table II of our paper that no significant PCB
concentrations could be measured in the air surrounding the landfill, even at one meter distance
from the main vent pipe. As the paper states, "only four of39 ambient air samples analyzed
contained detectable quantities of PCB.;' These were positive only for Aroclor 1260 (the least
volatile of the two Aroclors monitored) and "did not appear to correlate with proximity to the
vents." It would be clear to any analytical chemist or anyone with environmental monitoring
expertise that these were likely false-positive results. The levels detected were 0.01 to 0.07
µg/m3, at or very near the method detection limit (0.01 - 0.02 µg/m3). Had they been "real," the
more volatile Aroclor 1242 should have been found at much higher concentrations, as it was in
main and upper leachate vent pipes (see Table I). The lack of correlation of the measured ambient
air levels with proximity to the vent pipes, taken with the fact that Aroclor 1242 was the only
analyte identified in the air even though Aroclor 1260 was at much higher concentrations in the
vent gas, conclusively demonstrates that the vent pipes were not the source of the PCBs detected
in air, 1:?ven if the measured air values were real. It should also be noted that PCBs were
. ~2103/96 13: 01 '5'919 541 352i NERL/AMRD IMB (4) 002 .'1)()3
ubiquitous in the ambient air in the United States, typically at 0.005 to 0.01 µg/m\ at the time of
the Warren county air monitoring effort.
Our air monitoring results were also consistent with both the air emissions models applied
to the vent measurements. As we stated in the paper, the models predicted that no measurable air
concentrations of PCBs would result at 14 meters from the main vent and beyond.
In his analysis of the data presented in our paper, Dr. Hirshom refers to measurements of .
"Arochlors" (sic) obtained "at" the main vent (120.2 µg/m3 for Aroclor 1242). The vent pipe
measurements shown in Table I were made within the vent pipes, not in the air at or near the
vents. Hence, they cannot be compared with the ambient air measurements made at the
uncontrolled sites in Indiana and reported in our paper. There were other major differences
between the Warren County and Indiana sites. The Warren County site was brand new and
should have been emitting at a maximum rate. The Indiana disposal sites were old (before 1972,
as stated in our paper). The PCB-contaminated soil in Warren County was underground, in the
thermic temperature regime, and should not have been affected by ambient air temperature (i.e.,
emission rates should have been the same whether it was summer or winter at the time of
monitoring). In Indiana, PCB-contaminated surface soil was abundant; thus, emissions were
greate: in summer when the sun heated the soil. As we said in our paper, the PCBs measured in
the vent pipes in Warren County were be transported by methane from decaying organic matter
(primarily grass excavated along with the roadside soil) and should hav~ declined greatly once
that matter bad decayed. Therefore, Dr. Hirshom,s statement on p. 4 of his repon that the "high
levels found at the Warren County Landfill were quite comparable, and perhaps even greater than
the levels found above the other three uncontrolled landfills" is absolutely without merit.
As lead author of the ES&T paper, the interpretations of our findings were principally
mine. However, the report provided to EPA by Battelle Memorial Institute, who did the air
monitoring for the Agency under contract, reached the essentially the same conclusions ( see
attachment).
Attachment
12,03;9ij 1a:uz Nt.KL,, .'\m-uJ i J!l.O
SECTION 2
CONCLUSIONS
~VV.J • Vl.l,J
The conclusions drawn for results of this study are sul'!ITlarized below.
(1) The principal source of emissions from the landfill originate from
the main vent pipe. The average PCB concentrations of Aroclor 1242
and Aroclor 1260 measured in the main vent emissions during the
study were 123,000 ng/scm {-100 ppb) and 2,000 ng/scm (""'2 ppb)t
respectively. These concentrations are substantially lower than
the current occupational standards for workplace atmospheres which
range from 0.4 to 0.8 ppm.
(2) Ambient air PCB levels on and surrounding the landfill site (even
as close as one meter from the main vent) were found to be at or
below minimum detection limits (6 to 10 ng/m3) for the sampling
method. PCB levels generally present in \he atmosphere throughout
the U.S. are in the range of 5 to 10 ng/m.
(3) Mathematical modeling predicts that ambient air PCB concentrations
on and in the vicinity of landfill resulting from the main vent
pipe emissions may be approximately 106 to 109 times lower than the
detection limits for sampling method used in this study. PCB
contributions to the ambient air from the landfill based on the
model predictions are insignificant when compared to general
ambient air PCB levels in the U.S.
(4} It is anticipated that the low PCB emission rate from the landfill
will be reduced still further as decay of organic matter producing
the methane and other gases emanating from the vents subsides. The
reduction of hydraulic pressure by removal of water from the site
should also reduce ·emission rates substantially.
2
Dec~mber 3, 1996
MEMORANDUM:
TO: PA TRICK BARNES
FROM:
JOEL HIRSCHHORN~
MIKE KELLY ~\J
SUBJECT: SELECTION OF VENDORS
You should have rec'!ived by now the proposals for the lab testing and for the monitoring
wells as they were sent by Fed Ex last night. I had hoped that we could get together this week to
discuss and make our vendor selections, however Joel had suggested that perhaps we do this by
conference call.
I would like to suggest that we get together Thursday afternoon (December 5) via
telephone at 1:30. I can initiate the call here and hopefully get everyone on line. We should be
able to reach a decision on the bore holes fairly quickly; then perhaps we should look at the labs
as there are only four to consider, and then, depending on our progress, get into the monitoring
wells.
Once we have our recommendations, I will set up a time ~th Purchasing & Contracts to
have them proceed to the next step and get the contracts in place. We will just need to present
sound, technical reasons as to why we choose who we do. If there are any specifics we would
like to add or subtract from the contract, we need to let the Department folks know as well. For
instance, CDM proposes 4 holes; SME 2; ifwe can use 2, and CDM can do 2, will their cost
come down like SME? Have you decided what you need in the way of borings, etc.? These
types of questions need to be answered by us before I get the Department folks on the trail.
Also, Joel, have you gotten the information together for the trial detoxification study,
specifically as to what we are looking for and the potential bid list of participants? I would like
to get that out the door in the next couple of weeks.
Copy: Bill Meyer, Patrick Watters
STATE PROG. SECTION
\
ID: 404-S f,2 -878:3 UL L Uj '~b 14 :1u No .LIU( P.Ul
'
FAX TRANSMISSION
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION4
100 ALABAMA STREET, N.E.
ATLANTA, GA 30303
I:
'l'o: 0\ ,k \(._\\ ~ ~
~,ax#: '\ \0\ -~ \ r -3G.oS-
From: f"': \ Vo r s. ., ·\ L
Date:
Pages: S including this cover sheet
Subject: ' \ /1 l \ r \\ W <\.( /'(_/\ \._,..(:> q I\_ o i 1
COMMENTS: ,
. euf ru A t ~~ ~ r(J-
CO-CJ/AIRS:
DOLJJE B. BURWEI.L
J:£N FERR UCCIO
HENRl' LANCASTER
John H. Hankinson, Jr.
Regional Administrator
EPA Region IV
100 Alabama St.
Atlanta, GA 30303
Dear Mr. Hankinson:
The residents of Warren County, North Carolina have had a long difficult history concerning the
Warren;;GQurity.PCB Landfill that the state with the approval ofEP A Region IV and CERCLA
funding constructed some 15 years ago against substantial citizen opposition.
The Warren County PCB Landfill Working Group, fom1ed by the state and citizens, writes to you
now to request a serious. detailed, and immediate examination of the state, s compliance with all
ofEPA's requirem~nts for the constmction, operation, monitoring, and maintenance of the PCB
landfill.
I
The two Science Advisors assisting the Working Group have identified a major lack of regulatory
compliance by the state that we find dangerous and unacceptable. The serious and prolonged lack
of compliance by the state, as owner and operator of the landfill, also reveals a ,lack:'.Ot:;ovijrsight
at1d,:enforcement by EPARegion IV that demands attention, explanation, and correction.
Under authority of the Toxic Substances Control Act and with Superfund/CERCLA funds, EPA
made a commitment and accepted responsibility to protect public health and environment. It
seems clear to us that EPA has failed to meet its statutory responsibilities. You should also
appreciate that the PCB landfill has played a key role in the development of the environmental
justice movement in the United States.
The state ofNorth Carolina should be held to the same standards as industry. If EPA assumed
that the state would police itself, it was wrong.
We expect you to immediately form a high level, independent group to closely examine,the:state',s
entire history of compliance. We suggest consideration of Ms. Jewell Harper, Deputy Director of
--your Waste Management Division, to lead this effort.
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE (919) 257•1948 -FAX [phone]
STA TE PROG. SECTION ID:404-562-8733 DEC 03 '96 14:11 No.007 P .03
We are particularly concerned that the state: (l) did not carry out all requi~ed groundw~ter
monitoring;; (2) failed to analyze early data that we believe show that the landfill has had water
entering and escaping it; (3) failed to act or plan to remove large amounts of water inside the
landfill; and ( 4) failed to repair a dysfunctional leachate collection system.
Consistent with your commitment to facilitate efforts of the Working Group, we expect that this
matter will be expedited. It is the hope of the Working Group that the state will soon honor its
original commitment to detoxify (remediate) the landfill now that our Science Advisors have
concluded that feasible detoxification technology is available. Thus, the lifetime of the PCB
landfill will, we hope, be limited. Nevertheless, complete landfill detoxification will be some years
away. The Working Group believes it very important that EPA complete its compliance audit
soon, because the full extent and impact of the state's noncompliance should and will play an
important role in the statets decisions in coming months and public support for the detoxification
project. We also expect EPA Region IV to assist all efforts by the Working Group to achieve full
and safe detoxification of the landfill.
The members of the Working Group and its two Science Advisors (Dr. Joel S. Hirschhorn and
Mr. Patrick Barnes) will gladly assist your efforts to conduct the requested compliance audit.
Sincerely,
Henry Lancaster, Co-chair
•
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
;:,
\
STATE PROG. SECTION ID:404 -562 -8788
-ll/~2/96 PIH 13: 4.2 FA.\ 103 603 9104 lJS IWA HQ DSEI> DEC 03'96 14:12 No.007 P.04
~ ..
JOINT WARREN COUNTY/STATE fCB LANDFILL
. ·WORKING GROUP
I><)J.Z.a & Bt/Rftl.L
UN n:RIUct'IO,
11DiR1 Wc.un.R
Elliott P. Lawt, Awstant Adminjstrator
Solid Waite and Emergency llespollSCI U.S.EPA . . .
401 M. Slfect, ~W . ·
Wubingtou. ~-20460
. DearMr. Laws;.
Octob« 2S, 1996
The Warren C.ou¢>' PCB Lwlfill. Working Group is requM!ing the ·usta.cce of your office in
d~ several policy positions of EPA This landfill has an unusual history. Despite-strong
citlieu opposition to the aiting of the lan.dtlll. the atate obtained EPA approval f'Qr it. Moreover,
SUpcrl\lnd/CBRCLA funda ($2.S million)w~ provided to tho at.ate ofNorth Carolina through a
cooperative, 11greement iu May 1982 for ctcanup of'PCB wastes and eonstrum.ion Qf the landfill. .
_· But this had been prccedc,-i_by W'ARe~ii IV approval of the landfill in June 1~79 in response to
an application by Governor Hunt lnpocember 1978. lt wu your offico that apJ)fOved the ~ward
· of the ~ding to the ~e. .. · _ 1 -· · · · · · . ·· · • ·
We s.eelnm objective e,wnina.tion of the ~ent to which tlri,· ~I ahould hive tt> meet
· CBRCLA etatutoiy and National Contingency Plan n,quirements for remedial action sites. We ·
are not cleat u to whether the st,tc took advantas~ of the CERCLA opportUnity to designate-one sue for the .NPL 1Dd, if ao, whether the PCB cle.nup along State roads~ for which this Jandfi,ll
served u the remediation, was svch a alto. -. . , -. . ' . '
' '
We want .to inform you that the May 25, 1982 EPA ·document awarding the CERCLA funds to
the state comiim a numbm-or Special Con!litioris, including several that refer to compti,.nee with
C.E.RCJ..A pro-visiom and one that explicitly says "All a.ct.ivities conducted under tblJ c:ooperative
agrMmcmt will be eo~atent with the e,d5ting National Ccntingency Plan. .. II and .goes Oft to uy
that 11lten&na•rovwon ofdle NCP. all acti~ties abou!'d be consistent with the o,clltingNCP and
propos.cd amcndm• dated Maroh 12. 1982." MortoV~, ,"Wheri the nwised NCP ·u;.
promulgate¢ Jt lhal1 take precedence. II Thi, $OetllS very clear that current NCP requirements
· apply to tbia PCB .landfill.• . . .
,2o·RIDc;EwAY STREET. WARRENTON, ·N. c. 21ss, ·
. OFFig; (~l!) is?-19"8 -FAX (~19) 257-iOOO
\ilUUJ I
STATE PRO G. SECTIO N ID:4 04-562 -8788
. -...
DE C 03 '96 14:13 No .007 P .05
ijioo4
' '
-·We also note that one of the condit,ions m,akes clear that ,.The State will fully, comply with all , -
applicable requirements under the Toxic Substances Control Act (TSCA)..... -
. '
· The Worldng Group would like. a clear, definitive policy position by your office conccmlna the
, ~ent to which CERCLA ·anc1.NCP requirements apply to this landfill. For example,· does the five· ·
yeat_ review requirement apply? Call a local group ~pply for a T,echnical Assistance Grant? Can ·
failure of the 1andt1ll containmentsyatem be used to support a new remedial action?·
~ .
We l~k forward to -~ early response from you.
_ Sincerely,_. :
I Hmuy ~. Co-chair ·
720 RIDGEWAY. STREET, WA~~TON, N. ~. 27589
OFFICE (919) 257~1948 M FAX (,1,) 151-1000
'
1
5 ·-1217-1996 1 , 0LI.AM FROM
FROM 919 7 153665 SOLID WRSTt DIV
DATE:
TO: Bill Mrfe,
FAXMESSAGB
NVMBD
(bachadla1
ru No.t 71 .J605
Tu,11,n,:
. FROM: Or. R.ob~ 0 . Lewis
USE.PA . (MD-44)
Reswcb TrilDl't Pll'j NC 2771 l .
SUBJ:tCT: HitlCbona bport 00 Wr Cowlty PCB Lud&U
p . '
MESSAGE; . I
I was out \lDtil today and bave just reviewed the abow<efettl)ced opon \ba1 you t'axod to
1De ytsterday. . I t .
Tbt 1983 EPA pa.per (OD whlcij l was lead au\bor) tbat Dr. Hlra m attaeked iu ms
report ,r.,a$ publul:le~ iD 'Envtronm1n"'1iSdmc, 4 T1dtnolo1Y, a PNMeYi d journal widely
reeogul.ud •• tb, lNdlD.gjounw in tbeworld on envirowi'-Dtal momto . . Prior to public1ti0n,
it uod-OC'\\lt:t riaorous ~lmical rmewl,nthi11 \he EPA~ by two or mor leading experts
out11d, Ult Apley. Thwefore, our st~cmem dW PCB emlllloa.1 a-om e landfill wore
neg-Jigible at the time of the atudy were~-mppomd by tbe bipect level ort ell rtviaw.
Ii ls clear &orD the data prenat la Tabl• n of our paper thai no pi!cam PCB
concentratio.c., could be measured m · air llm'fO\llldina the JandfW, eveD OIIC metor dinante
!tom tho maic vat pipe. Al the plJH:f ~• •omy tour ofJP ambitDt air ts ualyzcd
wntalntd dertK!6ble qulotitiea of PCB1" Tbelewere politlve oDJy fbr Aft'!~ 1260 (the llan
.. Yolatile 0£ ibt two Arodora moDkored), .ct "cid cot appear to eonwm proximi~ ~ the
'/COts." It wowd be cl~ to ay ~al vbcmilt or uyoue widi · m011rtonng
""'Ptrti" that tbett were UkeJr false-' 0\'t naults. Tbe levelt dmatd ere 0.01 to 0.07
µs,'m1, at or my 11u.r dia metbod det 'an 1imh (0.0l • 0.02 ,-t,lm'). Ha they been "real," the
mort vulaUle Arotlor 1242 tbould ba b90D Couad II much ldper ccoc ·ocs, as it wu io.
JN.111 tn.d \IJ)Jlflt let.cb4te. vtDt plpet ( Table I). TIie Jack cl oomlation t.be meuur.d amblMt
a.Ir k\lu with proximity to thl vent , 11k• with th6 f&Cl wt A:oclor 24.i wu the oG1y
11.11alyt1 idtinaiod lo the air eveo tbou~Aroclor 1260 'Ml 11 mucb blaher ncentndou 1D th•
vent gu, conclu~ d~ouu-&~ tb9 vta1 pipM wwe i,ot 1hl oftbo PCBs detKted
in air, .,...esi if the mouuted air Vlhlca real. It abould alse be uottd PCB1 wwe
5 -07-1996 1 : 04AM FROM I-'. 4
12.03.1996 16:~e p. 2 .._---__ .,,,
•. ubiqul1ou, io tlae llllbl.i,111r iD Ibo U
I
od Siatu, l)'pically at 0. OOS to 0. o saalm', at the lime of
• tlae W11Tu county air 1110Diloriq ..d:.
Our air monltorin8 retultl ~also CO!lmtent with botJa tbe air 'NiOll.l snodela applied
to the vent meuurmmits. A. we iii the paper, tbe models · tbat no meuunblc air
concenttatioaa or PCBs, ,vouJd result 14 ID8leI1 &om tba malD veat 1Dd eyond.
1D bi, lllllyala ohbe data p ed bl 01.1r paper, t>r. Hinbom rcfl to mmwwmonts of
"Arochlors" (sic) obtained "at" the vlbt {120.2 'fAWC1 for Aroclor 12 2). The veat pip~-
measumnc:nu thown ln tabla I were t within the vem pip111 a°' la tb air at or DW' the
Vtml. Hetico, they r.lDllOt be compare ~ the ambltat air meuuremmt made It the
vncomroUed tltc1 in Indiana ud m>Wld iD our papw. 11aere wore other · or differ=ces
bttWteb tbe WtffllD Cc:,umy ud lnci litn. Tbe W~ Count)' llte brazid aew and
,hould have been emit'tiog 1t a a,a,,dm nda, Tbt ladiani ,Jisposal lites old (bef'oro 1972,
as stated in our paper). Tb~ PCB-co•iq&zunat,ed toil in Warren County wa widm·ground. in the
therm.le iempntw-o rcsLme, and &houJ not have beta dsttd by ambient · temperature (i.t.,
emission rata tbould ha've beea the whether lt was nmmer or winter at the time or
·moa.itoriog). In Indiana, PCB-cont ' ated ~ IOil wu ~ant; tnllssions were
gmte: in summer when ihe sun be.ted . e ,oil. Al we said ha ow paper, PCB• musuted in
the vent pipe, iD Wuma County weri-~ ll'USJ)Oned by metbaae &om d )'WI orawo mauer
(primarily srass excavated aloag witb ~ roadside ,oil) aad abould ha~ d • od greatly once
that matter had di,cayed. Therefore, . lusbon,11 statement oa p. ◄ or report that tbe .. biah
)9'f'els foWJd at tho wanu County U were quite comparabl1, and per pa even greater d\111
the levels found above the otbc:r three controU~ lllldfib" 11 absohrtel7 • bout merii.
M lead author of the ESclT pep , tb1 ilsterpretatioas of' O\U' t\ndia were principally
mine. However, the rq,prt provided to1EPA by Battdlc Memorial lmtitvt who did tbt air
monttorina for the AafflCY under co~ reached \ha 11searially the wne nelusiom {ne
atUthmeat). I
Attadm.ent
,..._ < • 5-07-1 996 1 : 05AM FROM p. 3 . .... ...
FROM 919rt~3685 SOLID wAS1E OIV 12 •• ,. 1996
' I
SECTION 2
CONCLUSIONS
Th~ co•c1ua1~•• dnwn fj, rtHlu of this study tr• s trltod bl1ow.
(1} Th@ pr111c1p11 ,ourc of tmhs1ons fro,m the hndf ll or1g1n1t1 from
the ma1" vent pipe. The 1v1r19e PC• ~on~entrat1 , of Aroelor lZtZ end Aroc.1or 1Z60 1111,ured tn tttt ffll1n vent t111aa ons dur1n; the
,tud1 """'' 123,000 ns/sr:in (--,100 ppb) end 2,000 n /scm (•Z ppb). ·
r11p1ct1v,1y, ThHe concent.rat1ons ll"t 1ubst1nt t.11.)' lower thin
the current occupat1 nal standards for workp1act 1tmo1phen1 ~hich range from 0.4 to O. ppm. ·
(2) ltnbient 11r PCS 1tv, son and surrounding tht la df111 sfte {eve~
as close II on1 mete from the main vent) were f und to be at or below m1"1mllffl d!tect on 11~1ts (6 to 10 n,/~3) fr tht 11111P11ng · method, PCB lev1l1 en1rally ~resent in J"" at sphere throughout the u.s. are 1n tht ange of 5 to 10 ng/~.
{3) M1thematic11 modtlin pred1tts that .ab11nt air I conetntrat1ons on and 1n the v1c1n1 y of landf111 ,esultfn; fr the m11n ~tnt
p1pe em1,s1onJ m&y a,,pro~1mately 10~ to 10' t1 es lower than the
det,ctioA 11mits ,,,,. samp11ng ••thoO wsed 1n this stud1, PCB
contr1but1ons to the ambient ,tr from .th■ 11ndf11 b111d cm the model prtdfctfons 1r 1ns19n1f1~1nt whtn cOa1p1red to 9en1r11 ambient air PtB ltvth in the u.s,
(4) lt 1s ant1c1p,ted thJt the 1~ PCB 111t111on rate ro~ the 1,ndf111 will l>e ~•duced still further as d1c11 of organic 1111tter producing the methane and otheri 91111 11111n1tin1 from tht vet, subside,. Tht
reduct 1ari. of hydr1~11~ preu11r, by 1"fQIOv1l of wat r from tht site
should 1110 rtdu~e. l'f aston rites 1ub1hnt11111.
2
12/03 /1995 10:13 91 '371 588[11 GARDNER F'AGE 01
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources AVA
James 8. Hunt, Jr., Governor
Jonathan 8, Howes, Secretary
Charles H. Gardner. P.G., P.E.
Director and State Geologist
FAX COVER SHEET
DEHNR
FROM: ___ ..... C ..... b .... a ...... r....,le ..... s..__._G .... a .... r ..... d'"-'O-e .... r _____________ _
CO: ____ _,L .... a...,n ...... d...__._B .... e-s .... 0 .... 1 .... ,c .... c .... e ..... s _____________ _
FAX#: [phone]
RE:---------------------
NO. OF PAGES {including cover sheet)
If you experience difficulty receiving this message -call -
[phone], Administration, Division of Land Resources.
Geological Survey Section
[phone]
FAX: [phone]
Lond Quality Section
[phone]
FJ\X: [phone]
P.O. Box 27687. Rolalgh, North Carollno 27611-7687 • Telephone [phone] . • FAX [phone]
Ari Equal Opportunity/ Aff!rmotlvo Action Employer • 50% recycted/10% post-consumer poper
12/03/1996 10:13 9197158801 GARDNER PAGE 02 L-"/1 <' ~-,fo.' !5;((~-'7---
LA'\.I ... ~----
l~ L-c..-1---
L-.. ., 11 o ...v,~ c:A-'\..
I t{J../~t, .{:,r-,,...C, (ib,..J,.., • ._
NORTH CAROLINA STA TE BOARD OF REGISTRATION
FOR PROFESSIONAL ENGIN:EERS AND LAND SURVEYORS
J. Albert.BaAA, Jr., PE, RLS
Chairman
Larry D. Barnett
Public Member
.. VJce-Cbalroa1_11_
Ray E. ~ders, RLS
SecreUry
J. Richard Cottingham, PE, RLS
R. Larry Greene, RLS
Helen W. Merritt
Public Member
David L. Peeler, PE
Kenneth D. Suttles, RLS
M. Frank Tyndall, PE
Jerry T Carter
Executi.ve Secretary
Administration
919-781-9499
3620 Six Forks Road, Suite 300
Raleigh, North Carolina 27609-7197
Novembe( 27, 1996
Mr. Charles H. Gardner, PG, PE
DEf.lNR, ..... -·
Land Quality Section
PO Box 27687
Raleigh, NC 2761 l-7687
Dear Mr. Gardner:
This will serve as a follow-up to your personal delivery of your letter of
November 18, 1996 and the attachments concerning the apparent practice of
engineering by Dr. Joel Hirschhorn, non-registrant.
Please be advised that this matter will be placed on the agenda oftbe No.rth
Carolina State Board of Registration for their meeting on December 5 & 6,
1996. At that time, it is my intention to request the Board to authorize the
staff to con.duct an investigation to detem1ine if a violation of G. S. 89C bas
occurred.
You will be advised as to any actions taken by the Board in this matter.
Should you have any questions, please contact me.
JTC/jsa
Violations Division
919-571-2990
·ncerelv,
;i,7:~
Executive Secretary
Continuing Education
919-781-9548
Fax
919-781-2035
· ..-3F A Environmental Consgitants '-_.Z::.di ze w: ==-----•~ Barnes, Ferland and Associates, Inc.
MEMORANDUM
TO: PCB Landfill Working Group
FROM: Patrick Barnes, Science Advisor
Joel O Kimrey, P G., Senior Hydrogeologist
DATE: December 2, 1996
SUBJECT: Air Emissions of PCB and Associated Health Risks
BFA#9S·0l7
We have performed a cursory review of the U.S. EPA research repon on !(fugitive Atmosphere
Emissions of PCB's from Hazardous Waste Landfills", I! well as the review of that report
prepared by Joel Hirschhorn, and, in general, it appears to me that the investigators made up their
minds that the Warren County PCB Landfill was going to be the control site regardle.ss of the
testing results. They failed to draw the most important conclusion of their study, which is that
cv~n so-called controlled landfill reprcsenu potentially significant health risks.
It is difficult to believe that the facility was not designed to include gas filters 11.t the main vent
opening . I believe that the community should demand an immediate explanation from the State of
this apparent disregard for the safdy of the citizens of Afton. Moreover, I recommer:d that
community leaders demand, in no uncertain terms, that:
1. The main vent or any uncapped opening to the landfill be fitted with an activated carbon
adsorption type filter within 72 hours . The filters should allow for influent and eft1uent
sampling.
2. 1n addition to the health related sampling recommended by Joel Hirschhorn, additional
sediment sampling should be performed by the El' A or the State which includes deposits at
the mouth of each major surface .drainage feature within 1/2 mile of the site. The: PCB ' s
which have been depo1itcd by air emissions may have accumulated in these surface drainasl!
fearures and thus may still present a threat to the environment.
The Holli1t4er Building• 3535 Lawton Road· Suite 111 • Orlando, Florida 32803
Office{407)896-8608• Fax[phone]
T0:6
PCB LANDFILL ENVIRONMENT AL SECURITY
SUMMARY OF FINDINGS
B)': rattick A. Barne:, -Sdenu Advisor
Joel 0. Kimrey, P.G. -Senior Hydro1tologi1t
Bad Site for Landfill
• The facility siting investigation failed to appropriately consider the critical nature of the
geolosicaJ setting in locating the landfill. No in-depth geological work was performed to
dctc:nninc actual subsurface flow characteristics
Bdd Engitunilfg Co1ttrols
• The system to remove leachate failed to properly consider the type of materials deposited and
subsequently does not function.
• Improper stormwater manaiernent during construction has allowed a significant amount of
water to enter the landfill.
• Pressure frotn the water in the landfill has rr:sulted in leakage through thb bottom hner
• The poody dc!!igned/installed top liner is also allowing additional water to enter the landfill
• Water entering and leaving the landfill represents a real thre1t.t to sroundwater and surface
water supplies of the area .
• Significant quantities of PCB 's have apparently discharged into the air through the main
landfill vent, and immediate action should be taken to install a properly siz.ed carbon
absorption filter .
Improper Mv1dtoring
• The State has failed to maintain compliance: with the: operating/monitoring requirements of the
landfill,
• The existwg monitoring wells are poorly designed and positioned, and will not properly detect
possible release of contaminants from the landfill. The process of establishing a.dditional
locations is ul'\derwa.y.
• The existing surface water and sediment sampling locations are also po~rly located an.d_ will
not intercept potential releases at the earliest stage, Here to, the estabh~hment of additional
locations is underway
The Hollister Building• 35:35 Law1on Ro'9d • Suite 111 • Orlando, Florida 32803
Offiee ( 407) 6Q6-8608 • Fa:x (~07) 896•1822
£0'd
R~comm~ndation5
• Redesign the environmtnt11) monitoring network.
• Move immediately towards complete detoxification of the landfill contents .
• Install a carbon adsorption filter on the main landfill vent.
More detailed discussion of these items arc available through the PCB Landfill Offic,e m
Warrenton -[phone].
I )-2S11.m.doc
The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando. Florida 3280:3
Office (407) e9e-aeoa • Fax [phone]· 1822
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FAX COVER SHEET
To = _ __.B=-4,t.4--1-Jb'""""------'=L~e"'""uL.L/....L.1-=s'----------
FAX NUMBER: S~/l---35 ~ 7 PHONE:
PHONE: 73.,3-4996
COMMENTS: ------------------------
TOTAL NUMBER OF PAGES INCLUDING COVER SHEET: /~ . .
DATE SENT: l~/aql,tt Ed/ '
~El A1B EMIS&JQN§ ANA HfiA!-TH RISKS
fBQM THI! WAAAl!N OAMNYY
Su,nmao:
pea LANDFILL
Joel S. Hirschhorn, Sci"ce Advisor
Warren County PCB Landfill Working Group
November 27, 1996
Data obtained from a 1983 EPA study showed con.elusively that uncontrolled releases of
PCBs into the air were occuning. Neither EPA or the state analyzed the data properly, and EPA
madi::: incurrect statemmts indicating there w.s 110 problem, even though no analysis mpported
the statements. In fact, the levels of PCBi found by EPA in the air near the lmdnll and in the yard
of a residential house more th.an a hAlf mile from the landiill were $tVeral times greater than tht
level of health significance found in EPA' s own risk assessmorts. The PCB levels foWld in the
winter of J 983 v-.·ere significantly above the one in one million c::icccss cancer death risk based
co»ccntration presented in EPA databases. PCB emission levels in warmer periods and in later
times du.ring the past 14 years since the PCB wastes were buried in the lalidfill could luve been
significantly higher. E.,q,o~e over long times to relatively low levels of PCB!i could also cause
non-cancer health effects, csp~ially in children. The PCBs rcle~sed into th~ air could also n:sult
in PCBs bcing deposited on nearby lands and, therefore, contaminate crops: local vegetable
gardens, and daicy and meat products ftom cattle grazing on local lands, leading to exposure
routes other than inhalation.
Arr analysis of rhe on(), 1t11~ document$ referring to the 1913 study by EPA @d the
only informatffJfl givui to tht public has shtJWn tlaat tlrt statt intardonally misNp,estntitd tht
findillgs of the 1983 tests for PCB t1ir rcf~a.su from tit~ land/UL For cxampl~ the highest
lcv~ls <>/ PCBs fou·nd at the landfiU's main vent were not reported b)' the ~t11t~, and tlae state
indicated that no meASKrabi~ amounts D/ PCB1 had been/ ound in the air 11rovnd tire siti:,
which was not the ctue.. The itat~ has penl.ste11tl1 deceived the public about PCB ai, releases
and, more importantly, tht significant.public health ri1ks resulting f,o,,. t/s~,n.
The reslllts reported here supply still more support for the st:nc takiDC seriously its
commitment to detoxify the Warren County PCB Landfill and to make a commitmcat for
supplying the nece:,sary funding very quickly. Tb ere u oow abundant proof that the
landfill bas not been safe and secure, that the crtticslly important bottom clay and plastic
liner system lesked almo,t immediately, that the lcschate tollectioa system never worked
effectively, and that PCB:11 h•ve leaked dired)y into die air and leathate iuto the
surrounding soils. A .number of new tests are rccolllllleildcd to assess health risks.
I
My revi¢w of the PCB fil~s provided by the state indicated very little attention bad been
given over the years since the landfill construction was completed in 1983 to the potential for
human exposure to PCB air emissions from the landfill. Many people ma)· have believed that
PCB$ do not pose hazards because they are not volatile organic compound.$ (VOCs). However.
althQugh PCBs are not classified as voes, they do poS&ess sufficiently bigb vapor pressures to
rcleue potentially significant vapors into the air, if no pollution control technology is used to
control such emissions.
Tne one, most important document found in the state files wis a copy of a professional
pllbJished paper entitled "Measurement of Fugitive Atmo~bcri, Emissions of Polychlorinated
Biphenyls from Ha22rdous Waste LandDlls" (ItG. Lewis et al, EnvironmeDtal Sc:imce and
Technolog), vol 19, no.10, \Q85). The two lead authors were affiliated with EPA's Research
Triangle Park facility. No document was found in the szate filts that provided any analysis oftbe
information and results in this published paper, e$ipccially with regard to the Warren County PCB
Landfill This was especially significant, because the paper provided data 011 the Warren County
faciliry, probibly the only data C'Ver obtained on PCB air releases from the landfill.
The publishcd paper noted ill its introduction that "PCBs pOi~SS suffi~ently high vapor
prcssurc ... to be emitted directly into the air surroundini hazardous waste .tisposal site$ through
volatilization. from conttmin.tted swfaccs. They also may be released from controlled lmdfills
throll!h vents, along with more volatile gases. 11
The paper presented the rcsultJi of field testing at four PCB landfills, includmg the Warren
County fadl.ity, which "was srudied to determine if PCBs were being emitted into the surrounding
atmospheric environment ftom sas vents and leachate access ports." The paper characterized the
Warren County Landfill as "ToSCA-designed" and referred to it as 1 "statc-of-the~an landfill
designed to exceed the requirements ofToSCA II These statemcnts referred to the federal Toxic
Substan~s Connol Act, the key federal law covering PCBs. But the paper indicated that the
l.a.udfill had a perforated pipe leachate collection system, which in fact was not installed, a.ud did
not recognize that the state had received waivers from certain landfiU requirenu:.ots, rahing doubts
about the paper's accuracy in dc:~"bing the la.odfill as statc:-gf~tht~art. The authors clearly
wanted tn use the Warren County Landfill as a control landfill against which to CODlpare data
obtained for other lcs, 50phisticatc-d PCB landfilb ("in the vicinity of one city in htdi&na") that
were described as "uncontrolled landfills'' where PCB materials were dumped or disposed and
were probably Superfund cleanup sites.
It should be noted that the experimental field work used sophiiticatcd and accurate
met.hods for collecting and measuring PCB levels in air. Also, the field work was conducted in
January and February 1983, which was some months after the PCB wastes were buried in the
landfil~ before the leachate collection system. pumps wexe first turned on, ap.d before the land.fill
construction was officwly considered complete.
2
£(I 'd 6£:ZT 96 , lZ AON
It is also important to note an imponant inconsistaicy iD the statements made in the
published paper, because non-professional people who may read the paper could be mismformed
or confu8ed. There were two statements about the significmce oftbc findings for the Warren
County facility. The paper' 5 initial summary said " ... air levels were at or nea.r background at the
T oSCA~designed landfill. PCBs were detected at low levels in gu vent$ at the latter [Warren
County] site." In the paper', section with conclusions, in referring to the Warren County facility,
it was said that "air emimons of PCB from a well-designed chemical waste landfill were found to
be negligiole." Tt is important to note these two statements are 11ot equivalent, because low
i~ not the same as nqlicible. Neglipole means illconsequenrw or insignificant, but .a level tbat
is measured may be low without being either incoosequco.tial or insigninoant with respect to some
important potential t!ffcct of PCB emissions. Moreover, drawing a conclusion that measured
PCB emissions were "negligible" requires much more analysis than concluding they are low,
because one must answer the question: negligiole for what effect? The easier task is to conclude
that the cmis5Wlls were low, because that could be: logically based on a comparison with 5imilar
data for the other landfills studied. However: to conclude that a level was negligible implies use
of sorn= uthcr criterion or effect, which normally would be for health risks. ln fact, the published
paper pre$ellted no analysis whatsoever in justifymg any conclusion in relation. to health risks.
The present rq,ort provides such an an~s.
It should be noted that the paper paid particular attention to the history of the Warren
County Landfill and included reference to "the great amount ofpu.blic concern ov~r the safety of
the disposal site . ., Moreover, the paper said: "Several months after closur~ of the landfill, local
residents voiced concems that gases emanating from the vc,:i.t pipe and (as ·yet uncapped) leachate
collection pipes may have becm inuoducing PCBs .into the SUJI'oundin8 atmosphere. In response,
a study was undertaken in J.m and Feb 1983 to monitor these emissions and the ambient air at the
site." Thus. it is fair to interpret the paper's statement about "negligible" air emissions to have
referred to health effects and public concerns about heahh eff'eets. It i$ also reason.able to believe
that the all the data from the EPA study and a highly objective, professional evaluation of the data
would have been given to local residents. This Science Advisor, therefore, also has closely
examined what information was commumcatcd by the state to the public.
Analyst, of Data
Data were obtained for PCB emissions (for Aroehlors 1242 and 1260) at the main vent~
the upper and lower le3ch.ate access poqs, and two small vents ( created by placing pipes in
surface bubbles in the thin plastic liner on top of the land.fill). Measurements were also made ''m
the yaTd of the nearest house (l km away)." This is a little over onebalfmile away from the
landfin.
The following are the most important observations about the data presented in the
published paper:
■ The highest levels measured were at the main vent. The highest level was 120.2
3
• • •• o •'' __ ,,..I ,-, -
tn)"d
micrograms/cubic meter (ug/cm) for Arochlor 1242. In trying to compare tJus level with
the other highest lev~ls fO\lD.d at the other three PCB landfills is difficult, be~u~ the study
used different modes of measurement. A bi~ diflerence is the height at which PCBs were
measured. For the Wan-en County landfill, the measurements at the mam vent ue
somewhat difficult to compare to ones made at different heights abov~ an open. landfill
location. Different heights mean that the potem.ial for diluting PCB vapors increases with
increasing height abO\'c the PCB waste. The published paper never made any expliclt
4!lalysis of the data from the diffetent landfills. How~1Cl", the paper focused on results
from measurements at 120 to 180 cm for the other three ledfilb, which is somcv.hat
analogous to the main vent pipe conditicm at the Warren Cowtty landfill For this
comparison. the n:ia."WJJWD level !o'lmd at the main vent was actually higher than IDOst of
the maximum levels reported over hot spots (i.e.: areas ofbigh PCB levels) at the otl1er
three PCB widfills ex.a:aJm.cd in the study, with the other, corre$pondmg values being
18.0, 33.8, and 193 ug/cm. But these other levels were fouu.d for field tcits conducted in
the ~•rnmer of 1983, md the paper showed that PCB levels were vn;· much higher in
JUDe/July thau in October, with the av~agc increase being about 200%. This .mg_gests
that the maximum level of 120.2 ug/cm found in Jan./Fcb. in Warren CO\lllty could easily
be 200C>.•, or more greater if measured in the summer, or perhJps some 3.50 ug/cm. In
fJtJter words, tite high levels./Ollnd llt the maill vent at the Warren County Landfill
Kirt quiu comparabk, and puhaps evert great~r than tht levels/Ollnd (UJ(Jvrt t/re otlto
three uncontrollt!d l@df dls, contra')' to the siatun~nt mad~ m t~t publishtd poper that
th~ levels wue "low. " ·
• It is important to note that the study also found that only the main vent was releasing a
positive gas flow, but there was no measurable gas flow for the leach.ate collection pons
and small vents. This mean5 that only the main vent was serving Ii a source of PCB
releases into the air during the wiutcr period of th.c study. 1bis fact does not chmgt the
accuracy of the measurements of PCBs at the other loc.ations, but only that there was no
imasurable n.-tural flow of gas out of those other openmgs at that time. The study
mc.1surcd th.c actual mass flow or flux rate for PCB releases from the main vent as 12. l
nanogramsisecond (ng,'s). In other words, any staU1ttmts by govern,n~nt officials tltat
no 'PCBi w~r~ being rek(l$~/rom the Warren County Landfill 11·ere touilly
c:Olft.rt1dictory to tit~ acruoljkld data o6tain~d in early 198.J. The £~'4 sl"dJ' metU11nd
1111controll~d rdeases of PCBs from the l@dful which probably would be signijicaJttlj
highu during wtUmu periods.·
■ The next highest levels were found at the upper leachate access port (2,·o of 1242 and
25% of 1260). lms is oon~tent with contaminated leachate residing in the upper
leachate collection system at the time.
■ Much lower levels were folmd at the lower leachate access pon (.03% of 1242 and 2.5%
of 1260). For both .PCBs, however, there were positive readings above the very low
detection limits reported. In other words_. r/a trt were rcliabl, f111di11gs of PCB ,1apors
so·d Tt:CT 96 , LC AON
from th~ lowo l~acllate collection systun b~low th~ main day 1111d phutic bottom linl!r
.tys~ This iJ,dicaud that PCB contaminaud wuJ,.au had readred the IOttJer
/eac/ttn~ collection ,y1um ut early 198J, HC#IIS~ there is 110 other puu,Jible
aplanatiOlt for flndi11g PCBs ln tlil! air draw11 from th~ acuss pipL EPA 's fu,ding
was conslsunt wiih leaking of contaw,.i.naud letidtau through both a.~ clay layer and
plastic bcttom liner i11te> the Iowa-leachllk ,,.c,,aitori1tg and collection layu ond sump.
■ Even hjgher kvcls of PCBs were fou.od 1t the two szmller ve21ts, with the: vent with the
hipest readings showing levels in the rmgc found for the upper leachate access pipe.
• Although most of the measurements at the closest house were below detection limits, one
of the sjx measurements was at 0.01 ug/cm for Arochlor 1260 (the more toxic PCB). The
key question is: is this concentration of PCB of health significance? To answer this
question one can consult several EPA risk asse&Sment type databases. Both EPA Region:,
3 and 9 maintain such databa$eS and th~· contain the level$ of PCBs in air that pose an
ex,c5s cancer death nte of one in a million ( or 10-ti) for residential exposure. 1 Those
concentrations are 0.00081 and 0.00087 u.glcmin the two EPA databases. Since the
measuted !eve] at the house was 0.01, the data ib.ow th&t the cancer risk lc:vcl at the house
Wai about 10 times greater, or approximately 10·5 risk. In other words, tbt winter-time
high reading at the house that wu over one.half mile away was of considerable
significance. Abo, the other findings that were below the detecti.oo limit$ of0.006 and
0.01 ug/cm for Aroohlors 1242 and 1260, respectively, are also sigilificam. The reason is
that the appropriate EPA methodolo!)' i.s to use onehalfthe detection limits when
ass~ssin! health risk, rather than &$$Ume that a nondetect is a zero conoent.tation. Thus, it
is proper to assume that most of the readings at the house would have been 0.003 and
0.005 ug/cm., and these are also above the IO'"' risk li:-,cl of0.00081 and 0.00087 and
correspond to riciks of3 to 6 x. 10·~. In otli~r words, all ofth~furdinpfrom tJu
published paJHr show that /e..,,tls of PCBs found at the residence cw,e:1,1 to the WarTQI
County 1.41tdflll In tlie winter of l 98S w~r, of lcca/th signifK:a,ace and, Inf aa, poud
aff w1111Cctproble /.ong term cancer risk. In all probGhillty the PCB levels found c,ffsite
wo11/d have l>etn conslduohly hirher In warm~, pui«ls, and m"J' also /save usc.reased
01Jertim~
• The Study al50 found measurable PCB lev~ls m ambient air at various other location~
particularly• uumbet of readings at the fc::nce line and downwind, with the m.ucimwn level
fouod at 0,07 uglcm, \lruich is som.e 100 tim.cs g,eatet than the 10~ cancer risk level, or a
risk of 1 O"', which is a very high risk level. This finding was even more evidence that PCB
releases &om the landfill were occumng.
■ TI1e pap~r did not pay close attention to the differences found in measured level& of
1The 10·' cancer risk level is 1he b~ crilcriou to use: because .it is 1be most used basis for
cleanup decisions in the federal Superfund program when residential exposures are appropriate.
s
Arochlor 1242 versus .Arochlor 1260. It is kno'WD. that the vaporiutio11 rates decrease
significantly with increasing chlorine content and the vaporization rate of 1242 is about l 0
times higher than for 1260. Because the water solubility of 1242 is about 100 times
pcatcr than for 1260, one would also expect more 1242 when leachate is the source of
PCB Y1pors. for the most pan, this relationship exuted in the data rcponed. For
example, for the mam vent data the average level was 120,2 ug/cm for 1242 but only 2
ug/cm for 1260. What merits some consideration, however, is that over the longer te~
the more slowly vaporizing but more toxic Arochlor 1260 will be expected to represent a
higher fraction of all the PCBs emitted &om the landfill
ln(orp1atign b;oyjdc4 By Ibc State Bu IHI Wr9De
Only three pertinent documents ha,·e been found in the files provided by the state. First,
the state's description of the bndfill and its chronology ~ntains a statement that in Jmuuy 1983
''EPA monitors p5 venting from landfill cd reports no significant emissions of .PCBs. 11 Use of
th~ t.:nn significant is like use of the tenn negligil>le by EPA, discussed earlier in this rQon. The
secmiD.gly simple statement is in fact incorrect and misleadin~.
Second, the second page from what apparently was only a t\\'O pasc actual repon from
EPA about the testin5 has been found in the .6Jc3 provid~ by the state. 2 T:h~ conclusions
presented in this on.c page section reveal a superficial analysis of incomplete data and a clear
attempt to dowuplay any health risk issue related to uncontrolled air releases of PCB&. It
certainly would have been normal for EP~ personnel to prepare some type of report for the state,
especially smce the study of PCB emissions was reportedly done because of citizen concems
10ne undated page was found; it is titled Section 2 Conclusions and the page number is 2
and pre~ted four conclusions1 indicating that the first and only other page may have been a brief
dcs..,iption of the field work by .EPA. Hand written statements at the top of the: page arc: ''Au
Quality, Monitoring .Data from Jan. '83, Air Vent (6" PVC) Warren Co. PCB Landfill." Most
likely the brief report was prepared by EPA during the latter part of 1983 or early I 9&4, perhaps
before an the d:ua was fully assessed. The first conclusion noted ~t the main vent was ''the
principle ~urce of emission, " The average values given for the two Arochlors match tho$c in
the published paper. The firSt eoncl-usion also said "These concentrations arc 5Ub5tantially lower
than the current occupational standards for workplace atmospheres ... " But workplace standards
are set for short time c-xposure and acute health effects. The secQDd conclusion referred to
amb1=it PCB levels, but did not correctly refer to levels found above detection limits. The third
conclusion referred to the result$ of~thematicil modeling, 111d stated that level$ would not be
~gnific:mt, but no mention was made of the positive finding at the nearby house. The fourth
conclusion predicted that the low PCB emission rate would be reduced still further because of less
decay of organic matter and production o{methane and by "removal of water from the site" that
should "reduce emission .-ates substao.tially." But the state says that methane is still being
produced and the water was not removed.
6
8 d
Third, a page titled ''PCB LANDFILL MlSCELLANEOU ~ ~AM-"U:~ -prcparea oy tne
state's Division of Solid W astc Management Division, and given in a documai.t entitled Sampling
Analysis, md .Uachste Removal Activity 1982-1993 (delivered to the Working Group in April
1994 ), contains lour results of gas measurements in J anuuy l 983, which is the EPA worli.. The
problem is that the dau do not match the data iD the pu.blished paper or the information in the one
page of conclusions .a.ppatcndy prepared by EPA 3 Some especially significant discrepmcies a.re:
■ The state reponed the highc::st level of PCBs found at the "gas vent exhaust'' (surely the
main vent) as "3 .0 PPB" (three parts per billion), which equates to 3 ug/cm, in comparisoo
to the .tctua1 maximum level reported by EPA of 120 ppb in the published paper and 123
ppb in. the one page of conclusions. Even if the state argued that it never closely e,wmned
the published paper it had in its possession for many years, it surely had the short report
prepared by EPA for the state so it could address public concerns.
• The state reponed for "ambient air samples" the result of "none detected1 .. but the state
failed to report the finding of PCBs in tbc air at the location of the house about a half a
mile from the landfill1 which is a very significant distance to find such measurable levels,
nor the positive £in.dings at tbc fCD.cclinc, as reponed in the published paper. Tiu:
statement in the one page conclusions page from the EPA report that ambient PCB levels
••were found to be at or below minimum det~ction limits" was definitely oot in agreement
with the data reported in the published paper, that inchlded four readings significantly
ab(,ve the detection lilnit. The only plwsible, acceptable explanatiou might be that the
brief EPA repon was prepared prior to completion of EPA 's analysis of all of its field
dau.. This would be consjstent with. the desire by the state to rccei\te the findingi oftbc
EPA study as soon as possible in order to address the consider.able public opposition of
Warren County residcnts to die landfill. In any event, the state had the published paper,
that clearly revealed the positive findings of PCBs at the fencelme ind the nea.rby house.
• The state reported for the-''leacbte collection pipe exhaust" a result ofleS£ tlwl ODI! pan
per billion. Since EPA me.mred PCBs at the both the upper and lower leaehate wUcction
access port$, the statc,s information is at best incomplet~ and at worse mwcadmg. The
State would logically have had a problem with explajDing any positive finding of PCBs
from the lower a.ccess pon. Tb~ one page of EPA conclusions did :11.ot inc~dc any data
for the leachate oollection accc$$ ports, raising the question of why the state teported less
th111 one part per billion, especially since the state had the publi&.hed paper tlat includ~
the maximum value of 2. 6 ppb given for the leachate acuss pons.
JJt may be significant that the data reported were given for January 6 and 12 only, but that
the published paper said that the study lad been undcl"takro in Januuy and February, suggesting
that not all the d3t:i became tc;.;ognizcd by die state, even though it was published in the paper by
the EPA scientists in 1985 and the state office had tlut papu for IIWly years.
7
HO~.:l
Becaus~ there a no et1ide,.u that tlae ac:111(,1 EP.-4 report or the publisl,cd paper had
btt~ provided to d,~ gttnaal public or the Working Group by the state, these discrq,ancies in
th~ only information made available tkmonstrat~ thllt tl,e nate ilt"ntio,rally misnFU~t~d
tht!j111di,,g1 of the 1983 tests/or PCB air rekaesfrt>m tli, ltutdfllL This wa done most
r,u:entJJ ;,. 1994. SffD'al coplu of the 198S publlsh,d pap,r w~rttfou11d in sttll~fllu"" thtt
landfill witlJ "marki,.g tl,a1 tlu paper had hem rectti'lttd ln 1986. .A,ll tli,facts show that the
stau ha Jteodfastl)· decei11ed t/s,e p14blic about tht dlltt1 and, morC! itnporta,rtly, the
:significan~e oftls,fuuling:s with rcspttct ID pllbllc /,ea/tit risks. All PCi tmls:sk»u could l,11:-1e
/,~a prevt!1ttt!d at "'u.imal cost bJ using some form of carbon 11ds"rptit11t tk11ic~ at oil l«mlflll
gas exit ports.
,. cl . PP HUPN
The concerns of Warren County residents about uncontrolled releases ofPCBs into the air
emanating from the W arrai County PCB Landfill were well founded and, in .&ct, proven by the
1983 measurements made by EPA, but inconectly di$l"egarded by EPA as well as the state. In
fact , the record shows that the state ha, explicitly misrepreseuted the facts of the EPA study in an
attempt to undermine the concerns of Warren CoWlty residents about the health risks of PCB air
emissions. Although many rc,idtnu hne btta vuy concerned about. drinkillg water bting
eontamin2ted, aU tht available data indiute that public health risks resultmg froui PCB air
emi.uions have probably been the most sicnifica11t threat for resident, li,in: relatively clo.se
to the landfill.
It is disturbin.g th.at EPA scientists made explicit statements designed to counter the
concerns of citiuns aud that those statements were not supponed either by the facts or any
an11ysis. Of course, EPA itself had give'll the state not only approval to construct the landfill, but
also financing for it, so it was not a completely impartial party, In fact, the levels of PC/Js
metUllred in 198J were ncitlro low or nqligihle, 4S EP.◄ claimed. Tiu rwo c/tief
co11sequasas of reaching tlte wrong concwsio11s was that no £mission control tt!clr1tology WCI.I
used t<J pr~t1ent PCB "j' rel1«us and no odditi<mal m,mitoring wa carried out If EPA had
co1nc to the c:ond11sion that si'pljlcant kv~ls of PCBs were b~ing emitted from the Iandfdl,
the serious Cbncerns of local residmts would /,ave bttusfully supported hy tht/edtNl
gova-nment. ft would J11ive been ,q,proprim~ /or EPA, on th~ basu of Its initial ftndJags, to
/,av~ co,,dwctt!d another rou11d of more atensive air monitoring in die summer of 1981,
uptcially ot lwnauius withht 011e to miles of th~ landfill.
As to the issue of PCB health effects and monitoring, it should be noted that the fedeul
g°" emment had examined the issue of whether exposure to the origin.al PCB spill materials on
North Carolina roads resulted in .increa~s in PCB levels in breast milk. The study was completed
in 1982 and published in 1983 (W.J. Rogan et al, Chroma.to graphic Evidence of Polycblorinated
Biphenyl E,cpo$U!e From a Spill, Journal Amuk:m Medical Assocmion, voL249, 110.8, pp. 10,1-
8
80"d
1058). The researchers at the National Institute ofEnvitonm.cntal Health Sciences concluded that
the data for· 12 exposed women that had been pan of a larger study indicated that some pan of
the PCB leveh found in their bodies correlated with the types of PCB& spilled 011 the roads. The
women had been exposed to PCB vapors from spill locations along roads. It would bave been
vecy useful to monitor tb.e PCB levels in br"st milk in women living near the W men Cowity
landfill, but that did not happen.
The levels of PCBs measured during the l 9ti3 winter period around the landfill and,
especially, in the area of the residen.;e closest to the landfill, were ofhetlth significance and
concem. lbere is every reason to believe, on the basis of scientific principles, that emissions of
PCBs from the W arrcn County PCB Landfill have been sipificant for over 15 years. Release
rates would probably have be=i greater in warmer periods and may have changed over time a5
more time was available for vaporization of PCBs within the landfill, as compared to the early
J 983 period, just a few months after the wastes were buried in th.c landfill. Although local
residents report having asked the state over the years to \UC some type of air pollution control
system. suc.b. as carbon adsoiption: the state: never implemented any control method.
In addition to cancer risks, however, attention must also be given to non-cancer beahh
effects that could result from long periods of exposure to relatively low PCB levels. Also,
exposure dwing pregnancy is a threat. Research at Wayne State University and published in the
New England Journal of Medicine iD September 1996 repo.rtcd developmental effects in eleven-
year old children whose mothers had consumed PCB contaminated fish in.:the I 980s while
pregnant. At birth children had smaller heads and lower weights, and later: children had lower IQ
scores. poor read.mg comprehension. memory problems and shorter attention span. Similar results
have been found in several animal studies and in studies of Taiwanese children accidentally
exposed to PCBs. The damage to children was d~ similar to the effects of lead poisoning in
children.
The air release of PCBs also raises questions about other exposure routes. For cxampl~,
air releases ofPCBs implies that some PCBs would be deposited on the local surrounding lands,
some of which are used for agricultural pmposes, suggesting that crops, vegetables gro"Mt in
houscb.old gardens, and dairy and meat products from cattle grazing on local lands could be
sources of PC.B exposure through ingestion, not only for local residents but perhaps for o\hers.
There is clearly a need for the st~te or EPA to conduct several types of tests, including the
following:
■ Current PCB emissions rates from the main vent and any other points open to the
atmosphere should be determmed using the most sensitive and reliable testing m~ods.
■ TestinE of PCBs iD human tissues among adults and children who have lived near the
landfill for long times should be conducted.
9
60 .d •-~'-' • 1 ... 1~1 ; I I ~1-/?'.-t7
df'1CkJ:1 :If'.! I >kl[iJTJ 8Jd
■ li"1lh effects surveys should be couducted for Ions tcnn nearby residents, especiall)·
children bome by mothers that Jived near th.c site during pregnancy.
• There should be some tc:sting of locally grown fruits md vegetables (and perhaps canni:d
locally grown produce known to have been grown some years ago).
If PCBs a.re still beiug released from the landfill, then an enpeerin.g study of using some
type of ca.rbo.n adsorptiou system. should be immediately in.itated.
Finally, the ruults reported here supply still more support for the ,rate aking
scfi01Jsly its commitment to detoxify the W arrea County PCB Laodrill and to make a
commitment for 1upplying the necessary funding very quickly. There is DOW abundant
proof that the lsndf"all h•s not been safe and H~ure, that the critically Jmportant bottom
cby .ind pl•stic liner ,ystem leaked, that the leachate colledioa system never worktd
effectively, and that PCBs have leaked direcdy into the air sod leach~te into the
!lun-ounding soils.
10
OT "d
SENT BY:REGION 4 OEA/ORC ;11-26-96 3:56PM :ii,U S E P ,\--1 919 733 4811;# 1/ 7
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. SENT BY: REG ION 4 OEA/ORC :11-26-96 ; 3:56PM
1/1,f,
Work Plan: Detoxification of the Warren County, North CaroUna,
PCB/Dioxin Landfill: :{'.i/ 'l•\,.!I·•
I. Restoration and Justice
j;J 919 733 4811 ;# 3/ 7 -q
• . •r' ~~
In D~mber, 19~8 t~e state of North Carq_tiN:annouQqed _its inte_ntion ~? site a PCB
landfill ,n poor, m,nonty Warren County "r1,.{Wf;,4less of pubhc sentiment. In response
to this announcement. Warren County Citizens Con90rned About PGB was formed.
Citizens began immediately to educate themselves, the community and the state on
issues relating to PGBs and landfill technology, particularly concerning the criteria tor
selection of sites and the significance of EPA regulations"'fnd waivers.
With no money to support their efforts (except the very little from local fundraisers).
citizens launched a four-year education campaign which reached out to local
churches, civic groups and community organizations. Class distinctions a~ racial
barriers were crossed, and people began to walk together down the long rdad to
environmental justice for Warren County. They prayed together, shared information
together and gave encouragement to those who felt there;;~~jttle hope for justice
for a poor, powerless county such as Warren. Finally, attflpµglf the state and EPA
agreed that the Warren County site was intrinsically unsafl !t~nd although soil
scientist Professor Charles Mulchi of the University of Marylarid concluded from his
own test borings that the site was intrinsically unsafe and 6.'ciUI<jn't be made sate
With engineering principles, the state ordered on September :1'5, 1982, the trucking
of 40,000 cubic yards of PCO-contaminated soils to the Warren County site, and, using
almost one million dollars worth of force, inadvertantly triggered what the QµJe
Qtl_ronicle termed "the largest nonviolent C!VH.dlsobe<f!~nce In the South since King
marched through Alabama." The,.e were .~f1JN'eeks of1sustained demonstrations and
nearly 550 arrests, It was the first time In tfistdry that citizens went to jail attempting to
stop the siting of a toxic waste landfill. On October 12, 1982. Ihe Washingtoo.J:QSl
celebrated Warren County's marriage of civil rights activism with environmental
concerns. The environmental justice movement as we know it today had begun. ~ti, : . •,
Over a decade later, in 1993, the state of North Carolina announced tllat ttiere was a
crisis at the PCB landfill because of 1.4 million gallpns of water that threatened to
.breach the liner. In response to the announcement, warren _county Conc~rned
Citizens formulated a framework for resolving the crisis to which ths state'i}reed.
There would be no "banctald" solutions. no trucking of the wasts to another· commun-
, ity; 9nly a permanent detoxification solution would be accegt~bJe. The Joint Warren
County/State PCA Landfill Working Group was fo,.med, ip~~i ~ijp of local citizens, local
and state officials, and local and statewide ecumenical ah:ofenvironmental leaders. :r~t~/
The objective of the PCB Landfill working Group Is enviro(lrqe,;rtal justice for Warren
County: detoxification, namely, the restoration ot the Warren,'.b6unty site to what it was
before the forced siting of W82. Warren County Concerned Citizens continues to work
through the Joint PCB Landfill Working Group on the many issues concerning de-
toxification and environmental justice for Warren Coyr,ity. Church, town meetings, and ,;\:};;: ;;~r
,tiirllf'~ f ~i..1~.;~_r:'
' SENT BY:REGION 4 OEA/ORC ;11-26-96 3:57PN 919 733 4811;# 4/ 7
public forums will continua to educate and empowP-r the people as they become
real stakeholders In their community'5 future1, &··
.~t ···.{-/ ~1-i··
What has the PCB Wmking Group accom'~!t$h:ed thus'~ar toward the achievement
of its objective? It has hired an independtfrifscientlst to futly characterize the site and
take split samples with the state. Test data from the independent scientist as well as
from the state confirmed the presence ot significantly high concentrations of the most
dangerous kinds of PCBs, furans and dioxins, induding w,tra dioxin, the most
dangerous of all dioxins. Tetra dioxin was also found in''two groundwater monitoring
. wells outside of the landfill at 80 parts per quadrillion while EPA's maximum allowed,
concentration is 30 parts per quadrillion. The presence of dioxin in the monitoring
wells cannot.be attributed to background contamination (for ~xample, the,R8st use of
agricultural chemicals sucl:l as chlorinated hydrocarbons) because the iild:ependent
scientist did herbicide and pesticide background scans and, found no detections.
There is no controversy concerning the test data, and fu~l:l~~t~sting is not necessary . ·•,-:=t~.r, .... , ..• ,
for the detoxification initiative. r;}?l>f~JJ·'· . )i;J~tr: · ·
Considering the cost of long-term monitoring of the landflfi~~nd the cost of monitoring
residents' wells in the area (Governor Hunt promi$ed in t~a;tt,o test wells in a three-
mile radius, and each independent dioxin test can cost fr6rrt $3,000-$3,500 per
sample), and considering the potential for extremely expensive litigation, It Is therefore
cost-effective for the state of North Carolina to detoxify the Warren County PCB/Dimcin
landfill. .~--\ .. ~~;t i-i i\: . ~r
What's more, the potential threat of risk ~Jtfotns continuous, and even Governor
Hunt in his 1982 letter to the citizens of. Warren County stated, ~You and I have
seen that scientists can disagree, and their disagreements concern us. That is why
I intend to see that the state of North Carolina keeps its commitment to you. your
children and your grandchildren to continue to press for taetoxification of the site,
to closely monitor and to guarantee its safety for generations to come. That is tile
pledge I made to your representatives in my otfice last Friday, and it is the pledge I
make to you now.'' ~-
II. (A)
, J ~
:· t:;j'
Over th~ years, Waf!en County Con~emed Citizens ha~~l~ifworking with
ecumenical and environmental IE!aders at the local. state${iritl national levels, and
from these relationships has emerged the Ecumenical Efj~ironmental Leadership
Coalition (EELC). sponsored by the local, state, and natiqt:Jal iEpiscopal Church.
The coalition consists of representatives of Warren Courity,JHe Episcopal Church,
United Church of Christ's Commission for Racial Justice, The North Carolina Council
of Churches, the Southern Christian Leadership Conference. NC WARN (the North
Carolina Waste Awareness and Reduction Network,}, BAEYDL (the Blue Ridge
Environmental Defense League,) and Gf~ef1peace.:J1-fhese organizations are working
and will continue to work with Warren Cfpty citizens and with the P~ B Landfill
' SE.NT BY: REG I ON 4 OEA/ORC :11-26-96 ; 3:58PM 919 733 4811:# 5/ 7
·, ~---
Working Group to motivate the pUblic to b~}:npr:e cons~jous of environmental justice
issues, particularly as they relatG to Warre;i p;unty.
II. {B) ·
In November, 1994, the Joint Warren County/Stata PCB ~~dtill Working Group
unanimously voted to recommend to the governor that detoxification of the landfill
begin as soon as possible. Several technologies were studied, but the agreed-upon
first priority was Base Catalyzed Decomposition (BCD), or some closed loop treatment
employing BCD. that would meet tne criteria of being EPA dem·onstrated a~pffective
on similar waste at~eams on North Carolina sites. BCD is being used to cle~n up
sites in Morrisville and StatesVille, North Carolina, and BCD would meet the criteria
of being EPA and state approved, and would, most import~n~Y'.ipe acceptable to the
community. _ /.i~~~;\•.f.:, \:.:f ("S'' .
By detoxifying the Warren County PCB/Dioxin landfill, twci'':(fytportant fundamental
precedents will be set that will be widely applicable. Throµg~JJ,e democratic process,
Warren County will resolve the PCB/Dioxin crisis with the state{and the EPA within
a mutually agreed upon justice framework centering on detoxification and formulated
by the citizens themselves. Second, detoxification will establish the precectents that
reflect EPA's own staMory preference for Olifsite, peri;i:ianent destruction technologies
for the treatment of dioxins and othQr wa~tj §.f\vherevef"possible. destructiOn
technologies crucial to preventing contindilrr-rrfonitoring and liability of potential
ott-site contaminant migration.
To achieve environmental justice for Warren County through detoxification of the
FCBfDioxin landfill by working with the very Governor tha'.t' sacrificed Warren is to
encourage the perception that the state of North Carolina and the EPA really do
care about poor black and other minority communitiAs and is to establish that
EPA's environmental justice program is for real. This is true espec_ially co9~idering
the symbolic significance of Warren County for ecumenical, environmenta(and clvil
rights organizations· across the state and nation. · ;-
II. (C) (t~w
Environmental justice for Warren County will require a cciH't:~rted effort on the part
of local, state and EPA officials to est,llbllsh sources tor fuMdip9 for detoxification.
Warren County citizens and the PCB Landfill Working Grbup :will continue to help
facilitate this effort through various means of communication. Efforts thus far have
included attending and speaking at EPA hearings (including EPA's Region IV Dioxin
Reassessment Hearing and the EPA sponsored Fed.<;lral lnteragency Hearings in
Atlanta,) meeting with Secretary Jonatha_g\H~~es, Department of Environment,
He~lth ~nd Nat~ral Resources, and ma~~Jtresentations to the No~ Carolina
Leg1slatrve Environmental Review Commission. ·
The local community, as well as citizen~ across the state, will continue to be informed
(3)
_, SENT BY:REGION 4 OEA/ORC :11-26-96 3:58FN 919 733 4811;# 6/ 7
.1:·},,; l~:i\·
through various publications and public tf ffl~ on issues relating to the PCB/Dioxin
landfill crisis, relating to the potential threat of continued risk to the community, to the
permanent reduction of this risk through detoxification, and to the powerful precedents
that will be set by the achievement of environmental justi9e for Warren County.
Ill. . _ _.;: .,tt
In order to achieve environmental justice tor Warren County through deto><ification
of the PCB/Dioxin landfill, political and economic challenge~ will nave to be met and
overcome. With the deep con:,mitment at Warren Coun~Jr-Pn?,3r,:ied Citi~ens and with
the concerted efforts of the Joint Warren County/State P.9,~)-~~ndftll Working Group,
in the spirit of cooperation, the process has brought the qg~nty doser to its goal of
detoxification, and these efforts will continue to do so untit::?.t~te and federal funds are . th' d 1·,_·w1'\-::,r.-. ~ committed to rs en . if' · '.i(:.Y .
:,,."i ,-i I ~• 1
When detoxification is funded. succAss of the project will be reflected in tne actual
success of Base Catalyzed Decomposition itself. Ul~imately, success will also be
reflected in the new image that Warren C<>Lintv will hijye, an image based not on the
failure of a dangerous landfill but on the .~§.~ss of its permanent remediation.
Warren County's success Will be the sudJess of Justice loving people everywhere
and will enable Warren County to move forward with positive economic development
as well.
Uf)
, SENT BY:REGION 4 OEA/ORC ;11-26-96 3:59PM; USE P A--1 919 733 4811;# 7/ 7
IV. Proposed Budget: Detoxification of ttie Warren County PCB/Dioxin Landfill
Restoration and Justice
Education Efforts:
(printing of materials, posters,
news annoucernents, video
supplies for public forums,
church and
civic meetings, etc.)
Phone and tax (long-dlstance only)
Travel
Paper, computer supplies, and
other miscellaneous office
supplies
Postage -
Labor ($15/hr x 20hrs.Avk x 40 weeks)
ln•kind contributions will indude
office space, telephone, computer
fax and copy machine, heat and
electricity, and volunteer labor
$2,000
$1 ,000
$3,000
$500
$500
$12,000
$1,000
,;f}¥¥
::\~~?ii";J
$20,000 total
Initial Funds for Detoxification Identified -Fall, 1995 ,·;Jti~J> 1.
')•;,} ~}(;}
. Further Funding Detoxification Sources Identified -Fall, Spring, 1995-1996
Initial lmpementation of On~Site Detoxification M Sp[!r;g, Summer, 1996 )i:J:> \'//
,,tl"il;::--,. 'Ki_¾..;~t-··
State of North Carolina
Department of Environment,
Health and Natural Resources
· Division of Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
MEMORANDUM:
November 18, 1996
TO: Warren County PCB Working Group
FROM: Michael Kelly
AVA
DEHNR
SUBJECT: STATUS OF RFP's, MONTHLY REPORT TO COMMITTEE
1. CORINGS IN LANDFILL:
Proposals were received from four different firms for the installation of wells and
borings in the landfill to extract soils to be used in the pilot test for detoxification. These
proposals were reviewed by the science advisors and Technical Committee. On Friday,
November 8, a request for clarification was sent out to all four companies with a quotation
tabulation form which separated the two tasks being quoted on-the borings and integrity check
on the top liner of the landfill. Companies were asked to re-evaluate their proposals based on
the possibility of methane in the landfill and to re-submit their quotes on Friday, November 15.
All four companies complied and copies of their submittal have been given to the science
advisors today.
Once the review has been completed and a recommendation made, we will approach the
contracting branch of the Department and ask their assistance in securing a contract with the
recommended vendor. If necessary, we may ask that the state provide a negotiator to enter into
talks with the chosen vendor.
We have been notified by EPA that they will require approximately 30 days to give us the
necessary permit to dig into the landfill. I have asked staff in my office to begin the preliminary
work on this task so that as soon as a contractor is chosen, they can immediately begin to secure
this permit.
2. DIOXIN / FURAN TESTING:
In September I visited Triangle Laboratories to inquire about dioxin testing on an
estimated 40-50 samples. Specifically, I was interested in the most cost effective and easiest
way to get analysis done on the wide range of samples we are considering having tested.
P.O. Box 27687,
Raleigh, North Carolina 27 611-7 687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/ l O"/o post-consumer paper
We discussed the various options and decided that it would be best to go with a full scale
(Level III) QA procedure. Based on our conversation, Triangle Laboratories provided me with
an estimate for this volume of work.
After discussing options with DEHNR contracting, I considered seeking sole source
contracting for this part of the project since the cost estimate was considerably less per sample
than we have paid in the past, primarily due to the volume. I did, however, decide to first call
other labs across the country (there are only 8 I know of capable of doing this level of testing) in
order to see what else was available. I ended up calling 5 additional labs which provided me
with a range of estimates, and in some cases, less expensive than Triangle's Estimate. I then
worked with our contracting personnel and put together a RFP.
This RFP was sent to six labs on November 8. I had originally asked to have their quotes
back by November 22, but have moved that date out to November 27 due to changes in the
Department's contract guidelines which were sent out at a later date. Once these proposals come
in, I will submit to the science advisors and Technical Committee for review, and work to get a
contract set up once a recommendation is made.
This committee needs to consider the importance of having lab personnel present to
accept samples from us at the landfill on the day(s) of sampling. I have asked that this cost be
priced out separately and not made it a perquisite for being considered fqr the contract. Three of
the labs (two of which are out west) do have personnel in the area that perhaps could provide
this service. It is not unusual to collect samples and send overnight via Federal Express to the
laboratory without having lab personnel present to actually take custody of the samples.
The labs indicated that their standard tum around time is 21 to 30 days. I asked that they
also quote on 7 and 14 day tum around.
I would estimate this contract to be $37-42,000 on their standard tum around times.
3. MONITORING WELLS
A bid request was sent out on November 6 to nineteen different firms from an
environmental well drilling/consultantJist put together in conjunction with the Division of
Water Quality. It was also advertised in the Raleigh News and Observer, which resulted in three
more RFP's being sent out. A copy of the EPA procedures ( a requirement of the bid) was
included on a diskette with each RFP.
A pre-bid meeting was held this morning. Attendance at this meeting was a requirement
of anyone desiring to submit a bid. Appropriate DWM staff and the science advisors were
present to answer questions and explain the RFP. A trip to the landfill was made following the
meeting in Raleigh.
The original RFP was for 12 wells. An amendment was provided today to add three off
site wells 1 to 2 miles away from the landfill. The general areas were discussed as we have not
chosen the actual sites as yet. These bids are due to the DWM on December 2, and will be
provided to the science advisors and Technical Committee for review upon receipt.
Larry Rose (Solid Waste Section Staff) and I, visited the area last Thursday evening.
Dollie Burwell had suggested three locations for the wells from persons she had spoken with that
would allow us to dig on their property. All three are certainly possible locations, however they
are all south / southeast of the landfill, and we would like to locate one north and east if possible
and use only one of these three. Additional names, taken from mailboxes on Limer Road and
Baltimore Road, were sent to Dollie on Friday, for potential contact and follow-up.
I cannot provide a reasonable estimate for this project at this time.
4. FENCING
Two fencing contractors in the Warrenton area have been contacted to provide quotes on
putting fences with personnel gates around each of the monitoring wells for security. It is
estimated that this cost would be approximately $6,000. The DWM will select the most
appropriate and cost effective contractor and initiate a contract to have in place and ready to
provide this service within a couple weeks notice.
STATUS OF SAMPLING PLAN:
A draft of the sampling plan was sent to the science advisors on October 2. They
reviewed it along with members of the Technical Committee and had some proposed changes.
A copy of the plan on disk was sent to Patrick around November 1. He was going to make the
changes and prepare the final draft.
The plan cannot be completed until all of the information is done on the wells and
samples to be taken. It should now, however, be at a point where it will require only minimum
work to finalize once the wells are in place and we are ready to take the samples.
...
Joint Warren County/State PCB Landfill Working Group
draft November 18, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 4:08 p.m. Monday, November 18, 1996 by Mr. Ken Ferruccio. The meeting was held at
the Warren County Office and was co-chaired by Ms. Dollie Burwell. The agenda was
distributed.
READING AND APPROVAL OF MINUTES
By consensus of the Working Group the minutes from the October 23, 1996 meeting were approved
with two corrections. ·
UNFINISHED BUSINESS
Proper and Inappropriate Lines of Communication
There was not much discussion on this topic. As a result one member of the Working Group asked
how was the agenda prepared. Ms. Burwell advised that the agenda is usually prepared by the co-
chairs or the Technical Committee. However, since the co-chairs nor the Technical Committee met
before this meeting, the secretary called or faxed members seeking agenda items.
Press Conference
Ms. Burwell said that she understood that the co-chairs would have a conference call before the press
conference to draft a statement from the Working Group. Then she was informed that Ms. Ferruccio
was planning to be on the conference call and to speak at the press conference. Ms. Burwell said,
"ifwe open the conference call and the press conference to one member of the Working Group, then
we must do so for all members." She added that she did not get the information about the conference
call until after the time of the call.
Mr. Ferruccio said that he thought there were to be two conference calls, one with the co-chairs and
one with the co-chairs and the Science Advisors. He contacted Mr. Barnes and Mr. Hirschhorn and
then contacted the secretary. After which a conference call was scheduled for Friday,
November 8 at 4:30 p.m.. Later, the time was changed to 6:00 p.m. and I assumed it was to
accommodate Henry's schedule, said Mr. Ferruccio. After dailing in for the conference call and
waiting several minutes, Mr. Ferruccio went ahead with the conference call without Mr. Lancaster
and Ms. Burwell. After the conference call, Mr. Ferruccio called Mr. Meyer's office to suggest that
someone be at the press conference to represent the State. Mr. Ferruccio agreed that the co-chairs
should have prepared a press statement. However, without participation from the other co-chairs he
thought that the Working Group should go ahead with the statements from the Science Advisors.
Mr. Mike Kelly advised that Mr. Lancaster was out of town and did not get back until 4:00 p.m. that
Friday and was not aware of a conference call until then.
'
draft November 18, 1996 Meeting Minutes
Page2
Ms. Burwell said that after the last meeting she understood that both the Science Advisors would
make their own declarations. A draft declaration was prepared by Mr. Hirschhorn, which was
approved by the.Working Group. Mr. Barnes did not have his declaration written, but was to have
his own statement as well. The co-chairs were to prepare a statement from the Working Group and
that did not happen.
Suggesting that we "chalk up" this one, Mr. Warren said we needed to have had a discussion and
assigned people to do certain things. He expressed concern that one co-chair felt he/she could not
attend the press conference. He added that we needed a coordinated effort, which we did not have,
but we did get some good points out at the press conference. Mr. Cooper added that the structure
of this organization does not lead to workability.
Saying that the media moves with him because they move with facts, Mr. Ferruccio added that facts
are what the media was given. He said the state papers spun their story toward the state and the
other papers/news stations spun their stories toward that citizens and the community. Ms. Burwell
said it is not about how the stories were spun, we are in an environmental justice arena. We have
to be careful what picture we send out. She stated, "why was the landfill put here? It was put here
because this is a poor African-American community. People of color should speak for people of
color. The Working Group should not have gone to a press conference without any people speaking
that represent the majority of the people in this community."
Mr. Warren suggested whenever there is a statement from the Working Group, all members
participate or delegate it to the co-chairs.
Ms. Bobbie Riley wanted to clear up the misconception that there was a statement from the Working
Group. She said that Ms. Ferruccio introduced the Science Advisors and they made their statements.
She added that she felt that they did a wonderful job.
Ms. Burwell said that she feels if the Working Group calls a press conference, they should have a
statement. Mr. Ferruccio agreed with Ms. Burwell and said since there was not participation from
all co-chairs no statement was prepared from the Working Group. Mr. Warren made a motion to
move on to the next agenda item. The motion was seconded and carried.
Policies for co-chairs and Science Advisors
Ms. Ferruccio motioned that this discussion be tabled. The motion was seconded and carried.
This discussion was tabled so that all co-chairs could participate.
Reappointment of Working Group Members
Mr. Warren motioned that this discussion be tabled. This motion was seconded and carried.
This agenda item was tabled so that all co-chairs could participate.
Status of Project Officer
draft November 18, 1996 Meeting Minutes
Page 3
Advising that he talked with Mr. Lancaster and Ms. Linda Rimer, Mr. Kelly said they liked the idea
that the Department would find a project officer or suggest one. Mr. Kelly added that he and Mr.
Patrick Waters have been working together. Their goal is to keep the project on target. He said that
Mr. Meyer has tried and that this is more than he can do. Mr. Kelly advised that Mr. Waters used
to work with the Superfund section, but is now pursuing his master's degree. He has come back to
the Division on a part-time basis, on this project.
Ms. Burwell said Mr. Lancaster reported that he would make a proposal to appoint someone from
within the Division of Solid Waste Management (Division). She said that we should table this
discussion and wait to hear from him. By consensus, further discussion was tabled, awaiting a report
from Mr. Lancaster.
Strategy for Funding
1) PCB Landfill Detoxification Project
Mr. Hirschhorn said that he is against going after federal dollars. Saying that there would be so many
hurdles to overcome and that could take three (3) to five ( 5) additional years. He said that we would
have to be in desperate need to pursue this option. If three (3) years from now the landfill is not
cleaned, then we might want to look at pursuing federal dollars.
Mr. Warren asked two questions about pursuing federal dollars. First was, "does not pursuing federal
dollars mean that we do not want assistance from the federal government and second, will sending
a letter to Mr. Laws, Assistant Administrator Solid Waste and Emergency Response of the U. S.
EPA, give the impression that we want the landfill to become a Superfund site?"
Mr. Hirschhorn said that if we show that there is an uncontrollable release of materials. Then the
State would be forced to act and if they did not, then the federal government would step in .
Ms. Riley said at the Technical Committee it was explained that if the EPA gets involved they will
not take in consideration the wishes of the Working Group. They would use the most cost-effective
remedy. If that remedy is incineration, then they would use incineration.
Ms. Burwell said that when we are talking about assistance for the EPA, we are not talking about
becoming a Superfund site. The EPA has some responsibility for the landfill being here and since they
have some responsibility, when we ask for assistance we expect it. Ms. Burwell said that she is a
citizen of this community and a person with political background. She asks that her position in this
community be respected.
Mr. Hirschhorn said the other part of the strategy is to compel the federal government and the EPA
to fulfill their legal obligations. These obligations are to hold the State to its responsibilities. He said
that it is not easy to compel the EPA to act; there is not one document in the State's files that show
draft November 18, 1996 Meeting Minutes
Page4
EPA oversight since the completion of the landfill. Mr. Hirschhorn added that the EPA has not met
their requirements and assumed that the State would stay in compliance. The State has been out of
compliance since day one stated Mr. Hirschhorn. He said that the first thing to do is to get the EPA
involved. Mr. Hirschhorn said Mr. Meyer told newspapers that the EPA approved a leachate
collection system without the perforated pipe. There is no paperwork in the files to prove this.
The Division does not know how the plan got changed, Mr. Kelly said. He added that the
Department of Administration may have the document in their files; the State is trying to locate the
paperwork.
Ms. Elmore said the EPA should have a copy in their files.
Mr. Kelly advised that the State is sending a person to Atlanta Thursday (November 21, 1966) and
would have that person check this.
Mr. Hirschhorn said that before going public with this issue he spoke with Mr. Meyer. There is a
diagram that the EPA gave approval for and, a final plan that does not have the perforated pipe in the
leachate collection system said Mr. Hirschhorn. In January and February of 1983 the EPA was at the
landfill and published a diagram that had the perforated pipe in the leachate collection system. He
added that he has not written anything that says that the Division of Solid Waste Management is
responsible. He has always said the State is the responsible party, adding that it is not important
which division approved or changed the leachate collection system. What is important is that Mr.
Meyer said that the State would not have approved a landfill without a leachate collection system.
Mr. Barnes added that he does not believe that the leachate collection system that was to be installed
would have worked. It has not worked, said Mr. Hirschhorn. Jim Warren said that the State should
have tried that leachate collection system before the landfill was filled. Mr. Hirschhorn said that they
should have operated the system while the landfill was being filled. He said that you cannot have a
landfill without a functioning leachate collection system.
Ms. Daria Holcomb asked what are the ramifications if the EPA did approve the landfill without this
leachate collection system. If the EPA gave approval for a landfill without a leachate collection
system then someone could go to jail was the response from Mr. Hirschhorn. He added, "the State
is fundamentally responsible" and that he would be amazed if the EPA approved the landfill without
a leachate collection system.
Mr. Hirschhorn said that in 1982 everyone seemed to have thought that the landfill and incineration
were the only two options; they were not. They may have been the most cost-efficient, but there
were other options. Ms. Burwell said that Warren County was blamed for the lost of lives, because
the Highway Patrol was here and not on the highways. When the lost of lives are taken in
consideration, trucking the PCB contaminated soil to Alabama or incinerating it would have been less
expensive.
Next, Mr. Hirschhorn advised that EPA scientist measured some release of PCBs into the air. He said
in January and February of 1983, before the pumps were turned on in March, PCBs were measured
draft November 18, 1996 Meeting Minutes
Page 5
in the air. The PCBs were measured at two pipes, at the sumps, and in the lower and upper leachate
from the vents. However, no report was written which included this information.
Mr. Ferruccio said that it was reported that only methane gas was coming from the vents. Therefore,
there was no need for filters to be installed.
Mr. Kelly suggested that air sampling for PCBs be added to the sampling plan.
Mr. Barnes said that he is beginning to believe a statement made previously by Mr. Ferruccio that
Warren County was used as a sacrifice zone.
Status of Letters
The secretary was asked to contact the offices of Mr. John Hankinson, Mr. Elliott Laws, and
Secretary Howes to make sure that they had received the letters that the Working Group voted to
send them. She could confirm by this meeting that the letters had been received by Mr. Laws and
Secretary Howes, but had not heard from Mr. Hankinson. Ms. Burwell said that she does not see the
need to contact these offices for confirmation. We have given these offices sixty days to respond and
after that time if we do not hear from them, then we should contact them for confirmation. After
some additional discussion, Mr. Ferruccio motioned that the secretary seeks confirmation from Mr.
Hankinson's office. The motion was seconded and carried.
Ms. Monica Porter said that the meetings are beginning to get longer and when a meeting gets over
two hours we are not being productive. She said that we are not being considerate of the members
that have to travel; she suggested that the co-chairs get together and "clean house." Ms. Porter said
that a lot ohime is spent with the co-chairs bickering and not taking care of business; adding that the
co-chairs should have met and had these discussions before the Working Group meeting.
At this meeting were several visitors, who live next to the landfill. One visitor, Mr. Massenburg
Kearney, said that he lives very close to the landfill. He said that living so close to the landfill, he is
very concerned about possible leakage. Adding that he had heard about the possibility of a
monitoring well being put on his property. He wanted to let the Working Group know that he has a
well on his property. It is not being used and he would allow it to be used as a monitoring well, if
it meets the needs of the Working Group. He said that the adjacent property owners are very
interested in what is happening and would like to get more information.
Mr. Patrick Barnes said that we should have a community forum, adding that it probably should have
been held before the press conference to inform the community. Ms. Burwell said that since the
press conference has occurred, we should not have a forum until the questions raised at the press
conference have been answered. Mr. Hirschhorn said that we should let the community know they
can come to this office and pick up documents, adding that he thinks a community forum is long
overdue. Mr. Copper added that the co-chairs are overworked. He said the co-chair should divide
and each work with other members of the Working Group, so they would not have such a heavy load.
There was concern expressed about whether the community members can understand the technical
draft November 18, 1996 Meeting Minutes
Page 6
information. Ms. Riley said that both Science Advisors could explain the information so that anyone
can understand. Reiterating the importance of a community forum, Mr. Hirschhorn advised that he
has had forums where people have come and asked questions and can understand the information.
It was suggested by Mr. Warren that a couple of people from the community get together and appoint
a committee to plan a community forum. Mr. Cooper said that the co-chairs should appoint and
structure a committee. It was the consensus of the Working Group that the co-chairs would appoint
a committee to plan a community forum.
Status of the RFPs
The report of the status of the RFPs was given by Mr. Kelly. He first informed the Working Group
of the RFP for soil removal, which will involve the integrity of the top liner. Mr. Kelly advised that
four companies responded to the RFP. The EPA advised that it will require thirty (30) days to issue
a permit for the removal of soil. Mr. Kelly said that once the company is selected that he would
pursue the permit from EPA.
The next report was given on the dioxin/furan testing. Mr. Kelly advised that, he has visited Triangle
Labs (Triangle) and toured the facility . He asked Triangle if they could lower their price, due to the
quantity of samples. They agreed and gave a considerably lower price. After which, Mr. Kelly called
other labs to check their prices. He got some prices that were about the same and some less. The
RFP for dioxin/furan testing was mailed November 6, 1996 and was originally due back two weeks
later. However, that date was chru:iged because some additional information had to be included. The
new date for the respondents is November 27, 1996. Mr. Kelly advised that he asked the companies
to bid separately on having a scientist come and take samples verses having them sent Federal
Express. He advised that the standard turnaround time, for results, is 21 -30 days. Triangle was
asked to estimate the charge if the testing was completed in seven days.
The last report was on the monitoring wells. This RFP went out on November 6, 1996 and was sent
to twenty-two (22) companies. Nineteen (19) of those companies responded and were present at
today's (November 18, 1996) pre-bid conference. These companies were brought to the site and
showed where the twelve (12) additional wells would be placed. The response is due December 2,
1996. Mr. Kelly advised that he put out an addendum to this RFP for the three (3) off-site wells. He
advised that Mr. Larry Rose came to Warrenton and visited some sites and all three (3) sites could
be used. Mr. Kelly advised that all wells will be fenced and will be I Ox IO. The fence will be 6 feet
high with 3 feet of barbed wire. There will be a 3 1/2 foot personnel gate. The estimated cost is
$6,000.00.
Mr. Kelly added that Mr. Barnes has been sent a copy of the Sampling Plan on disk so that he can
make the changes agreed upon at the last Working Group meeting. Mr. Kelly feels that the Sampling
Plan is at a point where it can be finalized.
Status of Landfill
draft November 18, 1996 Meeting Minutes
Page 7
Mr. Barnes estimates that the landfill is taking on 1/2 inch of water per year. He advised that 26,000
gallons of water is leaving the landfill yearly, adding that this does not mean that the water is
contaminated. Mr. Barnes said he does not agree with the State's position that the fluctuation in the
water level is caused by gas production. If gas production was the cause of the fluctuation then we
would not see a steady rise in the water level. He added that the more rain there is, the more water
there is in the landfill. Mr. Hirschhorn stated that his latest report will cast some doubt on the State's
position as well. His opinion is that if there is that much water in the landfill, the State estimates 1. 5
million gallons, then you would expect to have some water passing through the lower leachate
collection system. He added that he doubts that the lower leachate collection system is functioning.
NEW BUSINESS
Mr. Hirschhorn asked about the status of the RFP for the technology company. At the last meeting
he proposed a 2 phase RFP for the technology company. Mr. Meyer was to put him in contact with
Ms. Doris Strickland to check the legality of the 2 phase RFP.
Next, Mr. Hirschhorn asked who would make the decision of which technology company would be
used; how will this decision involve the Working Group, the State, and the Science advisors?
Mr. Kelly said the Science Advisors and the State would work that out, adding that the Division of
Contracts awards the vendor. Mr. Cline said that the Working Group could make a recommendation
and if it is a good reasonable decision, then the State would agree and award that vendor. Ms.
Burwell said that the Working Group, by consensus, agreed that unless there is a disagreement with
the Science Advisors and the State that they would choose the vendor.
Other new business was the resignation of a Working Group member. Ms. Billie Elmore gave her
resignation. She cited the time involved to properly prepare for these meetings, the approaching
inclement weather, and the distance and time that she has to travel as factors in her decision. Ms.
Burwell motioned to accept her resignation and to forward a copy to Secretary Howes. The motion
was seconded and carried.
OTHER BUSINESS
None.
ADJOURNMENT
. The meeting was adjourned at 6:55 p.m .. The date of the next meeting was not decided.
CO-CHAIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLLIE B. BURWELL
KEN FERRUCC/0
HENRY LANCASTER
TO:
FROM:
RE:
DATE:
Working Group Members
Doris Fleetwood
Information sent to the media for the press conference
November 14, 1996
Dear Members:
Enclosed is the information sent to the media informing them of the press conference.
,r'
Ir ......... ... • ...... ,.,,....,.._...__ --~ -· ......... ~-....... ~ ...... ...,,, ..
1-11 [lSCI 11-1or,N
,gJ)_~ASSOCIATES ((:§ -----
~, A Division of HygieneUcs E11vi1011111enlal Services, Inc. Suite 411
2401 Blueridge Avenue
Wheaton, MD 20902
r11011c: (301) ?'19 -1235
rnx: (30 t) 9,19 :1 237
DECLAllAl,ION OF DETOXIFICATION
rrECI-INOLOGY AVAILABILITY
As a Science Advisor to the Warren County PCB Landfill Working GrouJ) and an expert in
environmental technology, this is to certify that in my professional OJ)inion detoxification
technology appropriate for use at the Warren County, North Carolina PCB Landfill is now
commercially available.
Such technology has been proven effective and safe for detoxifying PCB waste and contaminated
materials. The gas phase chemical reduction and base catalyzed decomposition teclmologies are
being used at foll scale. Neither of these technologies were available some 15 years ago when the
state decided to construct the landfill to dispose of the PCB wastes.
Although the exact requirements and performance for the Warren County PCB Landfill will be
determined through planned testing, there is every reason to believe that one or both of the
feasible detoxification technologies will be fow1d to be practical for the site specific conditions,
constraints, and needs.
As originally envisioned by the State of North Carolina, in the Governor's commitment to
Warren County residents, the detoxification of the landfill can now be considered to be a
real, near term option.
The current slate fonded activity will refine for the State legislature reliable cost estimates for
landfill detoxification, using the technology shown by bench-scale testing carried out in coming
months to be the most appropriate for this application and community.
Minimizing site cleanup costs, maximizing safety of county residents, and achieving stringent
cleanup goals will be used to choose between the two available technologies.
October 23, 1996
SrfATEl\1EN'1, OF Dll. JOEL S. HIRSClllIOitN,
SCIENCE ADVISOR,
WAIUlEN COUN.TY PCB LANDFILL
\VOIUONG GROUP
November 12, 1996
Raleigh, North Carolin.a
lbere are tJuee crucially important ~echnicai facts that we now know about the Wanen
Co\.Dlty PCB landfill:
■ IE..c.u.tiQW_GY;_ Technology is 1va.ilable to detoxify the landfill
• NONC~ The state has not complied with many technical requirements
imposed by the federal government when it apptove4 the landfill to enswe that it would be
sitfely built, opei:ated, monitored, and maintained.
• S.AH .. al..:. 1 he l1tntlfill containment system is threatened by a huge amount of water in the
landfill and data indicate that it is not functioning in a secure manner, bec1mse water is
entering ruid leaving the landfill.
Explanation of Ti.min~ of Reporu as Science Advisor
On October 20, t 982 Governor Hunt made a commitment to detoxifying the site and
pt cdicated future detoxification of the landfill on appropriate and feasible technology becoming
de\'cloped. My recent decision to issue the Declaration of Detoxificatlon Technology Availability
w:1s deemed necessary because it had become clear to roe that the state ofNorth CBJoJina had
been delA}rittg a dec.ision to detoxify the land.fill. There is evidence that the state has known for
several years tb:lt such detoxification technology had become available. Now the issue is no\
.nhdh~r_detQ.~.mcltUQ.n cam be done. but whether the statt.iu,.repared to honor its orlclr>.aJ.
12.IU....w..~vru.tm..w.t.tub~ citizens or \Yarrcn County and whether the necesssry fundin_g_w:
ibtla.lMJJ.ilLdeto)(ificntion wi.lJ be provided soon.
My decision was also supported by my fmdingJ mowing that the state had failed to meet
exteusivc technical requirements imposed by the U.S. Enviro11mentd Protection Agency when it
approved the st:ite · s plan to construct the landfill. In particular, I recently submitted a report
(Analysis of the Leachate Collection System and Water in the Warren County PCB Landfill)
sho"wing that the state did .not install a critical component of the land.fill's leachate collection
system (perforated pipe system at the bottom) that it told EPA in 1978 it would use, that the
1
Hdll''6 9 661-80-17
I ·-
leacbate coJlection system has never operated effectively as required by EPA in 1979, and that the
presence of the huge amount of water in. the landfill present since its construction \.iolatcs EPA
requirem~nts. Although the state confirmed the prei:ence of the wtter in 1990, it did not disclose
it to the public until 1993. It is not clear whether EPA approved the omission of the perforated
pipe system, knew tlul.t rajnwater was not pumped from the landfill during constructi.on, and lcne\-\.·
that the leachate collection system has been dysfunctional.
The EPA approved the landfill and prnvjded funds from. tbe federal Superfund program,
on th.'.! basis of consider.able technical requirements for construction, opeution, monitoring, and
m.1intcnance of the landfill by the state. These requirements were very important, because the
location of tbe landfill was far from ideal. But the state has not effectively policed itself ,md the
EPA has not provided effective oversight and enforcement of the lanclfill's permit requirements.
Tue result is a. landfill tha.t no longer cAtt be assumed to be "s.tfe and secure" AS Governor Hunt
promised in 1982, but that has become increasingly unstfe. Because detox.lftutlon technology
is available, th~ tl_filMLILtlPOntibility to expeditiously remove the IAndfill hAzud from
!he "'arum County community that opposed It In the first place a, being unsafe.
Thkd, my analysis of the problems with the leachate collection system also indicated that
the lower leachate detection. and coUection system. the final safety mechanism before toxic
contaminants are released into the envuonment, was not reliable. Moreover, in my professional
opinion the available data on changing water levels inside the landfill and in nearby groundwater
monitoring wells, over about four years, were very well correlated, indicating that the landfill.is
leaking. Water seems to be entering the landfill because of seasonal changes in rainfall.
The T~hr,ology__fil_tfill_tion
There a.re hvo cornmercially available detox;fication technologies appropriate for use at
the Warren Couaty PCB landfill. Only these two technologies meet all of the reqnitements
est.ablished by the Working Group. One of these WH invented by EPA scientists and licensed to
several companies, it is called base catalyzed decomposition or dechlorination (BCD) technology.
ll1e othet is caUoo gas phase chemical reduction, and it has been developed and commercWized
by a company. Eco Logic. The development of both technologies has focused on PCB
destruction. Neither of these two technologies wetc proven 01 available when Governor Hunt's
Intergovernmental Working Group on PCB Detoxification issued its report in December 1984
that said »o deto"ification technology wu sufficiently proven to warrant use.
However, that situation changed completely a few years ago. Both of these technologies
have been folly commercialized and used at full scale, including PCB detoxification at several
locations in the United States and elsewhere. In 1994, for example, the state agreed with EPA
about the selection of BCD t~hno.logy for the cleanup of the FCX, Inc. Superfimd site in
Statt.svillc, NC. lhe decision document sai.d: "ThemJal desorption and BCD have proven
effective in the t.reatment of halogen:tted volatile organic compounds, halogenated semivolatile
organic compounds [that include PCBs), pesticides. herbicides, and dioxin/furans in soil." Also,
2
i-td8V · 6 966 l -80-17
ifl 1994, EPA concluded that for the Eco Logic process "High water-content wastes [like those in
the Wnm:n CoW1ty landfill] ... can be processed with destruction removal efficiencies of at least
99.9999%." EPA also said that there is "no formation of dioxins or furans" and that "Any dioxins
or fhrans in the waste are also destroyed effectively." In other words, by 1994 it must have
become clear to the state that there was feasible detoxification technology available to do what
the Governor had prontlsed many years earlier in 1982.
Only companies offering the two selected technologies will be given an opportunity to
have tl1eir technologies bench scale tested at their facilities 1n coming months, using PCB wastes
extracted from the landfill. The ma.in pwpose of the testing is to identify which of the two
technologies offers the best performance and also to obtain accurate estimates of the cost of the
full detoxification or clean.up of the PCB laodfiJJ. However, the tou.1 cost of the landfill
detoxification "ill be at the .$25 million level and possibly greater, depending on a number of
technical uctors to be rei,olved in coming months. Considering the large size ofthe JandfiU~
however, thjs is not an unusual cost for a permanent, safe remedy. lbe testing will follow a
prnlocol approved by the Working Gtoup. TI\e test data will be used to select one company to
wo1k with the Science Advisors to develop a prefunjnary design for the full scale detoxification of
the landfill. This preliminary design m11 provide accurate cleanup costs for the state legislatwe.
Once funding is provided nnd a contract negotiated, the chosen technology comp lily will couduct
au ousite trial test as the fust phase of th.e full cleanup to ensure safe and efficient operation.
Sum.mAry or professional qualifications;
► Earued Ph.D. in engineering from Rensselaer Polytechnic Institute, New York ( 1965 ).
► Full ten wed professor of engineering at the University of Wisconsin, Madison. ( 13 years).
• Senior Associate, Congressional Office of Technology Assessment in charge ofhauudous
waste, Superfwtd and other cnvuonmental issues. (12 years). Testified at dozens of
Senate an.d House hearings.
► Author of technical books and hundreds of technical papen.
► Nationally recognized expert in environmental technology.
► Has served as a technical advisor to many community groups affected by federal
Superfu1ld sites or state cleanup sites.
► Has seived as an environmental expert in many legal cases.
► Has been a consultant to many leading companies (such as IBM, Texas Instruments,
Warner Lambert, and Polaroid), government agencies (such as U.S. Agen.cy for
International Development, Department of Energy, and U.S. Information Agency) and
intematfonal groups (such as the United Nations Environment Program and Olganization
for Economic Coopeutiou. and Development).
Dr. Hirschhorn can be cont.acted at:
Phone [phone] FAX [phone]
3
l'ld6V ·G 9661-80-V
..
ANALYSIS OF TUE LEACHATE COLLECTION SYSTEM
AND \VATER IN THE WARREN COUNTY PCB LANDFUJL
Joel S. Hirschhorn, Ph.D.
Science Advisor
Warren County PCB Landfill Working Group
November 4, 1996
EXEClITIVE SUMMARY
This analysis has found that the leachate collection system, a aiticaDy important
safety feature of toxic waste landfills, nevei-opei-ated effectively in the Warren County PCB
Landfill. The routinely prescribed method of collecting water at the bottom of such
IAndfi.lls --and that the state uid it would use in its 1978 appliution for EPA approval --
was not installed. The state owned and operated landfill was not, therefore, a state-of-the-art
landfill, h1tsed ou best engineering principles. There are very serious questions about why, how,
and when a decision to omit the system of perlorated pipes happened, and who made it. It is
difficult to understand how the landfill was approved by both the state and the U.S. EPA. But it
is easy to understand ,vhy the state says there may be one million gallons of water in the land.fill
that were not removed by the leachate collection system
A fully functioning, effective leachate collection system was a key requirement
imposed by EPA in 1979 on the state. The state has been in noncompliance for many years.
This noncompliance is inconsistent with the Governor's promise in October 1982 r-before the
landfill cocstrnction had been completed --that "the landfill is safe and will remain safe in the
fotu.re." Jt is not clear whether EPA was given key information that would have made it difficult
for it to approve the landfill and cause it to take action against the state's JDAjor noncompliance.
W11ile the state insists that no new water is entering tbe landfill, it seems to have ignored
the more central problem that the leachate collecti.on system does not work, making the landfill
unsafe, illega~ aud undeservfog of public confidence. Although roost of the water in the landfill
has been th.c.rc from. the bcgirotlng, other data indfoate that addition.al water has entered the landfill
and some has escaped the landfill, either through defects in the containment system or through
o.onual tunsport through low permeability materials.
Although the original commitment by Governor Hunt to detoxifying the landfill was not
contingent on anything other than deto,cillcation technology becoming available, later statements
l
woa.:1 ~~\>'SE . E 966 I -50-V
suggest that the state may compare the risks from implementing detoxification to mamtaining the
landfill. But is the landfill safe and secure as the state has promi~ and asserted, and as EPA was
to ensure? It is not. Detoxification of the landfill will also include dewatering it. The
convergence of detoxification technology availability and the need to comply with federal
requirements and remove a public hazard support the highest possible priority for securing
state funding for detoJ.ificalon.
Analysis of UAta
This analysis focused on all the available data and documents related to the design and
functioning ofth~ Jea~bate collection. system and the amoWJ.ts of liquid collected since 1983. It
also refers to the data on varying levels of watet inside the landfill and in nearby monitoring wells
over the past several years.
A key document indicates that, from 7/29/83 to 10/25/89, 2,877 gallons ofleacbate were
removed . But one problem is that in early 1986, the data indicate that something went wrong
with the leachate collection system and it failed completely, because no liquid could be pumped.
lfwe examine the last two years of the total operating period we obtain:
11/2 1/83 ~ 11/5/84
12/11/84 -11/13/85
J 410 gallons
124 2 gallons
118 gal/month
104 gal/month
Another set of data indicate that from 3/7/83 through 7/29/83 there was no significant
amount ofleachate reported Indeed, close examination of the one page document with the
ea.rliest data reveals that the leachate collection system was operated .in a more continuous manner
in March and April 1983, indicating that dwing this period the initial water in the landfiU was
pumped but the quantities not reported. Proof of this interpretation exists in a memo by EPA
staff dated March 28, 1983 which r.eveals that pwnping on March 7 and 8, 1983 collected 460
gallons, or over 200 gallons/day. 1 In other words, there is evidence that a large amount of
leachate was being collected during March and April 1983, an.d then much. less leachate was
purupable resulting in the period of pumping being reduced substantially to only one day a month.
1 In fact, pumping was only possible for a total of about 2 hours over th.e two day period,
indicating a profound problem in the leachate collection system, since it was kno\\11 that water
had been allowed to accumulate in the landfill for at least five months, without ever operating the
leachate collection system The EPA persons seem to have focused on the effectiveness oftbe
treatmellt p:ut of the system to reduce PCB levels in the effluent discharge, rather than on the
effectiveness of the system to remove free liquid. It is not clear exactly wbat th.e EPA persons
knew about the rainfall in the land.fill and the design and construction of the leachate collection
system, or that the perforated pipe system had not been installed.
2
HOd.::I H'v9S 'E 9 66 l-S0-17
And then. starting .in early 1986 no liquid could be pumped. In other words, all the infomiation
shows a slowing do\vn of the liquid retrieved.
ff the initial heavy leachate removal during March and April 1983, in the 200 gal/day
range, had been pumped everyday then the amount would be some 6,000 gallons/month. But the
<la.ta indicate that the total number of pumping days were 26 in March and April, indicating a total
amo1mt of some 5,000 gall.ons. lbis level of rapid leachate removal in this 1983 period is
consistent with removing some initial water in the landfill. The Final Report by Sverdrup &
Parcel of August 2, 1983 made it clear that the leachate collection/disposal system had not been
operated to address excess rainwater during construction. Clearly, after the containment system
was completed the EPA oversight indicated that the leachate collection system was operating
effectively to remove some initial water in the landfill.
An.other key document is the June 30, 1983 report by the state's Division of Health
Services which made it clear that "Pumping of the leachate collection system commenced on
March 7, 1983 and continued at various intervals through June 1, 1983. Approximately .5,000
gallons of free liquids were removed from the .landfill and treated at the landfill's treatment
works."1
There is no plausible explanation for the large amount of water the state says is now in the
landfill, unless the leachate collection system NEVER operated effectively, because the three
year:s the leachate collection system was pumped was long enough to dry out the landfill. In other
words, compare the initial 5,000 gallons collected in the first two months of operating the
leachate collection system with the subsequent 2,877 gallons the state said was removed in over
two years, from 7/29/83 through 11/13/85 when the data showed the system failed completely to
pump liquid. This is a total of only about 8,000 gallons. These data present a reasonable picture
ohvhat occurred, namely some initial dewatering of the landfill. But was the amount removed
judicative of the total amount of water initially in the landfill?
A file document indicates that the state knew in March 1990 that water was present, that it
had installed a system to measure the level of leachate in the landfill on March 20, 1991, and it
calculated the amounts of water in 1991. Toe state has said that there is either 1 to 1.5 million
gallons of water, as stated in a July 1992 document, or what a May 21, 1993 letter from Jonathan.
Howes refened to as an "estimated 500,000 to 1,000,000 gallons of water which has been
collected in the bottom of the landfill." When the state made a public announcement of the water
in the landfill problem in May 1993 it referred to l million gallons. One area of uncertainty is the
height of the leachate in the landfill. A file document indicates that a March 1990 study oflandfill
leachate estimated approximately 13.3 feet of head, but a more recent document said that there
;;Jbis state agency 3Jso made the important connection between the effectiveness of the
leachate collection system and the potential harm to public health and environment when it said:
"A functional aspect of the bndfill's design is a mechanism to remove free liquid from the waste
mass and hence eliminate material that bas migration (or release) potential"
3
~Ocl..:l
was 1 O fect of saturated waste. EPA allows only one foot ofleachate head. My calculatio.ns,
based on the state's obse1vation that there is some 10 feet of saturated material in the landfill and
a pbusible void fra ction indicates that the water volume is probably closer to 500;000 gallons. 3
However, if the higlter height ofleacbate is correct, then the leachate volume would be closer to
the one million gaUons ~aure. An October 1992 document that the Division of Solid Waste
Management submitted for the 1993-94 Expansion Budget sought founds over two years to
remove the water in the landfill and justified the request by noting that "without removal of this
liqitid ... potentially co.ntaminated water may leak from the site and contaminate area groundwater,
resulting in a much more expensive cleanup in the future. 11
Any such large quantity of water is not consistent with the very small amount of initial
removal of liquid in March and April 1983 and the ensuing lower level of liquid removal The
removal of only some 8,000 gallons over the total operating period of the leachate collection
system represents rough(\.'/% or less of what the state says is in the land.fill. Iftbc large amount
had been present initially (as the state asserts), the only logical conclusion to draw is that the
leachate collection. system NEVER operated effectively. The fact that the EPA certified the
leachate collection system was operating effectively at first is not especially significant, because
EPA only examined tl1e very first few days of the system's operation and not the en.tire data set
for over two years and not in the contex1 of a huge amount of water being .in the landfill.
Could new water entering the landfill explain the huge amount of water inside the landfill?
TI1e data for the last two years of operation of the leachate collection system indicated an. average
100 gal/month, but this adds only 13,000 gallons of leachate, ifwe assume that this quantity
entered the landfill since Jan. 1986, for a total period is 130 months. Clearly, this figure is much
too low to explain the amount of water CUITently in the landfill.
The correct way to look at the 100 gal/month level ofleachate recovery is that it
represented a dysfunctional leachate collection system th.at was not operating effectively. The I 00
gaL'month recovery rate was most likely indicative of a very slow seepage of the water initially in
the lanclfill through a profoundly broken leachate collection system. In other words, the system
was bad to begin wjth and got worse over time, eventually resultiu.g Jn NO pumpable leachate hy
early 1986. It should be noted that all the PCB waste had been in the landfill over three months,
befor:e pumping fast began on March 7, 1983, all.owing enough time for free liquid to form at the
bottom of the land.fiU (i.e., percolate through the waste and desorb from the waste itself because
of p1essure and gravity).
1'fbe 1992 document included a detailed cost estimate for pumping water out of the
IandGU . TI1e plan ultimately precipitated the confrontation between the state aod some colJ"..munity
interests, who opposed the plan, that resulted in the formation of the current Working Group .
However, there is no indication that the public ever was given a detailed e~lanation of why the
water was created in the first place and about the failure to install the perforated pipe system
originally pfanned by th.e state.
4
HVLE> E 9 66 L-50-T-'
Dffl_s.sit_r1
To summarize, there are two possible ways of understanding the data:
1. If the collection system operated effectively initially, removed the original "vat er in. the landfill,
but failed by 1986, then water has surely entered the llllldfill after early 1986.
2. If the collection system NEVER operated effectively, then it is possible that the present large
amoun.t of water in the landfill is mostly associated with initial water (i.e., only about l % having
beeu collected initially from 1983 through 1985), but does not rule out additional water entering
the Jan dfill.
Is the first explanation plausible? After early 1986 could some as yet wiknown failure in
the cap system have occurred, allowing large amounts of water to euter the land.fill. and
ac-eumulatc in it? Assuming the first notice of the large amount of water in the landfill occurred in
1992, then the accumulation of at least 500,000 gallons over perhaps seven years must be
explained, which is roughly at least 200 gallons/day. This is too large to be accounted for by
ambient surface and groundwater conditions and low infiltration through low permeability
n.1.aterials or probably even through a cap nith a major defect. The problem is that the landfill is
above the groundwater table and most surface water runs o.ffthe site. Explaining 500,000 or
more gallons entering entirely from new water is difficult.
The challenge with the second explanation is that it is very difficult to imagine how a
11ew(r in.stalled leachate collection system could malfunction so quickly. This would have
required a ma,ior deficiency in the design and/or comtruction of th~ landfill that neith~r tJu
state nor EPA fully understood. If so, then the landfill should not have been approved by the
state and the EPA to begin with. Brd this is, in fact, dee most plausible explanation of all the
data and there is evidence that a necessary component of the leacl,ate collection system wa.,
missing.
Wbat appears to be a major design flaw is that the leachate collection system was
composed of "a 9'' layer of permeable sand, draining to a collection sump and 611 PVC extraction
pipe in the northeast comer of the Ltndfill", according to the Final Report by Sverdrup & Parcel
(July, 1983). 'lhe report also said that a filter fabric material was placed over the sand layer. This
infonnation. js consistent with one of the as-built engineering drawings for miscellaneous details
that includes a cross-section through the landfill and details of the leachate collection system. The
dnw,rug was also prepared by Sverdrup & Parcel and received by the state in September 1983.
This engmi?ering drawing conclusively slu:Ms that the leachate collection system was brued on
only a nine mch sand layer.
1h.is is crncial. because the more conventional and accepted design, in the professional
lit~rahue and EPA documents, to eusure effective drainage and liquid collection would have
5
vlOcL:I vl'9'8S 'E 966l -S0-l7
placed a series of perforated pjpes across the en.tir:e bottom of the landfiU in trenches filled with
gravel over which a sand layer would be placed, and then some type of filter fabric to separate the
wask. Did t.he state know when it first conceived the land.6.11 that this was th.e correct design?
Remarkably, the state's original 1978 description of the landfill it planned to build and
gh·en iu its application for EPA approval and funding said such a perforated pipe system ,:Vould be
used. 111.e December 1978 application by the state submitted by the Governor to EPA for
approval of the landfill included an Operational Plan with section 5 on the leachate collectjon
system. It said that the system would consist of"4-inch PVC petforated pipes on top of the clay
liner graded to a sump" and with. "one foot of porous material..placed over the clay liner to
enclose the perforated pipes." The state also said that the system "will allow liquid withdrawal for
the relief of any head buildup." [emphasis added]4
Even in a well designed landfill, the design of the leachate collection system is based on
assumptions about the amount of liquid likely to be formed, but nonnally the design would .not
have accoUD.ted for a very laige amount of water from rainfall into the open landfill dw'ing waste
placement and prior to cap construction. An enormous amount of unanticipated water could
cause a leachate coUection system based only on a sand layer to fail qwckJy, such as by clogging,
which is acknowledged to be the primary cause of failure of leachate collection systen1s.
However, it is especially suspicious that in the very first few days of operation the pump could not
be operated continuously because of a lack of liquid. This indicates a major proble~ beyond
clogging resulting only from particulates (solids) in the leach.ate. 5 A high hydrostatic pressure
resulting from a huge amount of trapped water in the landfill could have caused a rapid intmsion
of san.d fines directly .into the sump and single PVC pipe to the outside pump when the system
was first pumped. The thickness of the sand layer was less than the one foot normally specified
(one foot), and the sand may have had an excess of fines, which are kno\.Vn to cause clogging
problems. lbe state has given its own explanation ofwby the system did not operate which is not,
bovvever, consistent with all the available information but is consistent with the explanation given
'1bis descriptio.n, however~ is not consistent with what was described in the 1983
Sverdrup & Pa.reel post-construction report and the as-built drawing, which made no reference to
the aITay of perforated pipes. The state now confums that the perforated pjpe system was not
installed. As ludicrous as it may seem to some people, that a basic, standard feature of a key
landfill system could he omitted from construction, it is exactly this type of gross defect that
explains such a remarkable lack of performance in a leachate collection system. .
~The attempt by the EPA personnel to address this observation is not satisfactory, because
of the kno·wn presence of a large amount of water in the landfill, although it is possible that the
EPA persons did not kuow this. This would reqwre that they had no knowledge of the rain
conditions du.ring the many months the landfill was open and that the leachate pumps had not been
operated previous to their inspection.
6
WOH.:l
hete.6
The Sverdmp & Parcel report noted that the intent of the leachate collection and
treatment system "was to treat excess rainwater collected in the disposal area during PCB
pL-1cement, but the system was not used during construction because a D.H.R. Discharge Permit
had not been obtained prior to construction. The system was left in place to facilitate the State in
removing water accumulated in the upper leachate collection system during construction." The
state's own Final Report in September 1983 said that 111he pumping of the landfill's leachate
collection system to remove rainwater that accumulated during the operational phase commenced
ou March 7, 1983." In other words, the state confirmed that it knew in 1983 that rainfall had
accumulated in the .landfill But good engineering practice would not have allowed rainwater to
accumulate in the landfill. It was not safe to delay operating the leachate collection system undl
March 7, 1983, over three months after the last PCB wastes had been placed in the lan.dfill, \.vbich
altogether bad taken about two months for placement in the landfill. In other words, water was
allowed to accumulate for at least five months (ie., it is not clear from the records when exactly
the cap was fiTst placed on the land.fill).
The failure to extract rainwater during construction constituted a major construction
deficiency, allowing l4'Gter to accumulate, pond on the lower liner, and build up a high
hydrostatic pressure. It is doubtful that EPA wqu/d hove approved letting the rainwater buildup
in the landfill without any pumping of the leachate collection system. Moreover, the failure to
operate the leachate collection system during construction was especially shortsighted because of
the omission of the gravel protected perforated pipe system on th.e bottom of the landfill
There are several key questions that must be raised about the gross failure to install the
perforated pipe system:
► Did the statt~ or one its contractors initiate the decision to omit the perforated pipe systm?
► Did the state knowingly approve the omission of the perforated pipe system? If so, did the
individuals have environmental engineering expertise?
6Tbe nle document that referenced the March 1990 study also said ''It was discovered that
the foot v~J:ve in the leachate collection system had failed and needed to be replaced. lbis
explains why no leachate bad been pumped in recent years, since the system would not hold the
ptime water. 11 An a.s-built drawing shows the foot va.lve at the end of tbe PVC extraction pipe in
the sump. lbis explanation, however, is not consistent with what this analysis has found to be
overly low levels ofpumpablc liquid from the very onset of operating the system. Moreover, a
conclusion about the foot valve bein.g inoperable could be explained by the hypothesis given here,
namely that sand intrusion resulting from a high head of leachate in.capacitated the coJlection of
water from the sump. Nor did the state explain what might have caused the foot valve to fail.
7
4-05-1996 8 ·47PM FROM
What technical reasons were used to justify doing this?'
► Was EPA informed or con~ted about the decision, before or after the fact?
► Because the state knew that the perforated pipes had not been installed and that rainwater
had accumulated in the landfill, why did it not realize sooner than 1990 that there must
have been a dysfunctional leachate collection system? Why was public disclosure of the
large amount of leachate in the landfill problem delayed uo.til 1993?
It must be emphasized thst one of the requirements imposed by EPA on the state in
its June 1979 appro,·al of the Warren County PCB Landfdl was: "A leachate collection
system with a sump and access which will allow pumping out of any collected leachate is
required above and below the day liner." Clearly, the state has been out of co.mpliance for
many years. Furthermore, EPA's Technical Review in June 1979 also noted that "the leachate
collection system above the soil liner should be required with the appropri.tte sump to provide the
mechanism to allow pwnping out of any leachate collected to prevent any significant hydraulic
head buildup on the cLty Jiner.11 This requirement is not consistent with the state allowing
rainwater to buildup for many months prior to starting the leachate collection system. EPA,s
March 1983 report on its onsite activity said that it l\'llS designed "to evaluate the effectiveness of
the leachate withdrawal and treatmen.t system" and it noted that the leachate collection system
was "a safety measure to prevent buildup of hydrostatic pressure within the landfill.'' But EPA
evaluated on~v the first two days of the system 's operation. 1liis is an invalid basis for EPA
concluding that the leachate collection system was designed and constructed properly, aud no
document has been found to indicate that EPA eicamined tb.e longer term data for the S}·stem and
its performance.
It is also important to note that a professional paper, authored by EPA scientists at the
Research T1iangle Park facility, included an analysis of the Warren County PCB Land.fill and even
provided a figure showing the cross-section of the, landfill, which was described as "a state-of-the--
art landfill designed to exceed the requirements of To SCA. "8 The figure showed the presence of
petforated pipes within the leachate collection layers, both top and bottom. The appropriate
question is: did the EPA persons obtain the information for the dra"'ing, or the duwing itself:
from state or EPA persons directly associated with the landfill? Was the presence of the pipes
based on what was said originally by the state in its 1978 application to EP1' or on what wns
., A key document that has not been found is the final des.ign of the landfill used for
constrnction purposes. Presumably, such a document would have been produced and it should at
least show that the perforated pipe system was not to be installed, even if it did not explain why
the change was made from the original conception of the landfill.
8R.G. Le\.\is et al, "Measurement of Fugitive Atmospheric Emissions of Po.lychJoriuated
Biphenyls from Haz.ardous Waste Landfills," Environ. Sci Technol., vot 19, no. 10, 1985, pp . 986-
991. ToSCA is the federal Toxic Substances Control Act.
8
I-'. l
0 L .d
assumed to be present in a state-of-the-art hazardous waste landfill? Because the state has
con.firmed that the perforated pipe system was not installed, th~ issue of what EPA knew and
approved is of considerable s1gnificance.
lt is also significant that the Governor's 1984 Intergovernmental Working Group on PCB
Detoxification actually examined the landfiU's performance and said: "Some rainwater that
in11ltrated the PCB contaminated soil prior to placement of the final cap o.u tb.e landfill has been
collected in the leachate collection system. The water was removed on 37 occasions smce the
closure of the landfill ... " The clear message of this statement (like that previously by EPA) by a
hit?h level group of scientists and engineers was that the leachate collection system was effective.
Of course, this group only had ac«ss to about one year of data on the system ( apparently from
March 1993 through May 1984). The group concluded that the ''these data indicate that there is
no public health or environmental impact from the PCB landfill'' The final report said that ''While
the landfill was very well designed and constructed, proper maintenance is exceedingly important.
The hallmark of a successful landfill is a sound monitoring and maintenance program." Sucb
statements are. of course, completely inconsistent with what is now clear about the landfill,
particu]arly that the leachate collection system was not operated during construction, did not
.remuve a significant portion of the initial water in the landfill, and .has never functioned
effectively, that the state has done nothing to correct the problem. and that EPA has not
compelled the state to correct an deplorable situation. Apparently no member of the Governor's
group observed that the perforated pipe system that the state originally said would be used was
not installed
It should be noted that talk by the state ofth.e need to extract the water from the landfill
does not address the fundameotal deficiency of the leachate collection system. That is, even if
water was simply pumped from the landfill, it would not leave the landfill with a fimctioning,
effective leachate collection system, which is absolutely required. Use of some above ground
pumping system based on new vertical wells placed into the landfill would represent a major
change requiring EPA approval and raise a host oflong term issues.
Jt is also prudent to question the claim by the state that no leachate has penetrating the
main bottom liner. because no liquid has been found in the lower detection or leachate collection
systetn. This seems odd, because if such a large amount of water has remained in the landfill for
so long, th~n that liquid must have penetrated to some extent the lower liner system (both the 30
mil PVC liner with 23 patches, and the five feet of compacted clay). In a normal landfill, leachate
either is collected or it ponds on the bottom liner, where some can flow through the bottom liner.
In a well designed landfill, leachate is collected efficiently, and the sump is properly designed, so
that free liquid ponds to a roinimwn degree, gre11tly minimizing flow through the bottom liner. If
so much water has been in this landfill for so long, then one would expect some water to
penetrate the bottom liner. There are also several possible failure modes for the lower leachate
collection system For example, the as-built drawing suggests the possibility that water could leak
directly from the sump or that the sump itself became clogged by sand, because of features used in
9
HV'LV •E 966 L-S0-t7
1 l d
the top sump but not the bottom one.9 T11ere is /;tt/e reason/or the pubiic to trust the assertions
of tlze state that the lower leaclzate collection system is effective and reliable, and that no
leachate ha,; penetrated the main clay bottom liner and escaped
Lastly, it is useful to examine the highest rate ofleachate removal that EPA observed and
ask the question: if trus rate represented an effective leachate co11ectiou system, how long would it
have ta.ken to completely remove the huge amount of water in the landfill? Assuming 500,000
gallons, if the rate is 200 gallons/day as found in the fir~ two days, it would take at least 7 years,
and if the rate is 2,500 gallons/month as found .in the first two months, it is about 17 years. Such
long periods are not consistent with acceptable landfill design and consuuction, supporting the
view that this land.fill should never have been approved as a safe and sec\ll'e facility by the state
and EPA. For example, EPA has said that ''Approximately 2 to 5 years after closure, leachate
generally levels off to a low-level constant cap leak rate or, in a very tight, nonleaking closure,
falls to zero. "10
The state might assert th.at they believed the lack ofleachate retrieved starting in 1986
indicated normal behavior. But this only makes sense if state personnel had n.o knowledge of the
extent of rainfall that entered the landfill during its construction. which. seems implausible and
,.;ontradicted by 1983 documents. Even a rough calculation of the local rainfall during the totitl
constmction period between completion of the bottom liner and the cap for the acreage lnvolved
woul.d have provided a volume of water much greater than the 8,000 gallons collected from 1983
to 1985. It is worth noting that the pumping system was &b.o\\n to have a capacity of
withdra\\ring some 200 gallon.s/bour or 4,800 gallons/day. If there was some 500,000 gallons of
liquid in the landfill, theo: the system was capable of removing all ofit mjust over three months.
Even if there was on.e million gallons present, presumably any calculation would have shown
engineers that there was a llUljor disparity between the qunatity of liquid pumped versus what
should have been Vvithdrawn if the system had been operating properly, and that the problem was
the inability of liquid to reach the extraction pipe in the sump.
Da~_-<m . .W ater Level Variations
Failure of the leachate collection system is also compatible with the observed correlation
between height cycles in the water inside the landfill versus levels in the monitoring wells over
about four year~. The most scientifically consistent and correct explanation is that water level
in!-ide the landfill is reacting to wat.er conditions outside, with surface recharge water affecting
both the levels in the wells as well as the level inside the landfill, because some water is infiltrating
!'According to the drawing, no filter fabric was used on the lower sump, and the lo1\·er
SUJlll' was not formed by compacted clay but cut into the natural site soil.
'°EPA, "Requirements for Hazardous Waste Landfill Design, Construction, and Closure,"
August 1989, E PA/625/4-89/022.
the cap ~stem. 11· However, it must be acknowledged that in a properly designed and built landfil1
very little sutface water should infiltrate, because most surface water is supposed to run off the
sutface of the landfill. However, some water retained in surface soils can infiltrate the cap,
producing new leachate. EPA has said that "If closure is not complete, then the rate of leachate
generation in the primary coll.ectot may reflect precipitation trends. "11 Incomplete closure means
a low quality landfill. Because no leachate is being collected, the height of water in the landfill
serves as a surrogate measure and the current data indicate that the internal water level is related
to precipitation trends affecting the level of groundwater in nearby wells.
The state's attempt to explain the fluctuations in the height of the water inside t.he landfill
on the basis of temperature and/or pressure induced volume changes lacks credibility. The
p.rohlem is that there is too close a match with between the cycles of water height changes inside
and outside the landfill. The times when the level of water inside the landfill is highest do not
match -with the warmest parts of the year. Atmospheric pressure changes would not produce such
a systematic cyclic change. Pressure changes to new gas formation inside the landfill is highly
unlikely, because most decomposition of organic matter would h.ave taken place early after waste
disposal, not some ten yea.rs late.r. Nor would such changes be expected to match th.e cyclic
changes in the monito.ring well water levels.
A somewhat steady level of water inside the landfill is consistent with a dynamic water
inflow-outflow situation. Tue build up of water inside the landfill increases the pressure ( or head)
and eventually, for a certain set of defects in the liner system or even a certain level of
permeabjlity, some rough equilibrium can be established so that only some small fraction of the
total amount of water present is released from the landfill and then is replenished by new water.
A truJy catastrophic failure of the landfill's lower containment systern (sufficiently low in
the sides or in the bottom liner), of course, would result in a major reduction in the height of the
water level inside the landfill. But without a major failure in the containment system, it is
reasonable to see a roughly steady-state situation, with only a slight increase in the total internal
volume of water, even though water enters the landfill in response to external rainfall and soil
saniration conditions.
1 •There are several possible problems with the cap system. The state said in its t 983 Final
Report that bubbles in the PVC top liner were "pierced'' to allow temporary venting pipes to be
inserted, but the holes were not necessarily perfectly repaired. The clay layer may have bad
desiccation cracks or other defects. The PVC was also only 10-mil in thickness, increasing the
likelihood of water penetration.
1~EPA, "Design and Construction ofRCRNCERCLA Final Covers," May 1991,
EP A/625/4-91/025.
11
WO~.:l
~lusions
Available data are ntost consistent with an explanation based on some water
entering the landfill O\'er time and a very large iaitial amount of water caused by rainfall
during construction and initial water id buried w~utes remaining in the landfill. Because
only about 1 % of the water initially in the landfill was collected by the Je11cbate collection
system. the evidence is that the leachate collection system never operated effectively. Tb~
engineering design of the S)'Stem seems to have been grossly neglieent, because of the
absence of the standard gravel protected pe.rforated pipe system in trenches. Se<:ond, the
leachate collection system was not operated during construction as originally plu1Ded,
compounding the probleni because of heavy rainfall accumulation.
In other words, the landfill should never have been approved by the state and EPA
to begin with, because a critical requirement for the Jandml was never satisfied, and the
landfill i.s also lukiog. It is clear that the state itself was fully aware that the perforated
system it first included as part of the landrill design was not installed and, tbe.-efore, the
state has primary responsiblity for its omission.
EPA spedfically required a functionine, effective leachate collection system to a.,,·oid
buildup of hydrostatic pressure on the bottom liner. The state has been in noncompliance
for many year~. 'The files do not indicate any EPA e:uminatioo. of the leachate collection
system after iti fi.rst two days of operation. No document has surfaced indicating that the
state reported to EPA the omission of the perforated pipe system, the accumulation of the
rainfall, or the malfucctioning of the leachate collection system. Of course, a poorly
designed and nonfunctioning leachate collectioo system is consistent with water entering
and leaving the landfiU resulting from other dt-ficiencies in the landfill.
There is no reason to be optimistic about the state's assertion that the lower leachate
collection system, really a form of monitoring, is functioning properly. Although the state
asserts that no liquid has passed through the main clay bottom liner, there is little basis for
trusting tbst conclusion. To the contrary, there is more reason to believe that some water
has leaked from the landf"ill and gone undetected and uncollected.
While the landfill and the large amount of water in it are unacceptable, the way to
res,,/ve all the commitments of the state --the Governor's to the community and the state to EPA
-· is to seek the most expedient detoxification of the landfill possible, and understand that ii
would include total removal of a/I landfill contents, both water and PCB wastes.
It also seems appropriate for the Working Group to seek an investigation by state
and possibly federal justice authorities into the exact circumstances that resulted in a
gros:sly deficient lea~hate col.lection system and a landfill that has had a huge amount of
water in it for yeart1.
12
General
PCB LANDFILL HYDROLOGY AND
LINER LEAKAGE
By: Patrick A. Barnes, P.G.
PCB Landfill Working Group Science Advisor
In March, 1983 , shortly following construction, the State reported that a significant amount of
water had entered the landfill as a result of storm water events which had occurred during the
construction process (September -November, 1982). By June, 1983, the State had removed
S,000 gallons of water through the leachate collection system. It is unclear whether the 5,000
gallons removed represented all the water thought to be in the landfill at that time or not Over
several subsequent years the State continued to remove small amounts of leachate through a
largely inoperable collection system. Based on available data, the total leachate quantity removed
is approximately 8,000 gallons. In 1993, the State reponed that the landfill contained
approximately 13. 5 feet of water based on water level measurements made in the leachate
collection system.
The. increase stress on the bottom liner system coupled with several other complicating factors has
apparently resulted in a breach of the bottom liner integrity. Additionally, either through normal
weai:-, manufacturing defects or improper installation the upper composite liner of the landfill also
appears to be breached
Liner Des1w
Recent studies performed by Lee and Schroeder show that the composite liner system similar to
that designed by the State for this facility has high leakage rates associated with it. The. study
evaluated six liner designs using the HELP model and found the most effective system included a
drainage layer, followed by a synthetic liner, a low penneability soil layer, and additional drainage
layer, synthetic liner, followed by a final soil layer. It concluded that composite liners where the
synthetic liner is not in direct contact with the compacted clay layer are more likely to fail . The
PCB landfill bottom liner system includes one foot of fill between the synthetic liner and the
compacted clay layer.
I
The initial siting report indicates that the State made use of on-site clay materials in construction
of the clay liners. AJthough this material would have been substantially reworked and compacted,
the fact that this material comprised a portion of a thick section of material which was weathered
in place implies that over time it will tend to form cracks and avenues for percolation.
The 30 mil synthetic bottom liner was severely damaged by vandalism during the early phases of
construction. Some of these holes are depicted in pictures I through 12. Given the substantial
nature of the vandalism, the State should have probably considered placing an additional synthetic
liner above the damaged one rather than patching the damaged liner.
95•017
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The top liner system includes a synthetic PVC liner in direct contact with a low permeability soil
layer; however, the PVC liner is very thin (1 O mils) th.is, in addition to the numerous problems
which could arise from during manufacturing and installation, are reasons to suspect possible
failure. Problems during construction (see pictures I through 12) may have also contributed to a
loss of integrity.
Rainfall Occurrence
The monthly rainfall amounts for Warren County (Alcala) were reviewed to characterize its
relationship to the monitoring well hydrographs and ~he leakage level fluctuations. The graph
shows that the area receives a significant amount of rain consistently throughout the year with
peaks in early spring and early summer. Rainfall for Alcola for the past four years is given on
Figure 1. The peaks align quite well with the peaks in the water table hydrograph showing that
precipitation recharges quite readily within the landfill area. This is particularly interesting
because low penneability of the native clays was a significant factor in the State's decision to
select the Warren County site. Based on rev1ew of this data it is apparent that, alt.hough toe
onsite clays have very low laboratory permeabilities, the effective permeability of those same
sediments is actually much much higher.
The average rainfall per year for the Warren County area is approximately 45 inches. The area
received approximately 9 inches of rain during the months of September, October and November.
1982. The period of time attributed to water inflow by the State. The 9 inches does approximate
the 13 feet of water initially reported by the State. In l 995, which was a wet year, the average
rainfall increased by over 10 inches, to 56 inches. Consistent with liner leakage, this increase in
rainfall was also ultimately represented in a rise in landfill water level.
A1011itori11g Well Hydrograph
The obvious source of this rapid groundwater recharge is secondary porosity such as cracks in the
native silty sand and clay layers. The effective recharge of precipitation as analy.zed by at least a
one year hydrograph is a necessary first step in the hydrogeologic evaluation of potential landfill
sites, and wns apparently not performed by the State prior to site selection. As would be
expected, the rainfall variations match very well with the monitoring well hydrographs particularly
for monitoring wells 2, 3 and 4. MW• I appears to be partially plugged and does not respond in
phase with the other wells.
Generally, it appears that significant rainfall events which occur during the early spring and late
fall directly translates to a rise in groundwater levels while large rainfall events which occur during
sum1Uer months go largely unnoticed in the groundwater system. This is due to the much higher
evaporation which occurs during the summer months. The increase in evaporation in summer
months is a very important part of the hydraulic cycle and as wiU be discussed later, plays an
important role in the landfill water level hydrograph and the proposed leakage dynamics.
Another very interesting aspect of the monitoring well hydrographs when compared to both the
landfill water level and the precipitation amounts, is tha.t the genera.I trend of the wells is towards
-2-
decreasing water levels, while both precipitation and landfill water levels are increasing The
concurrent rise in rainfall amount and landfill water levels strongly indicates that precipitation and
thus leakage is controlling the landfill's water level.
Landfill Water Level Hydrograph
As would be expected in a lined landfill, the peaks in landfill water level do not align with that of
rainfall, instead they are shifted into the future on the leachate level graph (Figure 2). Although
this behavior is slightly masked for several smaller peaks, the highest rainfall months recorded,
March, 1993, 1994 and 1995 are consistently followed by peaks in the landfill water level six
months later in September. A second peak in rainfall in June, 1995 is once again followed by a
very high landfill water level peak six month's later in December. This regular pattern could not
be coincidental. lt obviously represents the period ohime it takes water to travel through the top
liner system eventually reaching the landfill water table.
With the exception of the six month shift in the hydrograph, the landfill water level is behaving as
would be expected for any natural system in direct connection with the emironment. It has a
water balance as would be expected for any flow basin. This is particularly disturbing because the
system was engineered to remain isolated from surface and groundwater influences. More
importantly, perhaps, as will be discussed later is that the landfill water level has consistently rose
during the period of record.
/.eakage Dynamics
The various components of the landfill water level hydrograph can be explained as follows :
I . Quickly following large rainfall events the two foot layer of top soil becomes saturated and
small amounts of rainfall seep through improperly seamed or worn areas of the upper
synthetic liner The majority of leakage through the upper liner probably occurs during
periods of low evaporation when the soil above the liner can remain saturated for much longer
periods following rainfall events. This increase in water level increases the threat to the
environment by increasing the pressure on the bottom liner.
2 Percolalion then occurs through the clay portions of the liner. Both by granular conveyance
and through cracks this process takes approximately six months and is the major component in
the offset between the landfill water level rise and monitoring well hydrograph rise.
3. Flow continues downward through the unsaturated landfill contents
4. Typically, during the months of July though November, the water level within the landfill rises
as a result of the leakage which occurred across the top liner during December through June
Significant leakage through the top liner does not occur within these months (July-
November).
95-017
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-3-
5. The resultant increase in pressure on the bottom liner attributed to the water level rise results
in leakage across that composite liner {primarily during December through June) which
subsequently decreases the water level within the landfill.
6. As Figure 2 indicates, the cycle repeats itself; however for the period of record more water
enters than leaves the system, i.e., Qin>Qout. Although for several months at a time the
reverse is true Qout>Qin.
DelaFed Rise
As discussed, the rise in water levels within the landfill is approximately six months out of phase
with the monitoring well hydrographs and rainfall data. This delay is primarily due to the effective
penneabiUty of the 10 mil PVC and 2 ft. thick clay top liner. It is believed that precipitation seeps
readily through the 10 mil PVC liner via openings due to manufacture defects, improper seaming
and installation and/or normal wear. Once under, this potential leakage water is protected from
evaporation and can seep through the clay under condition of saturated flow, or through a system
of fractures within the clay.
Using the groundwater velocity equation the leakage rate across the 24" clay layer can be
estimated as follows :
V=Kl
e
V • Velocity (length/day)
K = Penneability (length/day)
1 -Gradient (ft/ft)
9 = Porosity (un.itless)
K = I 0"7 cm/sec
I-d.h=l=l
dL 2
9 = .03 (Todd)
V = l0-7qn/sec(l) = 3.33 -6/cm • 1 inch • 86.400 sec.
03 sec . 2.54/cm day
V = .1133 in. • 180 days ~ 20 inches
day 6 months 6 months
This fits very well with the approximate thickness of the clay top liner (24 '') indicating that even
with a conservative permeability value (the one used by the State for the intact clay layer) water
can be transferred as shown by the hydrograph within an approximate 6 month period.
Each ~eason for the four years of record there is a rise in water level of approximately 12 inches
followed by a drop of about 11 inches. This cyclical pattern has resulted in a net increase in water
95-017
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-4-
level over the period of approximately 1 foot. Because of improper documentation and reporting
early on, it is difficult to say how much of the total volume of water present in the landfill
originated from storm events and improper stormwater management.
However, we have already established that the effective permeability of the clay will allow
transmission of water across it with the assumption that rain water readily passes through the
synthetic Uner through breaches.
It is assumed that the landfill materials have an average effective porosity (specific yield) of 5% or
.05. The approximate 10 inch fluctuation observed over a six month period can be attributed to
approximately 1/2 inch of leakage through the liner systems. For the period of record the landfill
area experienced over 45 inches of rain per year, one-half of an inch of leakage represents only _
l % of the total rainfall.
Volume Q[landfi/1
The volume of the landfill can be approximated by calculating the area of a plane midway between
the top and base of the landfill and multiplying it by the height. The mid point is equivalent to the
average of the top area and the area of the base.
Top Alea= 240' x 475' = 114,000 ft.1
Bottom Area= 100' x 300' = 30,000 ft.l
Mid Point"" 144,000/2 = 72,000 ft.2
Volume= 72,000 ft .2 x 22 ft.=
;: 1,584,000 .ft .3
Volume of Water
The volume of initial water in the landfill can be calculated using the same general procedure and
substituting the thickness (22 ft .) of the landfill material with the height of the l3 fl . water
column . as follows :
95-017
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Top Area (at Water Surface)= 400' x 175',.. 70,000 ft.2
Bottom Alea= 100' x 300' =-30,000 ft.1
Mid Point= 100,000 ft.2/2 = 50,000 ft.1
Volume ""50,000 ft.2 x 13 ft.
= 650,000 ft.~ x 7.58 gal
ft. 3
= 4,862,000 gals. , .05 (specific yield)
= 243,100 gals.
-5-
The base elevation of the landfill is 320' MSL. If the initial height of water in the landfill was 13
feet as reported by the State, that would equate to an elevation of approximately 3 3 3 ft . ln
February, 1996 the average elevation was approximately 2.5 ft. higher at 335 .S ft. MSL Since
the water in the landfill was first reported, there has been an increase in the amount of water in the
landfill by approximately 2. 5 ft.
The current volume of water (Nov., 1996) in the landfill based on the historical rise in water level
is estimated to be approximately 320,000 gal. (this includes an additional .2' of water level rise
between February and November) which represents an increase of 77,000 gallons over the l 4 year
landfill life or an average net increase of approximately 5,500 gallons per year .
If it is assumed that during periods of landfill water level rise only very small amounts of water is
being discharged, and if it is assumed that during periods of falling water levels that only slight
amounts of new leakage is coming in, then the annual inflow and outflow of water to and from the
landfill can be approx.imated as seen on Table l .
Because of the shape of the landfill it is necessary once again to use an average area to estimate
inflow and outflow The surface area used is that of the landfill at elevation 33 5 ft. MSL. The
estimated 3,000 gallon net increase in landfill water matches fairly well with the 5,500 gallon
amount estimated based on the 2.5 ft. rise in water levels over the life of the facility, especially
given that the State's initial height estimate was a rough estimate.
" ''
Di1chaiie
Table 1
Estimate Water Balance
Lut 3 Years of Data
. , Rise a:rid )F.~l'bi;:i:iith~ '''
y 1 .e~r · Yeat+:1: .,~ ... ~
Annual
Average Leakage
: 'Inell~~ Volume
Q Out 9 12 12 11 .0 25,965 gallons
Leakage (.45) (.60) (.60) (.55) (.55 in) --
Q In 12 10 15 12.4 29,033 gallons
Leakage (.60) (.5) (.75) (615) (.615 in.)
Note: The decimal given in the parentheses is the amount of leakage either in or out of the
landfill which is required for the observed rise and fall in landfill water level (the number
immediately above it).
95-017
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-6-
Construction Process
It appears that the Contractors involved in the construction of the PCB Landfill were faced with
several problems which could have compromised the integrity of the landfill from a very early
date, not the least of which was weather and vandalism. We were unable to obtain copies of the
field construction logs; however, pictures 1 through 12 show some of the construction , elated
problems. They were obtained from the State's files.
As can be seen, the landfill was largely unprotected from precipitation which resulted in a
significant inflow of rain water. Additionally, the top soil material appears to have been
inappropriately selected and/or compacted which resulted in exposure of the top synthetic liner
The pressure build-up below the PVC top liner as shown in the attached pictures is strong
evidence for the existence of fractures in the upper clay layer. These fractures would represent
one avenue for possible downward leakage of precipitation.
The pictures also shows the vandalism discussed which may have also played a key role in the lo~s
of lower Uner integrity. It is uncertain why this liner was not replaced instead of repaired by the
State contractors.
System Design & Leachate Management
The landfill system appears to be improperly designed in two key areas.
1. Top Liner System
Pictures l 1 and 12 show significant ripples in the top soil across the landfill surface. In
several areas, these ripples resulted in the exposure of the PVC liner. These features may
represent areas where surface water could pond and enhance percolation. The top liner
should have been designed to minimize slumping and potential water ponding,
2. Leachate Collection System
The leachate collection system which the State has indicated is largely inoperable, can only
pump very small volumes at any given time and is improperly designed . A significant problem
with the system design is the apparent absence of a perforated pipe extraction system . In
order to effectively remove water from the silty soils present in the landfill, a much more
extensjve system of leachate collection encompassing a significant portion of the bottom area
should have been employed.
The soil present within the landfill originated on road shoulders throughout the State, typical
road shoulder material is designed for stability meaning it is usually very poorly sorted. This
does not appear to have been a consideration in the system design.
95-017
lnt.egril.doc
-7-
Monitoring
The State is currently in gross non-compliance with the TSCA monitoring requirements. No
samples have been collected and analyzed from any of the four groundwater monitoring wells or
four surface water stations since July, 1994. Based on documents reviewed dated June, 1983 and
on the State· s Operational Plan environmental samples were to be collected twice per year until
otherwise stated by the EPA regional Administrator. The State has missed four consecutive
sampling events
Of particular concern to me is that the site only contains four monitoring wells which in my view
are not only improperly located but also poorly designed. The surface water stations selected also
appear to be dictated more by accessibility than environmental science.
The State was very much aware of the site hydrology and in fact used it heavily in the selection
process. In the 1980 Environmental Impact Statement the landfill site's drainage is described as
being controlled by six major draws around the landfiU site. Given that statement, it is difficult to
understand why no monitoring wells were placed directly at the head of any of these features
Also, after spending a significant amount of time in the field inspecting the hydrology of the site I
fi nd it incredible that no surface water samples have been collected at the several contact springs
which surround the site. These features represent the most likely points of origination for any
discharge which might result from the landfill bottom liner.
Additionally, based on discussion with State staff, it appears that the stream sediment samples are
being collected at the same locations as ,the water samples (approximately mid-stream). Given
that this is not the most likely location for sedimentation to occur, it is doubtful that they are
indicative of the potential impact from the landfill .
Discussion
The graph shows the fluctuation of water level as measured in the leachate access pipe and the
cent.rat vent observation well. The rise and fall of this water level was thought by the State to be
directly related to the heating and cooling of the landfill materials. We agree that heating and
cooling may result in some fluctuation; however, the heating and cooling process in a system with
very little organics (less than 2%) should not result in a long-term increase in water levels as
shown by the green line. Moreover, the frequency of the peaks and valleys align very well with
that of the monitoring well hydro graphs. In our opinion, this is a strong indication that the landfill
is functioning as a natural system that is receiving and releasing water. This pattern is not in
phase (the peaks of the water in the wells don't match with the peaks of the water in the landfill)
with the surrounding area because it takes the water several months · to flow through the
composite liners. The delayed yield shown is roughly analogous to that which you would expect
in a semi-confined , two aquifer system. It is the result of the time it takes water to seep through
the upper composite liner. For the period of record, it appears to be fairly constant; however. it is
important to note that the rate of leakage will increase over time . The leakage rate is directly
related to the permeability of that material, flaws in the liner system resulting from pinholes and
9~-017
(ntegrit, doc
-8-
holes formed during seam welding, manufacturing defects and vandalism Another potential
source of failure is stress cracking or brittle fracture.
The average increase of the water level by approximately l foot over the four year period of
record is in line with seepage rates used by the USEPA for flexible membrane liners and
represents approximately l/2 inch of leakage per year. It is our opinion that this increase is a
good indication that water is seeping into the landfill . The fact that the increase is not a steady
incline but varies seasonally is an indication that the system is also discharging water through the
bottom liner. There is a net increase in the landfill water level because more enters than leaves the
system.
In summary, if no new leakage water was entering the system the water level would remain Oar,
and if no water was leaving the system the water levels would not decrease then increase in a
cyclical pattern.
9~-017
lntegrit.doc
-9-
RAINFALL (inches) -0 A t.11 en 0 Nov-92 Jan-93 Mar-93 May-93 ~ z ::0 0 it Jul-93 ::0
:s.: m z Q Sep-93 ;;..
0 ::,-
V, 0 f Nov-93 C 5-z :,
~ 0
Q. JM-94 Q)
~ ~ .....
(I) Mar-94 "C' -@ z u• -r, (ti > :;i_ May-94
3 r c;.· r II' Jul-94 CJ 5
(0 ~ 0 -,
::::, Sep-94 > (")
0 -> 3 "2. Nov-94 ::0 It,
0 -~
0 ~
Q) Jcin-95 > 5
(0
Q)
(/) c; Mar-95 <0
► (1)
0 .
Cl> -f ni May-95 -0 z Juf-95 -
SPp-95
Nov-95
Jan-96
J "'
. State of North Carolina · Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
.AVA
DEHNR
November 1, 1996
Memorandum
To:
From:
Subject:
Linda Rimer
y Bill Meyer,
PCB landfill
The DWM intends to spend approximately $10,000 on instruments to monitor the PCB
landfill including: meteorological detection devices [temperature, manometers (for barometric
pressure both ambient and internal to landfill)]; stainless steel well casing)andfill gas detection
systems.
In addition, the Division is paying $22.53 per hour for 20 hours per week for a temporary
engineer to assist with the PCB project ($4,179.32 from August 12 -October 11, 1996).
The Division also has a team of staff including: the Division Director, Deputy Div. Director,
Public Information Officer, four Hydrologists, two Engineers, and one Environmental Supervisor
working at various levels of commitment on the project. For example, approximately 20% of the
Directors' time is spent on the project. This is, and has been, a significant investment by the Division
from our operational budget. At some point in the near future, we would appreciate some budget
consideration from the Department. ·
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
I ..
.\
-·· ·-··----·--·----..... •---·-·-
. .
r • \
I
'J
I
General
PCB LANDFILL HYDROLOGY AND
LINER LEAKAGE
By: Patrick A. Hames, P.G.
PCB Landfall Working Group Science Advisor
In March, 1983, shortly following construction, the State reported that a significant amount of
water had entered the landfill as a result of storm water events wruch had occurred during the
construction process (September -November, 1982). By June, I 983, the State had removed
5,000 gallons of water through the leachate collection system. It is unclear whether the 5,000
gallons removed represented all the water thought to be in the landfill at that time or not Over
several subsequent years the State continued to remove small amounts of leachate through a
largely inoperable collection system . Based on available data, the total leachate quantity removed
is approximately 8,000 gallons. In 1993, the State reponed that the landfill contained
approximately 13. 5 feet of water based on water level measurements made in the leachate
collection system.
The increase stress on the bottom liner system coupled with several other complicating factors has
apparently resulted in a breach of the bottom liner integrity. Additionally, either through normal
wear, manufacturing defects or improper installation the upper composite liner of the landfill also
appears to be breached
Lmct Desi~1
Recent studies performed by Lee and Schroeder show that the composite liner system similar to
that designed by the State for this facility has high leakage rates associated with it. The study
evaluated six liner designs using the HELP model and found the most effective system included a
drainage layer, followed by a synthetic liner, a low permeability soil layer, and additional drainage
layer, synthetic liner, followed by a final soil layer. It concluded that composite liners where the
synthetic liner is not in direct contact with the compacted clay layer are more likely to tail . The
PCB landfill bottom liner system includes one foot of fill between the synthetic liner and the
compacted clay layer.
I
The initial siting report indicates that the State made use of on-site clay materials in construction
of the clay liners. Although this material would have been substantially reworked and compacted.
the fact that this material comprised a portion of a thick section of material which was weathered
in place implies that over time it will tend to form cracks and avenues for percolation.
The 30 m.il synthetic bottom liner was severely damaged by vandalism during the early phases of
construction. Some of these holes arc depicted in pictures I through J 2. Given the substantial
nature of the vandalism, the State should have probably considered placing an additional synthetic
liner above the damaged one rather than patchina the damaged liner.
95-017
lntegrildoc
The top liner system includes a synthetic PVC liner in direct contact with a low penneability soil
layer; however, the PVC liner is very thin (l O mils) this, in addition to the numerous problems
which could arise from during manufacturing and installation, are reasons to suspect possible
failure. Problems during construction (see pictures l through 12) may have also contributed to a
loss of integrity.
Rainfall Occurrence
The monthly rainfall amounts for Warren County (AJcola) were reviewed to characterize its
relationship to the monitoring well hydrographs and the leakage level fluctuations. The graph
shows that the area receives a significant amount of rain consistently throughout the year with
peaks in early spring and early summer. Rainfall for AJcola for the past four years is gh1en on
Figure l . The peaks align quite well with the peaks in the water table hydrog, aph showing that
precipitation recharges quite readily within the landfill area. This is particularly interesting
because low penneability of the native clays was a significant factor in the State's decision to
select the Warren County site. Based on review of this data it is apparent that, alt.hough the
onsite clays have very low laboratory permeabilities, the effective permeability of those same
sediments is actually much much higher.
The average rainfall per year for the Warren County area is approximately 45 inches. The area
received approximately 9 inches ofrain during the months of September, October and November.
1982 . The period of time attributed to water inflow by the State. The 9 inches does approximate
the 13 feet of water initially reported by the State. In 1995, which was a wet year, the average
rainfall increased by over 10 inches, to 56 inches . Consistent with liner leakage, this increase in
rainfall was also ultimately represented in a rise in landfill water level .
J,.Jonitoring Well Hydrograph
The obvious source of this rapid groundwater recharge is secondary porosity such n.i; cracks in the
native silty sand and clay layers. The effective recharge of precipitation as analyzed by at least a
one year hydrograph is a necessary first step in the hydrogeologic evaluation of potential landfill
sites, and was apparently not performed by the State prior to site selection. As would be
expected, the rainfall variations match very well with the monitoring well hydrographs particularly
for monitoring wells 2, 3 and 4. MW•l appears to be partially plugged and does not respond in
phase with the other wells .
Generally, it appears that significant rainfall events which occur during the early spring and late
fall directly translates to a rise in groundwater levels while large rainfall events which occur during
summer months go largely unnoticed in the groundwater system . This is due to the much higher
evaporation which occurs during the summer months. The increase in evaporation in summer
months is a very important part of the hydraulic cycle and as will be discussed later, plays an
important role in the landfill water level hydrograph and the proposed leakage dynamics .
Another very interesting aspect of the monitoring well hydrographs when compared to both the
landfill water level and the precipitation amount&, is that the general trend of the wells is towards
-2·
decreasing water levels, while both precipitation and landfill water levels are increasing Th e
concurrent rise in rainfall amount and landfill water levels strongly indicates that precipitation and
thus leakage is controlling the landfill's water level.
Landfill Water Level Hydrograph
As would be expected in a lined landfill, the peaks in landfill water level do not align with that of
rainfall, instead they are shifted into the future on the leachate level graph (Figure 2). Although
this behavior is slightly masked for several smaller peaks, the highest rainfall months recorded,
March, 1993, 1994 and 1995 are consistently followed by peaks in the landfill water level six
months later in September. A second peak in rainfall in June, 1995 is once again followed by a
very high landfill water level peak six month's later in December. This regular pattern could not
be coincidental. It obviously represents the period of time it takes water to travel through the top
liner system eventually reaching the landfill water table.
With the exception of the six month shift in the hydrograph, the landfill water level is behaving as
would be expected for any natural system in direct connection with the en"ironment. It has a
water balance as would be expected for any flow basin. This is particularly disturbing because the
system was engineered to remain isolated from surface and groundwater influences. More
importantly, perhaps, as will be discussed later is that the landfill water level has consistently rose
during the period of record. ·
J.,ealw.ge Dy11amiq
The various components of the landfill water level hydrograph can be explained as follows :
I. Quickly following large rainfall events the two foot layer of top soil becomes saturated and
small amounts of rainfall seep through improperly seamed or worn areas of the upper
synthetic liner . The majority of leakage through the upper liner probably occurs during
periods of low evaporation when the soil above the liner can remain saturated for much longer
periods following rainfall events. This increase in water level increases the threat to the
environment by increasing the pressure on the bottom liner.
2. Percolation then occurs through the clay portions of the liner. Both by granular conveyance
and through cracks this process takes approximately six months and is the major component in
the offset between the landfill water level rise and monitoring well hydrograph rise.
3. Flow continues downward through the unsaturated landfill contents.
4. Typically, during the months of July though November, the water level within the landfill rises
as a result of the leakage which occurred across the top liner during December through June .
Significant leakage through · the top liner does not occur within these months (July-
November)
95-017
lntq;ril.doc
-3-
5. The resultant increase in pressure on the bottom liner attributed to the water level rise results
in leakage across that composite liner (primarily during December through June) whi<.:h
subsequently decreases the water level within the landfill.
6. As Figure 2 indicates, the cycle repeats itself: however for the period of record more water
enters than leaves the system, i.e., Qin>Qout. Although for several months at a time the
reverse is true Qout>Qin .
Dela.,ed Rise
As discussed, the rise in water levels within the landfill is approximately sbc months out of phase
with the monitoring well hydrographs and rainfall data. This delay is primarily due to the effective
penncability of the 10 mil PVC and 2 ft. thick clay top liner. It is believed that precipitation seeps
readily through the 10 mil PVC liner via openings due to manufacture defects, improper seaming
and installation and/or normal wear. Once under, this potential leakage water is protected from
evaporation and can seep through the clay under condition of saturated flow, or through a system
of fractures within the clay.
Using the groundwater velocity equation the leakage rate across the 24" clay layer can be
estimated as follows:
V=Kl e V • Velocity (length/day)
K -Penneability (length/day)
I -Gradient (ft/ft)
8 = Porosity (unitlcss)
K = I 0·7 cm/sec
l-dh=i=l
dL 2
8 = .03 (Todd)
V = 10·1cm/sec{l} -3.33 -6/cm • ~ • 86.400 sec .
. 03 sec . 2.54/cm day
V = .113 3 in. • 180 days a 20 inches
day 6 months 6 months
This fits very well with the approx.imate thickness of the clay top liner (24'') indicating that even
with a conservative permeability value (the one used by the State for the intact clay layer) water
can be transferred as shown by the hydrograph within an approximate 6 month period.
leaka~e Rate
Each season for the four years of record there i! a rise in water level of approximat"ly 12 inches
followed by a drop of about 11 inches. This cyclical pattern has resulted in a net increase in water
9j-OJ7
lmtlfll.doc
-4-
level over the period of approximately 1 foot. Because of improper documentation and reporting
early on, it is difficult to say how much of the total volume of water present in the landfill
originated from storm events and improper stormwater management.
However, we have already established that the effective permeability of the clay will allow
tran~mission of water across it with the assumption that rain water readily passes through the
synthetic liller through breaches.
It is assumed that the landfill materials have an average effective porosity (specific yield) of 5% or
.05 . The approximate 10 inch fluctuation observed over a six month period can be attributed to
approximately 1/2 inch of leakage through the liner systems. For the period of record the landfill
area experienced over 45 inches of rain per year, one-half of an inch of leakage represents only _
1 ¾ of the total rainfall.
l 'o/ume of La11dfill
The volume of the landfill can be approximated by calculating the area of a plane midway between
the top and base of the landfill and multiplying it by the height. The mid point is equivalent to the
average of the top area and the area of the base.
Top Area= 240' x 475' = 114,000 ft.2
Bottom Area= 100' x 300' = 30,000 ft.2
Mid Point=' 144,000/2 • 72,000 ft.2
Volume= 72,000 ft.2 x 22 ft ....
;; 1,584,000 fl.3
Volume of Water
The volume of initial water in the landfill can be calculated using the same general procedure ant!
substituting the thickness (22 ft.) of the landfill material with the height of the t3 ft. water
column. as follows:
9~-017
l.nlrgril~
Top Area (at Water Surface) -400' x 17S' ... 70,000 ft.2
Bottom Area= 100' x 300' -30,000 ft.2
Mid Point - I 00,000 ft.2/2 = 50,000 ft.2
Volume ,.. 50,000 ft.2 x 13 ft.
= 6so,ooo ft.11 x 7.58 aal
ft. 3
= 4,862,000 ,gals., .05 (specific yield)
= 243,100 gals.
-5-
The base elevation of the landfill is 320' MSL. If the initial height of water in the landfill was 13
feet as reported by the State, that would equate to an elevation of approximately 333 ft. ln
February, 1996 the average elevation was approximately 2.5 ft. higher at 335 .5 ft . MSL. Si11ce
the water in the landfill was first reported, there has been an increase in the amount of water in the
landfill by approximately 2.5 ft.
The current volume of water (Nov., 1996) in the landfill based on the historical rise in water level
is estimated to be approximately 320,000 gal. (this includes an additional .2 ' of water level rise
between February and November) which represents an increase of77,000 gallons over the 14 year
landfill life or an average net increase of approximately 5,500 gallons per year.
If it is assumed that during periods of landfill water level rise only very small amounts of water is
being discharged, and if it is assumed that during periods of falling water levels that only slight
amounts of new leakage is coming in, then the annual inflow and outflow of water to and from the
landfill can be approximated as seen on Table I.
Because of the shape of the landfill it is necessary once again to use an average area to estimate
inflow and outflow. The surface area used is that of the landfill at elevation 335 ft . MSL. The
estimated 3,000 gallon net increase in landfill water matches fairly well with the 5,500 gallon
amount estimated based on the 2.5 ft. rise in water levels over the life of the facility, especially
given that the State's initial height estimate was a rough estimate.
Di1char2e
Q Out
Leakage
Q In
Leaka~e
Table 1
Estimate Water Balance
Lut 3 l'ean or Data
.. : ... Rite· ind Fall b•'lij¢h~
Veanl : . · Year:~' :Vtar 3
9 12 12
(.45) (.60) (.60)
12 10 15
(.60) (.5) (.75)
Annual
J\veugr Leakage
' lnch~s Volume
11 .0 25,965 gallons
(.55) (.55 in)
12.4 29,033 gallons
( 615) (.615in.)
Note: The decimal given in the parentheses is the amount of leakage either in or out of the
landfill which is required for the observed rise and fall in landfill water level (the number
immediately above it).
95-017
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-6-
Construction Process
It appears that the Contractors involved in the construction of the PCB Landfill were faced with
several problems which could have compromised the integrity of the landfill from a very early
date, not the least of which was weather and vandalism. We were unable to obtain copies of the
field construction logs; however, pictures 1 through 12 show some of the construction related
problems . They were obtained from the State's files .
As can be seen, the landfill was largely unprotected from precipitation which resulted in a
significant inflow of rain water. Additionally, the top soil material appears to have been
inappropriately selected and/or compacted which resulted in exposure of the top synthetic liner.
The pressure build -up below the PVC top liner as shown in the attached pictures is strong
evidence for the existence of fractures in the upper clay layer. These fractures would represent
one avenue for possible downward leakage of precipitation.
The pictures also shows the vandalism discussed which may have also played a key role in the loss
of lower liner integrity. It is uncenain why this liner was not replaced instead of repaired by the
State contractors.
System Design & Leachate Management
The landfill system appears to be improperly designed in two key areas.
1. Top Liner System
Pictures 11 and 12 show significant ripples in the top soil across the landfill surface. In
several areas, these ripples resulted in the exposure of the PVC liner. These features may
represent areas where surface water could pond and enhance percolation. The top liner
should have been designed to minimize slumping and potential water ponding.
2. Leachate Collection System
The leachate collection system which the State has indicated is largely inoperable, can only
pump very small volumes at arty given time and is improperly designed. A significant problem
with the system design is the apparent absence of a perforated pipe extraction system . In
order to effectively remove water from the silty soils present in the landfill, a much more
ex.tensive system of leachate collection encompassing a significant portion of the bottom area
should have been employed.
The soil present within the landfill originated on road shoulders throughout the State, typical
road shoulder material is designed for stability meaning it is usually very poorly sorted This
does not appear to have been a consideration in the system design.
95-017
lnt.ea,it.doc
-7-
Monitoring
The State is currently in gross non-compliance with the TSCA monitoring requirements. No
samples have been collected and analyzed from any of the four groundwater monitoring wells or
four surface water stations since July, 1994. Based on documents reviewed dated Iune, 1983 and
on the State· s Operational Plan environmental samples were to be collected twice per year until
otherwise stated by the EPA regional Administrator. The State has missed four consecutive
sampling events .
Of particular concern to me is that the site only contains four monitoring wells which in my view
are not only improperly located but also poorly designed. The surface water stations selected also
appear to be dictated more by accessibility than environmental science.
The State was very much aware of the site hydrology and in fact used it heavily in the selection
process. In the 1980 Environmental Impact Statement the landfill site's drainage is described as
being controlled by six major draws around the landfill site. <,;ven that statement, it is difficult to
understand why no monitoring wells were placed directly at the head of any of these features
Also, after spending a significant amount of time in the field inspecting the hydrology of the 13ite I
find it incredible that no surface water samples have been collected at the several contact springs
which surround the site. These features represent the most likely points of origination for any
discharge which might result from the landfill bottom liner.
Additionally, based on discussion with State staff, it appears that the stream sediment samples are
being collected at the same locations as . the water samples (approximately mid-stream). Given
that this is not the most likely location for sedimentation to occur, it is doubtful that they are
indicative of the potential impact from the landfill.
Discussion
The graph shows the fluctuation of water level as measured in the leachate access pipe and the
central vent observation well. The rise and fall of this water level was thought by the State to be
directly related to the heating and cooling of the landfill materials. We agree that heating and
cooling may result in some fluctuation; however, the heating and cooling process in a system with
very little organics (less than 2%) should not result in a long-term increase in water levels as
shown by the green line. Moreover, the frequency of the peaks and valleys align very well with
that of the monitoring well hydrographs. In our opinion, this is a strong indication that the landfill
is functioning as a natural system that is receiving and releasing water. This pattern is not in
phase (the peaks of the water in the wells don't match with the peaks of the water in the landfill)
with the surrounding area because it takes the water several months · to flow through the
composite liners. The delayed yield shown is roughly analogous to that which you would expect
in a semi-confined, two aquifer system. It is the result of the time it takes water to seep through
the upper composite liner. For the period of record, it appears to be fairly constant; however, it is
important to note that the rate of leakage will increase over time . The leakage rate is directly
related to the permeability of that material, flaw:\ in the liner system resulting from pinholec. and
95-017
111tegrild~
-8-
t
holes formed during seam welding, manufacturing defects and vandalism Anothe, pote11tial
source of failure is stress cracking or brittle fracture.
The average increase of the water level by appro'timately I foot over the four year period of
record is in line with seepage rates used by the USEPA for flexible membrane liners and
represents approximately 1/2 inch of leakage per year. It is our opinion that this increase is a
good indication that water is seeping into the landfill. The fact that the increase is not a steady
incline but varies seasonally i.s an indication that the system is also discharging water through the
bottom liner. There is a net increase in the landfill water level because more enters than leaves the
system .
Jn summary, if no new leakage water was entering the system the water level would remain flat,
and if no water was leaving the system the water levels would not decrease then increase in a
cyclical pattern .
Sl}-017
lntegrit.doc
-9-
J RAINFALL (Inches) ... 0 -~ u, a, c» co 0 No11-92 Jan-93 Mar-93 May-93 ~ z 0 ::0 ~ ~'ul-93 ::0 s m z Q S!p-93 ;:. () ::r C/1 0 ~-Nov-93 c:: ~ z ::,
0 ~ ~ JM-94 QI -~ ~
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3 r ~-r "' Jul-94 0 5 (C) ~ 0 ...
5 Sep-94 )> (")
0 -► 3 "2-Nov-94 ::0 it,
C') -(t,
0 ~ c» Jcln-95 5 s; IO t'II
(/) C: Mar-95 <O
E ~
Q.
C> ~ May-95 -0 z Jul-95 -
Sep-95
Nov-95
Jan-96
CO-Cl/AIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLLIE B. BURWELL
KEN FERRUCCJO
HENRY LANCASTER
Jonathan B. Howes, Secretary
Department of Environment, Health and Natural Resources
P. 0. Box 27687
Raleigh, N. C. 27611-7687
Dear Secretary Howes:
October 29, 1996
The Warren County PCB Landfill Working Group has voted to request the State to conduct its
own compliance audit for the landfill. We are concerned because our Science Advisors have
informed us that the State appears to have ignored certain requirements imposed by the
U. S. EPA when it granted approval and funding for the landfill.
We would like the state, therefore, to thoroughly examine all of the regulatory requirements
imposed by EPA concerning the construction, operation, monitoring and maintenance of the
landfill, including: the specific requirements identified by EPA in various documents given to the
State when it approved the landfill and provided funding, the applicable federal regulatory
requirements existing under the Toxic Substance Control Act, and the applicable federal
regulatory requirement existing under the Superfund/CERCLA statute and the National
Contingency Plan.
Our expectation is that the self-compliance audit will reveal the specific areas where the State has
not completely complied with requirements, for how long the noncompliance has existed, and
what actions the state has taken or plans to take to rectify the noncompliance.
We believe it is reasonable to ask for a complete audit report within 30 to 60 days.
Thank you for your cooperation.
Sincerely,
Dollie Burwell, Co-chair
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
Fa x:919-733-5317
Air Quality Division
October 28_ 1996
Clct 28 '96
MEMORANDliivl
TO: Larry Rose, Division of Solid Waste Management
Ed Mussier
,-,·.:\:· r:[f:.\1
FIH)_\.1: Tom Anderson, Meteorologist, AQAB
TllROUGH:b.-Roller, Supervisor, AQAR
SUHJECT: Mct.corological Monitoring Station Site Selection
PCB Landfill Warren County
17 :CC
appreciate the opportunity to offer recommendations for selection an::l siting of a
meteorological monitoring station to supfPort your research efforts at th:' PCl1 Landfill located
in Warren County. NC The landfill site covers an open. cleared area of approximately ,
acres_ This site "vould provide adequate exposure for instruments used lo collect any o!' the
meteorological parar,1eters you mentioneJl wo~1_td be useful_i1~ ~our study includin['.: barometric
pressure, precipitation, and ambient temperature_
Due to the site restrictions that we distussed (eg. no digging allowed above the rontain:?r
site), I would recommend a portable or non-permanent type meteorological station po\vered by
a battery. These stations typically have an on-board datalogger such as a Campbell CR-1 0 ro
operate the meteorological sensors and co11ect data measurements over a user-specified time
period. Data from the station could be accessed directly at the station -:->n a routine basis or
rr;!motely via a telephone line_ Currently, the Toxics Protection Unit of the Air Quality
Division maintains several/of these types of stations at varicus sites across the state and ha\ c
been pleased with rhcir p¢rformance.
I
Preferably. the monitor;1~g station should be located on top of the knoi: in the center of the
site ,vhich would place it away from the influence of any treclines sho1.1.ld measurement of
vvind. speed an<l dire•;tion be desired. Locating the station inside the fonced area near the
wate~-levcl sampling wdl will also provide a secure and easily-accessible site_
If you decide to proceed with the procurement and installation of a mdeorological moni1orin ~
station, I will be glad to provide you wi ith recommended instrument sp,=cifications and vendor
contacts. Please give me a call at [phone] if you have any further question s or
comments.
To: Bill Meyer
From: Patrick Watters
Date: 10-28-96
Subject: DATA GAPS IN THE PCB LANDFILL DOCUMENTATION
I reviewed the Landfill "Conditions" (copy attached) versus what was found in the files at DWM.
The files I had as resources to review were the Division files, the files in your office (two
cardboard boxes) and the personal files of Larry Rose. I checked with Sharron Rogers, Bobby
Lutfy, Pat Williamson, the Solid Waste Fileroom and the Hazardous Waste Fileroom to see if
they had any relevant files on the landfill and they did not. I wanted to ask Pete Doom and Bob
Glaser but they were not available. I left an e-mail for Jimmy Carter to look and see what files
he may have relevant to this task. He will not be back in the office until Monday.
Based on my review on Saturday and Sunday 10/26 and 10/27 here is what I have been able to
determine.
Evidence of monthly inspections and landfill leachate monitoring (Conditions A and D) are as
follows:
1996 -Complete through September
1995 -Complete
1994 -Complete
1993 -Complete
1992 -Complete
1991 -Complete
1990 -Complete
1989 -Missing January and February
1988 -Missing Oct9her, NovenJber, and December
1987 -Missing April, June, Jufy, Aug6st, September, October, and December***
1986 -Complete
1985 -Complete
1984 -Complete
1983 _iDid not find ANY monthly inspection records, I did find leachate analysis sheets for May,
June, July, November and December
1982 -Nothing found.
*** I did find monthly inspection cover memos for April, July, August and September of 1987
but not the actual inspection form.
I did not find any documentation in the files that records were submitted to the EPA Regional
Administrator 90 days after closure. (Condition 11.C)
Mr. Al Hanke at EPA Region IV was sent copies of analyses of PCB Landfill environmental
samples as they were performed.
Since 1983, the following amounts of leachate (in gallons) was documented to have been
removed from the landfill.
1983 -5297
1984-1550
1985 -1012
1986 -100
1987 -Unknown
1988 -Unknown
1989 -Unknown
1990 -652
1991 -1220
1992 -1780
1993 -800
TOTAL -12,411 Gallons
Groundwater and Surface Water Sampling:
I did not find any evidence of the Background sampling that was required by Landfill conditions
11.H.2.a and 11.H.3.a
I did not find any evidence that all wells and surface water locations were sampled monthly
during operation as required by Landfill conditions 11.H.2.b and 11.H.3.b
I did find documentation for the semi-annual Post-closure groundwater and surface water
sampling (Conditions 11.H.2.c and 11.H.3.c) for the dates listed below. The earliest I found was
November 29, 1982. The last semi-annual sampling event was in May 1995. All other years
prior to 1995 except for 1987 had the required two sampling events.
May 24-25, 1995
November 16-17, 1994
May 18-19, 1994
November 18-19, 1993
May 20-21 , 1993
November 24, 1992
May 29, 1992
October 28-29, 1991
April 24, 1991
October 25 , 1990
April 18-19, 1990
October 25 , 1989
March 21, 1989
July 5, 1988
February 2, 1988
June 4, 1987
November 18, 1986
May 6, 1986
November 13 , 1985
May 24, 1985
December 11 , 1984
June 6, 1984
November 21 , 1983
May 5, 1983
November 29, 1982
I did not find any evidence of samples taken of the soil liner prior to disposal as required by
Landfill Condition I.
Overall Comment: These records are scattered between different people and in different
locations. Some are in a filing cabinet. Others are in cardboard boxes. I would strongly suggest
that ALL of the analytical and inspection records be collected and put in one location so they
don't get lost. A back up copy of these wouldn't be a bad idea either.
..
Landfill Approval Conditions Dated December 14, 1981:
II
A -Landfill leachate will be monitored monthly and collected leachate will be disposed of
properly. Records will be maintained on file at a designated State office.
B -Operation plan will be followed.
C -Records will be submitted to the Regional Administrator 90 days after closure.
D -Fence, gate and access road maintained in good working order.
E -Report to region IV any instance of PCB detection.
F -Designate a State departmental person responsible for operation and for post closure
monitoring before construction.
H.1 Ground and surface water monitoring collected and analyzed per EPA approved procedures.
H.2 -Groundwater
H.2.a Background -Each well sampled 3 times and data submitted to EPA prior to
disposal. At least one week between samples. Minimum of 2 replicate measurements
made for each value or concentration.
H.2.b During Operation -All wells sampled monthly.
H.2.c Post Closure -Each well sampled on a semi-annual basis.
H.3 -Surface water
H.3.a Background -At least two sampling points per surface water body (upstream and
downstream) sampled at the same time as the background groundwater samples.
H.3.b During Operation -All surface water locations sampled monthly.
H.3.c Post Closure -All surface water locations sampled semiannually.
I -Undisturbed samples of the soil liner will be taken and the laboratory permeability
determined and submitted to EPA Region IV prior to any disposal (1 sample / 25,000 sq. ft. of
liner)
CO-CJJAJRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLLIE B. BURWELL
KEN FERRUCC/0
HENRY LANCASTER
John H. Hankinson, Jr.
Regional Administrator
EPA Region IV
100 Alabama St.
Atlanta, GA 30303
Dear Mr. Hankinson:
October 25, 1996
The residents of Warren County, North Carolina have had a long difficult history concerning the
Warren County PCB Landfill that the state with the approval of EPA Region IV and CERCLA
funding constructed some 15 years ago against substantial citizen opposition.
The Warren County PCB Landfill Working Group, formed by the state and citizens, writes to you
now to request a serious, detailed, and immediate examination of the state's compliance with all
ofEPA's requirements for the construction, operation, monitoring, and maintenance of the PCB
landfill.
The two Science Advisors assisting the Working Group have identified a major lack of regulatory
compliance by the state that we find dangerous and unacceptable. The serious and prolonged lack
of compliance by the state, as owner and operator of the landfill, also reveals a lack of oversight
and enforcement by EPA Region IV that demands attention, explanation, and correction.
Under authority of the Toxic Substances Control Act and with Superfund/CERCLA funds, EPA
made a commitment and accepted responsibility to protect public health and environment. It
seems clear to us that EPA has failed to meet its statutory responsibilities. You should also
appreciate that the PCB landfill has played a key role in the development of the environmental
justice movement in the United States.
The state of North Carolina should be held to the same standards as industry. If EPA assumed
that the state would police itself, it was wrong.
We expect you to immediately form a high level, independent group to closely examine the state's
entire history of compliance. We suggest consideration of Ms. Jewell Harper, Deputy Director of
your Waste Management Division, to lead this effort.
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
We are particularly concerned that the state: (1) did not carry out all required groundwater
monitoring; (2) failed to analyze early data that we believe show that the landfill has had water
entering and escaping it; (3) failed to act or plan to remove large amounts of water inside the
landfill; and ( 4) failed to repair a dysfunctional leachate collection system.
Consistent with your commitment to facilitate efforts of the Working Group, we expect that this
matter will be expedited. It is the hope of the Working Group that the state will soon honor its
original commitment to detoxify (remediate) the landfill now that our Science Advisors have
concluded that feasible detoxification technology is available. Thus, the lifetime of the PCB
landfill will, we hope, be limited. Nevertheless, complete landfill detoxification will be some years
away. The Working Group believes it very important that EPA complete its compliance audit
soon, because the full extent and impact of the state's noncompliance should and will play an
important role in the state's decisions in coming months and public support for the detoxification
project. We also expect EPA Region IV to assist all efforts by the Working Group to achieve full
and safe detoxification of the landfill.
The members of the Working Group and its two Science Advisors (Dr. Joel S. Hirschhorn and
Mr. Patrick Barnes) will gladly assist your efforts to conduct the requested compliance audit.
Sincerely,
Dollie Burwell, Co-chair
Kenneth Ferruccio, Co-chair
Henry Lancaster, Co-chair
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
CO-CHAIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLLIE B. BURWELL
KEN FERRUCC/0
HENRY LANCASTER
Elliott P. Laws, Assistant Administrator
Solid Waste and Emergency Response
U.S. EPA
401 M Street, SW
Washington, DC 20460
Dear Mr. Laws:
October 25, 1996
The Warren County PCB Landfill Working Group is requesting the assistance of your office in
determining several policy positions of EPA This landfill has an unusual history. Despite strong
citizen opposition to the siting of the landfill, the state obtained EPA approval for it. Moreover,
Superfund/CERCLA funds ($2.5 million) were provided to the state ofNorth Carolina through a
cooperative agreement in May 1982 for cleanup of PCB wastes and construction of the landfill.
But this had been preceded by EPA Region IV approval of the landfill in June 1979 in response to
an application by Governor Hunt in December 1978. It was your office that approved the award
of the funding to the state.
We seek an objective examination of the extent to which this landfill should have to meet
CERCLA statutory and National Contingency Plan requirements for remedial action sites. We
are not clear as to whether the state took advantage of the CERCLA opportunity to designate one
site for the NPL and, if so, whether the PCB cleanup along state roads, for which this landfill
served as the remediation, was such a site.
We want to inform you that the May 25, 1982 EPA document awarding the CERCLA funds to
the state contains a number of Special Conditions, including several that refer to compliance with
CERCLA provisions and one that explicitly says "All activities conducted under this cooperative
agreement will be consistent with the existing National Contingency Plan ... " and goes on to say
that "Pending revision of the NCP, all activities should be consistent with the existing NCP and
proposed amendments dated March 12, 1982." Moreover, "When the revised NCP is
promulgated, it shall take precedence." This seems very clear that current NCP requirements
apply to this PCB landfill.
✓
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
We also note that one of the conditions makes clear that "The State will fully comply with all
applicable requirements under the Toxic Substances Control Act (TSCA) ... "
The Working Group would like a clear, definitive policy position by your office concerning the
extent to which CERCLA and NCP requirements apply to this landfill. For example, does the five
year review requirement apply? Can a local group apply for a Technical Assistance Grant? Can
failure of the landfill containment system be used to support a new remedial action?
We look forward to an early response from you.
Sincerely,
Dollie Burwell, Co-chair
Ken Ferruccio, Co-chair
Henry Lancaster, Co-chair
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
HIRSCHHORN
@~ASSOCIATES ~ A Division of Hygienetics Environn1enta/ Services, Inc. Suite 411
2401 Blueridge /\venue
Wheaton, MD 20902
Plione: (301) 949 -1235
Fax: (301) 949.j 237
DECLARATION OF DETOXIFICATION
TECHNOLOGY AVAILABILITY
As a Science Advisor to the Warren County PCB Landfill Working Group and an expert in
environmental technology, this is to certify that in my professional opinion detoxification
technology appropriate for use at the Warren County, North Carolina PCB Landfill is now
commercially available.
Such technology has been proven effective and safe for detoxifying PCB waste and contaminated
materials. The gas phase chemical reduction and base catalyzed decomposition technologies are
being used at full scale. Neither of these technologies were available some 15 years ago when the
state decided to construct the landfill to dispose of the PCB wastes.
Although the exact requirements and performance for the Warren County PCB Landfill will be
determined through planned testing, there is every reason to believe that one or both of the
feasible detoxification technologies will be found to be practical for the site specific conditions,
constraints, and needs.
As originally envisioned by the State of North Carolina, in the Governor's commitment to
Warren County residents, the detoxification of the landfill can now be considered to be a
real, near term option.
The current state funded activity will refine for the State legislature reliable cost estimates for
landfill detoxification, using the technology shown by bench-scale testing carried out in coming
months to be the most appropriate for this application and community.
Minimizing site cleanup costs, maximizing safety of county residents, and achieving stringent
cleanup goals will be used to choose between the two available technologies.
October 23, 1996
Joint Warren County/State PCB Landfill Working Group
October 23, 1996 Meeting Minutes . ,.., ........ ,,...)'<': 0,-,. ~, D!'J. -
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to ~-
order at 4:30 p.m. Wedne_sday, October 23, 1996 by Ms. Dollie Burwell. The meeting was held
at the Warren County Office and was co-chaired by Mr. Ken Ferruccio and Mr. Henry Lancaster.
The agenda was distributed.
READING AND APPROVAL OF MINUTES
There were three sets of minutes for approval. Ms. Deborah Ferruccio, in separate motions, moved
that the minutes from the April 25, 1996 meeting and the July 10, 1996 meetings be approved. The
motions were seconded and carried. Ms. Billie Elmore moved that the minutes from the August 27,
1996 meeting be approved. The motion was seconded and carried.
UNFINISHED BUSINESS
Report of tlte Executive Committee Meeting
The report of the executive committee meeting was given by Mr. Henry Lancaster. Mr. Lancaster
advised that present at the meeting were Ms. Dollie Burwell, Mr. Ken Ferruccio, Mr. Patrick Barnes,
Mr. Joel Hirschhorn, and Mr. Bill Meyer. Mr. Lancaster said that discussed at the meeting was the
manpower and Mr. Meyer's ability to handle this project with all his other responsibilities. He advised
that a proposal will be made to designate a project officer from within the Division of Solid Waste
Management (Division) who would be paid by the Division through the remainder of this fiscal year.
After that period, funds to continue the project would be sought from the General Assembly.
Mr. Lancaster also advised that membership to the Working Group ends for all members on
December 1, 1996. He said that there is consistent attendance to meetings by nine to ten members
and that the Working Group may want to take action on that issue. Ms. Burwell said that the
Executive Committee may want to meet and discuss the issue of membership before the next Working
Group meeting. It was the consensus of the Working Group to send a letter to the Governor before
December 1, 1996 to advise that the Working Group would like to continue.
Six Point Plan for Actions
I) Decision Making Process
Mr. Hirschhorn recommended that the Working Group create a system to speed up the
decision making process; saying that if a process is defined then the Technical Committee
could get things done.
2) Federal and State Strategy
Mr. Hirschhorn said that his analysis revealed that the Working Group should pursue a
Federal strategy. He suggested asking the State to perform a compliance audit of all EPA
permits for the landfill. In addition he recommended that the Working Group submit a written
request for EPA to perform an audit of the State.
October 23, 1996 Metting Minutes
Page2
Ms. Deborah Fenuccio, reporting for the Technical Committee, advised that Mr. Hirschhorn
was asked to draft a letter to John Hankinson, Regional Administrator of EPA Region
IV and to Elliott Laws, Assistant Administrator Solid Waste and Emergency Management,
on behalf of the Working Group. She advised that the Technical Committee recommends that
the Working Group approve these letters with copies sent to Congresswoman Eva Clayton,
Senator Frank Ballance, and to the National Environmental Justice Advisory Council
(NEJAC).
Ms. Burwell suggested that the members take time now to read the letters and then they will
be discussed. After reading the letter to Mr. Hankinson, Mr. Lancaster asked Mr. Hirschhorn
in what area(s) is the State not in compliance. Mr. Hirschhorn responded that he does not
believe that the State has never been in compliance, but that it is not now. He said that the
State has not done semiannual testing since the fall of 1994; the leachate collection has not
been done because the system is dysfunctional; and that water has remained in the landfill.
Mr. Lancaster asked how long the leachate collection system had been dysfunctional. Mr.
Meyer advised it was discovered in the fall of 1989. Mr. Lancaster asked Mr. Hirschhorn to
be prepared to document the areas of noncompliance.
Mr. Dennis Retzlaff voiced concern that the letter said that the State "failed to act or plan
to remove large amounts of water inside the landfill." He said that the State came to_ pump
out the water and some members of the Working Group were opposed to this action. The
State listened to their concerns and did not pump the water out. Ms. Burwell said the reason
some members opposed pumping, was because they were advised that the water would be
sprayed back over the landfill. Mr. Hirschl1om said that the State has a legal responsibility
for the landfill and if the State agreed to respect the wishes of some members of the Working
Group then they should have gone to EPA and asked for a waiver or approval.
Mr. Retzlaff suggested toning down the language of the letter. Ms. Burwell said that if
anyone does not agree with the verbiage of the letter then they should suggest changes. Mr.
Hirschhorn said that the EPA will do serious oversight only when it is pushed to do so. Ms.
Ferruccio said that the tone is necessary because the EPA has known about the
noncompliance and has done nothing.
Mr. Lancaster said that he would like to make three suggestions.
I) In any statement of lack of regulatory compliance, state specific technical
support.
2) Remove unconscionable and leave dangerous and unacceptable.
3) Remind Mr. Hankinson of his commitment to assist the Working Group.
Ms. Billie Elmore made a motion to accept paragraph five as written. The motion was
seconded with five (5) in favor and five (5) opposed. The motion failed . Mr. Retzlaff
suggested starting paragraph five by saying, "The State should be held to the same
standards of industry," and suggested removing the present sentence. Ms. Elmore
made a motion to rephrase as stated above. The motion was seconded and carried.
October 23, 1996 Metting Minutes
Page 3
Ms. Burwell added that it is the consensus of the Working Group to remove unconscionable.
It was suggested to take out the following sentence: "The Working Group believes it very
important that EPA complete its compliance audit soon, because the full extent and impact
of the State's noncompliance should and will play an important role in the State's decisions
in coming months and public support for the detoxification project." This sentence should
be replaced with, "Consistent with your commitment to facilitate the efforts of the Working
Group, we expect that this matter will be expedited." After more discussion it was decided
that this paragraph should start with the above mentioned replacement sentence. Ms. Elmore
motioned that the letters be forwarded as rewritten and signed by the co-chairs. Copies of
these letters are to be sent to Congresswoman Eva Clayton, Senator Frank Ballance and to
NEJAC. The motion was seconded and carried. Two members abstained from voting.
The second letter prepared by Mr. Hirschhorn was to Elliott Laws, Assistant Administrator
Solid Waste and Emergency Response of U.S. EPA Mr. Jim Warren motioned that the letter
be approved as written. The motion was seconded and carried.
Mr. L. C. Cooper motioned that a letter be sent to the State for a compliance audit. This
letter will be sent to Secretary Howes. The motion was seconded and carried. Mr. Meyer
recommended that the letter included specifics of what is to be included in the audit. Ms.
Ferruccio motion that the letter include specifics for the audit. The motion was seconded and
carried. One member abstained from voting.
3) RFP and Technology Vendor
Mr. Hirschhorn suggested that one RFP go out with two (2) parts.
1) The companies will bid on the bench-scale test at their facility, on materials
sent to them. The companies will be limited to two (2) technologies.
2) After the completion of the bench-scale test one (1) company will be selected
to participate in the design and remedy with the Science Advisors.
Ms. Ferruccio motioned to approve the two (2) phase RFP. The motion was seconded and
carried. One member abstained from voting.
Mr. Barnes said that the first part of the RFP is the competition on how the company
can meet the goals of the Working Group. The other part is to select one company
to participate in the design of the remedy. The design will be a collaborative effort.
Mr. Meyer suggested that the Science Advisors check with Ms. Doris Strickland to
make sure it is legal to buy a certain amount of hours. Mr. Meyer advised that Ms.
Strickland is Chief Purchase and Contracts, Division of Administration for the Department
of Environment, Health and Natural Resources. He said that he would facilitate getting Mr.
Hirschhorn in contact with Ms. Strickland.
4) Detoxification Cleanup Goals
October 23, 1996 Metting Minutes
Page 4
Mr. Hirschhorn advised that the Working Group must decide what concentration levels are
acceptable. He advised a range of cleanup goals for PCBs and dioxins and noted that the
Federal standard is the least stringent. The least stringent level is one or two parts per million
(ppm) for PCBs and one part per billion (ppb) for dioxins. This level of PCBs and dioxins
equates to 1 in 10,000 health risks. He advised that companies have only been asked to reach
this level and this is where they have their experience. He also advised that the levelasked for
in the RFP would be the preliminary cleanup goal. Ms. Ferruccio advised that the Technical
Committee discussed this issue and decided to recommend to the Working Group that
extremely stringent be used for the preliminary cleanup goal and so motioned. The motion
was seconded. Questions were asked about the implications and cost estimate. Mr.
Hirschhorn advised that since no company had been asked to reach this level that there is no
information on how much this would cost. He did advise that the cost would increase, but
how much could not be determined. Mr. Meyer said that the extremely stringent level will
be pushing technology to the edge and if materials have to be treated twice, who pays for that.
Mr. Barnes said that is why it is important to advise companies in advance of the cleanup
goals, so that this can be factored in before the bid is made. The motion carried. One
member abstained from voting.
5) Water in Landfill
This topic was tabled until Mr. Barnes gives his report.
6) Bioremediation
Mr. Hirschhorn advised the Working Group to make it clear to the State that the Working
Group wants them to stop pursuing bioremediation. It was motioned that a letter be sent to
the Division of Solid Waste Management, with a copy sent to Secretary Howes, to formally
request that bioremediation be ruled out as a feasible remedy and to encourage the State to
stop using its limited resources to pursue bioremediation. The motion was seconded and
carried. One member abstained from voting.·
Science Advisors' Pay
Ms. Burwell said that the Working Group needs to establish a policy concerning the Science
Advisors' pay. The Technical Committee recommends that all invoices be paid upon submittal to the
State. If a question arises on validity of invoices that should be turned over to the Technical
Committee for a recommendation. Mr. Warren made the motion to accept the recommendation from
the Technical committee. The motion was second and carried. Mr. Meyer added that invoices will
be paid according to State Administrative Payment Process. Mr. Lancaster said that he feels any
situation that deals with payment should be handled by the Executive Committee. After receipt of
the invoice if the Executive Committee needs additional information they will refer to the Technical
Committee. A motion was made that any situations dealing with payment of invoices be directed to
the Executive Committee, within three days of submittal to the State. If any additional information
October 23, 1996 Metting Minutes
Page 5
is needed the Executive Committee, within three days of receipt, will refer to the Technical
Committee. Recommendations will be made by the Executive Committee. The motion was
seconded and carried. One member abstained from voting.
Sampling Plan
Mr. Barnes advised that he and the State had discussed amendments to the Sampling Plan, but they
had not been included in the draft Sampling Plan. (Please review the memo with subject
"Amendments to the Draft Sampling Plan Dated, October 2, 1996"). Mr. Barnes would like to
include his amendments as an appendix to the sampling plan. It was advised that there will be no
split-sampling. Ms. Ferruccio said that if there in no split-sampling, how will the Working Group
know that the community is protected. Mr. Barnes advised that he will be on the site and that he will
be in charge of the labeling. He said that the companies will not know what they have other than that
it is a soil or a water sample. Mr. Barnes added that dedicated samplers should be used for each
well. Therefore, there would be no problem with equipment decontamination.
Mr. Barnes stated that the supplemental Sampling Plan mentioned collecting samples at each boring.
He said that there are a few items that he would like to see added and they are as follows:
1) Amend the Sampling Plan to include two soil samples in each of the three wells close ~o the
landfill and in the background wells, for PCBs and dioxins.
2) One other sample needs to be taken at the confluence ofRichneck Creek and the Unnamed
Tributary. Leakage will show best at the delta, where the two bodies of water meet.
3) Sediment and surface water samples are to be field selected by Mr. Barnes, with the consensus
that the Working Group approves the amendments to the Sampling Plan.
4) And the the Working Group should establish a process for further amendments.
Report, Status, and Recommendations of RFPs
There are three (3) RFPs to deal with. First a contractor needs to be selected to perform extraction
of materials. The Science Advisors and the State have ranked the four proposals they received. By
consensus the State and Science Advisors have excluded Patterson Exploration Services. They
received that lowest ranking from each party. Mr. Hirschhorn ranked Triangle Environmental, Inc.
(Triangle) first, however after discussing their bid with Mr. Barnes, they feel that Triangle's bid may
not have included all factors. The Science Advisors have put three calls into Triangle to verify what
factors were included in the bid; there has been no response to their calls. Therefore, Triangle is
being ruled out. Mr. Hirschhorn proposed that we enter into negotiations with Camp, Dresser &
McKee (CDM), since they were ranked first with the State and second with both the Science
Advisors. The negotiations will include the price, schedule and scope of work.
Mr. Mike Kelly submitted to the Science Advisors and Mr. Meyer a draft RFP for dioxin/furan
analysis. Mr. Barnes advised that there would be fifty to sixty samples taken. He also advised that
the Working Group approve this RFP. Ms. Ferruccio motioned that the Working Group accepts the
draft RFP for dioxin/furan testing. The motion was seconded and carried. Mr. Meyer advised that
six companies will be selected for the dioxin/furan testing. He said that the RFP should be out by
October 23, 1996 Metting Minutes
Page6
the end of next week (November 1, 1996) and that the companies will be given two weeks to
respond.
The RFP for well installation, Mr. Barnes felt was very important. He suggested five amendments
and they are as follows:
1) The diameter of the proposed wells will be four inches in diameter.
2) The proposed wells will be constructed of type 316L stainless steel.
3) The depths used for bidding purposes shall be 45 feet for the shallow wells and 90 feet
for the deep wells.
4) If necessary the contractor will attempt to drill past potential shallow obstructions a
minimum of three times.
5) The supplemental sampling plan be included as a working plan for the RFP.
Water in the Landfill
Mr. Barnes has plotted the water in the wells and in the landfill on the same graph. He advised that
a few conclusions can be drawn from this graph. One important conclusion is that there stands a
sufficient chance that the landfill is taking on water and water is leaving. Mr. Meyer said that he
disagrees and believes that it results from gas production. Mr. Barnes said that he does not agree
with the gas production theory. He stated that with gas production you would expect to see highs
and lows and not a steady increase. Mr. Meyer then asked Mr. Lancaster, "do you hear what Patrick
is saying, that the top and bottom liners are leaking." Then, Mr. Meyer said that since the system is
monitored through a one inch pipe that there may be an alternate explanation. Mr. Hirschhorn said
that he wanted it on record that he agrees with Mr. Barnes explanation. Mr. Meyer advised that he
would send out his information for a peer recommendation. Mr. Hirschhorn suggested that Mr.
Barnes information be sent to the same company for peer review.
Ms. Burwell said if the Science Advisors or the State want a peer review, then the Working Group
should know what is being peer reviewed. She added that the Working Group should agree on who
will conduct the peer review to assure that there is no conflict of interest. And after the peer review
is done, it should be reviewed by the Working Group first. Ms. Elmore motioned that the Working
Group accepts the recommendation for a peer review. The motion was seconded and carried.
Mr. Meyer advised that next week the State will be putting a two-inch pipe in the landfill. It will have
a tape that will give a daily read out. Ms. Burwell asked why the State was just doing this. Mr.
Meyer responded that he has always believed that pressure is the cause of the water fluctuation in
the landfill, but could not prove it. Ms. Burwell said if the State felt that the water fluctuation was
the result of pressure and could not prove it, why did they wait until now to take action to prove it.
She also said that the Working Group should have been advised before hand that the State was
planning to take this action. Mr. Ferruccio asked if a well would be put in and Mr. Meyer advised
that would be putting in a four-inch hole with a two-inch pipe.
Mr. Lancaster asked how long the State would need to prepare a report in response to Mr. Barnes'
report. He also asked if more accurate information is needed before the peer review is done and if
October 23, 1996 Metting Minutes
Page 7
the peer review would include recommendations as to the next step. Mr. Warren said if the peer
review can be done without holding up the process, let's do it. He believes the people who say that
the landfill is not leaking will always believe that it is not leaking no matter how many peer reviews
say otherwise. Ms. Burwell said that we don not want getting the landfill detoxified tied to whether
it is leaking. Mr. Hirschhorn said that saying the landfill is leaking should only be important because
it is not secure and therefore not safe. It is the consensus of the Working Group to give Mr. Meyer
a week to get his report ready and he will be given a chance to defend it. When the reports are
complete, they should be sent to the Working Group office to be forwarded to the Technical
Committee for review. After reviewing the reports, the Technical Committee will make a
recommendation.
NEW BUSINESS
Press Conference
Mr. Hirschhorn advised that at the Technical Committee meeting he presented a draft declaration of
feasible technology and that he now has a final version available. He also presented a statement that
he prepared as Science Advisor to the Working Group. Mr. Lancaster said that he liked the
declaration, but that the statement was inflammatory. Ms. Ferruccio said that she wants the public
to know that everything had not gone smoothly and that the process has been delayed by the _State.
Ms. Burwell advised that the Technical Committee is recommending to the Working Group to hold
a press conference. The date suggested by the Technical Committee was October 31, 1996 at 10:00
a.m .. There was agreement with several Working Group members that a few days before election
was not a good time for this release. They sited that a press conference would not get the media
attention that it deserves due to the elections. Mr. Hirschhorn said that he feels that the time to get
a politician to make a promise is during an election. Ms. Ferruccio agreed, saying that once the
Governor is in office, he's there and will not be able to seek reelection. Mr. Lancaster said that the
focus should be on the declaration of technology. The media would be shocked to hear that the
Working Group and the State are releasing the same document. After additional discussion, a motion
was made to hold a press conference a week after the election. The motion was seconded and
carried. A press release will go out on November 11, 1996 to advise that a press conference will be
held the following day. At the press conference the declaration of feasible technology will be released
with the concurrence of the State. Also, released will be the request made to the EPA and the State
to perform compliance audits. The press conference will be held at the State Capitol Building,
Tuesday, November 12, 1996 at 11 :00 a.m ..
ADJOURNMENT
The meeting was adjourned at 8:55 p.m .. The next meeting was scheduled for Monday, November
18, 1996 at 3:30 P. M .. There will be a Technical Committee held on November 12, 1996 after the
press conference.
State of North Carolina
Deportment of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Memorandum
To: Mike Kelly
Patrick Watters
From: Bill Meyer ~
Subject: PCB landfill Compliance Audit
NA
DEHNR
October 21, 1996
The Co-chairs and Science Advisors requested that the Division initiate a compliance audit for the
PCB landfill.
Enclosed is a copy of the June 4, 1979 and December 14, 1981 letters form EPA that approves
with conditions the PCB.landfill.
I have extracted some of the applicable approved conditions from the letters and 40 CFR 761.
Please note the codification numbers of the rules have changes, primarily from 7 61. 41 to 7 61. 7 5.
It is suggested that all approved conditions be included in the audit.
P.O. Box 27687,
Raleigh, North Carolina 27 611-7 687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50°/o recycled/10°/o post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Memorandum
To: Mike Kelly
Patrick Watters
From: Bill Meyer ~
Subject: PCB landfill Compliance Audit
.NA
DEHNR
October 21, 1996
The Co-chairs and Science Advisors requested that the Division initiate a compliance audit for the
PCB landfill.
Enclosed is a copy of the June 4, 1979 and December 14, 1981 letters form EPA that approves
with conditions the PCB landfill.
I have extracted some of the applicable approved conditions from the letters and 40 CFR 761.
Please note the codification numbers of the rules have changes, primarily from 7 6 I. 41 to 7 61. 7 5.
It is suggested that all approved conditions be included in the audit.
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Voice 919-733-4996
l'"KA 'f tY-/ hJ-vUUv
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
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DEC 14 1981
Honorable Jc11Es E. Hunt
Gove:rnor of i"<:>rth Carolina
Sta.te Capital
l<alcigh, North Carolina 27611
Lec:.r Governor Hunt:
---uJ ~ Co
On June 4, 197S, Resion IV gave conceptual approval, with certain
~ncutions, to the r~ren County, North Carolina, site as a chemiC=.l w-aste
land.till c:..s author.1zea in ~O CFR, Part 761. On€! of tt.e ccmditicns was t.."lat
t.ri-e St.ate sctxrit final plc.ns and s~ificaticns to this office for apprcval,
in writing, prior w the initiation of construction. 'lbeSe f,laru. ar.c
sf,eCifications nc.ve been 61.ilinitteo ana are hereby approved subject to the
enclose:i condicior:.s.
h-e com:r,2:00 you and the J?any involved fer your oeG.i.caticn to reaching ci £incl
solutior. tu this environrrental problem basec en the tecnnclogy as it E:Xists
t.cca:y. It we Can be oi: further assistance, please let me knew •
.Sincerely yours,
/s/ Charles R. Jeter
Re.gional Administr;~,:ir
Oiules R. Jeter
l-<eg icnal Admi.nist:.rator
£.nclosurE:
cc: L".r. burley B. M1tch1::il, Jr., ~retary,
horth Carolina ue_part:Irent
ot Crime Control an:l .Pu!::lic Saiety
icle.19h, 1\ort."1 Carolina
G.\•i. Suicklanc, Be_::.d
Solie & Eazaraous Waste i-:..anagement Branch
£nviror~£ntal tlealth Secticn
Der.a.rt.rr>t=nt oi huri.an ~sources
Division oLhe~t.h ~rvices
Raleigh, Eort.h Carolina
Cr. Sara Morrow
Liei::;artrrent of Hurran F(esources
Livision of he.a.1th Services
kleign, l,0rth Carolina
. ,:;
I
·--.
DEC 14 i98"\
Final Approval Conditions for 1?CB Chemical Waste Landfill in Warren County,
North Carolina, owned and to be operated, closed and pest closure cared for
by the State of North Carolina on property formerly owned by Carter C. Pope
and Linda w. Pope, found in Deed Book 278, page 252.
I. Reference June 4, 1979 approval letter signed by John.C. White
A. General requirement numbers 1, 2, and 5 remain in effect.
B. Technical condition numbers 1, 2, 3, 4, 6, 7, and 8 remain in
effect. Condition numbers 9 and 10 have been satisfied.
II. Additional conditions of this approval are:
A.
B.
Leachate collection will be rronitored monthly and collected
leachate dispesed of properly, if required (761.41 (b) (7)).
Records will be maintained on file at a designated State office.
7 {p /, 7SCl:i){}l
The operation plan will be followed, as approved (761.41
(b) (8) (ii)).
C. Records will be maintained and sul:mi tted to the Regional
Administrator within 90 days of closure (761.41 (b) (8) (IV)).
D. The fence, gate, and access road shall be maintained in good
working order as long as pest closure rronitoring is required.
E. Report to EPA Region IV any instance of detection of FC3 's through
the monitoring program immediately.
F. Designate a State departmental person who will be res:ponsible for
operati9n and for post closure rrontioring prior to initiation of
construction (761.41 (c) (5)).
G. Notify EPA Region IV 30 days prior to transferring res:ponsibility
for operation or any change in ownership (761. 41 (c) (7)).
H. Monitoring Program
1. General
The parameters for ground and surface water monitoring for
this program are found at 40 CFR (761.41 (b) (6) (iii) (A), (B)
and {C)). Samples should be collected and analyzed in
accordance with EPA approved procedures.
2. Ground Water
a. Background -Each well must be sampled at least three
times and the data submitted to Region IV prior to any
dis:posal. A minimum of one week should elapse between
sampling. At each sampling a minimum of t'MJ replicate
measurements for each value or concentration should be-
made.
/U
. ..
b. During Operation -During operation or for a period of
one year, whichever is shorter, all wells must be
sampled rronthly.
c. Post Closure -Each well must be sampled on a semiannual
basis.
3. Surface Water
4.
a. Background -EPA Region IV will designate surface water
sampling locations. These locations will include, at a
minimum, two (2) sampling points per surface water body
(one upstream and one downstream). Each of these points
will be sampled each time the background samples are
taken for ground water quality.
b. During Operation -Each of the designated surface water
sampling points will be sampled rronthly during operation
of the facility.
c. Post Closure -Each of the designated surface water
sampling points will be sampled on a semiannual basis
during the post closure period.
Chances in Program
Upon a determination by the State or EPA that containment has
failed, the sampling frequency of either ground or surface
water sampling may be rrodified. EPA may also require the
installation of additional rronitoring·wells and an expansion
of -the list of rronitoring parameters.
5. Well location and screened elevations shall be coordinated
with EPA Region IV in the field or by telephone as
appropriate.
I. Undisturbed samples of the soil liner will be taken and the
laboratory permeability determined and submitted to EPA Region IV
prior to any dis:i;;osal (1 sample per 25,000 square feet of liner).
t/
•
" •... : , ... -.:.•,;-1·,
United States
Environmental Protection
Agency
June 4, 1979
4Ji.H-RM
Region .1
345 Courtland Street NE
Atlanta GA 30308
Honorable James B. Hunt
Go vernor of North Carolina
State Capitol
Raleigh, North Carolina 27611
Dear Governor Hu~t:
Alabama. Georgia. Florida.
Mississippi, North Carolina.
South Carolina, Tennessee.
Kentucky
On February 17, 1978, the United States Environmental Protection
Agency (EPA) published final regulations in the Federal Reister
(43 FR 7150-7164) on Polychlorinated Biphenyls (PCBs , Disposal
and Ma rking. These regulations were ame nded by the Federal Register
.(43 FR 3391 8-33920) on August 2, 1978. These regulations prohibit
the dispos al of PCBs at any site not approved by the EPA after
April 18, 1978, and these regulations require that the owner and/or
operator of a chemical waste landfill used for the disposal of PCBs
su bm it informati on in accorda nce with Section 761.41, Chemical Waste
Landfills., to the Regional Administrator for review.
In accordance ~-:ith the above referenced regulations, a formal appl i-
cation was filed with this office dated December 12, 1978, requesting
app rov al of :a .site in Harren County, North Carolina ·which will be
ow ~e d and operated by the State of North Carolina and used for t he
disposal of PCB contaminated soil from the highway shoulders in the
St ate and from the Fort Bragg military reservation. A public he2ring
was held in \-iarrenton, rforth Carolina on January 4, 1979, for public
input. The hearing record was held open until January 12, 1979, for
additional written public input into the decision process.
The result of EPA's review is that the proposed site will meet a11 the
technical requirements· for a chemical waste landfill as required in
Section 76l.11(b), when constructed in accordance with the enclosed
conditions to this approval except for t he fellowing:
(1) 7Gl.11l(b)(l)(vi) "!~rlifici21 l i:;,:r t •·1 i d !l ~::;s 30 mil. ·J'.'
y re~ :'l Le r. II
(2) 76l.41(b)(2) "The site shall be at least fifty feet fro :n the
nea,re$ t ground\'1ater. 11
_ (3) 761.4l(b)(-5)(iii)(d) "Chlorinated Organics."
These three requirements are hereby waived for the reasons given in
the enclosed technical review. Your re~uest to waive the leachate
collection system underneath the liner is denied for the reasons
stated in the enclosed technical review.
-2-
Accordingly, the Warren County, North Carolina site to be owned and operated
by the State of North Carolina for the disposal of PCB contaminated high\'1ay
shoulder soil is hereby approved subject to the enclosed conditions as a
chemical waste landfill as authorized in 40 CFR, Part 7610 It is understood
by EPA and the State of North Carolina that this approval is based on . the
conceptual design only and that the final construction plans and specifica-
tions (if any) must be approved in wr.iting by this office prior to
the initiation of constructiono
This approval is not to be.construed to be approval for incineration,
storage, marking or records and monitoring. We will continue to work
with you in any way we can to expedite a public health oriented and
environmentally sound solution to the PCB problem in North Carolina.
Sincerely yours, . -2~ t:.. dft.i:6=
ohn .C. White
Regional Administrator
Enclosures
cc: Herbert L. Hyde, Secretary
NC Depto of Crime Control . "D,·o'l1•c c;:.;:-i::..,_·, Cl , U --' -'-J
M:irshail Staton, Chief
Sanitary Engineering Section
Division of Health Servi~es
NC Dept. of Human Resources
Jerry Perkins, Head
Solid Waste & Vector Control
N.C. Dept. of Human Resources &
Division of Health Services
Approval Conditions for the PCB Disposal Site Owned
And Operated by the State of North Carolina in
Warren County, North Carolina on the Property Described
in Governor Hunt's December 12, 1978, Application as Owned
by Carter C. Pope and Linda W. Pope Found in Deed Book 278~
Page 252 ..
A. General Requirements (all reports should be sent to the Regional
Administrator, Attention: James H .. Scarbrough):
l. Notify EPA at least two weeks in advance of the expected start of
construction.
2. Notify EPA at least two weeks in advance of the initiation of disposal
of PCB waste at the site.
3. Send EPA the data which is required by 43 FR 761.4l(b)(5}, monitoring
systems for baseline and on the frequencies specified.
4. Maintain .records as specified ·in 43 FR 76lo45(b)(3) as appropriate
and submit within 90 days after closure of the site to the Regional
A~mi ni stra tor ..
5. Advise EPA i riillediately of any changes, alterations or divergences
in the operational and man agerial policies and procedures as out-
lined in t he documents submitted in support of the application.
5. Report to EPA any instance of detection of PCBs through the monitor-
ing program iITTnediately ..
B. Technical Conditions of Approval:
l. The one foot of cover to be placed only on the middle 20 feet to
30 feet of the first lift of waste to preclude shunting any infil-
tration to the side walls. ·
2. • A soils engineering finn shall be employed to provide quality control
during the construction of the clay-silt liner.
3. Engineering expertise shall be provided by the State or a consulting
firm on-site during all operati ons to provide and assure conformance
with the f inal plan s . Such assuranc e sh all be fo l il isiied to t ;1'2
Fcg i on .Jl Ac:;;,ini st r0 t o r at the c0r:ipl ~t ion o f t h :: prnje:t ~-,ith ,i copy
of 11 as b1Jil t '' plan s.
4. A record shall be placed on the property deed v,hich stipulates
the particular boundary of the disposal area and waste contained
therein with the associated waste elevations.
S. The State shall maintain an "all weather" access road indefinitely
to permit access to the site and to facilitate collection of samples
from monitoring wells.
6. Waste will be compacted as much as practicable with tracked equipment
to prevent settlement after closure.
7. Appropriate erosion control measures shall be applied during excava-
tion, filling and after closure to minimize erosion.
8. Trucks used for hauling the waste must be covered.
9. The final plans and specifications (if any) shall be submitted to
the Regional Administrator (Attention: James H. Scarbrough) and
written approval received prior to the initiation of construction.
10. A leachate collection system with a sump and access which
will allow pu mping out of any collected leachate is required
above and below the clay liner.
I .
i I
1 ·
I •
!
..•
UNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY
DATE: June 4, 1979
susJECT: Techrlical Review -Chemical Waste Landfill for-
PCB SUbmitted by the State of North Ga.rolina
FROM: Chief, Residuals Management Branch
To: John C. White
Regional Administrator-
The State of North Carolina submitted an application for the approval
of a disposal site in Warren County, North Carolina on December 12,-1978.
The Tecruu.c·a1 review has been per'i'ormed. The results ·or applying the
~riteria found ii, FR 761.4l(b) to the application are as follafl'S:
(b)(l) Soils -Tne site 1s not 1n a "thick,· relatively impermeable
formation such as large-area clay pans." 'Iherefore, the soils are evaluat
on the follo;,,dr,.g criteria:
Required Prooosed
(1) Soil lin.er thickness 3 ft. ( canoacted) -', ~ 5 .ft. (can;:.acted)
(ii) Perrnea:Jility (cm/sec) mo-7 or 6.8X10-8 or
(0.0000001) (0.000000068)
(4L) Percent Soil Passing 2 30 75 Aver-c:.ge
No. 200 Sieve
(iv) Liquid Limit 2 30 51 Aver-cge
(v) Plasticity Index 215 18 Average
(vi) Artificial Liner 30 mil. None proposeol/
1/ A '1-.'3.iver was requested for this requirement. The primary justification
for the \·;aiver :,.,-as that t l;e Sta.tc \,ould in3 t ead pl<·lCe a 10 .::ill. plas t ic
liner . "urrb r ella.n t op on t he 1:-u::lf:U .1. coi.:~.'."·:J by t;·.·10 t•:=·~t of' soil ·.::1.!.ch
would t•-= s-~,:-J:.:-.·l •d t h sr;.1::;s J.n:~ s l or:21 . T,1.:'..::; di:::d t.,;rt i·:•)lJ_: d :;::.:1Lr..I.:>~ :-~,_-,·.
raim;2 t er irl'iltr ati.on into t h•:::! l2.11i t1ll. ·::.nis i•:;ii•..-c~c t';:.'qk-::3t s ::,):.1.l d
be approved.
.. . .
-2-
(2) Hydrology -The site is located on the crest of a ridge at lati-
tude 36° 20' 13", longitude 78° 09' 58" and is above the 100 year
flood level. This is verified by the U.S. Geological Survey (see
letter dated November 29, 1978, to Jerry C. Perkins). The oottan of
the waste will not be 50 feet above the groundwater. The min.1mur:1
distance will be held to 10 feet above the seasonal high groundwater
table. The State requested a waiver for this criterion. In r-eviewing
the justification of the waiver, I have concluded that the clay liner
in the bottom of the trench plus the liner on top of the waste ½hich
will act as an l..Ir;'brella for infiltration prevention, plus the leachate
collection system and su~p above and below the clay liner will
sufficiently protect public heal th and the erwirornient fran "Lmreasonable
risk of injury" as stipulated by paragraph 761 .41 ( c)( 4). Therefore,
trd s waiver should be aooroved as requested.
(3) Flood Protection -The application states that the diversion structures _
will be designed to divert the 24 hour, 25 year runoff fran the active
'port~on of the landfill. j:
(4) TopographJ--Tne topography at the proposed site is low to rroderate.
'I:"1e approval should be conditioned to require all practical erosion
pre·lention 022.Sure.s to be used.
(5) (i) Ivlonitori!"'-6 Sys~e::r,.s
a. The application st.ates that baseline data will be collected
prior to final approval. The approval soould be so conditioned. ,,...
' b. The application states that the surface streams and the grrund-·
water will be sampled .m::mthly during operation. The approval ·
should be so conditioned by ro....ferring to paragraph 761.4l(b)(5).
-c. Bi-annual rrnnitoring will be done after closure.
(11) Groundi-1-a.ter Monitoring Wells
'Ihe. application states that these 1,-rill be constructed and located
as required. EPA staff should verify t:ie location of these in
the field.
(1ii) Water Analysis
'Ihe analysis for chlorinated hydrocarbons is • requested to be
rr-i....ived. The regulations were written for canrrer-cial facilities
which would be disposing of many different wastes. Since PCB is
the only waste which will be disposed in this site, there is no
point to rronitoring for other chlorinated organics. This waiver
should be aooroved.
-3-
(6) L=achate Collection
'Ihe proposed design does not show a leachate collection system under
the liner as required by the r'eh.rulation. Because of the ground,,.,-a.ter
proximity and the demonstrated public concern, I recanmend that a
leachate collection system and sump be installed under the soil liner
to monitor the integrity of the soil liner. In addition, the leachate
collection system above the soil liner should be required with the
appropriate sump to provide the rrechanism to allow pumping out of any
leachate collected to prevent any significant hydraulic head buildup
on the clay lin.er. 'rnerefore, this waiver should not be aoor-oved.
(7) Operations
Tne operations plru1 submitted 1s satisfactor-y with the exception of
the one foot of clean soil to be placed on top of first lift of v1aste.
Tn.is clea.11 soil is to be used to prevent the trucks fran talcing out
contarrdnated soil on the wheels. Tnis one foot should be restricted
to the middle 20 to 30 feet of the trench so as not to provide a
.shunt to the side walls should any infiltration occur. Tnis restric~
tion· wlll 2.llow ariy infiltration to proceed down through the ha.Ste
to the leache.te collection system v.hich would lead it to the Sl.liTlp
for pump.L,g out.
(8) S:.1p;.x:;r•t.ir..g :Facilities -The supporting facilities are satisfactory
as desc:ribed. No rrention \•,-a.s rrade of long-term rraintenance of the
access rCc.d. Tne approval sh:Juld be conditioned to insure that all-
W=2:ther access 1s rraintained.
JOINT WARREN COUNlY/STAlE PCB LANDFILL
WORKING GROUP
TO: William L. Meyer
FROM: Doris R. Fleetwood
Working Group Secretary
DATE: September 30, 1996
RE: October 6, I 996 Meeting
Dear Mr. Meyer:
This memo is to confirm your meeting with the Science Advisors and the co.chairs of the PCB
Working Group, Sunday, October 6, 1996 at noon. This meeting will be held at the office of co-
chair Henry Lancaster. Mr. Lancaster has asked that I give you the direct line to his office, that
number is 919-715-4133. He has also asked that you arrive about 11:45 A. M_ and park on the
first level of the parking deck. Mr. Lancaster will let you in the building. If you are in need of any
additional information, please contact the Working Group office.
TO 'd
720 RIDGEWAY STREET, WARRENTON, N. C. 27589
OFFICE [phone] -FAX [phone]
July .1978
July 30
Augu$t .1978
August 2-5
August 10
August 15
August 18
September ·1978
September 6-19
October ·l978
October 5
November ·1978
November 6
APPENDIX A
CHRONOLOGY
First report of a chemical spill which was
later identified as PCB on N.C. 58 in Warren
County.
PCB located along roadsides in several other
North Carolina counties including Johnston,
Alamance, and Chatham. ·
Conference held with representatives of the
Department of Buman Resources, Department of
Agriculture, Attorney General's Office,
Department of ~ransportation, Environmental
Protection Agency, and the news media to
discuss the PCB dumpings.
Activated charcoal solution and liquid asphalt
applied along 210 miles of North Carolina
highways where shoulders bad been contaminated
by PCB. This action was taken at the recom-
mendation of specialists at North Carolina
State University, who submitted a plan for
temporarily deactivating the PCB to prevent
migration and to reduce any hazard to the
public.
The N.C. Department of Transportation began
applying a solution of activated carbon and
liquid asphalt to the 210 miles of contaminated
roadside.
Tests conducted along ·uncontaminated road
shoulders to determine the safety and
effectiveness of equipment to be used in
picking up the PCB.
Test conducted along a contaminated road
shoulder on Highway 58 in Warren County.
Test results of the pick-up of contaminated
soil along the roadside in Warren County
show that the contaminated soil can be picked
up and treated without harming the environ-
ment or personnel involved.
December 1978
December 1
December 12
Janua2 ·1979
January 4 ·
January 17
February 1979
February 2
June 1979
June 4
June 4
June 6
August 1979
August 16
Sept -Dec 1979
July -Aug 1979
September 1980 .
September 12
-

2

-
The state obtained an option on 142 acres of
land in Warren County to be used to dispose
of the contmni~ted soil that would be picked
up along the roadsides in 14 North Carolina
counties •.
Application· filed with the EPA for approval
of the Warren County site as a disposal area
for the PCB contmninated soil.
Public hearing on the Warren County site
conducted in Warrenton National Guard Armory.
Robert Burns and sons pleaded guilty to a
violation of the federal Toxic Substances
Control Act. Burns received an active jail
sentence and his sons were placed on probation.
North Caiolina petitions EPA to modify its
regulations to permit alternative methods of
disposal of PCB contmninated soil and debris
(i.e. in-place treatment).
EPA denies North Carolina's petition.
EPA's Region IV administrator approved Warren
County site, and the state's application to
construct a PCB landfill there.
Robert Burns and sons plead guilty to state
charges surrounding the PCB dumping in
Halifax County Superior Court. Burns later
received an active jail sentence and his
sons were placed on probation. Buck Ward was
found not guilty on state charges.
Suit filed by Warren County.
Draft EIS prepared, filed on December 28, 1979.
Comments received on EIS.
Engineering consultant firms were interviewed
by the state and a recouunendation-was made to
the Capital Building Authority for selection
May 1981
May 22
·November ·1981
November 25
·May •1982
May 13
May 26
May 26
June 1982
June 21
·July 1982
July 2
August 1982 .
August 4
August 10
-

3

-
of a firm to develop plans for a PCB landfill
in Warren County.
Buck Ward tried and found guilty of a viola-
tion of the federal Toxic.Substance Control
Act. Be received an active jail sentence
and a $200,000 fine.
Judge.Earl W. Britt grants summary judgment
in favor of state and EPA in Warren County
and Twitty suits, resolving legal obstacles
delaying constructing of landfill. Appeals
taken in both cases.
Contract for construction of the PCB landfill
awarded by the Capital Building Authority
pending the approval of federal "Superfund"
money to fund the PCB cleanup project. The
contract was awarded to the low bidder, Jim
Lineberger Grading and Paving Company of
Gastonia.
North Carolina and EPA officials announced the
signing of a cooperative agreement which
provided ·$2.5 million in federal "Superfund"
money to construct a PCB landfill in Warren
County, and to clean up the PCB contaminated
soil along 210 miles of North Carolina
roadsides.
120 acres surrounding the landfill site deeded
by state to Warren County as buffer zone.
Voluntary dismissal taken by Warren County
in suit on appeal.
Construction began on the PCB landfill in
Warren County.·
NAACP files discrimination suit in federal
court requesting preliminary injunction to
prohibit placement of soil in Warren County.
Bearing held before Judge Earl Britt.
Preliminary injunction denied.
September ·19s2
September 15
October 1982
October 6
October 12
October 27
November ·l982
November 1
·December ·19a2
December
December 13
December 27
·January ·19a3
January
January 26
- 4 -
Removal of PCB from roadsides begins by DOT
crews. Protests begin in Warren County and
· a total of 423 adult arrests were made and
100 juveniles were taken into custody over
the following 4½ weeks.
Fort Bragg begins removal operation for PCB
on base.· ·
State finishes roadside removal of PCB.
There were 241 shoulder miles picked up;
6,455 tru~kloads taken to landfill.
Fort Bragg finishes removing PCB from base;
76.8 truckloads put in landfill. Total
state/Ft. Bragg truckloads _7 ,223.
Capping operation begins; plastic liner and
clay liner in place, soil layer added. Bad
weather prevents final soil layer and seeding
of cap to be accomplished.
Heavy rains cause soil erosion on cap and
exposes plastic liner. Bubbles develop in
exposed liner from gas in the landfill caused
by decomposition of vegetation mixed in with
soil.· Bubbles vented, soil erosion temporarily
corrected and a temporary seed cover is
installed on the cap. Landfill will be
completed in Spring.
Buck Ward begins sentence at Danbury,
Connecticut, Federal Prison after being
denied petition for certiorari by U.S.
Supreme Court.
Federal Appeals Court affirms Judge Britt's
ruling in Twiddy case.
EPA monitors gas venting fro~ landfill and
reports no significant emissions of PCBs.
U.S. Files civil suit in federal court
against Buck Ward and Ward Transformer, Inc.
·February 1983
February 17
· ·March 1983
March 4
·May · 1903 ·
May 11
May 24
.July'l983
July 14
July 15
July 23
August ·l983
August 3
- 5 -
State dismisses state law suits.against Buck
Ward and state allowed to intervene in federal
suit. All counterclaims dismissed by Ward
against state.
. Voluntary dismissal. taken by plaintiffs in
discrimina~ion suit.
Contractor resumes work on completion of
landfill construction.
EPA grant period extended until .July 23, 1983.
Construction completed.
Inspection held at the site and acceptance
made by state officials.
Grant period ended.
Inspection held .at the site by EPA officials
and approval given.
Warren County PCB Landfill -Status
• October 1982 commitment
"The State will push as hard as it can for detoxification of the landfill when and if the
.wpropriate and feasible technology is developed. We will seek to establish a Joint
Local/State/Federal Working Group to pursue this end".
11
------I intend to see that the state of NC keeps its commitment to you, your children, and
your grandchildren to continue to press for detoxification of the site, to closely monitor it
and to Kenerate its safety for 1ienerations to come"
• June 1983
-Governor appointed 11 member county ( 4 representatives), state ( 4 representatives with
Bob Jansen representing the Governor's office) and 3 federal representatives on an
"IotecKovernmental WorkinK Group on PCB detoxification"
• June of 1983 until December of 1994
-Working Group reviewed 8 proposed technologies for detoxification
• December 1984
-the Working Group concluded that technology "appropriate for detoxification had yet to
be demonstrated" and recommended:
1. The landfill should not be disturbed at this time
2. Regular/routine monitoring should be initiated
3. Establish a mechanism "within state government to continue surveillance of
developments in PCB detoxification"
• December 1984 -1992
-DOT maintains fence, grass, road; Division of Solid Waste Management Department
Environmental Health and Natural Resources monitors landfill, groundwater, surface
water and identified significant amounts of water in landfill (rainwater was collected in
landfill while it was being filled). No releases of PCB were measured during this 8 years.
1
• January 1993 ·
-Secretary Jonathan Howes appointed Secretary ofDEHNR and is made aware of water
in landfill. Secretary Howes directs DSWM to recommend actions needed to ensure the
commitment for maintaining safety of the landfill.
• May 1993
-DSWM recommends extraction of rain water from landfill and irrigation over fescue
grass directly over landfill.
• June 1993
-Secretary Howes, Secretary Katie G. Dorsett, Deputy Secretary Steve Metcalf, Special
Assistant to Governor Carolyn Coleman, Dr. Ron Levine, State Health Director, Bill
Meyer Division of Solid Waste Management hold open public meeting with county
commissioners and citizens of Warren County to notify them of water in landfill and
opportunity to work with the state to make the landfill as safe as possible. The majority of
the citizens attending the meting objected strongly to simply removing the water without a
commitment for detoxification. Secretary Howes committed to work with the elected
officials and citizens to establish a process and a Working Group to address detoxification
of the PCB landfill.
• June 1993 -March 1994
-Secretary Howes initiates process of negotiation with citizens and county commissioners
that established a Working Group (Joint Warren County/State PCB Landfill Working
Group) to evaluate alternatives for detoxification of the PCB landfill.
• March 1994
-First meeting of Working Group to define membership representation and mission(s).
• March 1994 -May 1994
-Working Group established and an independent Science Advisor for the Working Group
is hired (funding for Working Group and Science Advisor provided by Secretary Howes,
DEHNR) for one year (May 1994 -May 1995)
• June 1994 -August 1994
-Science Advisor and Working Group work with state to perform intensive sampling of
PCB landfill contents, groundwater monitoring wells, streams, vegetation and land
surfacein vicinity oflandfill. The General Assembly appropriated $100,000 for capital
improvements to the landfill.
2
• September to October 1994
-Dioxin( s) at very low levels identified in landfill, groundwater and stream -Working
Group and citizens express concerns and criticism of state and perceive that the landfill
may be leaking. State does not agree that landfill is leaking. Science Advisor is directed
to initiate process for selection/evaluation of technology for detoxification.
• Spring of 1995
-Science Advisor recommends base catalyzed dechlorination (BCD) as the most likely
detoxification process for the landfill. Process is initiated to select vendors for BCD pilot
scale processes on the landfill.
• May of 1995
-Science Advisor contract ends. The Working Group works with Senator Frank Balance
to obtain appropriations for detoxification studies.
• June 1995
-$1. 0 million appropriated "to fund a pilot project to identify and select a technology for
detoxification and remediation of the PCB landfill in Warren County".
• June 1995 to March 1996
-Working Group meets 2 times per month
-Advertise for Science Advisor
-Select vendors for BCD technology and work with EPA Region IV to approve pilot
scale projects on the PCB landfill.
-Initiate process with CP&L to obtain electrical utilities on landfill.
-Submit RFP to environmental firms to provide excavation of PCB contaminated soils
from landfill.
• March 1996
-Contracts signed with 2 Science Advisors with detailed Scope of Work for detoxification
-Contracts signed with Warren County to provide office space, secretary, computers,
telephone service for support of Science Advisors.
3
• Near Future
-Science Advisors will make recommendations on environmental sampling, BCD project,
other technologies for detoxification and developing community involvement process for
Working Group.
-The Working Group currently is in a vezy aood position to accelerate activity and
proiu:ess for detoxification alternatives on the PCB Landfill.
-Ultimately the Working Group will recommend a detoxification process and request
funding for full scale detoxification
4
2-02-1996 8:19PM FROM
Sept. 3, l 996
To: Bill Meyer .................................................................................... by FA.."X
From: Joel Hirschhorn
Subject: responses to vaiious faxed questions received on 8/29/96
1. As I have told you~ I believe that Triangle Labs does good testing for dimcins. You have not
.indicated whether they have given you a quantity price. You suggest the option ofissuing an
RFP, but I do not know whether doing so will delay any analyses of clio:x.-in, nor whether the labs
on the list you sent are in EPA' s CLP program. Even when method 8290 is used, I notice that
some labs have unusuaTiy high detection limits. I also expect all data to be reported by the lab to
include TEQ values fo.r each sample, following EPA's procedure of using oneha1fthe actual
detection limit for non detects of iudividual isomers.
2. As to the lists of reporting values you sent, are they from your state lab? I do not understand
the use of.reporting values. Are you saying that non-detects are reported as these? I e:qJect to
see method detection limits for the actual tests conducted (i.e., not gene1ic ones). All the lists
received were for liquids, none for solids. I would like to know whether:the lab can test for PCBs
and obtain a detection limit less than 100 ppb. The list for organic ex1:ractables is incomplete; I
ex-pect to see tests conducted for all major P AHs, especially benzo( a )pyrene; here too I would like
to k:novv whether they can achieve a detection limit less than 100 ppb.
P. 1
2 -02-1 986 8 : 1 9F-'M !-KUM
Sept. 3, 1996
To: Bill Meyer .................................................................................... by FA.,-X
From: Joel Hirschhorn
Subject: responses to various faxed questions received on 8/29/96
1. As I have told you, I believe that Triangle Labs does good testing for dioxins. You have not
indicated whether they have given you a quantity price. You suggest the option ofissning an
RFP, but I do not know whether doing so will delay any analyses of dioxin, .nor whether the labs
on the list you sent are in EPA's CLP program. Even when method 8290 is used, I notice that
some labs have unusually high detection limits. I also expect all data to be reported by the lab to
include TEQ values for each sample, following EPA' s procedure of using onehalf the actual
detection limit for nondetects of individual isomers.
2. As to the lists of reporting values you sent, are they from your state lab? I do not understand
the use ofreportiug values. Are you saying that non-detects are reported as these? I ex-pect to
see method detection limits for the actual tests conducted (i.e., not generic ones). All the lists
received were for liquids, none for soJids. I would like to know whether:the lab can test for PCBs
and obtain a detection limit less than 100 ppb. The list for organic ex1ractables is incomplete; I
ex-pect to see tests conducted for all major P AHs, especially benzo( a )pyrene; bere too I would like
to kno"v whether they can achieve a detection limit less than 100 ppb.
cc: technical committee f i.,,i./ ~4 C. , j)
COll<;>k:u,t::,t_L "4 N4 L yT 1 CJk ML~
-?CB BDBJ
~ vOG &z4)
* s ~,i-vo/tJi',;E
/1$fr.ttlJb/.
/-#?rl6/Cl rhs
[) IHI to.I/
pulthtj
y_;27D
~or;;/ I
G1 ,q.J
92fo i
/3 I/
)fi-
;
J1
I
~1
I
y
,•L ,. ~~,. --~ ~-' I U
. -STATE IABORATORY OF PUBLIC BEALTB
PO BOX 28047 -306 N. WILMINGTON ST •• RALEIGH. NC 27611
ORGANIC CHEMICAL ANALl!SlS
PV'RGEABLE COMPOUNDS IAJ3NO
FIELD NO
COMPODND TYPE { ) { ) ( ) ( ) ( )
~w~~ ppb ppm ppb fPtll ppb pprf'l ppb pp,o fpb ppm :
l>lmlOMOMETBAm; 5
4-iiY:tT1nl.-2-P£NTANO!f!: ,o
a&-1.3-DTCHLOROP.R.OnKg s
TO~ ..
'I'RANS-1,3--l)ICHI.()~OPltOpt?Q;
1,1,1,2-'l"ETKACaLOR~
1,1,:l,-TllJcm,oROZTnA.~ ,/
:Z..BZJ'-011'1!: JO
ntTRA.CKLORO~ 5
Dll!~OKocmokOMlmW'll!:
!:l"KnX."('e l)EDR.OMll>E
CltLOH0.9!:~
1,l,l.2•n:TRAC~ROP:T~
rrBYl. ~ZEffl!:
J:n.Jtln:S
8l'T'Mm; '\ V
JlltOMOl"OIUC iO
TltAlm-1 ,.C-Dl-CHLOR~B'l:1ffl'CE io
1,1,3.nICU.OJI.OPROPA?tt ..5
l,.&-OIClltOR08!:NZt:NE I
1,1-DICKLOROll~ '11
1.:2-.tla.ROM0•3-CHL0R.OPROPAfflt ;J,8
vmTL >.JZrAtt. ;:.i.c;o
C -\'f-~:<,,al.(: L1~6 (('.:,.,;~l-,l.1).\~Tl~N OP-. i3Acc;.c·~-KCu,~r ...
J -Xatimated Talu•
~ -Actual Talu• jt ltnown to be less than vw.lue given.
L -Actual T&lu• i■ kno"'tl to be gre~ter th$.%1 v~l~e given.
.
:
V -Material. was a.nalY%•d for but bot aatectad. 'rb,e n=ber ia the Min~ O.t•etion Liait.
W.. -NOt -ly:ad.
l/ ~ Tentat!~• identification.
'"%._I -COMFlol.l.NO .R~L.lfl6LY P6tf'C.:.TABU:-1,;,Y,i_'{ jl',J HIG-H (<.J·.!ctN1"RAi j,~~)S. ✓ -· :S,-l:'\,lP;_r; H 1 ~-H LY l); 1_;..11y u . ,..,., DL'"") De ,v,.;;,-t~J'f', .. A .
DEHNR 3068-0 (l0/93)
,•
'·
,·,
( )
ppb PF"I
1
'.
PmlGeOM..ORC
I
IU
I '
STATE LABORATORY OF PUBLIC BEM,TB
PO BOX 28047 -S06 N. WJLMJNGTON ST •• RALEIGH, NC 27611
ORGANIC C.BEMICAL ANALYSIS
I PURGEABl.E COMPoUNDS LAB NO
FIELD NO -
COIIPOUM) TYPE ( ) ( ) ( ) ( ) ( )
M06)!1 {ppb ppb ppm fl'>b ppm ppb ppm ppb ppm ppb ppm,
CHI.ORO~ ;JO
VINT?.cm.0Rll>I; ,o
BaolllOJO:rHAMC ;J,0
CHLoll01:rHAN'lt JO
TJhCSI.OllOP1.UOROIIZ1'HAIQ: JO
,\Cl!:l'Ql'nt .;J..O
J. l-nJQ!l..ORQfllU:NE 5
lO.CO!laTlL\ltt I
~ em.o:am~ I
CADQ!( :0tsUL11Dit
TRNf&-1.2•:t>ICl!ll.ORO&na:NJt ,,1·
Aean.O~ ;21:>
1.1-mcm.oJtOlt'l'~ 5
::Z.BtJT.~on ::l.D
~ 1.2,nI<!HLC)ROtrr.a;!',"& 5
r,;fi.OROl'Oml I
1,1.l•TlUClJl.ORO:tn~ . I
CAJ'<aOl'I ~Rm!: I
~ I
l,2-'0tC2l.OROETBANZ I
TR%cm.0R.O~ I
1.2•::)ICHl,OROfflOPANJ: l
BROMOtllCl:a;O'RO,eTSAia J;
C -Po~, e-..;. .. AB -=~:-!Tl'll''tl!'H~Tic/'J cR 8i:ic.~Ct-Rc~1\.l D.
J -:!a!d.mat·111d y&J.u•
X -Actual 'nllue i• k=wn to be less th~ Talue given.
L -Actual Talue i• 'Jcnc,wn to J:>e llX•&t•~ than Talue qivan.
:
U -Material wae 4IJUl.ly:i:ed for but not ~•tected. 'l'h• number i• the Minimum Detection ~im.i.t.
l!OI. • Not a::aaly:ed.
1/ -Tentative identifie~tion. l./ .. ~~Po\l~D Ra, fH;3L'f OE.TfGRSt..c O~'-¥ 1N fHc-H CCN!£NTRfn7cNS, ·✓ -.SAAPL~ H11rttL'f ou.l.\rao. ~O~-:'D Oo ~ AffLY.
DEill'ffi. 8065-0 (10/93)
( )
ppl;J fPfl'1
PURGCOM-ORG
08/22/1996 2C:"J: 29 FROM EHt--lR ENU SCIENCES TO
STATE LABORATORY Of PUBLIC HEAL TH
P.O. BOX 28047 -306 N. WILMINGTON, ST., RALEIGH, N.C. ?7611
ORGANIC CHEMICAL ANALYSIS
BASE/NEUTRAL ANO ACIO LAB HO
EXTRACTABlES FIELD II
COf'1POONO TYPE ( ) ( ) ( J ( )
UNITS
frene In/ ':l';;r,,
?nzidine -~hL<n
JtVl benzvl Dhthalate /I")/~~
i'!lZ {.a}.anthracene
1,.-ysene 'I
3-dichlcrobenz~d,oe .~I ,,,,.~
is(2-ethv1hexv1)ohthalate Jf'J)'~:l,n
i-n-octy1 ohthalate JlJ/~:/n
!nto(b)flooranthene rnn1 ~n
?nzo(k)fluorafit~ne .
~nzo(a)ovrene
ideno( l • 2. 3-cd) ovr~
ibenzo(a.h)anthracene ' ?!'!ZO(q.l~ i)oer1lene ,,
nHioe .r;ti/11.,::;n . ~zoic add :
~nzy_l ~ i eohO 1
-ch loroani 1 i ne ,1
it>en.wfuran Jr,/ =?~l> . ~thyln.wtlthalene
-metllv 1 oher.o 1
-nJ?thV l pheno 1 .. ,
..(lit~n11 ine "ill ·11 .t:::".I'.
-oitroan1l1ne
-" i tr"Oi!n i l i ne I
.4 S-tri~hlorwheool '
"'ffl.». '-
I -Estimated value. t-\':2-0/.$011-
• -Actual value is known t.o be less than value given .
( )
. -Actual value is known to be greater than value given.
l -"'1ter1al ~as analyzed for-bot not dete<:ted. The riurber
IA -Not .analyzed.
is the Nininun Detection Umit.(rvt2>l-) ---I/ -Tentative identif1cat1on. (I -On NROC Li~t of Priority Pollutants.
( )
I
I
08/22/19"36 20 : 29 FROM EHi-JR ENlJ SC I ENCES TO
I
BA5f_/NEUTRAL ANO Acto
EXTRACT ABLES
(X)MPOUND
H-nitrosodimethvl,nine
bts(2-chloroethvl)ether
2-<:hloroohenol
Ohenol
1 3-dic~lorooenzene
1 4--dichloroben7.ene
i,2-dichlorobenzene
bis{2-chloroisooroovl )ether
hexachloroethane
N-nitroso--di-n;,ropylam1ne
nitrobenzene
i~h<>rone
2-nitrochenol
2.4-di~thvlohenol
~is(2-chlol"Oethoxv}methane
2 4-dichlo1"00henol
1 Z 4-trichlorobeozene
naohthalene
hexach l orobutad iene
~-ch1oro-m-cresol
hexachlorocvcl(npntad1ene
2.4.~-trichloroohenol
2-ch1oronaohtha1ene
acenaphthvlene
dimethvl phthalate
2.6-<linitrotoluP-ne
acenai,htheoe
2.4-<linitr-oohenol
2.-4-dinitrotoluene
4-nitroohenol
f'luorene
4-chlo l0henvlether
diethyl Dhthalate
!i6-dinitro-o-cresol
diohenvlainine
.izcb@f'lzene
4-b. ,~n,,lphenvl ether
heXachlorc:ben2eoe
oent.ach lorooheno 1
ohenanthrene
anthracene
d1bt.!ttl J>hthalate
fl uoranthene
J -Estimated value.
STATE LA800ATORY OF PUBLIC HEALTH
P.O. 80X 28047 -306 N. WILMINGTON, ST., RALEIGH. N.C. 27611
ORGANIC OIEMICAL ANALYSIS
LAB NO
FIE!.D #
TYP€ { } ( ) ( ) ( )
UNITS
IO/_!r-11'>
,
G,.lll __
jo/:t:u,
~//~~
10/~~n
w ~-'/t.!:o J-
lji"J/:il~
'~
"'ii,/Jl,,..qJ
Jl'J/:t2~
. ,,
K -Aetual value is known to be less than value given.
536E15 P. 05
( }
.
L -Actual value is known to be greater than value given.
u -Haterfal was analyzed for but not ~tected. The nurber
NA -Not analyzed.
is the Mininun Oetect1on Limit. (M2>L..) ---11 -Tentative identif1ca.t1on. y -On NRDC Ust of Priority Pollutants.
( }
NC Department of Environment,
Health, &. Natural Resources
Solid Wutc Management Division
SAMPLE ANALYSIS REQUEST S tatc Laboratory of Public Health
P.O. Box 28047, 306 N. Wilmington St.
Raleigh, North Carolina 27611-8047
Site Number _______________ Sample ID Number/Name _________________ _
Name of Site ______________ Collected By ______________ ID# _____ _
SiteLocation Date Collected Time -----------------------------------
Agency: Hazardous Waste Solid Waste _._ Superfund TCLP Compounds ----
Sample Type Inorganic Compounds Results(mg/1)
Environmental Concentrate Comments arsenic -barium -Ground Water (1) Solid (5) cadmium ---chromium -Surface Water (2) Liquid (6) -lead ---mercury
Soil (3) Sludge (7) selenium ---silver -
-Other (4) -Other (8) -
--Organic Chemistry Inorganic Chemistry -
--
Parameter Results (mg/I) Parameter Results(mg/l)(mg/kg) Organi2~ompounds Results (mg/I)
-P&T:GC/MS antimony benzene --Acid:B/N Ext. arsenic carbon tetrachloride ---2,4-D barium chlordane ----2,4,5-TP(Silvex) beryllium chlorobenzene --chlordane cadmium chloroform ----bept.achlor -chloride o-cresol -hexachlorobenzene chromium m-cresol ---hexachlorobut.adiene cobalt p-cresol ---endrin copper cresol ---
-lindane fluoride 1,4-dichlorobenzene --
-methoxychlor iron 1,2-dichloroethane ---toxaphene lead I, 1-dichloroethylene ----manganese -2,4-dichloroethylene
--mercury -bept.achlor
nickel bexachlorobenzene ---nitrate hexachlorobut.adiene ---selenium ... hexachloroethane --silver methyl ethyl ketone --FOR LAB USE ONLY sulfates nitrobenzene ---thallium pentachlorophenol -Date Received vanadium pyridine ---zinc tetrachloroethylene -Date Extracted pH trichloroethylene ---conductivity -2,4,5-trichlorophenol
Date Analyzed -TDS 2,4,6-trichlorophenol -
-flash point -vinyl chloride
Reported By --endrin
lindane --Date Reported --methoxychlor
--toxaphene
Lab Number 2,4-D ----2,4,5-TP (Silvex)
DHS 3191 (Revised 12/93)
DRAFT SAMPLING AND ANALYSIS PCB LANDFILL
SAMPLE ID
LOCATION
LEACHEATE
19 LEACH EA TE INLET
PCB
20 LEACHEATE OUTLET
SAMPLE ID
LOCATION
SURFACE WATER
21 SW-1 SOUTH UT NEW
22 SW-2 SOUTH WEST UT NEW
23 UTUS EXISTING
24 RCUS EXISTING (Below Bridge)
25 RCDS EXISTING
26 RCUS NEW (Above Bridge)
SAMPLE ID
LOCATION
SEDIMENT
27 USSS-ABOVE BRIDGE ON RD
28 BB BELOW BRIDGE ON RC
29 SS-1 SE DRAW ON UT
30 SSND N DRAW ON RC
SAMPLE ID
LOCATION
POND SOIL
31 PS-1 OVERFLOW PIPE BASE
32 PS-2 CENTER OF POND
DIOXIN/ BN/AE
✓
✓
FURAN
✓
✓
PCB
✓
✓
✓
✓
✓
✓
PCB
✓
✓
✓
✓
PCB
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
33 PS-3 DISCHARGE PIPE OUTLET ✓ ✓
SAMPLE ID
LOCATION
BLANKS
34 TRIP 1
35 TRIP 2
36 SOIL 1
37 WATER 1
38 WATER-2
39 WATER-3
40 HYDRO PA
41 LANDFILL SOILS
PCB
✓
✓
✓
✓
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
✓
✓
✓
✓
voe METALS
✓
✓
BN/AE voe
✓ ✓
✓ ✓
✓ ✓
OTHER
✓ ✓
✓ ✓
METALS OTHER
✓
✓
✓ ✓
Other for landfill soils include particle size distribution engineering classification, liquid limit, plasticity index, moisture
content, organic matter, nutrients
DRAFT SAMPLING LOCATION/ANALYSIS PCB LANDFILL
ANALYSIS
SAMPLE ID
LOCATION
GROUND WATER
1 MW-IA-NEW EAST
2 MW-lB-NEW EAST
3 MW 2-EXISTING NW
4 MW 3-EXISTING WEST
5 MW-3A NEW WEST
6 N2-4 EXISTING SW
7 MW-4a NEW SW
8MW-5NEWN
9MW-5aNEWN
10MW-6NEW S.EDRAW
11 MW-7NEW SOUTH
12 MW-7A NEW SOUTH
13 MW-8 NEW N. E. ORA W
14MW-9NEWN. DRAW
15 MW-l0NEWW. DRAW
16 BACKGROUND WELL 1
17 BACKGROUND WELL 2
18 BACKGROUND WELL 3
PCB
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
DIOXIN/
FURAN
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
BN/AE voe METALS OTHER
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
✓ ✓ ✓ ✓
Background wells located 1-2 miles off-site in NW, SW and SE quadrants. Attached is list of constituents and
detection levels for each analytical test. Wells m2-6,8,9 and 10 may require a nest ifhydrogeological
conditioning warrants.
Total Samples/ Analysis
40 total; PCB 40; Dioxin/Furans 40; BN/AE 23 ; VOC 23 ; METALS 23 x7= 161 (As, Ba, Cd, Cr, Pb, Hg, Se)
August 2 9, 1996
To: Technical Committee
From: Joel Hirschhom
Subject: Recommendations on decision making process and several act.ions
en Pr;oses
A) My advice is that the TC an.d WG use a more fomw means of CODllll\&nicating requests
to the state. There is a need to prepare carefully written memos or letters ftom the WG to either
Bill Meyer or a higher state official Verbal requests or motions at .meetings, such H what
happened this week on the issue J rwed about EPA permits for removing materials from the
landfill, are inadequate, unless they are followed up immediately by a writtea document thal
precisely spells out the details of the request. Details and creating a documented rec.ord of
requests and responses are very important in these matters.
B) My advice is that the TC adopt a standard procedure for .making deci.s.ions about
actions recommended by the Soieuce Advisors. I am referring to action memos, not .inf ormatio.ua.l
memo&, nor submission of work products. My recommended proceu is:
1. The SA faxes an action memo for the TC to the WG office for immediate distribution
by &x to TC members and the other SA.
2. The office arranges for a phone conf'erenu call within 24-48 h.our.s for the TC to
discuss and wkc decisions on recommended actions.
3. During that call with the SA&, the TC asks questions ud discusses action
reconunendatiOlls and either makes decision(&) Ott action item()), allowing followup activities by
SA(s)~ or some other decision is made. Secretary mainta.m, minutes of such calls. '. ,··
4. Within 24-48 hours:
a) As appropriate, the SA(s) fa.xes a work product to office for di$tribution to TC
(unless instructed to take SOUle other action directly, such as sending a memo or makin.s a call to
SOJlle party on behalf ofthc TC or WG) to facilitate the TC or WO itoplcmenting the decision.
OR
b) The TC or WG takes final action. Secretary keeps record of exactly what is
done.
1
121 fdcni str1te1Y
My advice is that the TC consider and the WG adopt the follownlg scntegy to initiate
steps to build a case for fedetal interv~tion and actions that ~port the goal of dotoxification of
the landfill. My analysis oftht histoiy of this situation lcadi me to conclude that them.tire
Strategy of the conmiwlity has been to depend on eventually obtaining the desired deoisiou~ and
funding from the state. This strategy has several dis.advantages, not th~ least of which are: a
fundameotal confli~t of interest the state has between being the owner and operator of the landfill
as well u the protector of public hwth, and all of the difficulties in buildins a teclmical
environmental, and economic case sufficient to obtain substamial state funding. My
reeommrndation i, that it is in the community's interest to de\·elop a parallel strategy that ii based
on the plausibility of forcing federal intere~, answers to requests., and various .interventions or
official positions that provide either pressure -on the state to take ccrtam actions, or supply
important suppon for what the WG reoomm~ds to the state.
There are three immediate action re~mmmdations:
a) The WG should submit a written request to the state for a compliance 1udi1 and
summary report giveu to the WG within 30 days. The WG would ask very specific, carefully
ctafted questions, based largely on various federal requirements that the state was required to
satisfy.
b} Toe WG would submit a written request to the EPA Region 4 Administrator to conduct
an official EPA compliance investigation under TSCA for the landfiJl, based on EPA ex1minatio.a
of its records, state records., at1d a facility inspection, if necessary. The need for very expedient
implementation would be made. Specific concern& would be identified.
c) The WG would submit a written n;quest to A!sistant Administutor Elliott Laws at
EPA Hcadquarte1s for his office to ex.amine specific policy issue, under CF.ACLA/NationaJ
Cobtin_gency Plan by asking key questions aff'ecting potential cleanup of the Landfill. The Jetter
wowd cite the details of the agreement bctwcea the EPA and the state, in the form of a
;;i;;opOf~tfY~•::g,m:i=t-!hat was funded uuder CERCLA/Supcrfund. Specific policy
determinations would 1,e requested oa specific is.,ucs, such as whether the current form of the
NCP applies to the landfill, and whether the statutory requirement for review of the remedy every
.five years applies.
C3) ssnsnx (0c BR (Pf AbtaiAipg a tesh,g0I0cx YtP4Pt
The issue is how to most efficiently follow state requitements for obtaming detoxification
technology companies for conductittg bench-scale tests and for one selected company to assist the
SAJ and WG in preparing a C<mceptual design of the desired remedy for inclusion in the p1(Jposal
to the state lelislatw:e. My idea is to use one RFP to cover both activities to save considerable
2
£0'd
time. My recommendation is that the WO consider my proposal a.ad formally submit it 1.0 the
state and ,eek a ded~on on whether it can be implemented in its present fonn or how it ~an be
modified to meet ate legal requirements.
The key components of the propo11al axe:
-The RFP would be described as the solicitation of a contractor that after completing a
successful bench or pilot scale test of detoxification technology will provide profession al servic~
in developing a conceptual engmeering design of the full remedial action at the landfill, mcluding
111. ouite demonstration tell prior to full scale use of the aelectcd detoxification technology.
-· The RFP would ddmo the following step, for interested parties;
a) Based on information given in the .RFP (including site baek.groU11d, &od scopt of work
for tut) 1 to 3 vmdots will be aclccted on the basis of RUbmiUed p1oposals to conduct a bench or
pilot sale test at their own f&cility on landfill materials provided to them.
b) After the selected companies submit the required rq,ons on test results aod provide any
additional .information tcquired, one company shall be selected to provide the conceptual design
sen-ices, b.ised on both the test results, other information provided, and the bids in the compauy's
proposal.
•-The RFP would ask for proposals that must contain oertaiu types of information,
including l,ids for the initial testing and. if selected. for the de~ services., ba&ed on scopes of
work for the two phases given in the R.FP Technology companies would be urged in the Rf P to
select a subcontractor ( such as an envuon.meu.tal design and cagineering 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.
-The state would enter into an initial contract with the to.mpanies selected for the bench
OT pilot tests. This con tr act would COI1tain a provwo.n stipulating that the company is hem~ ptc·
qualified or short-listed by virtue of being selected to conduct the test fo1 final selection as the
provider of the design services and that no other m will be issued by the state. Subsequently,
after one company is selected, the sute would Clltcr into the &al contt1c:t for !he pro,iiion of the
design ser.ices.
~l PstoJifis,tjog s!ssov0 &RPLJ
ht order to obtain useful bench scale te~s, it v.ill be ncce~sary to iDfonu potential vendors
in the llfP what the numerical goals of the detoxificatfan are for key <Xlntaminants. In other
w01ds, we must specify what level of PCB a and diox:ios are acceptable in residual treated
materials th.at would, presumably, be backfilled into tho e"cavated landffll. These levels ~ould be
3
170'd 0001-c.SC:-616 :Xl?.:J
the preliminary cleanup goals (PCGs) or performance requ.iremaits for waste ucatment. They
would be given as preliminary ooes, mainly because they might be changed a.fl.er all the test resuJt5
are obtained ( either increased or decreased).
The technical problCUI is deciding o.n what basis to use for the PCGs. The.re are two
principal approaches. A regulatory cleanup level may already exist that either must be used or
may be used. For example, certain file document& indicate that EPA would r~uire treatment to
achieve a level Jess than 2 i,pm for PCBs, but the state may typically 1oquire less than I ppm
(parts per million.). Wllcn~er a State has a inore stringent requirement than EPA. the state one
prevails.
The second approach is to use health risk based cleanup standards. Some risk based
concenuations already exist in the form of EPA generic Superfund Soil Screening Level5. These.
however, are based on certain specific exposure and risk assumptions that may .not be compl~tl}
applicable at specific sites. When they are not, only a site sp~c risk assessment can generate
other numbers. There are many tough issues for such risk aHessments.
Consider PCBs, EPA data reveal a 10°' cancer risk level for residential soil ingestion
exposure of70 ppb (parts per billion). However, EPA uses a value of 1 ppm (1~000 ppb) a& an
SSL and under its PCB oleaDUp guidance. This means that l ppm equal:; a risk of 1.4 ~ lo-~ ( a
tenfold higher risk). ·
But if dioxins are also present, they must be ~onsidered. If dioxins only are concjdered,
then the 10·' cancer risk level is 2 ppt (parts per trillloo) for cumulative in~estion, inhalation, and
dermal exposure to surface soil or 4 ppt if only ingestion is considered. EPA often attempts to
use a very high .level of l ppb for soil cleanup deci.sions, which is blatantly unacceptable. fl do not
now have a risk based concentration for PCBs bued on three exposure pathways, which would
be less than 70 ppb, possibly around 40 ppb .]
If both PCBs and dio,cins are present, however, then cumulative risk must be eo:nsideted,
meaning that le ... els BELOW the I 0 .. levels obtailled for them individually would correlate with
Jo" cumulative risk.
The problem is whether detoxification technologies can achieve very to~-.. rcs.id\131
,ontaminot levels cotresponding to 10·' risk )e\·els. Therefore, while PCGs cm be set ,·ery
stringently, actual te.tt data may show that no feasible detoxificatioJJ tccbnolog)' 411n mcct them
reliably and consistently ( eq,ecially with varying waste inputs, in terms ot couwmnant and water
levels, for e:umple ). In other words, the teclutical feasibility of detoxification tcdu10Iogy tbr th.is
application will depeod etn exactly ~at cleanup perfonnanee requirements are demanded. Th~
more protective the WG wants to be, the greater the probability that 110 fcuible technology c111 be
shown to exist. One of the more subtle issues that must be conSidered is whether typical e,q,osure
pathways a.re relevant for the site afiex post•treatmeut residuals are backfilled in,o the hlldfill. hi
other words, if treated residues ue buried in. the ground and eovcrcd with olem soil, tb.c:n there
4
OOOT-LSC:-6!6:X-e.:J
may be no plausible exposure pathways ( as long u the containment 1ern1ins effective), because
people will not iJlaest the material. or mhale aubome particles, or have direct dcnnal contact ~ith
the material. There might be some concern about leaching of the contaminants over time into
groundwater, but because both PCBs and dioxin, have low water solubility wt high soil
adsorption, such leachmg an.d migration will normally rc,ult m much lrlgbe1 acee:ptablc levels than
those obtained on the basis of QDCer risk. --.,,,_:
EPA often uses this reasoning to justify higher acceptable clemwp levels. In the extreme,
it justific, NO treatment because huardous c)lemicals are buried in some type of ~t~t
system.
The WG must decide what cle.anup goals to Ilse. Here ue 90.me alternatives:
--Least stringent l or 2 ppm for PCBs u.d 1 ppb for d.iox:ins (max S x 10 .. risk)
••StriD.gent: 70 ppb for .PCBs and 4 ppt for dioxins (4 ,i. 10~)
--Very stringent: 40 ppb for PCBs aud 2 ppt Cot dioxins (2 x 10.(i)
•• £xtreme.ly stringent: 20 ppb for PCBs and 1 ppt for dioxins (max l x 10..., risk)
[All of these risk .6.gutes ignore synergistic effects.]
Note that consideration ofnoa•cancer health effects generally results in rugher
contaminant le'\·els th.an those obtained on the basis of cancer risk assessment.
A practical problem i8 that if the R.FP cites very low cleanup levels for PCBs and dioxins
in residues., some compmics may not be interested in pursuing the work. Or, companies may
pursue the work, but have to increase the intensity of their tre.ttment, or plan OD retreating some
residues, that would increase costs substa:ntially. The incremental tteument cost increases for
iucremental risk reduction.s can be very large.
My recommendation is that the WG use the StriogCJlt ahernative abo"e as PCGs,
recognizmg that the R.fP will make clear that the lowest possible residual contaminant levels arc
desired, consistent with obtaining a cost-effective cleanup, and that the test resuhs from tl1e
several vendors selected for the testing phase and other information they provide will be used to
select final cleanup goals. After the WG zmltes a decision, I recommend that the $tlte be
infonned in writing of that dewi.on and asked for it, concurrence.
C~! •atatrn•H0P 211 :n:ua: w 11ml[lll
A major complication for detoxification .is the presence of water io the landfill, because it
affects technology perfurmmce and cost. There is a need for more coD1pJete and reliable
informa.tion from the state to assure that the RFP and design of the bench scale test is adequate.
My reco.mmendation i& lhat the WO submit a written request for information to the state. l11e
request would be for a technical summary of all ley information on water in the landfiD and
5
90 'd 0001 -c.SG-616:Xe.:J d110c9 9NI>lc0fll 8Jd
answers to specific tec~al questions. Note the interest is NOT on what caused che water, but
rathei: o.n the details describing the nltw'e of the current water.
(j} 1;0,smc4if fion
I have seen evidence that th~ state is still pursuing biorcmediation as a means of
dctoJLifying the landfill. J have co.ncluded thit no form ofbioremediatio.n is a candidate for
seJ~tioJl as a fcaS&"ble technology for this 1pplicatio11. Three other evaluations over 1he years also
reached that t-onclusion. Therefore, I recommend that the WG formally request the st.ate to stop
all activities related to biorcmcdiation use for the Ian~ because their resources ue far toil
limited and are needed for many other more important activities.
6
Joint Warren County/State PCB Landfill Working Group
draft April 25, 1996 Meeting Minutes
The regular meeting of the Ioint Warren County/State PCB Landfill Working Gr-oup was called
to order at 4:28 P.M Thursday, April 25, 1996. The meeting was held at the Warren Coup.ty
Office of the Working Group and was called to order by Mr. Ken Ferruccio and co-ehaired by
Ms. Daria Holcomb, Mr. Ken Fenuccio, and Mr. Tommy Cline. A generic agenda was
distributed.
READING AND APPROVAL OF MINUTES
It was suggested by Ms. Priscilla Tyree that minutes from February 22, March 7. and March 28
meetings be approved. Co-chair Mr. Ken Ferruccio disregarded the suggestion to approve the
minutes from the last three meetings.
UNFINISHED BUSINESS
None.
NEW BUSINESS
Mr. Joel Hirschhorn introduced the Master Planning Project. He began by discussing the
Important Reasons for Changing Current Strategy. They are as follows: :
1) Field testing of small amounts of site waste will not provide infonnation
that is more useful then bench-scale testing;
2) Costs of two field tests would be extremely high;
3) It is necessary to examine other detoxification technologies;
4) Current approach would not provide sufficient detailed information; and
S) A much stronger case for funding can be made by spending money on
more thorough site investigation and remedy design.
Next, tvir. Hirschhorn discussed the Key Steps of Recommended Alternative Strategy. They are
summarized below:
1 )
2)
3)
4)
s)
6)
7)
8)
9)
10)
11)
12)
80 'd
Detailed evaluation of detoxification technologies and vendors~
Initiate site investigation;
Design soi.Vwaste removal plan/select vendor,
Issue feasibility study report;
Invite vendors to conduct bench-scale treatability tests;
Science advisors evaluate test results and select/rank vendors;
Finalize site investigation report;
Working group meeting with highest ranked vendors;
Best technology vendor selected/pre-qualified for actual clean-up;
Selected vendor is hired as design contractor (under currem funding);
Remedy selection and remedial design repon; and
Report used as the basis for Working Group/DEHNR formally
proposing the landfill detoxification project to the State Legislature
to obtain funding.
LO :vT 96, £l das OOO T-LSl -616:Xe~ d()[lcJ9 9NI>lcJClfTl 8Jd
draft April 25, 1996 Worling Group Minutes
• Pagel
Mr. Hirschhorn advised that after all information has been gathered this approach will provide
the state with the information needed to provide funding of the detoxification project without
needing additional tests preformed. Mr. Hirschhorn then asked for questions, then the meeting
was turned over to Science Advisor, Patrick Barnes. Mr. Barnes continued with the Master
Planning Project, starting with Site Investigation Goals, the reasons for additional testing and
they are as follows:
1) Establish conditions of liner.
2) Bedrock condition and topography;
3) Transmissivity of weathered rock zone;
4) Direction of ground water flow;
5) Identification of contaminant plume; and
6) Types and amounts of contaminated media requiring clean-up.
Next, Mr. Barnes discussed Site Investigation Activities, what steps would be necessary and
they are summarized below:
l) Collection of samples to conform with permit requirements;
2) Analyze existing data; :
3) Develop and implement field sampling and testing plan;
4) Non-intrusive testing (Geophysics);
5) Soil borings;
6) Installation of additional monitoring wells; and
7) Collection of additional surface water and sediment samples.
Lastly, Mr. Barnes introduced the Master Plan: its purpose. its contents, and its implementation
schedule.
The purpose of the Master Plan is to serve as a:
1) Guidance document~
2) Road map;
3) Operation document; and
4) Stand alone document.
The Master Plan contents are outlined below:
PRELIMINARY TABLE OF CONTENTS
1.0 INTRODUCTION AND BACKGROUND
1.1 Site History
1.2 The Working Group
1.3 The Role of the State
60'd 0001-LSG-616:X~~
draft April 25, 1996 Working Group Minutes
· Page 3
1. 4 The Role of the Science Advisors
2.0 PROJECT GOALS AND OBJECTIVES
2.1 Mission Statement
2 .1 . 1 Impact Assessment
2.1 .2 Detoxification
2.1.3 Community Involvement
2.1.4 Responsibility of the Working Group
3.0 DEVELOPMENT OF FEASIBILITY AND REMEDY SELECTION REPORT
3 .1 Detoxification Technology and Vendor Evaluation
3. I . I Review of Past and Current Approach
3. I . 2 Comparative Analysis
3.1.3 Recommendations
3.1.4 Work Plan for Treatability Testing
3.2 Landfill Soil/Waste Removal Plan
3.2.1 Review of Current Approach
3.2.2 Soil/Waste Removal and Vendor Selection Procedure
3.2.3 Testing Requirements
3.3 Treatability Testing
3.3.1 Bench Scale Testing Results
3.3.2 Analysis of Data
3.3.3 Recommendations
3. 4 Remedy Selection
3.4. l Effectiveness/Performance
3.4.2 Safety/Environmental Impacts
3.4.3 Cost
3. 4. 4 Comparative Analysis and Recommendations
3.4.5 . Role and Responsibility of the Working Group
3.5 Procedure for Establishment of Remedial Goals
3.5. l Evaluation of Test Results
3.5.2 Ranking Procedure
3.S.3 Performance Standards
3.5.4 Responsibility of Working Group
3.6 Procedure for Selecting and Awarding Detoxification Design
Contract
3.6.1 Role of Science Advisors
3.6.2 Role of Working Group
3.6.3 Role of State
4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
4.1 Site Investigation
OT 'd 0001-lS,~ -616: XP .::l
draft April 25, 1996 Working Group Minutes
Page4
4 .1.1 Review of Past Sampling and Analysis
4.1.2 Field Sampling and Testing Plan
4 .2 Landfill Integrity
4.2.1 Leachate Collection System
4.2.2 Liner Condition
4.2.3 Water in Landfill
4.3 Scope of Off-Site Impact
4.3 .1 Soil
4.3.2 Groundwater
4.3.3 Surface Water
4.3.4 Sediment
4.3.5 Air
4.4 Contamirwrt/Waste Releases
4.4.1 Fate and Transport
4.S Estimates of Volumes Requiring Remediation
5.0 REMEDIAL DESIGN
5.1 Roles of Technology Vendors, Science Advisors/State
5.2 Site Layout and Logistics
S.3 Construction Phasing
5. 4 Health and Safety Concerns
S .S Impact Monitoring
5.6 Detoxification Field Pilot Test
5. 7 Preliminary Design and Operation Plan
5.8 Clean•up Cost Estimates
6.0 LEGISLATIVE FUNDING
6.1 Briefing Document
6.2 Presentation Procedure and Materials
6.2.1 Role of Working Group
6.2.2 Role of Science Advisors
6.2.3 Role of State
7.0 PROJECT SCHEDULE
Below is listed the Master Plan Implementation Schedule.
ACTMTIES
I ) Master Plan development
80:t-t 96, £G das OOOt-lSl-6t6:Xe~
TARGET DATE
May 15
draft April 25, 1996 Working Group Minutes
Page 5
2) Detoxification Technology/Vend or Evaluation June 15
3 ) Site Investigation August 15
4 ) Soil/Waste Removal lune 15
S) Treatability Testing August 15
6) Feasibility Study September 15
7) Remedial Goals October 15
8) Vendor Screening & Awarding of
Detoxification Contract November30
9) Site Investigation December 15
10) Remedial Design/Remedy Selection Report December31
11) Legislative Funding April 30
Questions were asked by Messrs. L. C. Cooper and Ken Ferruccio, and Misses Deborah
Ferruccio and Daria Holcomb. The questions concerned whether the Working Group, if they
approved the entire Master Plan, would have the opportunity to give their opinions and approval
on each phase of the Master Plan before it is carried out. After these concerns were voiced and
after much discussion, co-chair Mr. Ferruccio restated the motion to accept the Master Plan
with the understanding that the Working Group would approve each phase of the Master Plan
before implementation. Mr. Cooper, who had earlier made the motion to accept the Master
Plan, reminded Mr. Ferruccio that a motion was already on the table. The original motion was
seconded and carried. Ms. Daria Holcomb opposed the motion.
Mr. Joel Hirschhorn asked if it were possible that a smaller number of people could be contacted
when they were in need of a quick response. After discussion, it was moved and seconded that
the Technology Group would be responsible for working directly with the Science Advisors
when time is short. It was moved and passed that the Technology Group.
ADJOURNMENT
The meeting was adjourned by Co-Chair, Mr. Keo Ferruccio at 5:55 P.M. The date of the ne,ct
meeting is Thursday, June 20, 1996 at 4:30 P.M ..
Doris R. Fleetwood
Warren County/State PCB
Working Group Secretary
8(): t'T 96, £,: das 000T-lS,3-616: X-e.:J
Sq)L 10, 1996
Ta: Technical Committ cc ......................................................... by FAX ( 5 pages)
from; Joel Hirsdiho111
Attached is • copy of 2 newly published article "A Needle in a Haystack., that I think can be
education•~ bec.ausc it illuttute, how explaming why positive finding~ of dioxin have been found
in a study poac1 importan.t tor.:h~ical c'hallmges tbt can, however, be resolved.
In the cue described, eome logical 111d thorough tcclmical work demonstrated convincingly to a
government agmcy that the dioxin contamination came from a noo•sitc 50urcc. In this case aerial
deposition of diox:io.s logically explained V¥by aome low level, of dioxins bad been found in
w~stewater efllucnt at a site with a landfill. The concept of analyzing specific distn'bu.tious of
diom isomers to address the origin. of dioxins is important. _:
Some of the other data in the paper are also of interest, such a& TEQ dio,an found iD pure
laboratory water and the amount deposited from the air.
There are many ubiquitous sources of dioxin in air.
60:vT 96, £l das 1,ll"'h.l .J lJ..C' I · c."11 ~ t -F;A-~
000T-2.Sl-616: xe..:1 dn□>.:19 9NI>P:J□rl 8Jd
. cover story
A Needle in a HaY-stack
Tracking down tht e/w~ve dioxin source proved to he
a chalknge at a California Air Force bast.
udt Air Force Base, near
A'"1cr it1 Ca.iifomia's Cenual
Vallq, hu been in txlnence
ainct 1941. Until rwc years
•go. when ir became l c;Midatc for do--
sun:, it 'Ml tht tnini.og eanrer fur .,, B•
52 bor11bet tnd KC-135 canker crffi•
members. Over the :-nri, fud-mait1ly
JP·•• JP·I and gs.wline-was bandied,
with ine,,fo1blc: iew •nd oca.sienal 1pilh.
Other ptoct.tse1 pct"'t111ed on the ~
included airctaft and paru deaning. vslng
nic.hlorocthyietle (TCE) aa.d med,:,l
tthyl knonc {M!K). paintinJ and siMt
recc,-c:ry. Suffic1ent TC£ entered cbe
puundwattr fot the bast to be dcd,~ a
Naciona) Priorities List (NPL) site, and
chc: TCE plume ii tutttndy being •lnrcd
cltroUJh • pump.and-neat proptm.
Castle's wan~rer, after undergoing
primary ancl seconduy crurmenr . .h.d
his10ril:aJly been spnycd over a Inch.
field, 1 pottion of which ...,..., aver a
do~d landfill.
Cutk'• f&Otffl water wa, coll~ by a
ttric, of can.II and r.liKhttge-d into a
nearby cr«k. Tht conm,.,crlon of the
canak .Alowa abou, one fooc of -,,ati:r :o
collect ln. the bonom before u sw-a to
flow off l,ue. If du c•nal11 are empty
when r,Jn begift.l, it would al<e :aboiiC
0.25 indi o( r.ain tc proYici.e euffic~ot
•ater ~ Start I f!ow off base.
Col'larn, al,ou, du pouibill')' of the
.spr.a,·cd WUltWatcr lachinlJ huardc,us
,ub,rances fr~m rl\e lu,dfilt led. to :a
change in ,he wuttwurr ditcha~ lo-
1:t f En-ri.roM•-•d PR.OTIC1'10N
,,.. ...
By Russell A. Stowe
cat.ion. It wu decided to disch.argt the
emuent inro the same creek I$ tht
tcorft'I 1''lter.
This required • modifkation to the
N,tional Pollution Oisdurgc FJunin.&•
cion SysCffll (NPDES) pcrmic. ln grant•
inr; the permit, rhc Central Valley
Pqiuri~l Water Qualiry Control Board
(J\WQC8) dircce.ed mdng tor a wide
ranae of COllUffllnanu lirred in U1¢
Inland Su.rhcr Wa~r rlaA USWP), irt-
d11ding dioxin.
Dioxin Ttstfng
The dioxin tnrinJ on the wa,;e,irm:1 ef-
fluent ~ done in Ocrober 199,. The
mulu were poaitive for two eonge11ct
groups, 130 palls pct q1&&drillion for
OCOO, and 100 pg/L fur rotal TCOD.
No 2,3,7,8 chlorinated TCOD •·u
If dioxin were
actvolly precipitating
from the air,
then it should
be fa Iii ng over
a large area,
not ;ust on base.
..
f"oul\c. On the teccmmcncbtion of the
R.WQCB, the dtlutflt ~ ccscccl 2pio1
in Januuy. Th.ii time, the level, wue
,bout h&lf tho.e in Oc«iber for the wne
lWO conscnc)i,
By chi.a time, the court h.ui m: ujck
d\c ISWP •ncl iu mncwds. However,
the RWQCB found I violatio11 of
Ptt1po1ition 65 (du: Callitlrnia Safe
Drinking Warer and ToxlCIJ E11forccmenr
Aci), which limits clloxin to 2. Spg/L,
This Nquirtd I Mrincarion of che health
board, which ih\&od , wuning Stating
the v.-atcr in the rccelvinJ crrek was a
hcal\h husrd. Th, RWQCB directed
farthe( aampling and analy,ia through•
out the wa.ft~t11:r 111tem. the fttd.,·ing
wareu and the tcotmwuer 1ynerri ro
Eincl the Mpected dioxin rourtt.
A careful rad.ing o( Prop 6S ln4k1t•
ed it appli~ only to 2,3,7,8-TCDO,
...bid, \ll'a$ llot (owad. The RWQCB in-
terpreted Prof) 6S to mean tc:rlcity
equinlcnu (TEQs). The dioxin I~
expre.ucd J,, 2,.3,7.8-TCDO equivtltnn
were well below the Prop 6, limit,
However, by this tiffte, the rc,ulcs of
sediment testing i• ,he stotm wacct
clltdlea and rr:r;ei'Ying ac-elt yirided diox-
hu. The RWQCB fth =roved there
tvas a dioxin tourCC! so ~ Otl bue
111d directed further nmpling and cle-
vclopmcnf oft. remediadon plan.
labu-Andn-1on ln~. (LA) ,..., con•
m,sed ,o develop ind implement a satn•
piing plan ro And the !OUrcie. Due CQ the:
C)(Pffl" of analyzing (or dioxin-Sl..300
~·'"
J
J
Status of PCB Landfill Sampling Plan (9/23/96)
• Selected new sampling points in addition to existing sampling points
• Temporarily eliminated three background sampling points (doesn't want this
to hold up sampling event -may be done later)
• Agreed to sampling perameters (what we'll be testing for) for all sampling
points
• Agreed to use Triangle Lab and State Lab for analytical services
• Will use two chemists from Triangle Lab to receive all of the samples
• Agreed that Patrick Barnes will code all of the samples so that the labs won't
know the identity of the sampling locations
• Established a team of personnel (i.e., health and safety, hydrogeologists,
chemists and engineers) to perform the physical sampling
• Agreed on the sampling protocol (sample under low flow conditions so won't
have to filter)
• Agreed on analytical perameters and methodology (awaiting Joel's
concurrence)
• Patrick Watters is taking 1994 sampling plan and updating it --writing it
specifically for new sampling event
• In order to implement new sampling plan, must put in new well locations --
this involves going through the RFP process to put in the new monitoring
wells --there will be a pre-bid conference for this on October 11 --hope to
have the new wells installed around the beginning of November.
·-----·-----------11RN co REC DiEDS--· .. 'IS' 211J138.2lH
To: Jom Hwechhorn
From; Thi Tedtnieal COPlmlttN
C..; August 191 1996
&UDjlet: CGl'iirma&ton Of Meetings; Au;utl 1~ M•mQ
A an••nce calf lrwofving thl Tecnic;:al CammlttM and the aci4N10t fflMCWs ha$
beef\ IChlCI.NCI for ,\uguat 21 at s:oo a.m. " m"""9 Wltft Ole tun committee ha
blon ~ fo, Auguat 27 at -4:30 p.m.
Tho Tectrical CommittN ha• recewed your August 15th memo e,tplacntng reuons f01
1he dalays 111d -.n111na tno fOUQwtng eoncerna to Whtch we "WOvtd llke
lo responcs;
1) Pt~ DIPRd The Working Gr°'4> did receive your progrua report wilh
Oltl8f ffl • ht '""'ea to ,equtre ft--cor6rnation nor f..a,adt. Since
neither 1ht Working Group not the Technical CotnmittM mtt to teepond a, a gtOllp to
YoUJ PR¥• report, feedback from en inCMtull member d the group
COUid have been mtaconstrued as being rapr....-.th,11 of the group. tn fact, one mtmblr of the g,gwp prepared • det.ltled draft reaponae in wnting on Jt.iy 23 to
,our O,ogt'NI repott but did f1Dt Nnd it prtcll8ly bec9u,ae d lhl poselbllt)' 1hat It
wtN.lld M milCOMUuect at having gone~ 1he c;ommitt8e prOONS.
The conducing paragraph d )'Qlr prograe, rapoft •nfft9 lhl emphasis concerning
the detoklflcation OICl&iOn rrcm t.c:ftnical teuibility. ,. anassment. and
I fa,lfng lanc:111 to paving or. Claprovirlg 1hat h Jatdilf is ltlklng. Your Al9J&t 151Sl
memo dOet the _,,._ However, fn nit_, ct 1982, Gowrnor ..Mm HYnt doe, not
baae ~ dMOJdficdon cc,mmltment en a felklng 1anc1t11. nor IMf\ on ~s that the
lanr:fflQ poeea to tht oomnwnlty, but on technical feasiDility. And When secntary
Hown menllonl ntkf, ft Is dear tttat he is focusing on the poeabfflty cf the liner
bt'Ndling and on poaliblt rilkt intrlnelc to h deu»cftcatfon process itaetf. risks that
ahoUld rot &lit gr.-r tnen tt101t po98d by the fm;fflft. Therefor .. if • need to
reao_.. the dlto>dftcatlOn soh.dion. it wil not t. beeauae we tailed to prow #lat Ille
lardll fl lleking. M beea\rfo • could not demonstrate a safe and,...._
tachnOlogy.
2) lectlon 4 n tt Clear from the ttatament by Secretary HCMi•• quoted '" 'PX
Augu.,t 1611 memo ( p 2, paragraph 3) Nt ,-state's commitment to detoaly is
QOIW,fngent on demonetrattng a aafe and feasible ~. not on Pf'0INt9 or ~ that the landfilt is leaking. an trterpretatfon aubsllntiated by you,· 1Ummary:
To ,um \4\. "proving or dllprovlng that the tardiU
ts lelktng .. may not ha'd bNrl imOked •• an
8JCl)lk;it req1.1remant for oetoxfflO«tiOn Of your
lancllll. tu. whe\her Of not the lanclil i8 INklng wm deflnltaty d9cide the quality, st~. and
-~ or any proposal genera11ed by the
PO!
HOd.::I vf1V17 : 0 9f36 l -03-I
flt 2.J.81382111 WRN CO RtC DEEDS
2
Working Gr°'-'> to Obtain funding for demdication.
3> A polltlcal Nelaton •• unf ... lDt• ..... of IM ••Pl"• of
GltOllt1C1tton. YOU nave noc aUt>mtned to ttte l8Chnk:id commttte11 any dflta to
SUbl&lntllte I'll ptoblble COit of ~ticn. Fld'lefm«e, the_,.
cannot and wil nol be abllraolld from tne poriticat1 hiltOrtell. anc, emptrk:41 realities
informl~ Ult frlmtlwc:lrk. Sat. and lldlniealy r..-. detoxlflcatiOn lellds
nacNMrlt/ 10 the G0¥emor11 promise. and the Gowmot't promJ" •• well a, the
rMOQnlil)li&y of the atatt and EPA '81d fllOllaarity to -,,,propriatkins1 « to a
IUtUliMd IIClvtlm of ~le Mntiment unttt the appoprtdOnl
•• Qflfflld and thl apprepiatt acoans are taken. rne ttgum.,. Nt nt Governor·• promtw b ~ =nawn1ng app,opnaaon. ancs mat
IAJfopr1IIOM are contingent ~ 1 leadling &Inell& overtooka Iha tact Chat tn~
laaue • among the most Mtortcelly lignliclnt. the moat politically embetr~ng.
end 1ftlt most P(Jllntilly ~ fOr tht Jllt. and for EPA and underelti"'8Ms
the pdllclf will ct Ille iuetice community at the toc:ef. mte and nationlll lavels to --..a that the rNOlutiOn It camp6ttt.,le with Warren County·• undet9blf"dng «
arwtronmental jUStice. The pr ... nt framework cl9arty and ~
....... undlrltlnding.
4) CrlUquea of ICO. Vour continuous Cfit6qun d ECO are not even pe,&pheral
COOlldlr•tiOnl at hi P()tnt kl the prc,caa. Dilrn"""9 anti~ the WOt1l ~ ECO su•
IIIVII ut wnn tt,e fllcl that eaQOrdlng to the ltatt's own~ ( quality analyzed and
quaaay oontrolled by h ata1t·• own lat>,) s1gn11cant concentrations or Pees
Ind dlOMl8 have been detec;lld lnlidl tl'le landfll, and 9'gnlftcant concer,c,atiana ~
dioxtnl fn MleU of fedlfal lirnilt hlW bMa, d8t8Ctlld outlida d the fatdil. But
again. the r-.onabtly,:, ttia cammlttee ia not to txMd thluies ID explain the
presence of tht dbdnl u comfng from the landJII or frcm aome ou-. ,ource auc '°
l80ltl8fn Wl'lllhef datonlCllton al tht lardlll (Jtuing « nDt leaking) WOUid be
t8Cmicdy fllli)II and to consider tld'lnk'.al fealibnly wlhn tN eotllext Cl itSk
881111fflllflt
S) .. lnttenohed" ll'ld 1111__," Thtnlrlng. Sine. detoxlioatfan is to be baaed on
mnakMnlUonl pertlinln{I to technieal NtaitJitity •m f1Sk a1181Sfflent ralher tnan on
prOW'lg OI dlaprow,g Chat lhe tlncffll ia leaklng. and SlrlCl8 the members d tf'Nt
~ Ccmmtt1M u weN • tne full commfltN are prepa,~ to reassess me
de1uxiflCatlOn IOl\llion if a safe and ,-_,.. teohno'°9Y cannot be demOnStrated. yow
rufJk1 IS)IC:Ulatlva po1Ufan ht the~ d 90ml ffi8fflbefa of Iha comrntttee Is a
function r:A "blla" and •ent,-nched thinking" wat1ld seecn to transcend ta. t,cu,ds Of
IOQic and crdlity.. Tne oammaee hu no intentlOn of IA)roving a re80k.li0n tna,
HOci.:::l H\;1517 = 0 966 l -tJC:::-I
, \.
3
lnaufflclent or unreallstlc must be attributed to a lack of understanding
concerning the atgnltlcance of the polltlcal and htstorlcilt context
Informing the negotl•tlon framework within which the commtttee le
working. t agree wfth you that the committee may have to reaasen
the detoxification solution, but I disagree with you concerning the
reason. The rea•on would not be because we failed to show that tha
landflll •• leaklng, but because we failed to demonatrate a safe and
technically feaalble method of detoxfflcatfon.
I am eager to review your report concerning technologle• and vendors.
V'JOd..:l HVL-V=O 966l -OG-l
HIRSCHHORN & ASSOCIATES
SUITE 411
2401 BLUE RIDGE A VENUE
WHEATON, MD 20902
PHONE: [phone]
FAX: [phone]
Date:_~_/ ___ j_. J_~--"Y-~_· __ Number of Pages __ _,_7-__
p :Ji, & (Including Cover Sheet)
::·-m:~_?::___:__l~Jd-·~_;;-...,._-. :1::----.:."--/~r~-~-_-_-_-_-_-_-_~~~~~~-=-
Re: --------------:-----------
tkr
r
,
HOd:::I H\7'E17 '0 9661,-0c-l
August 20, 1996
To: Technical Committee
From: Joel Hirschhorn
Subject: Response to August 19 memo from TC
l do not know exactly what has gone on, but something seems to be occm1mg that is not
consistent with the strategy and Master Plan that the Working Group previously approved.
I have not been focused on. the issue of possible leaking of the landfill. What I h.ave emphasized is
that the site investigation work, which was approved, has to be an integral part of conducting all
the work previously approved, particularly with regard to understanding 'what the requirements
for any detoxification technology would be.
It seems to me that there is an artificial division between talking about detoxification of the landfill
a.od the detoxification. of any contaminated materials that have been caused by the landfill.
Also, the need to detoxify a large amount of contaminated water from inside the landfill is a major
issue for detoxification technology evaluation. BCD technology, for example, does llOt seem to
be especially effective or efficient for water treatment.
ff the Working Group wants to rescind its previous approval of the strategy and plan, that is their
right. But members should understan.d th.e implications for major uncertainties m the conclusions
made about the feasibility an.d cost of detoxification technology. Any preliminary design and cost
estimate that this project produced would not be reliable, ifthere was no or little reliable
information on the issue of whether surrounding soil or groundwater might be contaminated
sufficiently to require detoxification.
Perhaps the Working Group should rethink everything that they have already approved. If all you
want is a report from me saying that detoxification technology does exist and that, in theory, is
feasible and could be used and might be safe and effective for treatment of the landfill's contents,
th.en that is possible.
Because '"technical feasibility" is of such importance it should be understood that this seemmgly
simple concept includes a number of considerations, such as:
detoxification performance/ effectiveness
reliability of technology/vt:.-ndor
implementability
regulatory compliance
HOcL:J H\tE17 : 0 966 I -(Jc-t
safety
Most of these have site specific aspects that must be evaluated for a determination about whetheT
a technology is good enough for all criteria to be deemed •~technically feasible". But no
professional and no governmental organization views technical feasibility without also considering
cost.
Lastly~ the reason I .have felt it necessary to bring up the ECO work is that th.ere are continuing
statements that seem to me to be based on. ECO's work, conclusions, and recommendations.
2
July 23, 1996
To: Joel Hirschhorn
From: Ken Ferruccio
Subject: Jl,lly 8th Memo (Pragress Report)
Thank you for submitting to members of the Working Group your progress report.
I have read it closely and find that severat of your statements mUSt De regarded as
having a purely specuiative status. that others are clearly inaccurate, and that the
analysis In its entirety misses the whole point concerning what the working group is
trying to accomplish as well as the purpose of the appropriations.
I am not at this time concerned about the integrity Of lack of integrity of ECO or about
the validity or Jack of validity of ECO's methodOlogy. report, and conctusionS. Nor am I
concerned about whether Pat Costner's comments and conclusions concerning the
ECO report reflected bias. Nor am I concerned about speculations that ECO was hired
to s"4')p0ft "certain beliefs or t~rs of some memoers Of the working group." Nor am I
concerned about what the state should or shouldn't have done during earlier stages of
the process. Nor is it the purpose of this committee to make detoxification contingent
on whether or not it can be proved that the landfill is teaching. I must say afso that I
have no intention of predteating the s~ific integrity of the process on the "good faith"
of state officials and scientiSts.
Now, what am I concerned about? I am concerned abOut the 1.5 million gmlons of
water threatening to breach the bOttom Hner. tam concerned that state data {quality
analyzed and quality controlled) have indicated the presence of significant
conoentrations of PCBs and dioxins in the landfill and In the leachate coflectiOn
systems; that state data have indicated the presence of dioxins in excess of federal
limitS in three of the four groundwater monitoring wells; that state data have indicated
the presence of dioxins on the surf ace of the tanclm in the area of the vent, in seepage
on the side of the landfill. and in the creek: and I am concerned about the Governor's
1982 promise to the people of Warren County that he would detoxify the landfill when
technically feasible.
And so my immediate concern is the progress you have made exploring the universe
of technologies and vendOrs because the purpose or this committee is not to spend
money provtng that the landfill is leaching or that it is not teaching, but to test
detoxification technologies for feasibility. the purpose of the appropriations to begin
with.
I would Uke now to respond to specific statements you make in your report:
Statement: .. A large part of the problem is that ECO was probably hired because of
its willingness to support certain belrefs or fears of some members of the Working
Group and, therefore. ECO did not bring to the project truly objective and unbiased
capabilities· (1 ).
OOOTlSZ:Xe_:;l
11-lOd.::J f"-1'11917 = 0 966 l -0C:-· l
2
Aesponae: This statement must be regarded as having a purely speculative status.
Statement: " [ECO} did not consider alternatives to expensive testing of spfft samples
that WOUid offer similar benefits to the community . . . (2).
Reaponee: The committee insisted on split sampting because the committee fett. and
I believe continues to feel, that the scientific integrity of the process necessitates
split sampling.
Statement:" ECO's information on alternative detoxification technologies was
incomplete and inaccurate and the logic used to recommend immediate onsite
demonstration Of BCD technology was seriousty flawed. ECO never presented the full
range or tecnnJcal and economic inf ormatlon to justjfy its recommendation, nor did it
adequately examine implementation issues for its recommendation" (2).
Reaponae: I am eager to review your report on detoxification teehnofOgtes, vendors.
and related issues mentioned in me above statement.
Statement: • ... {The state] could hav11. and should have presented more criticaf
analysis of ECO's position that the data showed that dioxins had leaked from the
landfill• (3),
Reaponee: The state geve several alternattve explanations. You impreciSety state
ECO's wording regarding the issue of leaking.
Stetement: ..... [T]he state COUid have given alternative piausibte explanations of
the findings on dioxins V (3).
Response: The state gave the committee several alternative explanations_
Statement: .. While t recognize the unusual historical nature of the project ... "(3).
Reeponae: The following statement makes it dear that you do not understand
the historical nature of this project:
. . . (l)f new data do not support a conclusion that th$ landfHI has
been leaking and contaminating the environment. then the current
detoxification solution may have to be reexamined. (4)
Reeponse. Our rationale for detoxification doea not center on a leaking
landflll but on the 1.5 mHHon gallons of water threatening to bre•ch the
bottom liner, on the technical teatlblllty of detoxification •• rel•t..-:1 to
rl•k aaeeesment, and on the promise of the governor that the lendfltl wilt
be detoxified If technlcatly feasible. The belief that •uch a rationale le
N119l7: 0 966 l -ClC.:-l
-..
1t 2U13U1'H
3
would not be in lht best inllrlilt of the .... d Warren County and ia .,_.,or•
oommitted to an open procea w~ ht prtMftt tramewon(. Havtng 6lkl that.
member• d Irle cr;:wnm.uee ao have tne rigt1t io expreN their QWT1 QDirioos •~have
done in ~ mema•nda.
The reaponlibilily al h Technk:al Commtttee. TN Working Oroup. and of al partiM
arwolWtd. inckdng the It~ adenUIII~ •• to attempt to rotoMt N crlu MChin
the 5,-pCllnl frtrneWQrk bM80 on GO\i""°' Jim Hunt's open llttlr lO Iha dtizMl:I d
W•rren County, Oc:lobef 20. 19a; or, 1tll memorand\11l to Secrcury How. May 11.
19t3; on Stcretary Hawn' --to Ken FlffUCICIO, May 21. 1993; on Socntary
How•' 1et11r to ltle p,,ople of Warren County. May a.-. 1993; and•• e,cplained tn tne
Tachniell Commm•·• memo to l'OUf AUJl.1118; and in this memo as welt. we hope that
yet, wiH help ua attempt to read\ a resolLlion 10 lht ~ wltNn tht 9Jdlting framework.
ro3
v-JOcL::! HV517'0 966l-0C::-l
Fost-lt"· brand fax transmittal memo 7oi'1
August 15~ 1996
To: The Technical Committee
From: Joel Hirschhorn
Co.
Subject: Response to Memo received from TC; progress report
Today I received by FAX the Memo that seems to be dated August 8.
Co.
Phone#
Fax#
With regard to t..lie request for a conference call, the only time of the ones provided that I can
schedule is the rooming ofWednesday August 21.
I can attend the August 27 meeting of the full Working Group.
With regard to progress reports and the delay of the report ex-pected on June 14, I offer tbe
following ex'Planation. There clearly has been a major delay in the schedule originally provided
for the lVIaster Plan implementation. In my vi.ew, this ha.s resulted from a major de.lay in what was
supposed to happen \\-1th regard to the site investigation activities. My o,vn work has been
affected by this for several reasons. First, I have had to spend significant time on the site
investigation component of the activity. Second, my view is that the original schedule was based
on th.e premise of certain activities tracking each other, especially vvi.th regard to those activities
that w~e being directed by Pat Barnes versus those I am directing. A major delay in the site
investigation work means that rny ,vork ""ill also, logically, be delayed. For me to go ahead
independently could result in large inefficient spending of .fonds. Nevertheless, I have continued
to peifonn some work on technology evaluation. I also completed the vvTiting of the Master Plan
parts I was responsible for and submitted it to Pat this past Monday morning.
I submitted a progress report and received no confirmation that it was dismouted and received,
nor any comments or feedback of any kind. While I have mamtained communication ,vith Pat and
Bill Meyer, there has been little communication with members of the Working Group.
Some other issues of a substallrive nature were also raised in your Memo that I want to respond
to. Section 4 of the Memo refers to a five-point framework that I do not recall being raised or
discussed by the Woddng Group 'with respect to the presentation and approval of the Master
Plan. The Memo included a letter by Ken Ferrucio to Johnathan Howes, in Ken's capacity as
Director of the Ecumenical/Environmental Leadership Coalition. I do not know the extent to
which the contents of this letter represents the positions of the Working Group. The other
enclosure is a letter to Ken from Howes, given as a response to Ken's letter. Since this comes
from a state official it has some significance. But I do not agree with the interpretations on some
l
key issues given in Section 4 of the Memo.
Fo:r example, the TC Memo says that "the detoxification decision is to be based on the technica]
feasibility, risk assessment, and on the fact that the landfill is filling. Detoxification is not
contingent upon proving or di~-proving that the landfill is leaking."
Here is what Howe said: ·'the State stands by its commitment to deto'-'.-i.fy the landfill once a
process is developed that 'will do so without posing a greater risk to citizens than the landfill
itself" This means that we have to know something about the risk of detoxification and the risk
posed by the landfill itself Every remedial action poses some risks. But if the Jandfill itself poses
a high(er) risk, there ·will be a sound reason to detoxify. However, the lower the risk of the
landfill itselt: the lower the justification for detoxification.
I suspect that there are some members of the Working Group who fear that the planned site
investigation work \\-ill not support their belief --based in large measure upon the incompetent
and unreliable work of the previous advisor ECO --that the landfill has leaked and contaminated
the environment . The continuing use of these past findings indicates a bias against finding out the
nuth. I also want to emphasize that the mere leaking of this or any land.fill does not describe what
risk exists. Risk= hazard x exJ>osure. Any risk assessment of health threats must be based on
closed e>..--posure pathways. That is, any toxic chemical that has leaked from the land.fill has to in
some credible way become an actual dose that people have because of ingestion, inhalation, or
. direct deml.11 contact with the chemical contaminant emanating from the landfill.
In other words, failure of any hazardous waste containment system, such as this landfill, does not
necessarJy equate to a real risk to public health. TI1ird, even if there is some plau:;ible eA-posure
route ( current or fature ), the level of risk also enters the decisionmaking. This is not the place to
go .into great detail, but let me emphasize that demonstrating significant .health risk is no trivial
matter.
To sum up , "proving or disproving that the landfi]] is leaking'' may not have been invoked as an
explicit requirement for detoxification of your laud.fill, but whether or not the landfi11 is leal<lng
will definitely dec:ide the quality, strength, and effectiveness of any proposal generated by the
Working Group to obtain .fond.in.g from the state for detoxification. As I have said previously, the
entrenched tl1inking of some members of the Working Group has been based on some key
erroneous facts. One is that a detoxification of the landfiJl would only cost a few million dollars.
Of course, if detoxification was so clleap, maybe a political rather than an enviroumenta] decision
to fund detoxification --regardless of whether the landfill is leakin.2 and regardless of whether it ~ --poses any significant health threat --might be feasible. But ANY detoxification of the landfill will
be very expensive. And v\--hen it comes to spending $25 millio.n or more~ whet.her or not the
landfill .is leaking will be very important in making the case for detoxification. The second
preferred belief of some people is that water buildup in the landfill equates to lea.lung that equates
to significant risk. This too is not necessarily correct. For example, water releases do not equate
to substantial toxic chemical releases for chemicals that are not very water soluble.
2
I will be happy to discuss these issues and any other matters of interest at the meeting on August
27.
Please provide me with confirmation as soon as possible about the phone conference call that I
can accomodate on the mo.ming of August 21 and about the meeting on the 27th.
3
I
To: The 5cc:llf'1'it Adw;ors !
From: cal Com~ ittee
Date: A 1996 !
Subject: t Commitee Meeting
2) The re eomm·
report h
tlla state'
beapp:'
/
nd the Tedhnical Committea had a conference call on Au~ 7th and
s 118C$S~ry to focus your attentiOn on the following:
' I •
work apprQv&d by the Technical Committee and the Working Group.
I
technologies and vendors that was due on June :14th. The Technfcal
not yet retj)wed this report nor an expfanatton concerning wt,y me
n submi~ed. Other due dates have not been met as weft, tt"dudlng
mllllll~tcry testl~ and the fietd sampling and testing draft wmch needs to
the WOf'kiry9 Group.
I
3) v'Jae!dy pr · ass reports based on the scope of work. You agreed to provide these
reports. TI\IS eement ccpurred two months ago, yet the Technleal Committee has
yet to rec8fve prcgr~ report based on the entir~ scope and'scneduie er work.
4} The nv
.which co
deciSiOn i
the landfil
lar.dfflt IS
an on-el
17, 1993
5) Th9 W
meet with
make rero
tt-~refore ft
meeting, p
23. Your
framework which ~.as informed the Workfng Group sir.cs 1 SS3. and
to inform h Working Group, makes it c!ear that 1the detoxification
based on: technical feasibility. nsk assessment, and on the fact 1hat
Ing. Deto1".lrication is net conttngent upon proving: or disproving that the
. The flve--tioint framework also makes it ctear that the goat Is to find
n to the ctisis (Enciosures: Memorar.dum tc Jonathan 8. 1-J.owes. Mav
from Jonathan B. Howes, May 21. 1993). ,
i
Group will hieet on August ZT. The Techn!cal Committee needs to
ore the ~Gettng bGcausa the Technical Committee needs to
,_~,tions to:the full committee. The Technical Committee would
have a confftntncs call with you the week before 1he August 27th
ly on Wadnesday, August 21; Thursday, August 22: or Friday, August
e at the ~ust 27th meeting would be appreciMed.
Enc!esurss: ~::oe of Work, Memorancum. Letter • l I
AUG 08 '96 03: 21 F'M EHf'JR · PUBLIC AFFAIRS
Author: Monica Porter <[e-mail]> at Internet
Date: 8/7/96 5:02 PM
Priority: Normal
TO: Henry Lancaster at NRDCS0lP
TO: [e-mail] at Internet
Subject: PCB Up
P.2/4
---__ .. -------------- ---- - ------- ----Message Contents - - ---------- ------------------ -------
[[ PCEl.DOC 44l5 in PCBl .DOC ]]
Enclosed is a copy of a memo to the Governor updating him on the progress of
the E>CB working Group. I need your a.ssistance on the following:
1. Please suggest corrections, additions and deletions. All additions must
be kept brief. Carolyn Coleman does not want this over two pages.
2. I need the da te when the science advisors were hired. The last
coorespondence I have stated that both parties had agreed on March 7, 1996,
and that the contract would be signed within 5 days. I need the actual
date.
./ ✓
J.. I nee:d a clean copy of the budget and the Master Plan without the other
minutes on chi.. paper. If I can get that without anyone having to retype it,
please e-mail me. Otherwise, I can ret}"Pe .
./
4. r,,,7b,at is the correct name of ECO? If those letters stand for something,
I would like tc include that information.
5. Should I add anything in this report about ECO? I believe this occurred
before June 30, 1995. If so, what? Please provide a couple of statements.
✓
6. Poes the budget reflect ECO's payment? Did they receive payment from
another pool of money?
7. Should I add anything about the RFP's? If so what? Please provide a
couple of statements.
r will send another copy before it goes to the Governor for your final
approval.
Thanks for your help.
The following binary file has been uuencoded to ensure successful
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l\t1EMORANDUM
TO :
FROM:
Governor James B. Hunt, Jr.
Carolyn Q. Coleman
Special Assistant to the Governor
DATE: 5 August 1996
RE: Joint Warren County Landfill Working Group Update
Enclosed is a brief summary of the initiatives accomplished by the Joint Warren County Landfill
'Working Group from June 30, 1995, to July 1, 1996. The working group accomplishments
included:
I. Support Staff
Ms. Doris R. Fleetwood was hired on March 18, 1996, as the pan-tjme secretary for the
Warren County/State PCB Working Group. Mr. Joel Hirschhorn and Mr. Patrick Barnes
were hired on (Note: I need the date) as the science advisors for the PCB Working
Group. Joel Hirschhorn is employed with Hirschhorn Associates located in \Vheaton,
Maryland and Patrick Barnes is employed with Barnes, Ferland and Associates, Inc.,
located in Orlando, Florida.
A joint agreement was made between the North Carolina Department of Environment,
Health and Natural Resources and the Warren County Board of Commissioners to provide
office space, furniture, equipment, supplies, conference room, kitchen, restroom facilities
and parking for the secretary and the two science advisors. The Joint Warren County
Landfill Working Group office was opened on March 25, 1996, located in the CP & L
building in Warrenton, NC.
II. :Master Plan
The science advisors developed a Master Plan for the working group denoting their
process of operation. Enclosed is a copy of the Master Plan for your perusal.
III. Recommendations from the Science Advisors:
1. The initial work that was completed by ECO was reviewed as low quality by
Joel Hirschhorn (Science Advisor). He recommended that their findings should
not be considered correct or reliable. There were patterns of incompetent,
incomplete work and bias; which was detected in 1995, by an EPA official. The
Division of Solid Waste Management (DSWM) was criticized for not presenting a
more critical analysis of ECO,s position regarding the data that showed dioxins
had leaked from the landfill, even though the working group did not accept ECO's
report. DSWM should have been more forcefully opposed to the urgent need for
arranging onsite demonstration of BCD technology. In addition, DSWM should
have corrected inaccurate cost estimates given by ECO and given alternative
plausible explanations of the finding on dioxins.
2. It ,vould be more effective to spend more money on obtaining higher quality
data about the landfill and surrounding area and less money on testing alternative
cleanup technologies.
3. Site investigation should occur testing the soil) groundwater, surface water and
sediments that ""'ill provide data on whether the landfill is leaking, whether PCB, s
or dioxins have escaped the landfill and contaminated the environment, and
whether detoxification will have to address more materials than buried in the
landfill.
4, Detoxification technologies should not be tested in an onsite demonstration as a
part of this project. Such field testing would be very expensive and not provide
sufficient data to warrant the costs. Instead, various detoxification technologies
should be carefully examined and a few companies be invited to run tests on
contaminated materials removed from the landfill, in bench-scale or pilot testing
equipment at the companies' facilities . This is projected should occur
August-September 1996.
5, A technology company should then be selected to work with the science
advisors to produce a preliminary design for the landfill cleanup.
· IV Budget
The working group was allocated $1 million by the NC General Assembly to determine if
the landfill is leaking, explore water removal and detoxification techniques. The working
group has a remaining budget of $774,765.32 (i.e., see enclosure). ·
The General Assembly attempted to take back the remainder of the one million dollars.
The money was assigned under DOT. The money was transferred from DOT and put in
Division of Solid Waste Management in a non-reverting account.
If you have questions or require specific detail on any of the listed items; please contact me.
c :LEANUP .:LEVELS ro:a
:DIOXIN
CONTAMINATED SOILS
Joel S. Hirschhorn
Hirschhorn & Associates
2401 Blueridge Ave., Suite 411
Wheaton, MD 20902
[phone]
FAX [phone]
August 1996
This paper is being submitted for publication
in a leading peer reviewed environmental journal.
Abstract
CLEANUP LEVELS FOR DIOXIN CONTAMINATED SOJLS
Joel S. Hirschhorn
Hirschhorn & Associates
2401 Blueridge Ave., Suite 411
Wheaton, MD 20902
EPA' s use of a 1 part per billion level for dioxin contamination in residential soils is shown
to be too high and not protective of public health. It was derived in a 1984 cancer risk assessment
by another federal agency, but it is inconsistent with risk-based levels of 2 to 4 parts per trillion
obtained by using EPA's risk assessment methods. EPA has called the I ppb level a policy-based
level, which correctly distinguishes it from a risk or health-based cleanup standard. The 1984
assessment is shown to have shortcomings, and its policy recommendation of using 1 ppb was not
consistent with its scientific conclusions and caveats. For over a decade dioxins have been left in
soils at levels posing health risks and sometimes that EPA is legally required to address.
Moreover, noncancer effects have been ignored, but recent work has shown them to support
action at levels much lower than 1 ppb. To protect public health and be consistent with cunent
scientific knowledge and other EPA policies new EPA policy guidance for dioxin soil cleanups is
needed, and key elements are presented.
Key words: dioxin, risk assessment, soil cleanup, Superfund
Introduction
For soil cleanup decisions at Superfund sites, EPA has used I ppb of dioxin contamination
for over a decade. At issue is whether this level is protective of public health. Although given
originally as the concentration of the most toxic dioxin isomer, it now is given as toxic equivalent
(TEQ) concentration. TEQs are obtained from using toxic equivalency factors (TEFs) for certain
dioxins and furans that convert or normalize concentrations to equivalents for the toxicity of
2,3, 7,8-tetrachlorodibenzo-p-dioxin (TCDD), which has a TEF of one.
Surprisingly, even though there has been remarkable attention to and publications on
dioxins, there has been no detailed examination of the widely used 1 ppb cleanup level. This
analysis provides new information about the scientific basis for the 1 ppb level, alternative values
obtained by using EPA's methods, new information from the Agency for Toxic Substances and
Disease Registry (ATSDR), and information on EPA's use of 1 ppb in the Superfund program
and how its use compares to other EPA policies.
1
Source of the 1 ppb value
A paper published in 1984 by Centers for Disease Control (CDC) staff presented this-
value, 1 although the figure had probably. been disseminated within government in 1983. CDC
performed a cancer risk assessment that was based on doses for 10-6 risk, and exposure doses for
residential exposure to contaminated soil. CDC said that 1 ppb was "a reasonable level at which
to begin consideration of action to limit human exposure for contaminated soil."
For Superfund decisions, a 1989 EPA memo has been cited by EPA as setting a policy of
using the 1 ppb figure as an action or health concern level. 2 The memo cited the CDC paper as
the source of the 1 ppb figure. The memo was for a particular Superfund site decision and was
not issued as EPA policy guidance. Importantly, the memo noted ''that I ppb does not represent
a fine line between safe and unsafe conditions as the term 'action level' implies." But it has been
used in exactly that way. The memo did not include EPA's 1985 health assessment for dioxins3
among the references it cited. EPA still uses the cancer potency obtained in its 1985 study.
In 1987 EPA released the results ofits National Dioxin Study,4 which included soil
contamination data for some Superfund sites, but the laboratory testing detection limit was only 1
ppb for about 75% of the sites, meaning that levels below that were largely unaccounted for, as if
they were unimportant. If dioxin TEQ levels below 1 ppb are of health significance, then rather
than using EPA's method 8280 for dioxin testing which has a generic detection limit of I ppb,
only method 8290 with one of 1 ppt is appropriate. The continued use of 1 ppb as a cleanup
standard has sometimes resulted in the less accurate laboratory method being used, leading to
unreliable data for lower dioxin levels.
EPA risk assessment
EPA has developed risk assessment procedures and established presumptive numerical
values for key parameters. EPA Region 3 issues a widely used set of risk-based concentrations,
based on 1 o-6 risk, including values for residential soil ingestion. 5 Its value for TCDD is 4 ppt.
Changes in the parameters used in risk calculations can change this value, even for what
seems as the same basic residential exposure and risk level. For example, an EPA contractor for
the Escambia Treating Company Superfund site, Pensacola, Florida, calculated a soil level of 2
ppt TEQ for residential exposure and 1 o-6 risk. This figure reflected three exposure pathways of
ingestion, inhalation, and dermal exposure, that was appropriate because soil in an adjacent
community had been contaminated by dioxin for many years. EPA's 4 ppt is for ingestion only
and is more appropriate for soils on a cleanup site. The state of Georgia publishes a value
corresponding to 4.8 ppt, following EPA risk methods, but probably with some minor change in
one or more parameters.
Another issue is exposure to other site contaminants, especially PCBs, because they are
related to dioxins in molecular structure and toxicity, but EPA has not yet determined TEFs for
2
them EPA has said that PCBs could double or triple TEQ values, and a leading dioxin expert has
said that dioxin TEQs should be doubled to accooot for contributions by PCBs. 6 Recent research
supports this view of PCBs. 7
Difference between EPA and CDC soil levels
All risk assessments use the same basic method. But they can and are used and presented
in different ways. EPA's value of 4 ppt was obtained by asking the question: what level of dioxin
contamination in soil corresponds to a 10-6 cancer risk, assuming various parameters for ingestion
from residential exposure? But CDC asked: assuming a level of 1 ppb TCDD in soil and various
exposure parameters, is this level of health concern? There are two basic components of risk
assessment: (1) determining an uptake dose from the contaminated soil, and (2) determining a 10-6
risk-based dose from toxicity data. EPA used one set of toxicity data, while CDC used that one
plus another. CDC used a range of 10-6 doses (.028 to 1.428 pg/kg-day), and the low dose came
from the toxicity data also used by EPA, but the highest doses came from the other data. The
dose range allowed a risk range to be calculated. The lowest cancer dose equated to a risk of2.3
x 10-5 for 1 ppb dioxin contamination and various exposure assumptions.
However, the lower limit dose does not correspond to the value obtained in 1985 by EPA
and still used, which was .006 pg/kg-day. This smaller dose resulted from use of a higher toxicity
or cancer potency than most of the data used by CDC. This lower EPA dose, together with
CDC's exposure assumptions, results in a risk of 1.1 x 10-4 for 1 ppb dioxin.
CDC's exposure model used assumptions to obtain uptake dose that merit attention. For
example, it assumed that the 1 ppb level might be in 100%, 10% or 1 % of soil, and that some soil
had no dioxin contamination. This is like assuming that 1 ppb is a maximum value, but not
necessarily the average level over an area. EPA data are normally average levels. CDC assumed
a 12 year half-life for TCDD in soil, meaning that exposure over decades would not be to the
initial level, but to much lower levels. Remarkably, the same CDC paper also said that ''The half-
life of TCDD in soil is not known." A brief discussion noted the degradation by ultraviolet light
required certain chemical circumstances, and that biodegradation would occur "at a very slow
rate." Although there is no consensus on soil half-life for dioxins, the best estimate is 25 to 100
years.8 CDC's assumptions lowered uptake dose and health risk.
CDC used higher ingestion rates of soil for children than EPA does, but the level for
adults was the same. Various assumptions were used for dermal and inhalation uptakes, not all of
which agree with EPA values. The overall impact of all CDC's assumptions was determined.
EPA's smaller 10-6 dose was used while maintaining the other parameters the same as CDC used.
The result is 9.4 ppt for TCDD in soil. Because this is greater than the 2 ppt obtained for a
similar multipath exposure by using EPA's procedures, all of CDC's data reduced total exposure
and dose, and therefore risk, as compared to EPA's method.
CDC concluded: ''the excess lifetime cancer risk for exposure to residential soil with a
3
peak TCDD contamination level of 1 ppb ranges over 4 orders of magnitude, from above 10-5 to
below 10-8." Over time, EPA and others have ignored CDC's risk range for 1 ppb and, especially,
that risks lower than 10-5 resulted from a cancer potency lower than that used by EPA and less
conservative exposure assumptions. IfEPA's cancer potency and exposure assumptions are used,
an average concentration of 1 ppb has a ri~k of 5 x 1 o-4, which is high. The 1 ppb level is not a
l o-6 risk based concentration. It is a value that CDC associated with a range of l o-6 risk cancer
doses, all greater than EPA' s value, and exposure conditions that in total resulted in less dioxin
uptake than with EPA's exposure parameters.
CDC's policy recommendation
The CDC statement that 1 ppb ''is a reasonable level at which to begin consideration of
action to limit human exposure for contaminated soil" was given in the paper's abstract. But in
the paper's summary, CDC said ''we have concluded that residential soil levels greater than 1 ppb
TCDD pose a level of concern." These are two very different statements. The second one was a
clear scientific conclusion that is compatible with EPA's value of 4 ppt, because it did not specify
a safe-unsafe boundary, but only an unsafe level. The abstract's statement was a policy
recommendation for government to use a 1 ppb level to decide whether or not to take action,
such as soil cleanup or relocation of residents, that EPA adopted. As the above analysis has
shown, the policy statement is inconsistent with EPA's scientific findings and risk assessment
procedures, is not fully supported by CDC's findings, and has resulted in the incorrect belief or
assertion that levels below 1 ppb are not of health concern.
111e CDC paper had other related statements, including "a soil level of l ppb TCDD in
residential areas is a reasonable level at which to express concern about health risks." ( emphasis
added) This phrase is not equal to the policy recommendation of "at which to begin consideration
of action." Another CDC statement was "Although from these calculations levels of TCDD
below 1 ppb are, for practical purposes, considered not to reach a level of concern, several
additional considerations related to the risk assessment calculations should be pointed out to
decision-makers involved in risk management." In fact, the paper had several critical caveats,
such as acknowledging "insufficient information about exposure of people to soil, and insufficient
information about intake ofTCDD by humans from such soil." Also, ''whether a certain level of
TCDD in soil will give rise to concern has to be evaluated on a case-by-case basis." No such
caveats accompanied the abstract's policy recommendation. Nor did they support use of 1 ppb as
a presumptive cleanup standard.
The CDC study had been conducted because of the highly publicized dioxin contaminated
sites in Missouri that EPA's Superfund program was addressing in a highly politicized
atmosphere. CDC was charged with determining ''what level represented an unacceptable risk to
the population living in these contaminated areas. "1 However, before the CDC risk assessment, at
the end of 1982, CDC had already issued a warning that Times Beach should be completely
evacuated on the basis of soil contamination data. In other words, CDC was asked to do what
ATSDR was subsequently created for. IfCDC had said that contamination levels below 1 ppb
4
posed a health concern, EPA's decisions on soil cleanup would have been greatly affected, and
costs would have been much higher.
There would not have been an impact on relocation, because EPA had decided in early
1983 to buyout all residents that had been supported by the CDC warning several months earlier.
The Missouri buyout was seen as an attempt by EPA to "reverse the agency's tarnished image, "9
because at the time EPA was in turmoil, under intense public scrutiny, and top political appointees
were dismissed or resigned. Later, attention shifted to soil cleanup. In 1986, Syntex attempted to
get EPA to increase the soil cleanup level from 1 ppb to 10 ppb to save 65% of cleanup costs that
it and other companies were responsible for. 5 In fact, the uncertainties and caveats in the CDC
paper could be used to support such an effort, making 1 ppb seem like a political compromise.
EPA's desire to have companies pay for Superfund cleanups has conflicted with reducing the
dioxin cleanup level below the CDC figure. In 1988 EPA used the 1 ppb level in its decision for
Superfund cleanup at Times Beach, Missouri. It set the stage for EPA's dioxin soil cleanup level
becoming policy-based rather risk or health-based.
Noncancer health effects
A recent paper by ATSDR staff addressed noncancer health effects and possible levels of
dioxins for cleanup decisions. 10 This is important, because over the past few years there has been
increasing recognition that noncancer health effects of dioxins may be more important than cancer
impacts. For example, a recent successful environmental book said "dioxin acts like a powerful
and persistent ho1mone that is capable of producing lasting effects at very low doses -doses
similar to levels found in the human population .... Dioxin and dioxinlike PCBs are known to affect
the immune system as well as many parts of the endocrine system"" The ATSDR authors noted
that "recent studies suggest that noncancer end points may be more sensitive indicators of dioxin
exposure," and derived a value of 40 ppt for chronic exposure of children, which is called an
EMEG, or environmental media evaluation guide by ATSDR. EPA has also used a childhood
only basis for noncarcinogenic soil contaminants. 12
The authors also concluded that: ''No absolutely safe exposure (i.e., above zero) can be
identified." The cancer dose-response models used by EPA and CDC (i.e., linear multistage) also
assume that even one molecule can result in cancer.13 Although a recent analysis, using EPA's
dioxin toxicity data, showed only a 10-15 cancer risk from one TCDD molecule,14 public concerns
about dioxin exposure are increasing, in large measure because of noncancer effects.
Moreover, the ATSDR authors acknowledged the need to address incremental exposures,
resulting from multiple, background, and past sources of dioxin exposures. They noted that
"ingestion of homegrown vegetables and fruit, and dermaVdust inlrnlation exposure of those
working in the garden must be considered" and that "special attention must be paid to the
exposure of children playing on contaminated soil." In other words, depending on varying
background exposures for different people in different locations, an additional exposure from a
cleanup site may be more or less important in causing new or additional health effects. Also,
5
there has been recent findings of synergistic estrogenic effects among PCBs and pesticides whlch
strongly suggest similar interactions with dioxins. 15 All such conditions "suggest the need to
further lower the TCDD levels in soil in order to lower the total exposure," according to the
ATSDR authors. They recommended that although the 1 ppb level "may be appropriate guidance
value ... to the extent that parameters of exposure and/or human factors would suggest the
existence of at risk or vulnerable population groups, alternative values such as these outlined in
this paper should be considered."
The 1995 ATSDR Public Health Assessment for the Escambia site used an EMEG of 50
ppt for dioxin TEQ in soil. But ATSDR said ''The levels of dioxin-TEQ in off-site soil are
unlikely to cause noncarcinogenic health effects." even though the report gave the maximum level
of 950 ppt from 1992 testing. The report also said ''Because the cancer risk in people from
exposure to dioxin-TEQ is currently under scientific review, we do not know what carcinogenic
health effects are likely." But the uncompleted EPA dioxin reassessment did not nullify the EPA
cancer risk information that EPA itself has continued to use, including for the Escambia site. The
50 ppt value was ignored by EPA, which only focused on cancer risks and the I ppb level. Thls
author knows of no Superfund site where EPA has used noncancer effects of dioxin to set or
influence cleanup levels or other actions, such as relocation of residents.
Background levels and incremental risks
There is a critical need at Superfund sites to determine the local backgrolllld level of
dioxins in soils and the level of dioxins in blood lipids in people plausibly exposed to site dioxins,
especially when contamination is found in residential soils. Backgrolllld data se1ve two purposes.
One is to decide whether soil contamination is significant. The other to determine whether an
exposed population has prior or multiple exposures. TI1ere is no scientific support for dismissing
dioxin contamination below I ppb as merely background concentrations, an approach often used
by EPA, unless data are obtained from control samples at some distance from the site. Using data
from locations near a cleanup site or on it, which is sometimes done, provide overly high levels
that are not true background levels. Higher than normal background soil and blood levels for an
exposed population provide the basis for lower dioxin cleanup levels, either on the Superfw1d site
or offsite, or both.
Background soil levels of dioxins in North America vary widely, from 2.26 to 13.66 ppt
TEQ, according to EPA.16 Thls range is not surprising, because some geographical areas, even at
significant distances from point sources, have been impacted by air deposition of dioxin
conta1ninated particles from waste incineration, industrial manufacturing, and other sources.
Also, EPA assumed nondetects equal to half the detection limit, which is EPA's procedure for
risk assessment, 17 but is not necessarily used when data are reported. A study on dioxin
background exposures in the United States assumed only a . 96 ppt TCDD soil level, compared to
EPA's average of 8 ppt TEQ.
The background level issue and paying attention to multiple exposures to dioxin were
6
examined in a 1985 EPA analysis that focused on findings of dioxin soil contamination in
Midland, Michigan, where Dow Chemical operated a plant that had produced pesticide chemicals
having dioxin contamination and incinerated chemical wastes. 18 The EPA risk assessor argued
that 1 ppb was probably not appropriate to evaluate the findings. EPA's data showed the average
level of TCDD (TEFs were not set until 1989) to be 48 ppt in Midland residential and public
access soils, as compared to 2.4 ppt in Middleton, Ohio, a comparable industrial city. The
average level around the perimeter of the Dow Chemical plant was 327 ppt, compared to 2.2 ppt
around a steel mill in Middleton. Dow Chemical had obtained its own data on soil levels in a
number of industrial cities and reported an average of2.2 ppt. The EPA risk assessor argued that
the Midland levels were not normal background levels, and were especially significant because
many residents had been exposed as workers at the Dow Chemical plant, that people had been
exposed to soil and air dioxins for decades because of release from the facility, and that they had
eaten homegrown vegetables and fish from a local river that were probably contaminated by
dioxins.
Here was a specific case where site specific circumstances showed the need to see levels
below 1 ppb as of health concern, and to use a lower level for cleanup and relocation decisions.
Like the Missouri situation, here too there was a political dimension, because in early 1983 t4ere
was a controversy involving a senior EPA official, forced to resign, based in patt on actions that
allowed Dow Chemical to affect EPA's decisions on dioxin contamination in Michigan.8 lt is
clear that the Missomi and Midland cases were the precedents fo r EPA's use of the 1 ppb level as
a policy-based figure.
EPA's actions for the Escambia site in Pensacola also illustrate problems related to
background levels. In 1995 soil sampling was done in the residential community close to the
Escambia site, part of which is adjacent to the Escambia site and part a little more distant and
even closer to another Superuud site (Agrico Chemical). Samples were also taken from four
areas outside tl1is immediate community but only slightly further away. EPA has acknowledged
levels of dioxin contamination of health concern only in a small portion adjacent to the Escambia
site, where the average level was 587 ppt TEQ, but where several locations had levels above I
ppb. The area a little further away from the Escambia site had an average of 70 ppt, and the next
more distance area 7.3 ppt. In the neighborhood closer to the other Superfund site, that is more
distant from the Escambia site, the average was 12.4 ppt. For the four areas outside the
residential community, a school yard had 7 ppt, a baseball field 7.5 ppt, a vacant lot 22.7 ppt, and
a residential yard 7.8 ppt.
EPA's position was that all the areas, except the one adjacent to the Escambia site (where
the I ppb level was exceeded) did not pose health risks and that they had not been impacted by
the Escambia site. No data were obtained, however, to determine background levels in the
Pensacola area. Nearly all dioxin levels were above the 2 ppt determined for residential exposure
and 10-6 risk, including two areas where children spent time (the baseball field and school). lt
should also be noted that some residents were exposed as workers at the former Escabia
operation, that the dioxin contamination of the residential soil had initially occurred many years
7
before the site entered the Superfund program, that an EPA removal action that excavated an
enormous amount of contaminated soil and piled it on the site had probably caused some releases
of dioxin, that soils were contaminated by several other highly toxic chemicals, and there were
pervasive health problems in the community. Thus, the issue of incremental dioxin risk was
relevant as evidenced by an ATSDR Health Consultation for the Escambia site prepared in 1992
and its review by the A TSDR Health Activities Recommendation Panel. Because of "likely"
worker exposures at the operating wood treating company and because "off-site exposures may
have occurred," the panel recommended a health evaluation of residents living the site. It was to
include physical examinations and laboratory tests. These were not implemented, however. The
testing for dioxin in blood lipids would have provided important data regarding past exposures to
dioxin among residents.
A recent study revealed the proper use of offsite control soil samples to obtain
background levels. 19 Interestingly, the average background TEQ level was higher than the
cleanup site's level, and both were very low (less than 3 ppt). The background levels were
explained as resulting from the impacts of traffic on a major highway on an otherwise rural area.
The data supported the conclusion that the cleanup site was not contaminated by dioxins.
Prospective ve.-sus retrospective exposures
Dioxin risk assessment work has focused on prospective residential exposures and
whether residual soil levels after cleanup would pose unacceptable health risks. Oddly, however,
in many cases dioxin contamination is found in residential soils where people have already been
exposed to the levels found. While the prospective approach is valid for cleanup sites themselves,
that might become residential areas, the retrospective approach accounts for additional
incremental dioxin risk for dioxin contaminated residential areas with exposed populations.
CDC's work for Missouri was such a situation, yet its analysis was only prospective.
Instead of using a half-life to calculate lower dioxin levels for future exposures, it should have
worked backwards to obtain higher levels for the people exposed to the soil in the past. As in the
Missouri, Midland, and Pensacola cases, for many situations the retrospective approach is
necessary, and even EPA's levels of 2 to 4 ppt are not necessarily protective when additional
incremental dioxin risk is considered.
Consistency with cleanup levels for other site contaminants
At most Superfund sites, soil contaminants are designated as Contaminants of Concern,
and EPA sets cleanup levels as preliminary or final remediation goals. In many cases, these are
based on 1 o-6 risk and residential exposure. In those cases, when dioxins are also site
contaminants, the issue arises as how EPA can use 1 ppb when according to EPA's own risk
numbers the 10-6 risk is 2 to 4 ppt. Reasonable people question how the government can use the
10-6 risk level for every toxic chemical except dioxin, that EPA acknowledges to be the most toxic
chemical. Moreover, if some soil with up to 1 ppb dioxin remains after cleanup, then residual
8
risks are 10·4, negating the benefit of cleaning up the other contaminants to 1 o·6 risk levels.
EPA soil screening values
EPA has established generic soil screening levels for 110 chemicals, for use in the
Superfund program. 10 These are based on 10-6 risk and residential soil ingestion exposure. They
can serve as preliminary or final remediation goals, unless site specific information is used to
support other levels. But no value was presented for dioxin. The explanation from EPA is that a
policy decision had already selected 1 ppb, and that EPA's dioxin reassessment is ongoing.
EPA's use of the 1 ppb level
A good example of the current problem is an EPA study in 1995 that tested residential
area surface soils in a small town, Tifton, Georgia, with a number of toxic waste sites. EPA
dismissed the findings of dioxin in all 14 samples solely on the basis that they were below 1 ppb. 20
This author's analysis of the data found that the sample locations could be divided into three
groups, based on distance away from the Marzone/Chevron Superfund site. It was found that the
5 residential soil samples closest to the site ( about a quarter mile or less) had an average dioxin
TEQ level of 65.2 ppt (with a maximum of 120 ppt). For the three locations further away the
average was 5.9 ppt. For the 6 locations about one-half to a mile away the average was 2.6 ppt.
However, the detection limits were unusually high for the 8290 method, suggesting systematic
underestimates of TEQ dioxin. This was compounded by the procedure of ignoring all
noudetects. EPA guidance is to use onehalf the detection limit. Correcting the data resulted in
TEQs for the three zones given above of 66.8, 14.4 and 10.5 ppt, with increasing distance from
the Superfund site. This is strong evidence that dioxins had migrated from the site into the
smTounding community by means of airborne transport of dioxin contaminated soil particles (from
the cleanup site or from the original industrial operation at that site). The corrected TEQs,
moreover, indicate levels of health concern at all distances from the cleanup site.
Although ATSDR reviewed the data for EPA, it simply said that the levels found were
below health concern, without providing any explanation or analysis, and ignored the EMEG of
40 ppt for noncancer effects, exceeded at three locations near the site. No problems with the data
were noted. Neither EPA or ATSDR noted, at the time the study report was released, that no
testing of dioxins had ever taken place at the two toxic waste sites fitting categories known to
likely have dioxin contamination (pesticide and wood treating sites).
Subsequently, when testing showed widespread dioxin contamination at the
Marzoue/Chevron site, where EPA had previously established pesticide cleanup levels for I o·6 risk
from residential exposure, EPA attempted to dismiss all findings below I ppb, choosing to focus
on one area with levels well above I ppb (maximum of 3 ppb ). For these test results ouehalf
detection limits were used for nondetects. The position that dioxin contamination in the main
former pesticide factory surface soil was just background, and not a result of pesticides, was
inconsistent with the average level of 45 ppt TEQ (maximum of276 ppt), findings of dioxin in
9
subsurface soil (greater than surface soil levels) and chemical storage tank contents, and the lack
of measuring background TEQ in the Tifton area. Where subsurface dioxin levels were
substantially greater than in surface soils, levels of site pesticides were also correspondingly
greater than in surface soils, providing additional support for concluding that dioxin
contamination was caused by some pesticides handled at the site.
In 1996, EPA Region 4 conducted an analysis of dioxin cleanup levels at Superfund sites
(unpublished). Over 12 years, 20 sites used the 1 ppb level, and 6 used levels greater than 1 ppb
and 7 less than it. In three cases the cleanup levels were low, between 4 to 7 ppt, at about the
10-6 risk level. Nevertheless, EPA officials often state that it would set a dangerous precedent if a
value less than 1 ppb was used. The "danger" is economic, namely that a lower cleanup or action
level increases the costs of cleanups and relocations, and might affect decisions ah-eady made and
cause more cleanup. New residential areas built on soil previously cleaned up to 1 ppb would be
vulnerable.
Legally, it is clear that the I ppb value is, at best, only guidance, but it was never issued by
EPA as guidance. At various times EPA has stated that the 1 ppb level is an action level, a
screening level, and a level of health concern. It is not, however, a rigid cleanup standard having
statutory or regulatory standing. Yet as concerns about Superfund costs, funding and liabilities
have increased, EPA's desire to impose the 1 ppb level has increased. The 1989 EPA memo bad
cited the important caveats of the 1984 CDC paper about making decisions on the basis of site
specific circumstances. A 1992 EPA memo on the strategy to be used in the Superfund program
for addressing information from the agency's dioxin reassessment made no mention of the
program's use of 1 ppb.21 Ways in which decisions could be reopened were presented and a
commitment was made to ''use the best science available in making its decisions." But the proper
policy statements by EPA have not resulted in retrenchment from EPA's use of 1 ppb as the
presumptive dioxin cleanup standard. Only a few Superfund site decisions have used lower levels,
and they were not major sites.
Data on other types of cleanup sites, federal and state, are difficult to obtain. But a
cleanup at the Naval Seabees Center, Gulfpoint, Mississippi, used a dioxin cleanup level of 5 ppt
to remove contaminated soil with about 100 ppt dioxins. And the state of Florida is using a 7 ppt
level for a 1 o-6 risk and asking that it be used for the cleanup of the Coleman-Evans Wood
Preserving Superfund site. If a state has some type of standard, requirement or criterion for a
lower dioxin cleanup level, than EPA can be compelled by statute to use it.
Legal violation
The 1 ppb level corresponds to a risk over 10-4 according to EPA's risk data. Under the
federal National Contingency Plan (NCP) governing the Superfund program, such risks require
EPA action. There is some confusion over what current risk requires EPA action versusfuture
risk and cleanup goals, because of the NCP's risk range of 10-4 to 10-6. But NCP language, EPA
guidance, and recent General Accounting Office reports made it clear that current risks above 10-4
require EPA action,22 usually by taking a removal or emergency action, or an interim remedial
action. EPA does not have to achieve future residual risks of 10-6, but under the NCP if it does
not it must explain why. Usually, the reason is non-residential exposure. Using EPA's figure of 4
ppt, l 0-4 risk equates to a soil level of 400 ppt ( appropriate for cleanup site soils), and using 2 ppt
it is 200 ppt (appropriate for residential soils). In other words, when data reveal levels above
these, EPA is legally required to take action. Conversely, when EPA ignores levels below I ppb
and above these lower levels, it is not complying with the NCP.
At the Escambia, Pensacola site in 1992, after EPA had completed a removal action that
consisted of a massive excavation of contaminated soil to protect groundwater, it tested soil in a
few residential backyards immediately over the site's fenceline and found dioxin, ranging from 34
to 950 ppt TEQ with an average of 316 ppt. It used a sample for background very near these
locations and on the Escambia site itself that had 14 ppt. Three years later, EPA obtained more
dioxin data showing even higher levels in residential soils (average of 587 ppt TEQ and maximum
of 3 ppb in the area closest to the site). Four years after the original evidence of dioxin
contamination in the residential area, EPA had not taken any action, such as soil removal, soil
covering, or relocation of residents to protect public health against risks greater than 1 o-4. The
residents were not helped by ATSDR's Public Health Assessment in 1995 that raised no concerns
about dioxin.
Treatment technology
It is also relevant that in 1994 EPA established universal treatment standards as part of its
land disposal restrictions program under the 1984 Hazardous and Solid Waste Amendments. The
treatment standard for TCDD is I ppb, which apparently was taken from the policy-based level of
l ppb for cleanups. This standard can be applied to technologies used to detoxify dioxin
contaminated soil. It provides a disincentive for achieving lower levels. It also suggests problems
because ofland disposal of soils with dioxins at lower concentrations that pose health threats.
EPA's original concerns in the 1980s about cleanup costs, especially if treatment
technology such as incineration was used, are less warranted today. There are more technologies
than ever, including BCD dechlorination developed by EPA and licensed to several companies
that have commercialized it, a Canadian technology that destroys dioxins, and several commercial
solvent separation technologies.23 It is possible to achieve residual levels to low ppt levels.
Increasing competition has reduced unit costs. People concerned about dioxin exposure have
learned about these newer technologies.
Dioxin cleanup and risk management policy
Since the mid-l 980s EPA has used an increasingly inconsistent and technically indefensible
basis for decisions about dioxin contaminated soil. The I ppb level was based on a risk
assessment by CDC that bad deficiencies and to some extent misrepresented its results to present
a simple policy decision rule with enormous economic implications. There was considerable
11
demand for that dioxin cleanup level in the mid-l 980s. Now, however, there is no credible
scientific, health based, or logical defense for using the 1 ppb figure. The translation of CDC's
risk assessment results into a Superfund action level and EPA' s initial uses of it occuned during
the aftermath of the 1983 backlash against the environmental policies of the Reagan
Administration. But many senior EPA managers still believed in those policies, and they
established a policy-based dioxin cleanup standard that has prevailed.
Changing to a scientifically credible health-based dioxin cleanup level has been seen by
subsequent EPA managers as threatening. Rather than focusing on health risks, they manage
bureaucratic risks. Lower dioxin soil cleanup levels could result in demands to reopen past
cleanup decisions that in combination with more stringent cleanup decisions would require higher
federal appropriations for the Superfund program at a time when they are being decreased. Yet
this problem only worsens with time as more decisions are based on 1 ppb. Concerns about
cleanup costs are valid, especially by government officials, but using l ppb that poses health risks
as a solution is not viable public policy.
Another concern of EPA managers is that use of a lower dioxin cleanup level could affect
regulatory permitting and public acceptance of various industrial and waste management facilities.
Titis raises a conflict between protection of public health and concerns about impacts on sources
of dioxin, such as industrial and municipal waste incinerators. As Silbergard and deFur observed,
"much of the continuing delay by government 111 implementing comprehensive management of
[dioxin] risk arises not only from scientific uncertainty but also from the politics and economics of
controlling specific dioxin sources."
An attractive delay strategy for Superfund managers is waiting for EPA's final dioxin
reassessment, because it is commonly understood it will take years to complete. Their risk
management means letting successors inherit this problem. The final report is not likely to
remove the fundamental problems with the I ppb level. The dioxin soil cleanup issue has been
successfully kept at the Superfund program level, allowing EPA to ignore its inconsistencies with
larger agency goals and commitments. EPA's continuing use of 1 ppb, however, undennines its
goals of using good science, common sense, and risk management to improve decisions and
public confidence. Ultimately, there are institutional risks and penalties that can only be
minimized by taking the initiative to conect the dioxin cleanup problem. Ironically, the 1 ppb
level was a consequence of an EPA crisis in 1983 and it could precipitate another one.
EPA's inability to retreat from the 1 ppb level reveals more than bureaucratic ine1tia,
however. Over the past decade a climate of bureaucratic loyalty has emerged. It intimidates
lower level Superfund site managers and prevents them from departing from the "company line"
by using lower dioxin levels for cleanup and relocation decisions. This is difficult because as
front-line managers they get the demands from angry people for more effective dioxin testing and
cleanups and for relocation ofresidents. Defending EPA's 1 ppb is increasingly difficult.
12
Public perceptions
Policy aside, use of 1 ppb, rather than 2 or 4 ppt based on EPA risk methods, can only be
logically interpreted as either EPA rejecting its own risk assessment methods and results, or EPA
acting as if a dioxin cancer risk greater than 10-4 is acceptable, which violates the law. When
cleanup levels for other contaminants are set on the basis of 10-6 risk, either by means of risk
assessment or use of EPA's soil screening levels, use of 1 ppb is even more untenable. How can
EPA defend using its risk numbers for all chemicals except the more toxic dioxins?
Use of 1 ppb erodes public confidence in risk assessment, as revealed by advice given to
community groups addressing dioxin cleanup sites: "It doesn't matter if the risk level is one-in-a-
million, one in-one-hundred thousand, or one-ten thousand. [N]o amount of additional exposure
is acceptable and a risk assessment approach that attempts to define a negligible or acceptable risk
is irrelevant. "24
The public, now well informed ( some would say inflamed) about dioxin also knows that
noncancer health effects are now probably more significant than cancer, particularly if synergistic
interactions with pesticides and PCBs occur. For noncancer effects, ATSDR staff have shown
that dioxin levels much lower than 1 ppb are appropriate. All the available scientific information
support using low ppt dioxin TEQ for cleanup and relocation decisions. The scientific community
has sent a clear message that there is no safe level of dioxin exposure. The ubiquitous presence of
dioxins should cause cleanup decisions to recognize other exposures, not to dismiss levels of
dioxin below 1 ppb because "dioxin is everywhere." EPA's use of 1 ppb literally adds insult to
lllJUry.
Conclusion
This risk, historical, and policy analysis provides support for new EPA Superfund
guidance that specifies the 2 and 4 ppt levels for residential and cleanup site soils, but permits use
of different dioxin TEQ levels if they are supported by site specific infonnation. The guidance
should clarify that chronic health effects other than cancer should be considered, that past and
other sources of dioxin and PCB exposures should be accow1ted for, that control samples should
be used to detenniue background levels, that EPA method 8290 should be routinely used, and
that non-detects should be converted to onehalf their actual method detection limits to calculate
TEQs. The guidance should also clarify what types of sites should be tested for dioxins in soils,
because cases have arisen where either no dioxin testing was performed or where the testing was
performed very late in the Superfund process, even though site information supported dioxin
testing. EPA could also provide a framework for evaluating past decisions and whether there are
grounds for reexamining them
13
References
1. R. D. Kimbrough et ai Health Implications of2,3,7,8-Tetrachlorodibenzodioxin (TCDD)
Contamination of Residential Soil, J. Tox. and Env. Health, v.14, pp.47-93, 1984.
2. EPA, memo by J. Winston Porter, head of the Superfund program, to Barry Johnson, head of
ATSDR, Jan. 26, 1989.
3. EPA, Health Assessment Document for Polychlorinated Dibenzo-p-Dioxins, EPA/600/8-
84/014F, 1985.
4. EPA, National Dioxin Study, EPA/530-SW-87-025, 1987.
5. EPA Region 3, Risk-Based Concentration Table, April 19, 1996; Internet at
http://www.epa.gov/reg3hwmd/riskmenu.htm?=Risk+Guidance.
6. L. M. Gibbs, Dying From Dioxin, South End Press, Boston, 1995. pp.39,42,8.
7. U. Jarnberg et al, Polychlorinated byphenyls and polychlorinated napthalenes in Swedish
sediment and biota: Levels, patterns, and time trends, Env. Sci. Tech., v.27, pp.1364-1374, 1993 .
8. D. J. Paustenbach et al, Recent developments on the hazards posed by 2,3,7,8-
tetrachlorodibenzo-p-dioxin in soil: implications for setting risk-based cleanup levels at residential
and industrial sites, J. Tox. Env. Health, v.36, pp.103-149.
9. A O'M. Bowman, Epilogue, in The Politics of Hazardous Waste Management, J.P. Lester
and A O'M. Bowman, eds., Duke Univ. Press., 1983, p.253.
10. H. Pohl et al, Public Health Assessment For Dioxins Exposure From Soil, Chemosphere,
v.31, pp.2437-2454, 1995.
I 1. T. Colborn et al, Our Stolen Future, Dutton, New York, 1996, pp. 120, 181.
12. EPA, Soil Screening Guidance: Technical Background Document, EPA/540/R-95/128, May
1996.
13. E. K. Silbergard and P. L. deFur, Risk Assessment ofDioxinlike Compounds, in Dioxins and
Health, A Schecter, ed., pp.51-78, Plenum Press, 1994.
14 . S. E. Hrudey and D. Krewski, Is There a Safe Level of Exposure to a Carcinogen?, Env. Sci.
Tech., v.29, pp.370A-375A, 1995.
15. S. F. Arnold et ai Synergistic Activation of Estrogen Receptor with Combinations of
Environmental Chemicals, Science, v.272, pp.1489-1492, June 7, 1996; S. S. Simons, Jr.,
Environmental Estrogens: Can Two "Alrights" Make a Wrong?, p.1451; J. Kaiser, New Yeast
Study Finds Strengths in Numbers, p.1418.
14
16. EPA, Estimating Exposure to Dioxin-Like Compounds, Vol. 1: Executive Summary, Draft,
EPA/600/6-88/005Ca, 1994.
17. S. B. Floit et al, Evaluation of the Use of Substitution Methods to Represent Nondetect Data,
in Superfund Risk Assessment in Soil Contamination Studies: Second Volume, ASTM STP 1264,
K Hoddinott, ed., Amer. Soc. for Testing and Materials, 1996, pp.70-83.
18. EPA Region 5, memo from J. Milton Clark, Health Effects Specialist, to George A Jones,
Chief, Superfund Implementation Group, July 30, 1995.
19. G. R. Nemeth et al, Background Determination of Element and Anthropogenic Compounds
in Soils of the Maryland Coastal Plain, in Superfund Risk Assessment in Soil Contamination
Studies: Second Volume, ASTM STP 1264, K. Hoddinott, ed., Amer. Soc. for Testing and
Materials, 1996, pp.3-18.
20. EPA Region 4, South Tifton Residential Area Investigation Report, Tifton, Georgia, Sept.
1995.
21. EPA, memo by D. Clay, head Superfund program, to EPA Administrator, Feb. 27, 1992.
22. GAO, Superfund -Information on Current Health Risks, GAO/R.CED-95-205, 1995;
Superfund -Improved Reviews and Guidance Could Reduce Inconsistencies in Risk Assessments,
GAO/RCED-94-220, 1994.
23. EPA, Superfund Innovative Technology Evaluation Program-Technology Profiles Seventh
Edition, EPA/540/R-94/526, 1994.
24. S. Lester, Risk Assessment and Dioxin, Everyone's Backyard, v.14, n.2, pp.24-26, 1996.
15
~c_._l/{A
,r.-µ 5
Joint Warren County/State PCB Landfill Working Group
draft July 23, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:45 P.M. Wednesday, July 23, 1997. The meeting was held at the office of the Working
Group and was called to order by co-chair Henry Lancaster.
UNFINISHED BUSINESS
Discuss implications of new Secretary for DEHNR
Mr. Lancaster informed the Working Group that he met with the new Secretary, Wayne McDevitt,
who will be sworn in on August 1; Secretary McDevitt(the Secretary) said that he wishes to do no
department business until that time. Mr. Lancaster advised that he believes that the Secretary 1s
going to favor citizen involvement and that he is committed to detoxification.
Jim Warren made a motion to ask the Secretary to endorse the process that the Working Group has
already established . The motion was seconded and carried. A letter is to be sent to the Secretary
asking for his endorsement of the process previously agreed upon for the reconstitution of the
Working Group.
Reports and Recommendations regarding sampling and testing
Patrick Barnes presented a draft table of contents for the site investigation report. (See Attachment)
He said that the reason for the site investigation was to lend support to the process and to find out
what is in the landfill. Because of this investigation, we have found that:
1) dioxins are outside the landfill,
2) water is entering the landfill, and
3) PCBs have been released into the air.
Mr. Barnes added that a formal report is at least a month away and that it must be very
comprehensive.
Ken Ferruccio said that dioxin was found in two of the monitoring wells, Mr. Barnes said that well
5D has the most toxic form of dioxin; he added that the well was put at this location because if there
were any leakage, that well 5D would be the most logical place for it to occur.
Joel Hirschhorn added that the dioxin found in well 5D is not characteristic of dioxins found in PCBs,
what is in well 5D is very unusual. Mr. Lancaster asked if it matched anything found in the landfill.
Both Science Advisors replied no.
draft July 23, 1997 Meeting Minutes
Page2
Mr. Fenuccio asked the Science Advisors if they were satisfied with the chain of custody for the soil
delivered to Eco Logic and ETG for the bench-scale study. Mr. Hirschhorn advised that Eco Logic
had infonned him that the seals were broken on the materials they received and that they believed it
happened during transportation.
Mr. Barnes added that the companies may not be sure they could pen down the cost going from
bench-scale to full-scale detoxification. Deborah Ferruccio asked when the companies are looking
at cost, will they have to look at the characteristics of the materials to be detoxified. The
characteristics of the material are important, but the volume of the material that needs to be detoxified
is the most critical information they will need, said Mr. Hirschhorn.
Ms. Fenuccio asked ifwe know the chemical makeup of the material brought from Fort Bragg. Mike
Kelly advised that the State did not sample the soils from Fort Bragg. Discussion followed, it was
agreed by consensus that the Science Advisors and the Working Group would request information
on the composition of the soils sent from Fort Bragg. Mr. Hirschhorn agreed to draft this letter.
Air testing was discussed next. Mr. Hirschhorn advised that there were only a few positive results,
but with an aged landfill you would not expect to have a lot of positive air tests, but bursts of PCB
emissions. He added that we have a lot of information fitting the position that the landfill lacks
integrity. Bobbie Riley added that the testing was done during cold weather and one would expect
the burst of PCB emissions to be more prevalent during hot weather. Ms. Ferruccio said PCB air
emissions over the years is a serious health threat. Mr. Hirschhorn added that emissions would be
expected to be higher in the past and declining over the years.
Next, Mr. Hirschhorn questioned the integrity of the report from Soil and Materials Engineering
(S&ME), saying that there are serious deficiencies in the report. S&ME was contacted by Mr.
Hirschhorn and was advised that there were drafts of the report. He asked the State to provide
copies of the draft and of their comments made to S&ME. Discussion followed. After which, Mr.
Kelly agreed to provide copies of the draft report and copies of the comments made by the State.
Report from tlte Tecltnical Committee
Mr. Warren advised that the Technical Committee recommends that the Working Group formally
requests a copy of any compliance order issued to the State. The motion was seconded and carried.
Mr. Kelly advised that he contacted the Science Advisors, provided them with a list of tasks that need
to be completed and asked how much would each task cost. After comment from the Science
Advisors it was decided, by the State Office of Purchasing and Contracts, to divide the remaining
funding between the Science Advisors for specific tasks. Ms. Burwell added that any issues that
involve funding should be directed to the executive committee.
'
Pilot Studies
draft July 23, 1997 Meeting Minutes
Page 3
Mr. Hirschhorn advised that the pilot studies are complete and that we are waiting for the analytical
data. He· suggested that we should have the completed reports by mid to late August. Mr. Kelly
advised that he has spoken with both companies. Eco Logic said their report would be complete in
about two weeks and ETG has already started to send some data and their report should be complete
by August 8.
Next, said Mr. Hirschhorn, will be selecting one company for phase two. Mr. Lancaster asked if the
criteria for making this decision has been decided. Discussion followed. It was agreed that the
Science Advisors will develop the criteria, present it to the Working Group and then they, the State
and the Science Advisors, will make the decision. It was decided by consensus that if there is no
agreement, the Science Advisors are to contact the office to schedule a conference call with the
Technical Committee, Science Advisors and the State.
Mr. Kelly advised that a technology company, Taylor, Inc., has asked if they could have some
material to test their process. They advised Mr. Kelly that they would do all of the testing free of
charge. Mr. Kelly advised that they have a patented process that leaves ammonia and chloride as
residuals. After discussion the Working Group authorized Mr. Kelly to advise any companies that
contact him that the process is closed.
ADJOURNMENT
The meeting was adjourned at 9:20 p.m .. The next meeting will be dependent upon the completion
of the final reports from the Science Advisors.
rcn LANDFILL
SITE INVESTIGATION REPORT
l.O BACKGROUND
1.1 Introduction
1.2 Goals and Objective ·
1.3 Investigation Approach
2.0 FILE REVIEW .
2.1 Monitoring and Reporting Compliance
2.1. l Past Analytical Results
2.2 Landfill Design
2.2. l Liner System
2.2.2 Leachate Collection System
2.2.3 Site Hydrology
4.0 FIELD INVESTIGATION PLAN l'ROCEDURES
95-017
TOC.doc
3.1 Off-site Activities
3.1.1 Monitoring Well Placement
3.1.2 Monitoring Well Design and Construction
3.1.3 Surface Wnlcr Sampling
3.1.4 Sediment Sampling
3.1.5 Surface Soil Sampling
3.1.6 Air Monitoring
3.2 Facility Testing Activities
3.2.1 Landfill Content
3.2.2 Leachate Samples
3.2.3 Sediment Basin and Substrate Samples
3 .2.4 Sand and Carbon Filtration Bed
3.3 Top Liner Integrity
3.4 Landfill Waler Extraction Wells
3. 5 Quality Assurance/Control Procedures
3.6 Analytes and Analytical Methods
PCB LAND FILL
SITE INVESTIGATION REPORT
(Continued)
4.0 ANALYSIS OF FIELD TESTING RESULTS
4.1 Site Geologic Setting
4.1. l Strata Distribution
4.1.2 Soil Permeability and Groundwater Flow
4.2 Water Quality Characteristics
4.2. l Groundwater
4.2.2 Surface Water
4.3 • Surface Soil and Stream Sediment Characteristics
4.3. l Surface Soil Adjacent to Facility
4.3 .2 Stream Sediment
4.4 Air Quality Analysis
4.4.1 On-site
4.4.2 Off-site
4.5 Landfill Facility
4.5. l Leachate
4.5.2 Contents
4.5 .3 Treatment System ·
4.5.4 Physical Characteristics of Wastes
4.5.5 Entrined Water Quantity
5.0 CONCLUSIONS
5. I Discharge Potential
5.2 Off-Site Environmental Impacts
5.3 Waste Characteristics and Site Setting
6.0 RECOMMENDATIONS
6.1 Immediate Measures (60 -90 Days)
6.2 Long Term (l to 2 Years)
95-017 -11-
TOC.doc
PCB LANDFILL
SITE INVESTIGATION REPORT
(Continued)
TABLES
2.1 Past Analytical Results Summary
3. I New Sample Location and Analysis
4.1 Summary of Field Permeabilities
4.2 Summary of Field Parameters
4.3 Analytical PCB Results Summary
4.4 Analytical Dioxin Results Summary
4.5 Analytical BN/AE Results Summary
4.6 Analytical Metals Results Summary
I.I
1.2
1.3
2.1
2.2
2.3
3. I
3.2
3.3
r :.4
~.5
3.6
4.1
4.2
4.3
4.4
Location Map
Site Map
Master Plan Flow Chart
Facility Map (Prior to Field Work)
Facility Design
Hydrograph
Major Flow Paths
New Sample Network
Air Monitoring Network
Off-Site (Background) Wells~
Generic Monitoring Well Design
Extraction Wells
FIGURES
Lithologic Cross Sections A-A',~
Lithologic Cross Sections ~•, B-B'
Water Table Contour Map ~
Depth to Rock Contour Map
APPENDICES
I. PCB , BNAE and VOC Analytical Results
2. Dioxin/Furon
3. Liner Evaluation Report
4. Air Monitoring Analysis
5. Monitoring Well Installation Report
95-017 -111-
TOC.doc
Joint Warren County/State PCB Landfill Working Group
draft July 10, 1996 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called
to order at 4:40 P.M. Wednesday, July 10, 1996 at the Warren County PCB Landfill Office by co-
chair Mr. Ken Ferruccio. A generic agenda was distributed. Mr. Ferruccio had prepared an
agenda that was not available for distribution.
READING AND APPROVAL OF MINUTES
Ms. Deborah Ferruccio moved that the minutes from the June 20, 1996 meeting be approved. The
motion was seconded and carried.
REPORTS
Mr. Bill Meyer reported from the meeting with the Science Advisors. He reported that they
reviewed the sampling and analysis plan. They discussed the location of additional monitoring
wells, on-site and off-site; sediment samples; surface-water sampling; and background sampling
stations. Mr. Meyer advised that Mr. Barnes is working on a draft schedule for these activities
which is due on July 17, 1996. If the Division, Mr. Barnes, and Mr. Hirschhorn agree, this draft
will be completed and given to the Working Group. A meeting will be scheduled at that time.
Ms. Ferruccio asked the purpose of off-site monitoring wells (wells). Mr. Meyer said that the
wells would determine the background concentrations of chemicals that are not influenced by the
landfill. This information would provide a basis to compare the ground-water around the landfill
to other locations in Warren County. Ms. Ferruccio voiced concern with the wells; she stated
that if the wells show dioxins away from the landfill that data may be used against the effort to
detoxify the landfill. She questioned if this information helps in the effort to detoxify the landfill
or does it just prove whether the landfill is leaking. Ms. Burwell then said that after reading the
press release she felt as though the focus had turned away from getting the landfill detoxified to
proving that it is leaking. After discussion the Working Group decided not to use the press
release at this time. The Technical Committee, along with the co-chairs, would write another
press release.
Next, Ms. Williamson gave an update on several issues. She advised that the fax machine had
been ordered and would be delivered in approximately three (3) weeks. Ms. Williamson also
advised that the C P & L lines and poles are in and the transformers would be installed when
power needs are determined. Lastly, she advised that the names of the youth representatives
along with a new address for Rev. Leon White were included with the list given Ms. Fleetwood.
Ms. Fleetwood agreed and advised that the youth on the list were all seniors this past school year.
It was suggested that Ms. Naomi Allen be contacted to give new names for appointment.
I -••
draft July 10, 1996 Working Group Minutes
Page 2
A report was given on the Technical Committee's conference call with the Science Advisors.
During this conference call, because of the concerns with the status of the master plan, the
Division proposed a meeting with the Science Advisors. This meeting was scheduled for July 3,
1996. A report of that meeting was given earlier by Mr. Meyer. The Technical Committee asked
the Science Advisors to prepare a weekly informal report stating what they have been working on.
The Science Advisors agreed. The Technical Committee advised that at the last Working Group
meeting the topic of Public Relations (PR) was discussed and the Working Group decided that PR
should be handled by the Science Advisors. Mr. Hirschhorn volunteered to handle the writing of
a press release. During this conference call, the subject of on-site demonstration was broached.
The Committee decided that an on-site demonstration was too expensive and the bench-scale
study would be used. Mr. Meyer said that there are two (2) biotechnology companies in North
Carolina and asked if they were viable for this site. Mr. Hirschhorn advised that bioremediation is
not very successful with complicated sites. Mr. Warren added that whatever is decided, it must
be able to be sold to the General Assembly.
NEW BUSINESS
Ms. Ferruccio advised that Warren County had been given a $19,000.00 grant from the US EPA
for use by the PCB Working Group. She advised that she had received a packet of information
confirming the grant and nothing else. She said that she had tried to contact the project officer
and still she got nowhere. Ms. Ferruccio thought that if this were handled by a city official more
information could be obtained and the grant funding released to the Working Group. Ms. Burwell
advised that she would talk to the project officer and would find out how we could work it in the
Working Group so the funds could be managed by our office.
Next, a letter from Ms. Billie Elmore was read regarding insufficient notification of regular
Working Group meetings and no notification of Technical Committee meetings. Ms. Burwell
suggested that a letter be sent or a phone call made to Ms. Elmore to explain that meetings over
the next several months will be sporadic. When time permits, she will be given the requested 14
days notice and 30 days notice. Ms. Elmore stated in her letter that she had discussed her
concerns with Mr. Warren about insufficient notice and asked him to relay this to the Working
Group.
Last, Mr. Cooper provided the Working Group with a budget of how the Working Group monies
are being spent and asked Mr. Meyer to comment. Mr. Meyer stated the Working Group is
paying full salary for a part-time secretary and full building maintenance, not a prorated share.
Mr. Cooper advised that the contract stated that the State would contribute $25,000.00 and
would be provided with a part-time secretary, provide supplies, and would help with the building
maintenance and that is what the State is getting. Mr. Meyer advised that he has asked to be
removed from the responsibilities of the contract, because he did not participate in the
-I ' ,
draft July 10, 1996 Working Group Minutes
Page 3
negotiations, does not know what was told to the County about how the monies would be used or
what was agreed upon. After more discussion it was decided that Ms. Porter would get copies of
the contract, and review the contract and report her findings to the Working Group.
ADJOURNMENT
The meeting was adjourned at 6:10 P. M. by Mr. Ferruccio. No date was set for the next
meeting.
Doris R. Fleetwood
Warren County/State PCB
Working Group Secretary
07/11/1995 12:04 4071:1'3E,:l 822 PAGE D1
BFA Environmental Consultants
Barnes, Ferland and Associates, Inc.
MEMORANDUM BFA #95-0J 7
TO:
FROM:
COPIES:
PCB Landfill Working Group
(Technology Group) fi
Patrick A Barnes, P. G
Science Advisor I .
Joel Hirschhorn
DATE July 9, 1996
SUBJECT: Project Status Report
/
Ptione#
On July 1st I had a detailed conversation with Senator Frank Ballance about the status of the PCB
Landfill. The Senator was very appreciative of the update and indicated that the situation was
still on his radar screen. We set a tentative meeting date for the founh week in July to discuss
specifics. I recommend that key members of the Working Group be present
Related to the Supplemental Field Sampling and Testing Plan I have petfonned the following:
• Coordinated sarnple locations with the State.
• Obtained and reviewed cost infom,ation from analytical laboratories.
• Analyzed information on the site's hydrogeology.
• Developed a conceptuaJ model of the groundwater flow system in preparation for July 3rd
meeting with the State.
Both Joel Hirschhorn and I attended the July 3rd meeting with State technical staff personnel to
discuss the proposed Supplemental Field Sampling and Testing Plan,
In general, discussions centered around the following topics:
• Inadequacy of the prevous work performed:
• Number and location of monitoring wells near the landfill and in the draws_
• The need for and proposed locations of additional surface water and sediment sarnples.
• Number and location of background monitoring wells.
• Criteria for determining clustered locati.ons.
• Type of ana.lysis for the difierent matrices to be tested.
• Pros and Cons of split sampling.
• The need to justify all testing efforts and costs.
• Responsibility and time table for plan development.
Formal meeting minutes will be prepared by the State_
The Hollister Building· 3535 Lawton Road• Suite 111 • Orlando, Florida 32803
Office [phone] • Fax (407) 896·-1822
Joint Meeting of PCB Landfill Science Advisors and State Staff
July 3, 1996
Raleigh, North Carolina
PCB Landfill science advisors Joel Hirschhorn and Patrick Barnes met with
Division of Waste Management staff on July 3, 1996, at 10 am in conference room 3 at
the division office in Raleigh. The purpose of the meeting was to discuss the sampling
plan for the PCB Landfill.
Present for the meeting were Joel Hirschhorn, Patrick Barnes, Bill Meyer,
Sharron Rogers, Pat Williamson, Larry Rose (hydrogeological technician), and three
geologists with the division--Bob Glaser, Pete Doorn, and Grover Nicholson.
At the beginning of the meeting, Mr. Hirschhorn said that he had reviewed the
information on the sampling event in July 1994, as well as the report prepared by Ms.
Pauline Ewald, head of ECO, and the subsequent letters criticizing her report. He said
he wanted all details handled before the upcoming site investigation is conducted to
prevent mistakes of the past from occurring again. He suggested a detailed report on
all decisions and the basis for those decisions be developed and presented to the PCB
Working Group.
Mr. Meyer proposed doing the sampling in phases. He said he had to be able to
defend the sampling, both technically and economically, to the General Assembly. He
felt that if the first round of sampling indicated a leak, then he could defend the need
for additional samp~· on a te~nical and economic basis. ,.,JO,, ,,,.itJJ .u~ ffi_
-~~. • • ~~at.,~~ ~~ ~ee o pu ~~~ng wells adjacent to 4Cb.., ~
the landfill plus one hydropunch at the seep located in the northwest comer of the ~
landfill, one well near the head of each of four draws leading from the landfill (four ~ ·
wells total unless nested), and three background monitoring wells. Mr. Hirschhorn
suggested that the three background monitoring wells be located one to two miles from
the landfill at the following locations: one in the northwest quadrant across Richneck
Creek; one in the southwest quadrant on property owned by the county; and one in the
northeast quadrant.
Mr. Barnes agreed to draft a new sampling document by July 17 based upon the
revisions agreed to by the group. This will include a new map showing the sampling
points. Mr. Hirschhorn suggested that the revised monitoring/ sampling document
should be jointly signed by the science advisors and the state. The science advisors
and the state will contribute specific parts of this detailed report. When the document
., . '
is complete and signed, it will be presented to the PCB Working Group for approval.
The group approved Mr. Hirschhorn's suggestion.
The group also agreed on the following:
that any laboratory results would be sent simultaneously to the
science advisors and the state
that Triangle Lab in the Research Triangle Park would conduct the
testing for dioxin/furans by the 8290 method
that samples sent to the State Laboratory of Public Health for analysis
would be "blind" with only general descriptions such as sediment,
water, etc.
that Mr. Barnes will be on the site during the sampling event
that Mr. Barnes will have the "key" to the laboratory samples
that there will be no split samples
-that sediment and surface water samples will be tested for PCBs and
dioxin only
that there will be
1 trip blank every other day of sampling (water)
3 equipment blanks (water)
1 soil blank
1 surface water sediment blank to be analyzed only if there is a hit
1 hydropunch (soil)
4 sediment samples
5 surface water samples
3 background monitoring well samples (groundwater)
15-19 groundwater samples from monitoring wells e.-dja:cent to th€
~-
soil samples from borings (monitoring wells) adjacent to the
landfill (Patrick will discuss with Bill to determine number)
Mr. Meyer said he would
check with the state lab for detection limits for PCBs + /-10 ppt
-talk to lab personnel regarding the routine detection limits for
organics
-prepare an analysis chart.
Conclusion
A detailed sampling/monitoring plan for the PCB Landfill, including
justifications for decisions regarding this plan, will be prepared and signed by the
science advisors and the state, and then presented to the PCB Working Group for
approval.
6-2:3-1996 3 ,57At.-1 FROM
Appendix for technology RFP
EXPLANATION OF SELECTION OF 1WO DETOXIFICATION TECBNOWGIES
A detailed tech.n.ology screening, evaluation, assessment and comparative analysis has been
performed for the Warren County PCB Landfill. All but two treatment technologies were
screened out. Ouly Base Catalyzed Deco.q>osition (BCD) and Gas Phase Chemical Reduction
technology were found to be appropriate and potentially feasible.
The original use of the term detoxification technology by the state of North Carolina implies that
technologies that are considered cleanup or remedial technologies but that do not by themse.lves
detoxify PCBs are not appropriate for the Warren County situation. Potential feasibility has had
to be demonstrated through prior successful full scale use of a technology for PCB detoxification
work.
All forms of containment technology such as caps and subsurface banier walls have been ruled
out as being inappropriate.
All foJIDs of separation technologies that do not actually detoxify through treatment have been ·
ruled out. These include, for example, thermal desorption, solvent extraction, soil washing, and
soil vapor extraction.
All forms of stabilization/solidification have been eliminated as inappropriate~ because they Jiave
not been thoroughly prnven. to actually and permanently destroy PCB molecules, rendering them
pennanently nontoxic.
Any use of high temperature incineration has been ruled out as being inappropriate because of its
potential for causing harmful toxic air emissions and its long history of being deemed
unacceptable by communities, especially when used in locations close to residential areas.
AU forms ofb.iotreatment or bioremcdiation have been screened out on the basis of insufficit,nt
proven effectiveness. For many years various forms ofbiotreatment have been pursued for PCB
cleanups. The conclusion has been reached that biotreatment .is not yet proven effective and
reliable enough for full scale use either as an in situ or ex situ technology, in aerobic or anaerobic
form or some combinatfo.o. of them, for the Warren County application ..
Jn situ vitrification has been screened out because of insufficient full scale application. Thjs
technology has been under extensive developtne11t for many years, chiefly mthin the DOE systern.
While soroe people have viewed this technology as a variant of incineration, chiefly because it
employs very high temperatures. it usually is considered as a unique technology. Buried wastes
can be heated to melt all materials and form a vitreous or glassy material. The process thennally
destroys organic contaminants and an extensive olfgas, air pollution control system is used.
Interestiugly, in October 1995 EPA granted Geosafe a National TSCA Operating Permit for the
I
Pa
6-2 3-1996 3 ,57AM
_.I .. "
FROM
nationwide treatment of PCBs within a large number of prescribed circumstances, including
maximwn average concentrations of 14,700 ppm md maximum hot spot concentrations of 17,860
ppm. The company obtained this regulatory permit on the basis of a site demonstration that
achieved various perfonnance criteria, including six .nines destruction. and removal efficiency and
less than 2 ppm .PCBs in vitrified product. No detectable dioxins/fun.o.s were found in offgases.
But the demonstration was not on in situ wastes similar to the Warren County sjtuation. This
technology must be considered detoxification, and it offers the comparative advantage of being
intrinsically applicable fo,: in situ treatment, avoiding the need for excavatio.n of materials. In
theory, the technology could be applied directly to the Warren County Landfill, perhaps ~ithout
dewatering the site, although the site's location would pose significant problem for using the
exten.sive equipment. The conclusion has been reached that this technology is not acceptable or
feasible for the Warr en County application, and that it could not be suitably evaluated through
bench-scale testing.
Because the objective is to select a detoxification technology that has already been proven
effective for PCB detoxification through full scale, commercial use, and tha1 will be demonstrated
effective for full scale application at the Wanen County PCB Landfill on the basis of bench-scale
testing of site contaminated soils, no technology that has not yet been fully deployed in a full scale
detoxification of PCB wastes will be considered appropriate and potentially effective for this
application. No technology that exists only as a research or developmental technology is deemed
appropriate and potentially feasible for this application and, therefore, for bench-scale testing.
2
P.5
. ..... ' -
• ,I
• ~ .. ... • I ■..._,..-._ • t~ I• ~ I
---irVIrUKIAl~T REASONS FOR CHANGING
CURRENT STRATEGY
• Field Testing of Small Amounts of Site Waste will not
Provide Information that is more Useful than Bench-Scale
Testing
• Costs of Two Field Tests Woufd be Extremely High
• It is Necessary to Examine Other Detoxification
Technologies
,
• Current Approach Would not Provide Sufficient Detailed
Information
• A Much Stronger Case for Funding can be Made by
Spending Money on More Thorough Site Investigation
and Remedy Design
KEY STEPS OF RECOMMENDED
ALTERNATIVE STRATEGY
• Detailed Evaluation of Detoxification Technologies and
Vendors
• Initiate Site Investigation
• Design Soil/Waste Removal Plan/Select Vendor
• Issue Feasibility Study Report
• Invite Vendors to Conduct Bench-Scale Treatability Tests
• Science Advisors Evaluate Test Results and Select/Rank
Vendors
KEY STEPS OF RECOMMENDED
ALTERNATIVE STRATEGY
(Continued)
• Finalize Site Investigation Report
• Working Group Meeting with Highest Ranked Vendors
• Best Technology Vendor Selected/Pre-Qualified for Actual
Cleanup
• Selected Vendor is Hired as Design Contractor (Under
Current Funding)
• Remedy Selection and Remedial Design Report
• Report used as the Basis for Working Group/DEHNR
formally Proposing the Landfill Detoxification Project to
the State Legislature to Obtain Funding
·. . ' ' .. '. . ' -. >-
SITE INVESTIGATION GOALS
• Establish Condition of Liner
• Bedrock Condition and Topography
• Transmissivity of Weathered Rock Zone
• Direction of Groundwater Flow
• Identification of Contaminant Plume
• Types and Amounts of Contaminated Media Reguiring
Clean-Up
SITE INVESTIGATION ACTIVITIES
• Collection of Samples to Conform with Permit
Requirements
• Analyze Existing Data
• Develop and Implement Field Sampling and Testing Plan
• Non-Intrusive Testing (Geophysics)
• Soil Borings
• Installation of Additional Monitoring Wells
• Collection of Additional Surface Water and Sediment
Samples
•.. · . ' . . . . . . . ·.. ·-. ·.1
MASTER PLAN
PURPOSE
• Guidance Document
• Road Map
• Operational Document
• Stand Alone
PLAN CONTENTS
• Introduction and Background
• Project Goals and Objectives
• Approach for Evaluating Technologies and Selecting
Remedy
• Approach for Performing Site Investigation
• Legislative Funding
• Project Schedule
PCB LANDFILL IMPACT ASSESSMENT
AND DETOXIFICATION
MASTER PLAN
PRELIMINARY TABLE OF CONTENTS
1.0 INTRODUCTION AND BACKGROUND
1. 1 Site History
1.2 The Working Group
1.3 The Role of the State
1.4 The Role of the Science Advisors
2.0 PROJECT GOALS AND OBJECTIVES
3.0
95-017.00
2.1 Mission Statement
2.1.1 Impact Assessment
2.1.2 Detoxification
2.1.3 Community Involvement
2.1.4 Responsibility of the Working Group
DEVELOPMENT OF FEASIBILITY AND REMEDY SELECTION REPORT
3.1 Detoxification Technology and Vendor Evaluation
3.1.1 Review of Past and Current Approach
3.1.2 Comparative Analysis
3.1.3 Recommendations
3.1.4 Work Plan for Treatability Testing
3.2 Landfill Soil/Waste Removal Plan
3.2.1 Review of Current Approach
3.2.2 Soil/Waste Removal and Vendor Selection Procedure
3.2.3 Testing Requirements
3.3 Treatability Testing
3.3.1 Bench Scale Testing Results
3.3 .2 Analysis of Data
3.3.3 Recommendations
3.4 Remedy Selection
3.4.1 Effectiveness/Performance
3.4.2 Safety/Environmental Impacts
3.4.3 Cost
3.4.4 Comparative Analysis and Recommendations
3.4.5 Role and Responsibility of the Working Group
3.5 Procedure for Establishment of Remedial Goals
3.5.1 Evaluation of Test Results
3.5.2 Ranking Procedure
3.5.3 Performance Standards
3.5.4 Responsibility of Working Group
3.6 Procedure for Selecting and Awarding Detoxification Design Contract
-1-
MPTOC.DOC
3.6.1 Role of Science Advisors
3.6.2 Role of the Working Group
3.6.3 Role of the State
4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
4.1 Site Investigation
4. 1.1 Review of Past Sampling and Analysis
4.1.2 Field Sampling and Testing Plan
4.2 Landfill Integrity
4.2.1 Leachate Collection System
4.2.2 Liner Condition
4.2.3 Water in Landfill
4.3 Scope of Off-Site Impact
4.3.1 Soil
4. 3. 2 Groundwater
4.3.3 Surface Water
4.3.4 Sediment
4.3.5 Air
4.4 Contaminant/Waste Releases
4.4.1 Fate and Transport
4.5 Estimates of Volumes Requiring Remediation
5.0 REMEDIAL DESIGN
5 .1 Roles of Technology Vendor, Science Advisors/ST ATE
5 .2 Site Layout and Logistics
5. 3 Construction Phasing
5 .4 Health and Safety Concerns
5. 5 Impact Monitoring
5.6 Detoxification Field Pilot Test
5. 7 Preliminary Design and Operation Plan
5. 8 Clean-up Cost Estimates
6.0 LEGISLATIVE FUNDING
6.1 Briefing Document
6.2 Presentation Procedure and Materials
6.2.1 Role of Working Group
6.2.2 Role of Science Advisors
6.2.3 Role of the State
7.0 PROJECT SCHEDULE
95-017.00 -2-
MPTOC.DOC
ACTIVITIES/TARGET DATE 1. Master Plan Development 2. Detox. Tech & Vendor Evaluation 3. Site Investigation 4. Soil/Waste Removal 5. Treatability Testing 6. Feasibility Study 7. Remedial Goals 6. Vendor Screening & Awarding Of Detoxification Contract 9. Site Investigation Report I 0. Remedial Design/Remedy Selec. Rpt. 11. Legislative Fundin 0 Report Submitted to Working Group/State PCB Landfill Master Plan Implementation Schedule MONTHLY Jul Au ~ ~~~ ~ ~-Se Oct .. ·~ Nov Dec. 96 ~~-~;-~~~s. 9 Technical Memorandum (Procedure Document) Submitted To Working Group/State 0 Technical Specifications Submitted To Working Group/State PLAN1.XLS Jan-97 Feb Mar Apr
I
ATTENDANCE AT WARREN COUNTY PCB WORKING GROUP
MEETING
DATE: ap;u__i d;-1 ;qCJ&:
i
... ,,
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James 8. Hunt, Jr., Governor
Jonathan 8. Howes, Secretary
William L. Meyer, Director
April 1, 1996
MEMORANDUM:
TO: Patrick Barnes, Science Advisor
Barnes, Freeland & Associates
THRU:
FROM:
Joel Hirschhorn, Science Advisor
Hirschhorn and Associates
Bill MeyeriW\
Dollie Burwell
Ken F erruccio
Henry Lancaster
SUBJECT: Assignment from Working Group for Development of PCB Landfill Detoxification
Project Master Plan
The Working Group has directed the Science Advisor to develop a PCB Landfill
detoxification master plan as defined in the Scope of Work incorporated under Task 1.
Task 1 includes four elements with fourteen (14) subdivisions. Certain elements may have
a higher priority than others. Some may need to be modified, based upon your recommendations,
by the Working Group. Element four requires the Science Advisors to draft or outline all tasks
and processes with milestones, scheduling, and budgets for all elements for consideration by the
Working Group. This includes development of the master plan. The Working Group requests
that either an outline of the master plan with times, milestones or schedules be submitted within
two weeks; or, that the full master plan be submitted within thirty days. The Working Group
requests notification of which option the Science Advisors select within two days of receipt of this
request.
The Division of Solid Waste Management will provide the Science Advisors with a copy
of all information and documents from the first meeting of the Working Group up to the present
time. A copy will also be provided for the file in the office of the Warren County Working Group
and Science Advisors. In the future, all information and documents on the detoxification project
will be provided to the Science Advisors as well as the file in the Warren County office.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
April I, 1996
Page2
The Working Group has hired a Secretary who will serve as a contact for the Working
Group and ensure that your needs are responded to in an effective and timely manner. The
Working Group has also established a Technical Committee for review of your work and to make
recommendations to the full Working Group.
The Working Group welcomes the Science Advisors and looks forward to a good
working partnership that focuses on our goal to detoxify the PCB Landfill in a timely manner.
,r •
Joint Warren County/State PCB Landfill Working Group
April 25, 1996 Meeting Minutes .J UL 18 1996
The regular meeting of the Joint Warren County/State PCB Landfill Working Group·:wa:s--~all~4 -~ _· -·
to order at 4:28 P.M. on Thursday, April 25, 1996. The meeting was held at the Warren County
Office of the Working Group and was called to order by Mr. Ken Ferruccio. The meeting was
co-chaired by Ms. Daria Holcomb, Mr. Ken Ferruccio, and Mr. Henry Lancaster. The generic
agenda was distributed.
READING AND APPROVAL OF MINUTES
It was suggested by Ms. Priscilla Tyree that minutes from February 22, March 7, and March 28
meetings be approved. Co-chair Mr. Ken Ferruccio disregarded the suggestion to approve the
minutes from the last three meetings.
UNFINISHED BUSINESS
None.
NEW BUSINESS
Mr. Joel Hirschhorn introduced the Master Planning Project. He began by discussing the
Important Reasons for Changing Current Strategy. They are as follows:
1) Field testing of small amounts of site waste will not provide information
that is more useful then bench-scale testing;
2) Costs of two field tests would be extremely high;
3) It is necessary to examine other detoxification technologies;
4) Current approach would not provide sufficient detailed information; and
5) A much stronger case for funding can be made by spending money on
more thorough site investigation and remedy design.
Next, Mr. Hirschhorn discussed the Key Steps of Recommended Alternative Strategy. They are
summarized below:
1 ) Detailed evaluation of detoxification technologies and vendors;
2 ) Initiate site investigation;
3 ) Design soil/waste removal plan/select vendor;
4 ) Issue feasibility study report;
5 ) Invite vendors to conduct bench-scale treatability tests;
6 ) Science advisors evaluate test results and select/rank vendors;
7 ) Finalize site investigation report;
8) Working group meeting with highest ranked vendors;
9 ) Best technology vendor selected/pre-qualified for actual clean-up;
10) Selected vendor is hired as design contractor (under current funding);
11) Remedy selection and remedial design report; and
12) Report used as the basis for Working Group/DEHNR formally
proposing the landfill detoxification project to the State Legislature
to obtain funding.
,r •
April 25, 1996 Working Group Minutes
Page 2
Mr. Hirschhorn advised that after all information has been gathered this approach will provide
the state with the information needed to provide funding of the detoxification project without
needing additional tests preformed. Mr. Hirschhorn then asked for questions, then the meeting
was turned over to Science Advisor, Patrick Barnes. Mr. Barnes continued with the Master
Planning Project, starting with Site Investigation Goals, the reasons for additional testing and
they are as follows:
1) Establish conditions of liner;
2) Bedrock condition and topography;
3) Transmissivity of weathered rock zone;
4) Direction of ground water flow;
5) Identification of contaminant plume; and
6) Types and amounts of contaminated media requiring clean-up.
Next, Mr. Barnes discussed Site Investigation Activities, what steps would be necessary and
they are summarized below:
1) Collection of samples to conform with permit requirements;
2) Analyze existing data;
3) Develop and implement field sampling and testing plan;
4) Non-intrusive testing (Geophysics);
5) Soil borings;
6) Installation of additional monitoring wells;. and
7) Collec~ion of additional surface water and sediment samples.
Lastly, Mr. Barnes introduced the Master Plan: its purpose, its contents, and its implementation
schedule.
The purpose of the Master Plan is to serve as a
1) Guidance document;
2) Road map;
3) Operation document; and
4) Stand alone document.
The Master Plan contents are outlined below:
PREL™INARY TABLE OF CONTENTS
1.0 INTRODUCTION AND BACKGROUND
1.1 Site History
1.2 The Working Group
1.3 The Role of the State
1. 4 The Role of the Science Advisors
., •
April 25, 1996 Working Group Minutes
Page 3
2.0 . PROJECT GOALS AND OBJECTIVES
2.1 Mission Statement
2.1 .1 Impact Assessment
2.1.2 Detoxification
2.1.3 Community Involvement
2.1. 4 Responsibility of the Working Group
3.0 DEVELOPMENT OF FEASIBILITY AND REMEDY SELECTION REPORT
3 .1 Detoxification Technology and Vendor Evaluation
3 .1.1 Review of Past and Current Approach
3 .1 .2 Comparative Analysis
3 .1. 3 Recommendations
3.1.4 Work Plan for Treatability Testing
3.2 Landfill Soil/Waste Removal Plan
3 .2.1 Review of Current Approach
3.2.2 Soil/Waste Removal and Vendor Selection Procedure
3.2.3 Testing Requirements
3.3 Treatability Testing
3.3.1 Bench Scale Testing Results
3.3.2 Analysis ofData
3.3.3 Recommendations
3 .4 Remedy Selection
3. 4 .1 Effectiveness/Performance
3. 4. 2 Safety/Environmental Impacts
3.4.3 Cost
3.4.4 Comparative Analysis and Recommendations
3.4.5 Role and Responsibility of the Working Group
3.5 Procedure for Establishment of Remedial Goals
3.5.1 Evaluation of Test Results
3.5.2 Ranking Procedure
3.5.3 Performance Standards
3.5.4 Responsibility of Working Group
3.6 Procedure for Selecting and Awarding Detoxification Design
Contract
3.6.1 Role of Science Advisors
3.6.2 Role of Working Group
3 .6.3 Role of State
4.0 DEVELOPMENT OF SITE INVESTIGATION REPORT
4 .1 Site Investigation
4.1.1 Review of Past Sampling and Analysis
4.1.2 Field Sampling and Testing Plan
4.2 Landfill Integrity
4.2.1 Leachate Collection System
4.2.2 Liner Condition
4.2.3 Water in Landfill
4.3 Scope of Off-Site Impact
4.3 .1 Soil
4.3 .2 Groundwater
4.3 .3 Surface Water
4 .3 .4 Sediment
4.3 .5 Air
4. 4 Contaminant/Waste Releases
4.4.1 Fate and Transport
4. 5 Estimates of Volumes Requiring Remediation
5.0 REMEDIALDESIGN
April 25, 1996 Working Group Minutes
Page 4
5 .1 Roles of Technology Vendors, Science Advisors/State
5.2 Site Layout and Logistics
5.3 Construction Phasing
5.4 Health and Safety Concerns
5. 5 Impact Monitoring
5.6 Detoxification Field Pilot Test
5. 7 Preliminary Design and Operation Plan
5.8 Clean-up Cost Estimates
6.0 LEGISLATIVE FUNDING
6.1 Briefing Document
6.2 Presentation Procedure and Materials
6.2.1 Role ofWorking Group
6.2.2 Role of Science Advisors
6.2.3 Role of State
7.0 PROJECT SCHEDULE
Below is listed the Master Plan Implementation Schedule.
ACTIVITIES
1 ) Master Plan development
2) Detoxification TechnologyNendor Evaluation
3 ) Site Investigation
TARGET DATE
May 15
June 15
August 15
4) Soil/Waste Removal
5) ,Treatability Testing
6) -'Feasibility Study
7 ) Remedial Goals
8) Vendor Screening & Awarding of
Detoxification Contract
9 ) Site Investigation
10) Remedial Design/Remedy Selection Report
11) Legislative Funding
April 25, 1996 Working Group Minutes
Page 5
June 15
August 15
September 15
October 15
November 30
December 15
December 31
April30
Questions were asked by Messrs. L. C. Cooper and Ken Ferruccio, and Misses Deborah
Ferruccio and Daria Holcomb. Mr. L. C. Cooper moved to accept the Master Plan. The
motion was seconded and carried, Ms. Daria Holcomb opposed the motion.
Mr. Joel Hirschhorn asked if it were possible that a smaller number of people could be contacted
when they were in need of a quick response. After discussion, it was moved and seconded that
the Technology Group would be responsible for working directly with the Science Advisors
when time is short. It was moved and passed that the Technology Group would meet with the
chairs of Working Group to choose a Chairperson for this the Technology Group.
ADJOURNMENT
The meeting was adjourned by Co-Chair, Mr. Ken Ferruccio at 5:55 P.M .. The date of the next
meeting is Thursday, June 20, 1996 at 4:30 P.M ..
D~s R. Fleetwood
Warren County/State PCB
Working Group Secretary
P.1/1
State of North Carolina
Deportment of Environment,
Health and Natural Resources
Legislative & Intergovernmental Affairs NA
James 8. Hunt. Jr .. Governor
Jonathan B. Howes. Secretary DEHNR
Henry M. Lancaster 11, Director
MEMORANDUM
TO:
FROM:
Alfreda Jordan-Webb, County Manager
Warren County, NC
Henry M Loncaster, II, Co-Chair ~1/~
SUBJECT: Warren County/State Joint PCB Landfill Working Group• Oericol Support
20 February 1996 DATE:
The Co-Chairs asked that I convey their concerns and our joint opinion that four issues be
covered as part of the pending interview process related to hiril)g a clerical support person for
the Working Group.
1. The job candidates should be asked about their experience and ability to take
and prepare minutes of meetings. Absolute transcription is not required, but,
accuracy is important.
2. Job candidates should be asked about their experience and ability to type
technical or scientific data in various formats and layouts.
3. Job candidates should also have some degree of familiarity with accessing the
infonnation highway via personal computers.
4. · Job candidates must understand that they will provide clerical support services
to the Working Group for a maximum of twenty hours a week and thus must be
able to manage their time wisely and stick to priorities. There will be a need for
the clerical support person to work directly with the science advisor(s)
contracted by the Working Group. That support will include facilitating that
persons efforts to become familiar with Warren County and its citizens.
Please do not hesitate to contact me if you have any questions. These items are offered to
assist you in selecting a person to fit the Working Group's needs.
HlvfL:rak
CC: L.C. Cooper
Dollie Buzwell
Ken F erruccio
William Meyer
•. P.O. Box 27687, Raleigh;North Carolina 2761 i-7687 Telephone [phone]
,. -C-, ,_1 I"'\.,.. ........... •-:._,, ,. 4,&,_,.....:_ •-A-..:-..., ~--•-• •-•
• ,.! .. .BF A Environmental Consultants _,_ -
. , Barnes, Ferland and Associates, Inc.
Mr. Bill Meyer
Division of Solid Waste Management
N.C. Dept. of Environmental Health
401 Oberlen Road, Ste. 150
Raleigh, N.C. 2760S
February 20, 1996
SUBJECT: Science Advisor Scope of Services
Dear Mr. Meyer:
BFA #95-017
As we discussed Friday, BFA considers the fee presented to be an upset Hmit. Because several of
the tasks were undefined, it was necessary to assume a more comprehensive scope of activities.
Also, the cost for those tasks identified as joint is very difficult to approximate because of
different interpretations on the level of effort by Joel and myself As you can see Joel and I did
agree on who would lead joint tasks and an approximate split of work for those tasks. It is
generally 70/30 with the lead Science Advisor perfonning the majority of the work.
All of the dollar values identified should be considered allowances, and more appropriately used
to determine your project budgets. The actual cost for services will be based on the hourly cost
(see attached rate table) of implementing the activities approved by the Working Group.
It was also very difficult to detennine travel expenses for the project; therefore, it was assumed
based on similar projects that travel would be approximately 10% of the total project cost.
The text typed in bold represents additions which were made to the base scope of services. The
most substantial of these is to develop a ground water and surface water fate and transport flow
model for the landfill area. Such a model is highly recommended because it would aid in
detennining what the environmental impacts might look like if the system is leaking or does leak
in the future. With adequate information going into the model design it could be used to
determine at risk areas and where future samples should be collected.
It appears the most currently pressing issue is the development of an RFP to select contractors to
obtain soils for the landfill for detoxification pilot testing. Based on review of the draft RFP
package, the discussions we have had, attendance at the pre-bid meeting, I would like to suggest
that the State delay submittal of a final RFP by approximately one (1) month. Although the RFP
package prepared is very comprehensive for a proposal document, I believe that the
The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando, Florida 32803
Office [phone] • Fax [phone]
02/20/1996 16:59
Mr. Bill Meyer
February 20, 1996
Page2
4078961822 BARNES FERLAND ASSOC PAGE 02
State/Working Group should use the design capabilities of the Science Advisor to convert the
RFP into more of a design specifications document. The benefits of detailing more of the design
ourselves are:
I. The bids will be more comparable. If the entire design is left up to the contractors it will
be very difficult to analyze the bids obtained. Several contractors may propose to use
completely different approaches and the difference between the rugh and low bids may
vary by an order of magnitude;
2. We can stress the areas of work which are more important to us;
3. To discourage bids from non-qualified contractors;
4. More control on the quality of the work to be performed by the selected contractor;
5. The more guidance you give the contractors with respect to the results we desire the
lower the bid will be. Therefore, more detailed specifications should lower costs.
lf you or any of the Working Group members have questions concerning this letter or my price
quote for the Science Advisor services, please don't hesitate to contact me.
I look forward to working with you ·and the Working Group on this very important project.
P A&'psg/2·20BM 1.doc
cc: Dollie Burwell, Co-Chair
Ken Ferruccio, Co-Chair
Henry Lancaster, Co-Chair
Sincerely,
Barn and Asso ·
I
Patrick A. Barnes, P.G.
President
.BFA ,..._ 9
..
'
01-11"-l'IC.:::> r C.l'U..Hl'ILJ HOOU\.,
Joint State PCB Landfill Working Group
Science Advisor
Barnes, Ferland and Assoriates, Inc.
Rate Table
Hourly
Science Advisor $100.70
Senior Environmental Engineer $74.20
Senior Hydrogeologist $68.90
Senior Chemical Engineer $66.25
Project Scientist $39.75
Project Engineer $39.75
Toxicologist $74.20
Technician $34.45
Clerical Support $31.80
Rates are based on a 2.65 multiplier
.BFA ,.., m :r= a
02/20/1996 16:59 4078961822 BARNES FERLAND ASSOC PAGE 04
Science Advisor Scope of Work -PCB Landfill -Patrick Barnes
I. Develop PCB Landfill detoxification project master plan, including:
S J0,000
$ 6 000
$ 3.000
$ 6 000
$ 8 000
1. Review all readily available, appropriate and applicable information
and provide written report evaluating existing environmental conditions
at landfill, and make recommendation to the Working Group after
considering at least the following. It is assumed that the Stat~ will
make all such documents available.
(a) Groundwater quality, volume and flow, monitoring systems
(b )* Leachate, volume, chemical characteristics, extraction, treatment
and application systems. This subtask will be performed jointly
by Mr. Barnes and Mr. Binchom. It is assumed that this
subtask will be led by Mr. Binchom and that the allocation of
work effort will be 70•/o / 30%. Ao allowante of $3,000 has
been assigned.
(c) Surface water quality, volume and flow, monitoring systems
including sediment
(d)"' Other considerations deemed appropriate by the working group.
Responsibility for this effort will be on a case by case basis.
An allowance of $8,000 is assigned.
Subtotal 1.1 $33,000
"' Joint Dames and Hinchom task
02/20/1995 15:59
$ 3,000
$ 14,000
$ 40,000
$ 3,000
$ 2,000
$ 10,000'
$ 5 000
41:178951822 BARNES Fc.RLAND ASSOC PAGE 05
2. Provide recommendations and processes for additional evaluations,
monitoring or other protective measures required as a pre-requisite for
detoxification or until detoxification is accomplished.
(a) Review two existing groundwater monitoring proposals submitted
by Division of Solid Waste Management staff and George Bain,
P.G., and recommend actions for implementing, and inspect
implementation.
(b) Develop ground and surface water fate and transport
computer model to aid in determining how pollutants may
behave if released.
(c) Evaluate the use for geophysical surveys in the assessment of
landfdl's integrity. In particular, the condition of the liner
and evaluating how much water it contains.
(d)»--Evaluate the need to remove water in landfill as a prerequisite for
detoxification and as a safety factor to control release from the
landfill. This subtask will be performed jointly by Mr. Barnes
and Mr. Hirscborn. Mr. Birscborn will lead with the
alloc·ation of work being approximately 70% / 30%. An
allowance of $2,000 has been established for BF A's role in this
effort. Only actual cost will be billed.
(e) Evaluate the need for and design (if necessary) of a health
impact assessment of the individuals in the vicinity of the
landfill identified as being at risk.
(f)lr Provide recommendations for other protective measures deemed
appropriate by the Working Group, such as off-site monhoring and
evaluation of landfill liner systems. This subwk will also bt
perf ormcd jointly; however it wiU be led by BF A. Once again
the approximate split in work will be 70% / 30%. BF A has
established an allowance of $5,000 for our role on this subtask.
Subtotal 1.2 S772000
..BFA =:::w
... ~ ,--. _.-..,. ------• ---• ·-· ' .
02/20/1996 16:59
$ 2 000
$ 2,000
$ 20,000
$ 10,000
$ 15,000
4078961822 BARNES FERLAND ASSOC PAGE 06
3. Identify and recommend alternative appropriate and feasible
technologies for detoxification of landfill .
(a)* Review BCD permits submitted to EPA by SoilTech and ETC for
R&D under the TSCA, and make comments and recommendations
concerning technical and administrative issues (including budget)
to Working Group.
(b )• Design and/or draft RFPs/contracts for tasks requiring to support
and implement detoxification efforts.
(c)* Design or draft RFP for providing materials from the landfill for
pilot/bench scale detoxification technology studies ( excavation,
storage, drying and delivery to vendors).
(d)* Prepare technical reports on detoxification efforts that are of
sufficient quality for sdentific peer review as well as sufficient
clarity for use in presentations for community involvement and
understanding, and support efforts in the General Assembly for
funding detoxification of the landfill.
All subtasks under this wk will be performed jointly, items (a) and
(d) will be led by Mr. Birschom and have a 70% / JO•lo and 60% /
40-Jo split, respectively. Items (b) and (c) will be led by BFA and split
10•10 I 30%. All of the cost estimates should be considered allowances.
Subtotal 1.3 $49,000
,.
$ 3 000 4. • Draft/outline all tasks and processes with milestones, scheduling and
budget for all elements of deto,ofication into a project plan for
consideration by the Working Group. BFA will d~velop a Gant chart
using CAD to be used as an overall project schedule. This task
will br split 70% / 30% between BFA and Mr. Birscbom and led
by BFA. An allowance of $3,000 has been applied for BFA's role.
Subtotal 1.4 S 32000
II . Develop community interaction plan
$ S 000
$ 15,000
$ 8,000
$ 8 000
Subtotal Task II
1. Prepare/outline all elements and format for maximum meaningful
community participation in detoxification efforts.
2. Work with sub-committee/Working Group to implement community
participation plan.
3. Prepare materials/information for community presentation that maintain
scientific accuracy and can be understood by the community.
4. Participation in direct communications and other public participation on
detoxification efforts in the Warren County community.
$36.000
BFA ~ =1:tw = er=
.• .
fr;: ~ r.\ D I I , ; .: .
L;\ l j l ,.·.,
m. Develop proposals and plans for legislative suppon of detoxification efforts
S 2,000
S 3,000
$ 6,000
1. * Prepare/plan for clements essential to inform members of the General
Assembly of the necessity of detoxifying the landfill.
2. • Participate in effons to maximize the potential for funding by the
General Assembly.
3. Participate in lobbying individual and groups of members of the General
Assembly for detoxification of the landfill.
Tasks ID.I and ID.2 will be split 70•/o / 30% between Mr. Hinchom and BFA. The costs
indicated are allowances.
Subtotal Task m Sl 1,000
B.FA ==-:::r,--=
02/20/1996 16:59 4078961822 BARI-ES FERLAND ASSOC PAGE 10
tv.• Perform additional tasks or delete task as directed by Working Group. An additional
cost or S10,000 bas been added as a contin1ency for BFA'• role in other unidentified
talks.
s 10,000
Subtotal Task IV 510.000
Subtotal Tasks I tbrou&h IV
Plus 10%
5219,000
21,900
BFA Science Advisor Project Total S240,900
Travel and Expenses
.BFA e:-, -w ;n:
. .
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PRE BID CONFERENCE
WARREN COUNTY PCB LANDFILL OPEN/CLOSE
FEBRUARY 16, 1996
NAME
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WARREN COUNTY PCB LANDFILL OPEN/CLOSE
FEBRUARY 16, 1996
vJ \LL\AM DE\.\ N ~
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ADDRESS/PHONE
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PRE BID CONFERENCE
WARREN COUNTY PCB LANDFILL OPEN/CLOSE
FEBRUARY 16, 1996
NAME
S>wr W'h,'~c,-t,
be flrl ,\S rk l de.,
COMPANY ADDRESS/PHONE
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Barnes,
Ferland and
Associates
FAX
4078%1822 BARNES FERLAND ASSOC
3535 Lawton Road, Suite 111
Orlando, Fla. 32803
Date: rl /; 2j1 b
Number of pages mcf uding cover sheet
To: /
L,)1_!/ /!f 71= l .
Phone: Phone: ( 407) 896-8608
Fax phone: Fax phone: ( 407) 896-1822
CC:
rHUL.. \o.l J.
RE.MARKS: 0 Urgent 0 For your review O Reply ASAP 0 Please comment
;t:/-:; ii
/
a,_::;7 ~ ~ i~ /1.R.re CL¥-(_
5v7y-rf~ q~p/,~_s
-
02(12 /1995 15:55 4078951822 BARNES FERLAND ASSOC PAGE 02
<;;"d/~/4J ~.,/,;/,1
1~,,,_,f
~~~-t-
Payment to the Contractor shall be made on percent complete basis for each task identified in the
Scope of Services.
I J{:,g /IUk/:;. ~/4--;;) . f<-)
At the option of the Department, this contract may be renewed on an annual basis thereafter.
17/~ o' f ./4, .,e._.,/ ef /?sH<"tJ}'r/c ~
Amendments to the base Science Advisor Scope of Services shaU be negotiated with the
Department on an as-needed basis. With the approval of the Department, the Contractor may
make adjustments to the project's base hourly rate table.
I ~ I -/-.C)-/ 1/-t,v vf.,1-t~ ~(., i t-.t-,$
The Science Advisor may sub-contract with Department approved specialty subconsultants. The
Contractor may assign a 10% management fee to the services of such subconsultants. This fee
( will co~er management :~d coordi~ation of project e~orts.
\.__ 1 Jjz,,ij a/-:-'---L./ ;lc,-~7 1' o/,:;A 1-#
Reimbursable expenses such as travel, meals and lodging shall be paid by the Department on a
direct pass through basis. Mileage shall be reimbursed at a rate of $.30/mile.
Those subtasks identified as joint in the attached Scope of Services shall be the responsibility of
the lead Science Advisor as identified in the Scope. Liability for potential claims resulting from
actions associated with joint tasks shaU be shared based on the degree of responsibility for the
execution of that task.
t-1-<UM P . 1
HIRSCHHORN
~~~~~OCIATES __ _ _ ·-~ A Division of Hygienetic~ ~nvironment.al Servl~s. Inc. Suite 411
2401 B1ucrlcige Avenue
w1,e::iton. MD 20902
Pr,one: [phone]
F:ix: (301i ()49.1_23;
February 12, 1996 ................................................................. by FAX (2 pages)
To: Bill Meyer
From: Joel Hirschhorn
Subject: Cost estimates and contract for Science Advisor position
Attached are my estimates for labor costs (at $100 per hour) for the tasks provided in the SOW
from your office. I have also added a task to cover reimbursable expenses. My estimated total
costs are $145,000 for both labor and expenses.
I want to emphasize that all my estimates are very approximate and have been :made without
ha\ing much information th.at would allow more accurate estimates. For example, I have not seen
nor have I been provided with any inventories of documents that will have to be reviewed for
various tasks. Nor is it possiole to clearly know the extent of required travel for meetings in
Nortl1 Carolina and perhaps elsewhere. Moreover, based on my experience to date in reaching
this point it is very clear that the complex nature of the Committee and the role of your office as
well as th.e political dimensions of the project can all result in more than normal amouuts of time
for substantive wo.rk as well as discussions, report preparation, and travel than I have ordinarily
encountered with such work.
Therefore, I have prudently tried to err on the high side in my estimates in order to protect my
company and to reduce the need for e>..i.ensive change orders.
On the positive side, I want you to know that I intend to try to cut costs whenever possible. For
example, on tasks shared with the other Science Advisor, Patrick Barnes and I have negotiated
lead roles to reduce redundant efforts and streamline the process.
My company attomey has approved the draft contract. But I want to note that under paragraph
11 of the contract I cannot legally provide my work products to parties outside the Department.
This would inhibit communications to Committee members_ I will require written authorizatjon to
allo,-v me to provide my work products to either all or specific Committee members.
7-.13-1995 9: 16PM FROM
ESTIMATED COSTS FOR HIRSCHHORN -SCIENCE ADVISOR
I.
II.
m.
1.
2.
~ .:>.
4.
1.
2.
a.
b.
C.
d.
e.
a.
b.
C.
a.
b.
C.
d.
e.
f.
$6000 (general, report, meetings)
2000
2000
5000
5000
4000
TASK 1-1: $24,000
4000 (general, reports, meetings)
8000
8000
4000
TASK 1-2: $24,000
8000 (general, reports, meetings)
6000
2000
2000
12000
10000
6000
8000
8000
10,000
TASK I-3: $46,000
TASK 1-4: $ 3,000
TASK I $97,000
TASK II $16,ooo
TASK III $10,000
TOTAL LABOR: $123,000
TV. Reimbursable expenses
1. travel 20000
2. other direct costs 2000
TASK IV $22,QQQ
TOTAL ESTIMATED COSI
P.2
James B. Hunt, Jr. Governor
Ka.tie G. Dorsett, Secretary
Mr. Earl R. Limer
Route 4, Box 413
North Carolina
Department of Administration
January 24, 1996
State Property Office
Joseph H. Henderson., Acting Director
Warrenton, North Carolina 27589
Dear Mr. Li mer:
It was a pleasure seeing you last Thursday evening at the Warren County Courthouse. I believe the
Committee is making progress to detoxify the land fill.
Inquiries have been made about your concerns of maintenance performed by the Department of
Transportation on the PCB Landfill. We have contacted Mr. Clarence Thompson, Highway Maintenance
Engineer, in Warrenton to identify which sections of the property that have been mowed or bush hogged. Mr.
Thompson informed me that DOT crews bush hogged the perimeter of the 19.317 acres of the landfill prior to it
being surveyed. As you recall the Joint Warren County State PCB Landfill Working Group requested the State
to post no trespassing signs around the perimeter of the landfill. Prior to the survey, the Department of
Transportation bush hogged property lines to allow easy access around the perimeter. Mr. Thompson also
informed me that DOT crews bush hogged several trails to Richneck Creek. These trails would provide easy
access for the Division of Solid Waste Management to take samples from the creek. This request was made by
Mr. Larry Rose of the Solid Waste Section. Mr. Rose also informed me that he indicated the approximate
location for the trails to enable him to get a vehicle close to the sample area.
Thank you for your concern; we are delighted to know we have a watch dog for the PCB Landfill site.
TEC:wsh
cc: Clarence Thompson
Larry Rose
~ ~ rat::
o my . Cline
Real Pr erty Agent
State Property Office • 116 West Jones Street • Raleigh 27603-8003
Telephone [phone] Fax 9 l 9-733-143 l
State Courier 51--01--00
An Equal Opponunily / Affirmative Action Employer
f 1 ' l i _,..
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