NCD980602163_19970113_Warren County PCB Landfill_SERB C_Preferred testing for PCB air emissions-OCR

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Jauunry 13, ]997
To: M"lke Kelly ·
From'. Joel Hiri.chhom
Subject: PrMetted testing for PCB air emissions; peer review
As to the preferred testing meithod$ f01 detc.rtn.ini~,g ''w.hetb~r there is a problem" at the Wan·eu
Comity Laudfill, l now have had tin.,eto research the mut. My reoommondation to the state is
thal if eny testing for PCB air emissions is oonduoted 1,y th@ i.tate that it Qhould follow the
n1ethods etoployod by In.cliana University in its work "Lt,ng-Tenn Meawrem~ts of Atw.ospho1ic
PolychJorinated Biphenyli in tbei Vicil.lhy of Superfim.d Dumps,'' (M.H. HCIU1anson and R.A.
H'nes, F..nvirou. Sci&, 1'oohnol., v.231 n.10, 1989, pp,12543-1258).
Titc experiment el approaob used in this relevant work waa far more sonsitive and oomprehensive
than the EPA work in 1982. PCB level~ in air at three commucity loontions, miles ft·om
Superfimd dump sites, wer;, mAd~.
The Indiana work correctly paid attention to the large effect of ambient temperature on PCB
levels,. corroctly meaR!red PCBs in both vapor and panioulate forms;, used high volume sampling,
had a detection limit very much fower than in EPA', work, and measured and reported total PCB
congc11e1 levels rnthcr than only two commercial mtures (i.e., Art>clon).
Noto thnt Professor Hites, one of the authors oft.he above s:tudy, i& one of the two pei·sons Bill
.Meyer asked for a review of the work c<>ndueted by EPA and my comments on it, However, I
stro1tg)y object to tht way Bil Meyor r.ought external rMcws. For example, I would want to
know tho extent t() which Prof. Hites has fundmg from EPA. And &om -whom did Bill Moyer
obtain the names: of the two perso1\s h~ ohose t.o solicit reviews from? Nor do we. know what
kind of ~atctMI1ts may have been. made to Prof Hites by BID M~yer. In any e'\'ont, there is a clear
published record of the tnethod, u~d by J>rof. ffit;is v0.rsus those used by EPA. Intere~ingly1
althouih the 1985 paper by Dr. LeY& et al of EPA was referenced in tht Indiana paper, not OJlC
piece of data was cited, even though a large nmount of publishod dllta on PCB air lovels was
prese~tod by .Pro£ Hit~s in his paper,
Rrtsed on my professional experienoe, I would not expect Pro£ Hites to say anything that Dr.
J,,cwis uf .EPA ~ght find disagreeable, because Pro£ Hlt~~ would h1we a lot more to lose than to
gain profo~onally. The ;ame is ttuc for the Canadian regulatory official asked for a review. In
foot. most profe&sionah placed in the p<>sition that Bill Meyer ci·eated would \)() blased in favor of
a senior EPA petson. In orde,-to 11void this sigojS,~ant oonstn1int1 someone in Bill Meyer's
position would have to create safoguards1 such as by aS&Uiing oomplett oonfidentitlity or the
• ~:vi~cr's ld~ntify, And of course, if Bill Meyer wmtod to be :wr, he woul~ hl\vc asked me to
n(')minat.c perton, for ~cb a poor t'e\'le\Y,
cc: Technioal Committee,
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