NCD980602163_19970624_Warren County PCB Landfill_SERB C_Status Report of Warren County PCB Landfill-OCR

STATUS REPORT OF PCB LANDFILL
WARREN COUNTY, NC
JUNE 24, 1997
STATUS REPORT OUTLINE
PCB LANDFILL, WARREN COUNTY
JUNE 24, 2997
ACTIVITIES INVOLVING SITE ASSESSMENT
&
DETOXIFICATION STUDIES
I. MOBILIZATION I SITE WORK
1) Contracts awarded for site work:
S& ME-excavation and boring into landfill; cap evaluation
ENVIRONMENT AL INVESTIGATIONS-monitoring wells
SOUTHWEST LABO RA TORIES-dioxin analysis
2) Mobilized on site February 12
Simultaneously began digging of monitoring wells and borings in landfill
3) Contracts issued to ETG, West Chester, PA, and ECOLOGIC, Ontario, Canada for
detoxification studies
II. MONITORING WELLS
1) Installed 15 strategically located wells around landfill
2) Installed 3 background wells for evaluation and comparison
III. BORE HOLES
1) Placed two bore holes along centerline of landfill, north and south of vent pipe
2) Excavated soil for utilization in bench scale detox study
3) Installed two monitoring/extraction wells in the bore holes
4) Excavated 8 x 8 foot area to liner for evaluation; removed sections of plastic for
testing and took core samples through top liner and cap for lab evaluation
IV. SAMPLING
1) Extensive sampling plan developed and implemented, over 200 samples
2) Included surface water, sediment, soil and background samples
3) All monitoring wells, bore holes and soils from excavations
4) Variety of testing-PCBs, dioxin, metals, herbicides, pesticides, organics
V. DETOXIFICATION STUDIES
1) ECOLOGIC-gas phase chemical reduction; initial testing done May 27
2) ETG-testing started June 17
3) Reports on Phase I (study results) anticipated in August
4) Contract to be issued in September for Phase II, draft preliminary design
5) Phase II report, estimated cost and implementation plan for detoxification expected to
be complete in November. Note: only 1 Phase II contract will be issued for the
technology chosen from the two after evaluation of Phase I.
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VJ. AIR SAMPLING
1) Extensive air sampling done at the landfill prior to mobilization and after work had
commenced at the site
2) High volume and low volume samplers utilized following recommended procedures
from a 1983 EPA study
3) Personnel monitors placed on workers doing excavation in landfill
4) Perimeter of landfill gridded and plugged, checked for methane to determine if leaks
are occurring around the top of the landfill
VII. COMPLIANCE ISSUES
1) Working Group sent a letter to EPA in November 1996 requesting a compliance
inspection by the EPA
2) The state is out of compliance in respect to monitoring requirements in the permit and
failure to remove water from the landfill
3) The Working Group has also alleged that the state installed a faulty leachate removal
system during construction of the landfill, ignoring the design plans
4) EPA is investigating and we fully expect a compliance order to be issued within the
next 30 days
5) This order will probably include a condition of water removal, which is adamantly
opposed by the Working Group.
6) The Working Group wants the state to enter into a compliance order with EPA which
includes detoxification in lieu of "lesser remedies."
VIII. FOCUS BY WORKING GROUP AND SCIENCE ADVISORS
1) Desire to show that the landfill is leaking
2) Lab results indicate no PCBs in the groundwater, dioxin compounds are present
3) One air sample showed a high concentration of PCBs; other testing does not confirm
their claim of cracks in the cap
4) The plastic liner, a part of the overall cap design, shows signs of stress, pin holes and
portions of the seam coming loose; clay cap meets or exceeds standards
5) Interpretation of water levels in monitoring wells by the Science Advisors "clearly"
shows water coming in and going out of the landfill
6) The state is out of compliance with its permit and cannot be trusted to maintain it
safely, and therefore, detoxification is the only solution
IX SCHEDULE
1) July: Report and conclusions from Science Advisors on site assessment/
investigation
2) August: Reports from detox studies, Phase I
3) September: Recommendation and contract for Phase II, detox study
4) November: Phase II, detox report due, outlining cost and procedures for full scale
operation and detoxification of landfill
5) November-May (1998)-community involvement, plan for funding
6) May-secure funding, seek contract for detoxification
7) Fall 1998-issue contract for detoxification, begin work January 1999
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STATUS REPORT
PCB LANDFILL
WARREN COUNTY, NC
JUNE 24, 1997
PART I: BACKGROUND. INFORMATION THROUGH NOVEMBER 1996
PART II: RECENT EVENTS. SAMPLING. DETOXIFICATION STUDY
PCB LANDFILL STATUS
BRIEF BACKGROUND
In 1993, Governor Hunt was briefed by state officials on the status of the PCB
landfill in Warren County. He was told that the contents of the landfill had not been
sampled since construction, and that there was water in the landfill that needed to be
tested and removed. The PCB landfill was constructed to be a dry facility. At the
direction of the Governor, state officials met with Warren County officials in a public
meeting to determine what to do about the water. The intent of that meeting was to
get concurrence on extraction of the water. Several citizens demanded that
detoxification be considered as a prerequisite to dewatering or done simultaneously
with dewatering of the landfill. They also cited the commitment that Governor Hunt
made in a 1982 letter to the citizens of Warren County to detoxify the landfill when
feasible. As a result, DEHNR set up a 16-member working group composed of Warren
County citizens, environmentalists, and state officials to make recommendations to the
Governor about the future management of the PCB landfill.
The working group met for the first time in January 1994. Upon the group's
recommendation, a contract was entered into with Pauline Ewald, head of
Environmental Compliance Organization, on May 1, 1994 for $82,950 (money came
from DEHNR) to serve as the group's science advisor for one year. Her duties were to
recommend site evaluation procedures, a methodology for water removal, a
detoxification technology, and long-term controls for the PCB landfill.
In July 1994, a sampling event was conducted at the landfill by Ms. Ewald's
company and the state. No PCBs were found outside of the landfill. However, the
laboratory that analyzed the state's samples detected some dioxin at the ppq (parts per
quadrillion) level in three of the monitoring wells around the landfill. Opinions varied
as to where the dioxin originated. Despite the fact that Ms. Ewald tried to discredit the
state's findings, she used those findings to conclude in her report that "In the absence
of other likely sources of chlorinated contamination, it is likely that the PCB landfill is
the source for the dioxin and furan contamination noted at the site." The report
prepared by Ms. Ewald was not acceptable to the state. It was peer-reviewed by several
outside sources who were also critical of her report.
The state recommended that the landfill be resampled. The working group
opposed both resampling and removal of the water from the landfill. Ms. Ewald's
report convinced several members of the working group that the landfill was leaking.
Even though several members of the working group acknowledged that the presence of
water in the landfill presented a potential risk, they did not want the water removed.
They have repeatedly expressed concern that if the landfill were made safe by removing
the threat of the water that the state would not proceed with any detoxification effort.
Ms. Ewald recommended that a technology known as base catalyzed
dechlorination (BCD) be used to detoxify the landfill. The state advised the working
group that at least three methods should be considered and that the General Assembly
would want information about various technologies available for detoxification, why
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;.
certain technologies were approved/rejected, and costs. The working group felt that
the BCD process was a suitable technology and would be acceptable to the community
because it could be done on site. The state and the working group went through the
process of selecting vendors to conduct pilot projects at the landfill using BCD
methods. Two vendors even went through the EPA process for approval. Both
eventually received approval by EPA. Pilot-scale proposals by the vendors included a
cost ranging from approximately $700,000 to $800,000 for on-site testing of
technologies.
Ms. Ewald's contract expired in May 1995.
CURRENT STATUS (July 1, 1995-present)
Membership ·
The original working group was composed of 16 members. At the working
group's request, the membership was raised to 24 in September 1994. Presently,
there are 21 people on the working group, with Senator Frank Balance serving as an
ex-officio member and Mr. Bill Meyer, director of the Division of Waste Management,
serving as staff. Three positions are vacant (one public safety and two youth).
Approximately 10-12 members show up for meetings on a regular basis, and they are
the decision-makers. The others attend meetings sporadically or never attend. There
are only two elected officials on the working group. County Commissioner Lucius
Hawkins' attendance is sporadic. He was defeated in the spring primary. Ms. Dollie
Burwell, the Register of Deeds for Warren County, is one of the co-chairs and a regular
attendee. She also was defeated in the spring primary.
The credentials of the working groups members, other than the three state
representatives, are basically unknown. The working group very heavily relies on the
state for staff, technical expertise, and support. Yet members have repeatedly said
they do not trust the state.
Expenditures
In March 1994, Warren County was awarded $100,000 from the Solid Waste
Grants Program to be used for capital improvements on the PCB Landfill.
During the 1995 session of the General Assembly, the legislature appropriated
$1 million from the Highway Fund for pilot projects to determine the most appropriate
technology for cleanup of the landfill.
The working group members decided they needed the services of another science
advisor as well as support staff. On March 7, 1996, Mr. Joel Hirschhorn (Maryland)
and Mr. Patrick Barnes (Florida) were hired as science advisors for the working group.
On March 18, 1996, Ms. Doris Fleetwood was hired as a part-time secretary for the
working group. A joint agreement was made between the DEHNR and the Warren
County Board of Commissioners to provide office space, furniture, equipment,
supplies, conference room, kitchen, restroom facilities and parking for the secretary
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and the two science advisors. The working group's office opened on March 25, 1996, in
the CP&L Building in Warrenton, NC. The $1 million appropriated by the General
Assembly is being used to pay the science advisors, the secretary, and office rent. The
science advisors are each paid at the rate of $100 per hour of work. The cost for the
half-time secretary and office space is $25,000 for one year. As of September 1996,
$60,252 has been expended from that fund, of which $31,809 has gone to the science
advisors.
In the fall of 1995, the Division of Waste Management began working with CP&L
to provide electrical service to the landfill for pilot projects or any full-scale
detoxification effort. CP&L was paid $64,384 for this service from the capital
improvements account. Poles and lines for electrical service are in place, and
transformers will be added when the specific electrical demands are lmown. This
provides a permanent source of power for detoxification efforts or dewatering the
landfill, as well as other activities that may require electricity.
Master Plan
After talking with the working group and reviewing files and documents related
to working group activities and the PCB Landfill, the science advisors developed a
master plan. This master plan stated why the working group should change its
current strategy and offered an alternative strategy. The working group approved the
master plan at their April 25, 1996 meeting.
The science advisors offered several reasons for changing the current strategy of
the working group. Briefly, the science advisors stated that it would be just as
effective, and less expensive, to invite a few companies to conduct off-site, bench-scale
tests on the landfill's contents rather than pilot-scale projects. This would also mean
that less material would have to be removed from the landfill for the studies. The
science advisors stated that other detoxification technologies must be thoroughly
examined. They also said that a much stronger case for funding from the General
Assembly could be made by spending money on a more thorough site investigation and
remedy design.
The science advisors recommended several key steps in the alternative strategy.
They felt that a more detailed evaluation of detoxification technologies and vendors
should be conducted by the science advisors. They also suggested that a site
investigation be conducted to determine the current status of the PCB Landfill and the
surrounding area. This investigation, if approved, will include the placement of
additional monitoring wells and a resampling of the landfill and surrounding area. The
site investigation will cost roughly $50,000 (excluding state staff costs), and it will be
funded from the $1 million approved by the General Assembly.
The alternative strategy also calls for several other items:
Designing a soil and waste removal plan and selecting a vendor to do
this;
Issuing a feasibility study report;
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Inviting vendors to conduct bench-scale treatability tests;
Evaluating test results and selecting/ ranking vendors (to be done by
science advisors);
Finalizing the site investigation report;
Meeting with working group/highest ranked vendors;
Selecting best technology vendor (pre-qualified for actual cleanup);
Hiring best technology vendor as design contractor (under current
funding);
Selecting a remedy and issuing a remedial design report.
The remedial design report would be used as the basis for the working group and
DEHNR to formally propose the landfill detoxification project to the General Assembly
to obtain funding.
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
September and four responses were received in October. These responses were
reviewed by the science advisors. Pending some additional clarification, the science
advisors recommended CDM (Camp Dresser & McKee).
The working group, including the two science advisors, held a meeting on
October 23, 1996. At that meeting, Mr. Hirschhorn presented the members with a
draft letter to EPA Region 4 Administrator John H. Hankinson, Jr., accusing the state
of a "serious and prolonged lack of compliance." The letter stated 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." The letter also stated that "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 4 that
demands attention, explanation, and correction." With a few corrections, the working
group agreed that the co-chairs were to sign the letter, and it would then be sent to Mr.
Hankinson.
Mr. Hirschhorn presented the working group with another draft letter to Mr.
Elliott P. Laws, EPA assistant administrator for Solid Waste and Emergency Response.
The working group requested a clear, definitive policy position concerning the extent to
which CERCLA and National Contingency Plan requirements apply to the PCB landfill.
This letter was approved as written.
Mr. Hirschhorn presented the group with a signed declaration stating that in his
professional opinion, detoxification technology appropriate for use at the PCB landfill is
now commercially available. The two technologies he named are gas phase chemical
reduction and base catalyzed decomposition. In addition, Mr. Hirschhorn presented a
written statement that accused the state of "delaying the efforts by the Working Group
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to complete the current project to assess, test, and select detoxification technology."
He also stated that the issue is not whether detoxification can be done, but whether
the state will honor the commitment made by Governor Hunt in an October 20, 1982
letter.
After considerable discussion about whether to release the letters and the
statements to the news media before or after the November 5 election, the working
groups decided to issue a media advisory on November 11 informing the news media
that there would be a press conference on November 12 at 11 am. It was later
announced that the press conference would be held at the Capitol Building.
At the October 23 meeting of the working group, Mr. Barnes noted that he had
met with Senator Frank Balance and US Representative Eva Clayton, at the request of
working group co-chair Dollie Burwell. Mr. Hirschhorn was not invited to this meeting,
and he subsequently wrote a letter to the working group seeking clarification as to who
had the authority to initiate such an action (i.e., could a co-chair or working group
member authorize such an action without the consent of the others).
Mr. Hirschhorn wrote another letter complaining that co-chair Henry Lancaster
had never explained to him that he had the option of being the sole science advisor or
working with Mr. Barnes. Mr. Hirschhorn said that he was given only the option of
working with Mr. Barnes. In his letter, Mr. Hirschhorn stated that he would have
chosen to be the sole science advisor had that option been given to him.
In response to the accusations made against the state in the letter to John
Hankinson and the two statements drafted by Mr. Hirschhorn, the Division of Waste
Management had a temporary engineering consultant review inspection/monitoring
files to determine if the state was in compliance with permit conditions. The following
are the findings:
• Monthly inspection and landfill leachate monitoring reports are complete for
1984-1986 and from 1990 to the present. Reporting was spotty for 1987-
1989. The PCB landfill was closed in 1983, and 1984 was the first full year
of required reporting;
• From 1983-1993, an estimated (based on pumping rates and pumping time)
12,400 gallons of leachate was removed from the landfill. No documentation
was found for 1987-1989. Amounts ranged from a low of 100 gallons in
1986 to a high of 5,297 gallons in 1983. Pumping was not conducted in
some winter months when the temperature was below freezing and the
leachate in the pipe was frozen. In 1994, an estimated 100 gallons was
pumped each month (pumping time available, but calculations incomplete at
this time). In August 1995, pumping of leachate at the landfill was ceased at
the request of the working group. As of November 1996, pumping has not
been resumed;
• Semi-annual sampling has been conducted each year (beginning in
November 1982) except for 1987 when there was only one sampling done. At
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the request of the working group, semi-annual sampling ceased after May
1995. Semi-annual sampling resumed in early October 1996;
• The Final Technical Report for the PCB landfill project was sent to EPA
Region IV Environmental Scientist Al Hanke in September 1983;
• Background sampling of groundwater, surface water, and surface water
sediments was conducted July-September 1982 (documented in June 30,
1983 letter from Tom Karnoski to O.W. Strickland and is part of the Final
Technical Report to Al Hanke;.
• In the spring of 1990, the Division of Waste Management notified officials in
the Secretary's Office that there was water in the landfill that needed to be
removed, but that funds were not available. A request for funds to dewater
the landfill was not a high priority in the department's legislative budget
package in 1991, and did not make it to the General Assembly. As
mentioned earlier in this report, state officials met with Warren County
officials in a public meeting in May 1993 to determine what to do about the
water. One of the goals of the working group, established as a result of this
meeting, was to assess the need to remove rainwater from the landfill and
recommend to DEHNR the basis and technology for removal or allowing
rainwater to remain in the landfill. The working group did not address this
issue (until the October 23, 1996 meeting) other than to say that it did not
want to dewater the landfill unless done in conjunction with detoxification;
• The RFP (February to October 1996) for the excavation of soils from the
landfill requires the construction of two to four extraction wells into the
landfill. These extraction wells can also be used to dewater the landfill. This
activity will also provide data on the status of the top liner with respect to
liner integrity or leakage.
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. To the division's knowledge, the sampling plan is the
only document that has been significantly delayed. We had envisioned that the
sampling plan would be ready for the working group's approval in the summer. The
initial draft plan supplied by Mr. Barnes was inadequate and lacking in detail. Division
staff worked with Mr. Barnes to draft a plan that could be implemented. The sampling
plan cannot be implemented, however, until the monitoring wells have been
constructed.
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
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The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2 , 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background wells will be
included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
11/7 /96
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RFP for Excavation, Handlin&, and Storaee of PCB Soils from Landfill
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
-September and four responses were received in October. However, the RFP did not
clearly indicate that the respondents were to consider the presence of landfill gases,
particularly methane, in design and operation of tasks in the proposal. We have asked
the respondents to indicate their consideration or lack of consideration of methane in
their proposals to the Division of Waste Management. We have also requested all of
the respondents to include an itemized list and cost of all separate elements in their
proposal response to the RFP. The responses are due at noon, Friday, November 15.
The RFP for the excavation of soils from the landfill requires the construction of
two to four extraction wells into the landfill. These extraction wells can also be used to
dewater the landfill. In addition, this activity will provide data on the status of the top
liner with respect to liner integrity or leakage.
PCB Landfill Samplin& Plan
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. We had envisioned that the sampling plan would be
ready for the working group's approval in the summer. However, the sampling plan
cannot be implemented until the monitoring wells have been constructed, and the
state has focused its attention in this direction.
RFP to Conduct Dioxin/Fu.ran Testin& on Water, Soil and Sediment Samples
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
RFP to Construct Monitorin& Wells
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2, 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background.wells will be
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included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
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PCB LANDFILL, WARREN COUNTY
ACTIVITY UPDATE
June 20, 1997
I. RECENT ACTIVITIES
On February 12, 1997, the Division of Waste Management mobilized on site at the PCB
landfill in Warren County to begin site investigation and assessment. This phase of work was
designed to do three things:
1) Put in additional groundwater monitoring wells around the landfill, and 3 "off-site"
wells,
2) Put two bore holes in the landfill to extract soil for a detoxification study, and replace
the bore holes with extraction wells, and
3) Collect a series of samples for analysis.
Contracts were issued to various companies to do the work. Two companies, S&ME and
Environmental Investigations, are both local companies and were chosen for items #2 & # 1
(respectively) above. One laboratory in Wilson provided air analysis on samples collected by the
division, and a laboratory in Oklahoma was chosen to do dioxin analysis. The state health lab
provided most of the analysis for the division.
Two vendors were chosen by the Science Advisors and Working Group to provide the
bench scale detoxification study. A contract was issued to ETG, Inc., West Chester, PA, for a
process called base catalyzed dechlorination, and to Eco-Logic, a Canadian firm, to demonstrate
a process called gas-phase chemical reduction.
The landfill activities were completed in mid-April. The Division of Waste
Management's personnel worked more than 2,000 man-hours on the project.
II. MONITORING WELLS
Eighteen new monitoring wells were installed. Seven of these wells were around the
outside perimeter of the fenced-in area, seven were placed in a perimeter from 100 yards to 1/2
mile from the fenced in area, and three were placed on private property approximately 1-2 miles
(air miles) from the landfill (east, south and west) to serve as "background" wells.
The wells, in some cases, are "nested" in the same location, ie one deep and one shallow.
Four monitoring wells already existed at the landfill.
These additional wells will help to identify the geologic and hydrologic features around
the area of the landfill and additionally provide more locations from which monitoring samples
can be taken. The off-site wells provide a broader scope of the groundwater conditions in
Warren County at three different areas located sufficiently far enough from the landfill to insure
that they would not be impacted by it.
III. BORE HOLES
Two bore holes were placed in the landfill, one along the south ridge line and one north
of the vent pipe. These holes were used to extract contaminated soil from the landfill to be used
in the detoxification study. Extraction wells were installed in these holes and could easily be
utilized for the removal of water in the landfill.
An area around the bore holes approximately 8 feet by 8 feet, was opened to the top of the
plastic liner which covers the top of the landfill cap. Samples of the liner and borings from the
landfill cover, cap and materials in the landfill were taken and analyzed for a variety of strength
and permeability parameters.
The plastic liner was in "fair" shape. Some pin holes were noted and of particular
interest, the seam of the plastic liner was not glued in one spot and had been penetrated by grass
roots from the surface cover. The clay cap and cover over the liner were tested and both exceed
the current landfill cover standards for permeability.
IV. SAMPLING&ANALYSIS
More than 200 samples were taken from the landfill, monitoring wells, streams, sediment
and surrounding surface areas during March and April. Samples were analyzed for many
different parameters to include PCB, dioxin, herbicides, pesticides, volatile organic chemicals
and metals.
The initial review shows nothing unusual in the area. No PCBs were detected in the
groundwater or surface samples; trace amounts were found in the landfill leachate inside the
landfill, and of course, in the soils contained in the landfill. All other tests essentially show "non
detects" or negligible amounts, and only the dioxin analysis appears to be in question.
An outside firm from Broken Arrow, OK, was contracted from a list of approximately
eight companies across the country capable of doing dioxin analysis. The samples were
analyzed for 1 7 different dioxin compounds. It is normally accepted that two compounds
(2 ,3,7,8 TCDD-tetrachlorodibenzodioxin, and 2,3,7,8 TCDF-tetrachlorodibenzofuran) are
considered "toxic" and of concern. One monitoring well north of and adjacent to the landfill
showed some TCDD, 24 pg/1. This is the only "hit" for a 2,3,7,8 dioxin compound in a
monitoring well, although other dioxin compounds were found in numerous samples, including
the background and "blanks." We have neither received nor produced a report as to the
conclusions from the dioxin data, however, the Science Advisors hired by the Working Group
are using this information to say that the landfill is leaking dioxin into the groundwater. As
mentioned, we found no PCBs in the groundwater, and the Science Advisors have said that our
detection limits were not low enough to adequately determine if, in fact, PCBs are present (the
detection limit was . I ppb, the drinking water standard is .5 ppb ).
The Environmental Protection Agency "split" some samples with the state, and we have
been told that their data is similar to ours. The Science Advisors have been asked to give us a
date as to when they will have a final report.
V. DETOXIFICATION STUDY
As previously mentioned, two companies were selected by the Science Advisors and
Working Group to perform bench-scale detoxification on samples supplied to them by the state.
These technologies, base catalyzed dechlorination and a gas phase chemical reduction method,
are currently being evaluated. Phase I reports on the studies are due in August, and will be
evaluated by the state and Science Advisors and a contract for a Phase JI, preliminary draft
design, will be given to one of the two vendors and technologies.
A Phase II report should be available in November, which will outline the process for full
scale detoxification of the landfill and the estimated cost. We currently project the costs to be in
the $20 million to $30 million range and would estimate it to take from I 1/2 to 2 years to
complete.
There are a number of technologies available for this type of work. We continue to
receive a number of calls from companies that would like to have their technology considered,
but we have so far focused only on the two selected by the Science Advisors.
VI. AIR SAMPLING
Prior to starting the work in and around the landfill, the state took ambient air samples
from the vent pipe (air inside the landfill) and around the landfill, to check for PCB air
emissions. One of the Science Advisors made a report in November that referenced an air
emission study conducted by the EPA in 1983. His conclusions were somewhat different than
the EPA made, and he was successful in convincing the Working Group that PCB air emissions
were continuing to emanate from the landfill.
In response to this, the state placed a carbon filter on the vent pipe that allows methane
gas generated in the landfill to escape.
In the initial air testing done by the state, air from inside the landfill and at four other
locations did not detect the presence of any PCBs in the air. One sample, however, situated on
the landfill near the vent pipe did show high levels of PCB. Another sampler 2 meters away, and
one pulling air from inside the landfill, did not detect any PCBs. The laboratory rechecked the
sample near the vent pipe, and confirmed the presence of PCB. We have no explanation for the
presence of PCB, particularly in the quantities found, except for lab contamination. The Science
Advisors, however, firmly believe that this is a result of cracks in the cap and the PCBs are
escaping at that point. No other evidence indicates that this is occurring.
The state set up and performed air monitoring at the landfill once work began using high
volume air flow pumps, and workers digging in the landfill wore ambient air monitors. The
results of this testing detected no PCB's.
In January, the state put in a series of plug holes over an extensive grid around the
perimeter of the landfill and later tested each of these holes for the presence of methane.
Methane is being generated and escaping the landfill through the vent pipe, and therefore should
be detectable in a plug hole if cracks exist in the cap, which would provide an escape route for
the gas. None was detected in any of the 25 plug holes sampled.
VII. COMPLIANCE ISSUES, EPA
As a result of investigations and inquiries conducted by the Division of Waste
Management and the Working Group, we have determined that there are areas in which we have
not been in compliance with the EPA permit issued for this landfill. For instance, some monthly
inspection reports are missing for some years prior to 1990, and it can be assumed that the
required monthly inspections were not done.
A permit condition requires that water be removed from the landfill. We know water
exists in the landfill, and we attempt to pump water out on a monthly basis, but are unable to
actually remove much water with the current system. The Working Group, since its inception,
has apparently opposed the removal of water from the landfill because members feel that it the
water is removed, there will be much less incentive to detoxify the landfill. We tried to work
with the group on this matter, but it later used that against the state on the issue of non-
compliance.
We are required to perform extensive semi-annual monitoring at the landfill. We have no
records for two years since the closing of the landfill, and know that in the second half of 1995
and in 1996, no sampling was conducted at the request of the Working Group due to plans for an
extensive sampling plan as part of the site investigation and assessment.
There has also been a lot of discussion by the Science Advisors in regards to the "missing
pipe system" which was in the original set of drawings for the leachate collection system, but not
in the "as built" drawings. Until recently, we were not able to document that the change had
been approved by the EPA. Accusations of" short cutting" the construction of the landfill were
made.
The Working Group sent a letter to EPA in November of 1996 detailing how the state
was out of compliance with its permit. The EPA is investigating and we fully expect them to
issue us a compliance order to come into compliance, maybe as early as next month.
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We further expect this order to require us to begin removal of water from the landfill,
which is still adamantly opposed by the Working Group. There are also no funds currently
available to utilize for coming into compliance.
VIII. AREAS OF FOCUS BY THE WORKING GROUP I SCIENCE ADVISORS
The Working Group clearly would like to see the state make a public statement declaring
its intent to detoxify the landfill.
Much of the efforts of the Science Advisors has been to demonstrate that the landfill is
leaking and posing a threat to the citizens of Warren County. As previously mentioned, a lot of
attention has been given to potential "hot spots" without regard to additional results and technical
reasonmg.
For instance, focus is being placed on dioxin, when certain conegers of dioxin are found
in almost every sample tested, yet they 'are "proof positive" that the landfill is leaking, even
though we have very low levels of PCB in the leachate inside the landfill, and no dioxin. There
are also no PCBs in any of the monitoring wells.
The air sampling results for one sample "shows ambient exposure to PCBs," yet the level
is so high that if it was a real "hit," PCBs should have been detected in other samples as well,
especially either in the vent or on one of the high volume samplers.
The Science Advisors are using fluctuating water levels in the monitoring wells and in a
vent pipe to show the landfill has water coming in and going out, as evidenced by the pin holes
and bad place in the seam of the plastic liner. Yet the moisture content and permeability of the
cap is almost the same as it was originally, which would not support the theory of "large cracks"
in the cap. Lack of these cracks is further supported by the methane sampling.
The Working Group wants to show that the state cannot be trusted to keep the landfill
safe, as evidenced by its non-compliance and its failure to properly construct the leachate
collection system, and therefore, it must be detoxified.
IX. ANTICIPATED SCHEDULE
Under the current contracts, we anticipate having a report on the site investigation from
the Science Advisors this summer. The Phase I detoxification studies are expected in August,
and we should issue the contract for Phase II around September 1. The Phase II report, which is
the preliminary draft design, should be received in November. This report would be reviewed
and the Working Group would put together a strategy for the 1998 General Assembly to receive
funding.
Should funding be received, we could issue a contract in the fall of 1998 and begin
detoxification in early 1999, if the technology from the current study is chosen. The process
would be lengthened possibly by one to two years if other technologies are considered.