NCD980602163_19971218_Warren County PCB Landfill_SERB C_Joint Warren County and State PCB Working Group, July - December 1997-OCR

SENT BY:ETG ENVIRONM~NTA, rnc;12-18-97
, 7 ( , . r --" 11l ~ K ~
ETG t~-L
Envlmnmental, Inc.
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SENT BY: ETG ENVIRONMENTAL, INC; 12-18-97 2: 4 3 PM West Chester, PA-+
MEETING SUMMARY
Place: NCDEHNR Offices -Raleigh, NC
Date: November 14, 1997
Attendees: NCDEHNR, Division of Waste Managment
Purpose:
Background:
Bill Meyer Mike Kelly
Matt Gamble Bill Sessoms
Ed Mussler Pat Williamson
BF A -Pat Barnes
Hirschhorn & Associates -Joel Hirschhorn
ETG Environmental -Steve Detwiler, Mitch Moss
ICF Kaiser -Pat Sullivan
Kickoff Meeting For Phase II Preliminary Design For Full-Scale
Detoxification Of The Warren County Landfill Utilizing Base
Catalyzed Decomposition (BCD) Technology
The Working Group for the Warren County Landfill conducted a thorough
evaluation of possible technologies for detoxification of soil contaminated with PCBs and
dioxins/furans. The USEPA patented, ETG Environmental, Inc. (ETG) liceused Base
Catalyzed Decomposition (BCD) process was one of the technologies selected for a
Phase I pilot study. Based upon the success of that study, the ETG/ICF Kaiser (ICF)
team was selected by the Working Group and NCDEHNR to perfonn the Phase II
preliminary design. This meeting in Raleigh was convened to develop an action plan and
a detailed report outline for ETG/ICF to begin preparations of draft sections of the Phase
II report for l'eview by the meeting attendees.
Key Topics of Discussion
1) The NCDEHNR and Joel Hirschhorn reiterated the two primary goals of the
Phase II report, including the generation of an accurate cost estimate to obtain funding
from the legislature and to form the basis of an RFP for full scale landfill detoxification.
The state emphasized that success on obtaining Phase II work does not guarantee success
on Phase III work for ETG/ICF.
2) The Working Group Science Advisors (Pat Barnes and Joel) outlined the
progression of the project including the phase II (preliminary design) report, final design
(possibly including additional investigative work outside of the landfill) and construction.
Emphasis must be given to positive community involvement (jobs, economic benefit to
SENT BY: ETG ENVIRONMENTAL, INC; 12-16-97 2: 44PM west Chester , PA-+
economic benefit to businesses, educational opportunities) and potential for impact on the
community during construction (air monitoring, storm water management, etc.) A
number of issues for the Phase II report were discussed (see attached memos from Joel
and Pat).
3) Discussions were initiated relative to project duration and soil and air treatment
standards. Agreement was reached concerning a project duration of approximately two
years from constructimvdetoxification activities. Agreement was reached on soil
treatment standards of 200 part-per-billion (ppb) for PCBs and 200 part per trillion (ppt)
dioxin toxicity equivalent concentration (TEQ) with deed restrictions on the final use of
the property. Agreement was reached that air emission standards would remain as
required for Phase I activities. ETG reiterated that meeting these air standards would be
no problem1 and that improvements to the vapor recovery system (from Phase I study)
would be incorporated into the full scale treatment.
4) A detailed outline was developed, which is included as an attachment. Due to the
necessity of having a document tailored to the Warren County Project, collaboration
among the State, Science Advisors and ETG/ICF is essential to producing a quality
product. A detailed Executive Summary will be required to assist the effort to obtain
ftu1ding from the legislature.
5) The State indicated that they would nQl support sections of the report which stated
that the landfill was leaking. They did, however, acknowledge deficiencies in the
construction of the landfill, and reiterated their commitment to detoxification of the
landfill. The State expressed the requirement that no ongoing operations and
maintenance would be conducted at the site after detoxification. The possibility that the
clay and liner under the landfill would need to be treated was discussed, and will be
evaluated further. The ultimate disposition of the synthetic (plastic) liner was also
discussed, with possibilities of on-site or off-site disposal. The disposition of
approximately 400 tons of cement kiln dust used to solidify water in the landfill was also
discussed. ETG reC!ommended that this material be treated on-site, as opposed to off-site
disposal.
6) Current plans call for interim review of the draft sections by the attendees. A
draft report is expected to be issued by 01/15/98, with the final report by 02/01/98.
Efforts to obtain funding can begin in earnest once the final report is available.
Immediate completion of contract documents is required to meet this schedule.
SENT BY: ETG ENVIRONMENTAL, INC; 12-18-97 2: 45PM West Chester , PA➔
Phase II
Full Scale Preliminary Design
Report Outline
Section
Executive Summary
I. Introduction
1.1 Purpose
1.2 Scope of Work/Objectives
II. Background
2.1 Mapping
2.2 Project Description
2.3 Geologic/Hydrogeologic Conditions
2.4 Topography
2.5 Selection of BCD Process
2.6 Federal Regulatory Overview
ill. Design
3.1 Purpose of Preliminary Design
3 .2 Pennitting/Health & Safety Issues
3 .3 Site Preparation/Infrastructure/Utilities
3 .4 Mobilization
3 .S Excavation (Health & Safety Issues -Air Monitoring)
3 .6 Performance Demonstration
3.7 Treatment (Health & Safety Issues -Water Content)
3.8 Air Monitoring (Health & Safety)
3 .9 Quality Assurance/Treatment Standards
3, 10 Decon/Demob/Site Reclamation
3 .11 Security
3.12 Schedule
3 .13 Contingencies
IV. Community Involvement
4.1 Community Oversight/Funding
4.2 Economic Benefits (Training, Local Businesses)
4.3 Educational Benefits
4.4 Emergency Response Training
Action
ETG, ICF, Science Advisors
ETG,ICF
ETG, ICF, Science Advisors,
NCDEHNR
ETG, ICF, Science Advisors,
NCDEHNR
Science Advisors, ETG, ICF
SENT BY: ETG ENV IRONMENTAL, INC; 12-18-9 7 2: 45PM
V. Cost Estimate
5 .1 Assumptions/Uncertainties
5.2 Costs
VI. Appendices
A. Drawings
B .. Technical Contract Specs (Outline)
C. Engineering Calculations
D. Health & Safety Plan (HASP-Outline)
E. Spill Mitigation & Contingency Plan (Outline)
F. Site Assessment/Permitting Plan (Outline)
West Ches ter, PA➔
RCTIUIT'/
1 ·-::• 1ci 19o::i 7 ~--·· _ _,, ·-:, 4 .r:..
9197153605 SOLID WASTE DIU
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DIVISION OF WASTE MANAGEMENT
TO:
FAX:
FROM:
COMMENTS:
919-733-4996, Ext. 201
Fax: [phone]
FAX TRANSMISSION COVER SHEET
--------------------
TOT AL NUMBER OF PAGES INCLUDING COVER SHEET: l
DATE SENT: lf l'l/t.J J
-!DEH~R I ENVIR. EPI. TEL:[phone] Dec 09,96 13:27 No.002 P.02 J
State of North Carolina Department of Environment, Health and Natural Resources
Division of Epidemiology AWA _____ ,
James B. Hunt. Jr .. Governor
Jonathon B. Howes, Secretary
Michael Moser, M.D., M.P.H . DEHNR
December 9, 1896
MEMORANDUM
TO: Bill Meyer, Director
Division of Waste Management y:,-71<!!? .
THROUGH: Stanley Music, M.D., OTPH (Lond .), Chief , ---·-z._.,,,:1
Occupational and Environmental Epidemiology Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist ti(J;(µ-
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 US EPA study
"Measurement of Fugitive Atmospheric Emissions cf 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 msy be present at the site. Therefore, a worst-case risk
estimate is provided based upon the concentrations reported at the following locations:
L9cQ!ions
beside main vent
nearby house
fence line, downwind
0 n Rrw ?/687. RolelQh ,
lconc. detected}
11 ng/m3
12 ng/m3
50 and 71 ng/m3
N{iC
Excess Cancer Bisk
1x10,t;
1x10·5
5 to 7x10-G
An Equal Opportunity Affirrnative Action Empie
DEHNR I ENVIR. EPI.
,f TEL:[phone] Dec 09,96 13:27 No.OO ? F' L17 -.. ...._)
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 1x10·11• However, the actual risk at
the site is most likely lower than 7x10..o because the PCB concentrations present at the
site are most likely lower than reported. The PCB air concentration associated with a
1x10·11 excess cancer risk (target risk) is 1 O 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.
RECO,MMENPATIQNS
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 1 o-o , 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 haye any questions at 715-6429.
LKW:lp
Attachments
cc: Dr. Stan Music
Mr. Bill Pate
DEHNR !ENVIP. EPI. TEL=l-919-733-9iss
Draft for Public Comment
LJtHNR/ENVIR. EPI. TEL:[phone] Dec 09,96 13:2s No.002 P.os
\'. t.. •• :· f'CBs
5. POTF;NTIAL FOR HUMAN EXPOSURE
de~_r:\ding orgm1isms or, altemaLively, by adding a gcm:tically engineered strain lhat combines IIH:
activities of mixed cultures (Untcnnan et al. 1989). Since PCB d(~grndution is n co-me1abolic
process, the <.1ddi1ion of biphenyl (lf monodilorobiphenyls as growth s11bstratc.~ to i-upply tht
nutritional requirements nnd to induce the catabo)ic pathway is r~quin:d to sns1ain the r,rowth of rhe
di::grnder population for biodegradation of PC...'Jh in soil (Guilbeau!! (:I al. 1994; Hickey et al. 199] ).
ln addition, the presence of ~urfacc active agents has hl~e-n shown to increase the. hioavailability of
PCBs lo lhc microorganisms. However, enriched cultures were unahk to hiodcgracle PCB
congcnl~rs containing five or higher chlorine substitution (Guilbeault et ,11. 1994 ). 1t has IK:en
reported that the mono-, and di-chlorobenzoate, and possibly other higher chlorobenzoates fonrnxl
from aerobic degradation of PCJh act as inhibitors towards fut1her degradation of higher chlorinated
PCBs (Guilbeault cl al. l 994 ). Therefore, the efficiency of PCB degradation is nnt only controlled
by the enzyme substrate selcclivity pattern , bul also by the metabolite prodm:tion pattern .
5.4 . LEVELS MONITORED OR ESTIMATED IN THE ENVIRONMf;NT
5.4.1 Air
The atmospheric concentrations of PCih in various locations art: given in Table 5-2. The range of
atmospheric concentrations of f>CBs in mban areas is 1 .. 10 ng/mJ wilh a incan of 5 ng/m 1
(Eisenrtich et .ii. J 992). The atmospheric concentration~ of PCBs in 1wo rural areas arc in the rang e
0.2-0.95 ng/m3 with a mean of 0.6 ng/-and in two remote. areas are in the rang;cl()_,,2-::.oJ 8
ng/1111 with n mean of <0.1 ng/m' (sec Table 5-2). The range at~-~;;~--~~,'sphcri~ ·pe,13
concentrations in other locations arc as follows : 0.01-0. 7 ng/rr( and 0. l ng/m '. respectively, in
mariiH9coastal areas; and 0.2-4.0 ng7m3 and J .0 ng~~;e~pectivcly, ;;~;~h~ Grca1 Lakes
(Eiscnl'elcn et at7994""w,th the available data, it -i~-diff:ic1~l~-1~ cs1abli~h -1hc trend in armosph-~ric
Peft-tnifcci1tra1io11s ovt:.r the last two decades following 1i1c r;~sation of PCB production . Thi s is
because monitoring data indicating the levels of PCBs in air at tlH~ same. location over this time
pcriou are. still lacking (levels from one locatic,n cannot be compared with levels from m10Ih~r
because of differing emission sources), and the recent ~tudics (Schreitmucller anti Dallschmiter
1994) generally report the atmo!-pheric concentrations of the congeners and not lht: 101111 PCB!-nr
Aroclors. On the h11sis of typical atmospheric conccnlrntions of PCJh in pn;-l 980 smnplc:--
(Eisenrcich et nl. l 9Rl) and the !eve.I.~ in more recent years ( set Table 5-2), ii can be CC)lli_:lu<kcl rh ~:
PCH <.:onccntrations in air rnay have. shown a slightly decreasing trcn,l frorn the prc:--l 980 tt1 po~t-
DEHNR I ENVIR. EPI.
·(£
---
TEL:[phone] Dec 09,96
5. ron:NllAL H)H HUMAN EXPC>SUnE
TABLE 5p2. Atmospheric Concentrations of Polychlorinated Biphenyls
·----···--· ·--·--·· --·-----• ... -
ConcentrationN
Location Year (ng/m~) Reference ----· --··-----
Boston, MA 1978 7.1 Bidlcman , 981
Columbia, SC 1978 4.4 Bidleman 1981
Columbia, SC 1985 2.3 Foreman and
Bidlcman 1987
College Station, TX 1979-1980 0.29 Atlas and Giam
0.11-0.48 1987
Newport News , VA 1988 0.39 Knap and Binkley
(0.185--0.794) 1991
Bloomington, IN 1986-1988 Summer: 1.74-3.84t' Hermanson and
Winter: 0.31-0.62 Hites 1989
Chicago, IL 1989-1990 13.5 Holsen et al. 1991
(7.55-20.26)
Adirondack, NY 1985 0.95 t(nap and Binkley
(0.339-1 .359) 1991
Chesapeake Bay 1990-1991 0.2, Leister and Baker
(0.017--0.508) 1994
Lake Superior 1986 1.25 Baker and
Eisenreich 1990
Rural Ontario, Canada 1988-1989 0.2 Hoff et al. 1992
(0.55-0.823)
Antarctica 1981-1982 {0.02-0.18) Tanabe et al. 1983
Arctic 1986-1987 0.02 Baker and
Eisenreich 1990
1Values are given as mean concentrations. The ranges are given in parentheses.
1.values at three different sites.
·-· . -··
J2 :03 :96 13 :01
ft
~
DATE:
TO:
'6'919 5-11 352i NERL : A~IRD : YB
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EXPOSURE RESEARCH LABO RA TORY
AlR :MEASUREMENTS RESEARCH DMSION (tv1Ail.. DROP 44)
RESEARCH TRIANGLE PARK, NORIB CAROLINA 27711
TEI.'El'HONE 9l!M41-306S FACSD.fil.E 919-541-3527
E-MAIL lewis. [e-mail]. epa. gov
FAX :MESSAGE
3 December 1996 NUMBER OF PAGES: 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:
[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. 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
outsid~ the Agency. Therefore, our statements that PCB emissions from the landfill were
negligible at the time of the study were supponed 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, ~ven if the measured air values were real. It should also be noted that PCBs were
12 1 03 :96 13:01 'B'919 5H 352i NERL /AAfRD :.llB [4) 1)1)2 :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 Warr en 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 W a.rren 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 have declined greatly once
that matter had decayed. Therefore, Dr. Hirshorn'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).
Anachment
12-'03:96 13 :ll:! "0'9HJ 5-ll J5:!7
SECTION 2
CONCLUSIONS
10 1.11_1 ;5 : uu;J
The conclusions drawn for results of this study are sumnarized below.
{l) 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),
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 the atmosphere throughout
the U.S. are in the range of 5 to 10 ng/m3.
(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
' ·. . ....
D~~bet 10, 1996 ... : ....................................................................... by FAX (fi\'e pages)
To: Technical Committee
From: Joel Hu-schhom
Subje~: ~esponflCS to EPA Jetter of 3 ~er. Pteviously provided
In examining the EPA lett~ to Bm Meyer I focused on the m&in points and I hive
concl1.1de<! that I have no rea:on to abandon or change my original .&.cling, and ooncluaion&. 1
Ju,e faxed a requ~ to the ~uthor of the EPA letter for a C.OP)' oftlw original contractor (BatteD.e
Mttru:>rial Institute) report, which, :f proV\ded, may reveal other interestini information. It is
imponant to em;,hame that only two documents have surfaced regarding the origmal 1983
measu.rcm~nts b_y EPA, the published paper from 198.S md one pag; of concl\lsions n-0111 what
'£PA now says was a contractor report prepared for it. Only the latter would have the testing
details allo..,..'Ulg the. mon complete anaJysii of v,;hat actually happened during the testing.
'EPA h.u said that "our statements that PCB eJD1ssions from the Landfill were negligibl, at
the time ef the st.idy were ,uppc,tted by the highest level of t"bni~ review." The problem is
th&L th~ pape!: itself: u r noted pre'\-iously had a logi~ inco.osisrency betweet1 two of its
m:atereents, o.ne saying th, w .. uion, were ~egligible and the othtr that the :missiC1ns were at low
leveis Cle.art,-, PCB emiuioni were mea£:Ured .and reported int.he paper. Any rt\iewer of the
paper; how~,,er. auy h•ve missed th! importance of the two statements u,d, moreover, may hive
!nterpreted tht> statement about emission5 from the Wa!'TC!) County landfill being negligible as not
ne,essan}y related to health effects. ID fact, the paper presented no information about PCB levels
anc heah.t effects. Tht paper was t1'out pCB emi1si0t1~ from different land disposal situations.
oot poteutiaJ health impacts.
EPA is nl)v. defending itsel£b)· U)'iD& that tho ict11aJ measur~tS of'PCBs Mwtre likely
f,l~c-positivc rcAh~.'' This .is a rc.owklble sutemeot. It wu not made iI:. the orign,al paper, nor
is th~re a~y cvido:icc to mpp.-,11 this c-0nterrtion. Now, nPA cll.ims that "It would be cl:ar to any
a.nfllyti~s.l ,;bcmi~ or aoyone with envir~tal monitoring e,cpertist thst these were likely false-
po.s:itive resuh:t n Notice the qu.wner "likely." If &eientists have a very sound technical reason for
beiic..,mg that e~erimentaJ data are false•positive resuh, (i.e., 1 &ding of 2 chemical when none
;s re21fy pr~sent), they either would not repon the data in a publication or they would clearly
uti\Allate why the data should b~ 'l..iewed as false posnives. Any objective analysis oftbe EPA
published paper "ill &how that there tfi; no aus,emon or proof that the reported ambient air PCB
lc:vels were nlse.pow.-es. 'For EPA to now cla.im that ks data were likcl;· fals.e-positives is
cis±nge:inous at best. ~d for it to attfflll)t to create explanations now but not in the pu'blisbed
par,er is not normal profession&! conduct.
A pan ofilie c,ment :.outeution about fal~e-positi:ves is that if the data ""ere 11rea1" •• and
·-· ......
PCB iJJOF-l'.lNG ;3ROUP Fa:x :919-257-1000 Dec 10 '% 16=15 F.05
they c:ertaicly were real enough tor the EPA pm-soa.s to report and rublisb them ~• thc::o the more
vo!atile Atoclor 1242 rather thu the rr~uured 1260 would have been measured. But there are
varic,us pcs.sibJe e>.'J)laoation. of \\rhy the less vol:.ltile and not the mote volatile Aroclor could be
fol.!lld in 1mbiezit air monitoring. These possible reasons include: vwbl~ r;,,es of PCB emi.ss:io1u
&om th.t landfill it different time~ malchtg a small number of measurements in ambient air aot
refective of the cumulative types of emissions over time; a greater loss of the more volatile
A.rc,;lot prior to the time of the measurement especiaDy becaus.e ofthe mny months that the
WL'1.cs were c,q>osed to tht atmosphere whcm they were first dumped on the roads and continuing
through their di.posal in the open pit; different envirozmieutal interactions dwiDg the air trau.spon
of the vapors. k1.dmg to different variatiou oftbe PCBs reachmt a pea point ofmeAsmement;
the gr~ter water solubility of 1242 vfrau, t 260, by • factor of abovt J 00, that .in the vecy wet
nwm.ils m$ide the latidfill could e,ti,lain why ~tisiderablc 1242 could be trapped iJl (he water and
not relea!-e<l to the ~r (i.e . the dilferenee in water solubility is much greater than the difference m
vJpor pres..~re); more of the 1242 may have bten biodegraded over the tttirt time the wartes
exiited prior to the gas v11porization.
The letter from EPA note, that the more nonnal higher l~el of 1242 over 1260 wu found
in th~ m.1m and upper leach.ate vent pipes. But of c.ourse it docs u.ot oott that tb.e relationship
~ei:ween the tv.·o Aroclors was not the non:oal t}pe m three other categories reponed .in the
orig.in.! published paper (lower leachate port and two small vents). Moil interestingly, for
~xa1Dple, one of the mw1 vents (E) had Aroclor 1260 levels twice that of 1242, and 2.t levels tliat
~e detectit,i, i~sue is i.netcvant. Cleviy the~ are er.niscfons meuured in the sm1U veot wbe1e a
l;..ibble h•d fonncd in the top plutic liner lfmore 1260 th1.t1 1242 clearly came from this source
~flandfilJ gas, then wh>· does EPA make s-.ich c issue of find.mg more 1260 than 1242 at any
otf..sitc location? EPA al.so imkes the mistake of a"'1Jlling that a nnn•detect finding i~ ~4u.at tn
zero concC!ltration ,. when in fa.ct that is a scientincaJly incorrect and improper assumption to
nah. At ill the other at::\bieot testing locations where no positive ltvds of PCBs wn-e reported,
tbe values m•y in fact he )()mething less tlw1 the detection limit.
The letter from EPA also attt.mpts to mag a point that the ambient lir levels fotmd "did
o,it appe,z corrdate (sic) \\ith pro,dmitj· to the vents.'' In actual fact, there i£ problem in EPA 's
mterpretation because i:mnediateily after the statement cited, the paper tlsc said "The two
lr.aXJlllJ.a1:! levels were found ~8 m downwind of the main vent . '1 In other words, of the four
posi!i"c finding~ of PC.Bs in ambiem air reported as 11 11, 12, SO, and 71 nglm'", according to EPA
the teAJings of SO and 71 (now cWmed as not re.al, but inalyzed nevertheless by EPA) we.re net
at t~c ho-.isc. which was, accordi:o.g to the paper, ,ome 1000 m away. Accordmg to the ptper, the
high.ist lev~l mea'11ted was at the fen~lint and logically £O wH the second highei;t level found .
Tbt.t leaves two very si.inilu but lower PCB level$ foWld at two other 1oc.uons, which accord.mi
to Ttble TI oftbe paper were at the nearby house a.od beside the main vent. The only
mH~renlent, ttiereforc, that is somewhat irTegultr is the lower level found beside the main vent.
because it seem~ mucb too low (i.e., ii there are a sufficif2:ltly luge number of mumrements one
expects to find the hightf:t ooncentntions at the ~urce, with steadily lower concentntions at
increasing ·iisur.c.es a"'>' 5-om the SOt!TCC). But the anolD&ly is the very low reading ne,1 to the
2
Fa.x:919-257-1000 Dec 10 '96 16:16 F'.05
1lWl2 vent, especially because much higher le\lels were measured in.Ii.de the ~in ..-eot and EPA
uid that there was a pci.itive ga& fl.ow with PCBs being emitted .from the mam vent Ho~·ever,
su~b low readings whcr~ higher levels are expected CIA be explamed by, for example~ van&;ble
emission ntes, variable wmd co:id.i:tion.s., and poH1"bly different times ofmeuurements at different
lo~ltions
mdHd, EPA w a big problem trying to e,cpwn why the high ltNets tound inside the main
v\?alt did iot translate mto much higher levels "beside main vent" \\-bicb pre$Um8bly was.
ac-c~rdil'lg to the 6.gure sbowiog th.e sampling locations, only l m away. The problem of course is
that variable wind eonditions will lead to ,, .. sttv different levelJ measured at any given location,
unless many more meuuretnent, arc taken ov~r time. The original paper noted that wind speed
"•ricd from 0.04 to 6.6 mis, and th.at the 1D:1biem air monitoril'.g was oot done on the same days
that te&1m~ took place in the vents. The latter fact sugrests th!t highly variable emissions from
the landnll Weft occurrina, expl.ammg why a Vet) low readms might obtained near the main vent.
Al$0, the paper indicate.s that the ambient air monitoring occurred on different days, explaining
why PCB levels would char,ge signmcant}y for difl'erent locations.
The original EPA papt1' said that ambient air da.ta were given in its Table ll and that "only
four oftb~ 39 ambient .air sample, ~-zed oontained detectable quantities of PCB" and tliat
"duei: .!tamples were positive for Arodor 1260 onl)· (at 11, 1~ SO, and 70 a.g/m')." The problem
is that .in Table-D there ,re three footnotes for each of the three data showing poiitive levels of
PCBs detected. as follows:
b~side ~ vent: "1 One of in measurements above detection limit."
fenc: line, downwind: "h Two of' 13 mea~ements 11bove detection limit (0.05 and 0.07
'-lg/m'). ,,
neub)· house'. •• One of Six measw:emmts above detection limit."
There is a di~repmcy betwCCE these footnotes and the bod>· of the paper's text. The total
cumber of measurement sc-ems like 25, not 39. Another problem is thit the tabulated data
indicate tll&t the detection limit was lO ngtm3, but tht sec()nd £ootnote indicates that the det.ction
lhni\ was from ~Oto 70 ngini', and both the original paper and the reoent EPA lertei-said that the
d-=tcction limits were from 10 to 20 q/m3· while the p■ge of c;onclusioas from EPA's cowactor
repo.rt said the detection limiu were 6 to 10 ng/mJ. Only cJose examination of the original
l.Ab~ratory d;ita meets ihat might be in the Battelle ocmuactor repon co111d resoh:e these
discrepancie,.
EPA', letter cltims wt ,.the v~t pipes were not the source of the PCDs detected in air,
even 1f the measured air values were re,l. '' First, EPA is acknowledging that the data may
acrJ.aily be accurate positives ind, second, EPA is speculating that some Other source nf PCBs
e,us1ed around the landfill. In fact, in its original publi.Ehed paper, EPA said that "air levels were
at or nu.r backerou.nd" at the Wure:n County landfill, \Wich &e--ienti.S~ally is a very different
ug-.:ment than its preKDt ooe based on claiming that the 6.odings were false-positives . In other
3
Fax:[phone] Dec 10 '96 16:17 F.07
word&, originally EPA disregarded the .levels of .PCB.; it meuured m ambient air by arguing they
were "at or uear ba.ckpound" and now by arguing that they were not reall)' positive finclingi . But
in fact, e'\'':tl the £PA tr~t lb.at the measured (real) PCB level&were o~· bacqround does
not stand up WJ.dcr cloae 11Crutiny.
EPA cites the general data for the U.S. about hiJhl>• variable amhimt air levels o(PCBs,
\.\itl: the maximum being 10 nitm', wh.ich i£ actually less tbu all four positive findings reponed in
th~ i,a.pcr (11, 12, ,o ud 71 nglm') More importantly: the nn!e given iD EPA's letter (and
~eo origilwly in EPA', contuetor report, but not the pub1ished paper) does uot distinguish ihc
typ~s ofiocations at which PCBs have be~ measured Inf.ta. the b.igber level$ of ambient PCB
l~·el!I cotTes-pond to more industrial and wban areas, and areas near any type of incineration. of
wi&te. not the rural area at which the Wa.nen County landfill u located. Lcgicall}·, the low c.d of
the range report~ namely S ng/m'. might be appropriate f.or mch I rural locatiou, but the correct
scimt:.fic methcd in gucb an mve.ctigation is actually to take measurements at a subsuntial di&tance
from the lfrely point source (ie., the landfill) b\it within the loeal geographic vea. Then, this
experimental ba(;kg.:ound levef appropriate for the fflldy should be wed. But assuming that the
low e!ld of the nati01Jal tl!)Jc my be ~ppropriate, the four positive findings are significantly
higher, widumining EPA's IJJWJleDt.
The letter &om EP.4 claims that the ''The Warren County site wu brand new and should
h:.\ e been emitting it a m.a>.imum rate." This is sheer nonseuse and perhaps tnore than any othe-r
EPA .statement demonstrates that EPA penon1 are trymg very hard to co"·er up tbe truth. Wily?
The:-e are variovs sound, sdcntific reasons why land.611 emission rates were not n~ssarily the
highest at thr timt of the .EPA meuuremezits, in~ludmg: th~ tempenture at the time was low (-1
tn -1.i~c) relative to summer periods -...ium high emiui0t1 rates would occw-: the complex mi.\'tU.re
of materials ~ctually placed m the lai:d.fill 111d the disposal process nece"arily traps PCB vapors
that take time to End tr:AMport pathwJys; the Juse amount ofwaterprese-nt m the materials
buried 11\ tbe land.filJ from heavy nmfalls would slowly sink and accumulate to the bottom of the
bnd.fill ,md th.e intern~ dr)ing process (for M>me of the buried waste) would more easily allow
PCB vap,Jrs to escape over time.
Lutly, EPA is arguing that its computer modeling (the details of~ch were not given in
th~ pibfo,hed paper bU1 m.ly be in the contractor report) sbowc:d that calculated (not measurtd)
levels of PCBs at some di~ADoe away from the l.a.nd.611 would be "far below the detection
c:1pabiliry of the sampl!r employed " But such dispersion modeling is based on mmy teclmieal
assumptions about the source of e:mssio.:i~ and mmy cli.i:!1&tk conditions that cannot be assessed
at this po)int. Implicitly: in it& otipw published pap,n, EPA was argum: that the theoretfoaJ
modeling .it.owed dau below The PCB levels actually 1•teasuHJ tt disuoce, •"-'IY from the
landfill. But EPA did ~•)tactually sa,1 in its published p,per that the :modeled data wer~ below
bad·:.grou.nd level&. M?r~ importmtly, th! eore bui~ for EPA'• modeling were only three
meas\lrements ,,fthe gas flo"" from the main vent and MJme t.m1-'tat~J data fur ,~at was measured
in L'te .nu.in vcot. leading to what EPA descnbed ,~ an annge gaseous PCB emission rate. Toe
p10blem. of C-OW'~. is that there were only a smaII number of meuureme:au dwing a wmter
F CB o.lORK ING GROUP Fax:[phone] Dec 10 '95 16:18 P.08
period, reducing the n:liability of the specific•• used by EPA m its modeling and un.dcrmming
any objective confidence in the resuhs of the modeling. In tzuly obj~ive and fair work, field
me~wemects of air le\-'els of a to>eic substance are used to evaluate whether the modeling is
accurate and reliable. But m this ease, there was not even an e,cpliQt analysis by EPA ofiu O"'-ll
positive measu.-.m,enu and it, modeling Tesults.
Jn conc.buioo. the i,mpgrta;at deficiency of the EPA work w11 diet tht>· oner
d.e.tidc.d.1bat then wu syfflricnt ua,on. to per[orm much more complctt tcstins for PCB
cmi,uiocs from the )lacrcn Coupo; laodfiil, IPA. of counc, had I conflict of intcrcu,
b~usc It had approved tbc WJ.n:eA Counn, PCB IandfW and the obj«tivc of the 1983
ao,dy ~ccm3 to baye...b_eco to prove that 1ovcr11mcnt e,nctiontd PCB 1,ndfills were "safe"
rclatiy~ to @~..o..tr__o.lltd toxic wuit ait" with PCBa that rcguh;cd dnJU.U!, Since the
~tT-e.tt Coun~y PCB t,aadfiU n:ss tbr cleanup {or tbc otitinal PCB road dumpiar •imati0D
IMl_I.P A approved and fund«!. it dc.atb· was not in EPA '1 intereu to re.port a,nificaot
.aruS pot.cntia.11)' danuroue fuels of PCB air cmis,iana from iu controlled ltndfdl. Aho.
EPA'! i:,ubliahs=d PIPtt, 3uhm,ittcrl far publication ;o December 1984. about two ytars aftt,:
the landfill w11 conctrutied, deuribcd the Warren Co11nty landfill has h1vin1 the
pcrforaud pip,u,um tb11 we now know ms Dot insuUed, EPA 's description of lbc
landflU;, nat0:1>f·th.e-1rt wu consistent with what EPA :wsnte,d to portray, nsmdv a
'-IUJ_b:Qlled landfill that b,x-'.0Jlll).ID$on would show how bad the uacontroHed Indiana PCB
sit-C$~t. But £PA', description wu inascw:uc and. pcrbuu, iotcntioa1llY so it u the
l.Ultc nvw dair.u, tP.lJtuJf 1gpro-.,e,d a cb•DH in the daign of the Warren Counn· l1ndfill w,, wou,td have had to ~c,ur f.n J98l and that allowed the statt to omit wine the
pctfout.ea iucbatc caJ1ection Gioe o·stem at thr bottom or the landfill.
5
12111 1es 1~:B9 '5'919 541 3527 NERL/ AMRD /~IB
DATE:
TO:
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EXPOSURE RESEARCH LABORATORY
AIR MEASUREI\1ENTS RESEARCH DIVISION (MAIL DROP 44)
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
TELEPHONE [phone] FACSIMILE 919-541-3527
11 December 1996
Bill Meyers
E-MAIL [e-mail]
FAX MESSAGE
NUMBER OF PAGES: 2
Fax No.: 715-3605
Telephone:
FROM: Dr. Robert G. Lewis
USEPA (MD-44)
Research Triangle Park, NC 27711-2055
SUBJECT: Response to Hirschhorn's Latest Comments
MESSAGE:
(4] 00] /00:!
I will not dignify Dr. Hirschhorn by responding to his latest attack on the quality of the EPA
monitoring study at the Warren County landfill and my scientific interpretations. It is obvious that nothing
will persuade him to abandon the faulty reasoning that he has committed himself to in order to convince
the citizens ofWarren County that they are at risk.
I will, however, provide you with my biographical sketch in support of my credentials and suggest
that you ask him to do the same. I can send you my full C.V. (28 pp), if you wish. I believe that I am
v.ridely recognized throughout the world as an expert in environmental monitoring, especially for organic
compounds in air. I wrote the defining chapter on sampling for organic chemicals in air for the American
Chemical Society's Professional Reference Book, Principles of Environmental Sampling (L. Keith, ed.),
and am currently writing a book on the subject for the ACS. I have also authored or coauthored eight
ASTM standards and two ISO standards on monitoring methods, including one on the methodology
(updated) used in Warren County (ASTM D 4861). Furthermore, Battelle Memorial Institute, which did
the field v:ork at the landfill for us, is one of the leading environmental research institutions in the U.S. I
would suggest that you get the opinions of two of the world's leading PCB air monitoring experts as to
the validity of our conclusions and Dr. Hirschhorn' s arguments. They are both very familiar with my work.
Dr. Terry F. Bidleman Tel. [phone]
ARQP Fax. [phone]
Environment Canada
4905 Dufferin Street
Downsville, Ont., Canada M3H 5T4
and
·Prof.Ronald A. Hites (current editor of ES&T)
School of Public Health and Environmental Affairs
Indiana University
10th. & Fee Lane
Bloomington, IN 47405
E-mail: [e-mail]
Tel. [phone]
Fax. [phone]
E-mail: [e-mail]
'
'5'919 541 3527 '.\ERL/AMRD /~IB [a) 002 /()1)2
Biographical Sketch of Robert G. Lewis
ROBERT G. LEWIS is a Senior Scientist in EPA's National Exposure Research Exposure
Laboratory, Research Triangle Park, North Carolina. He is responsible for overseeing research
focused on new sampling and analytical methods for pesticides, PCBs, dioxins and related
semivolatile organic chemicals and for their application to total human exposure assessment.
Dr. Lewis received bis Bachelor of Science in Chemistry from the University of North Carolina,
Chapel Hill, North Carolina in 1960 and bis Ph.D. in Physical-Organic Chemistry in 1964 from the
University of Wisconsin, Madison, where he was a National Science Foundation Fellow and a
~ational Institutes of Health Fellow.
FoUovving six years 'With industry, Dr. Le'Wis joined the EPA in 1971 and held the positions of Section
Chief from 1971 to 1978 and Branch Chief from 1978 to 1993 . He has done substantial research on
monitoring and exposure assessment methods for organic chemicals in air and other environmental
media ::md in human and biological tissues and fluid5 . He established and headed for 12 years EPA' s
first ambient air methods development program. He was a member of EPA' s first task force on PCBs
in 1972 and in 1983 was appointed by the Governor of North Carolina to the Intergovernmental
Working Group on PCB Detoxification.
Dr. Lewis has authored or co-authored more than 200 journal articles, books, book chapters, and
other scientific articles and reports on various matters of environmental concern. He bas been
mvarded the EPA Bronze medal for Commendable Service t'Wice and has received four Scientific and
Technological Achievement Awards for outstanding journal articles.
Dr. Le,\is is a member of the American Chenucal Society (since 1958), Air and Waste Management
Association, American Association for Aerosol Research, American Society of Testing and Materials
(Fellow), International Standards Organization, Phi Beta Kappa, Sigma Xi, Alpha Chi Sigma
(Chemistry), Phi Lambda Upsilon (Chemistry) and Delta Phi Alpha (German). He has been listed in
American Men and Women of Science since 1966. He has served on numerous committees and work
groups concerned 'With environmental monitoring, exposure assessment, and the chemical profession.
He is currently chairman of ASTM D22.05 .02 on Organic Chemicals in Indoor Air, U. S.
Representative to ISO on Indoor Air, Research Area Manager for Environmental Measurement
Methods for the EPA Residential Pesticides Exposure Research Program and an advisor. to the EPA
National Human Exposure Assessment Study (NHEXAS), NCI/EPA/NIEHS Agricultural Health
Study, the Lower Rio Grande Valley Environmental Study (NAFTA), the Great Lakes Air Deposition
Project and the Pesticide Spray Drift Task Force.
·~1
I,
-\ December 16, 1996 ............................................................. by FAX (5 pages)
To : Technical Committee
From: Joel Hirschhorn
Through: Doris (for distribution prior to WG meeting as muc.h as possible, and to all Worlong
_Group members at meeting ofDec. 17)
Subject: Review of orieinal EPA contractor report on PCB air emissiow
1n response to my request~ I received the Final Report on Ambient Monitoxing For PCBs At The
Warren County (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 situlltion. lu
general I have found even more problems and reasons to be concerned about the entire hlstor1 of
this situation.
r,1v latest review, analysis and conclusions strongly support the position or the Tcc~-u
Committee in its re~Qi_nition that it is imperatin that fun disclosure of tht dao2tr..L'lf.thc
landfl,!1 be openly comn1unicated to the public; and the state iovernment through ,mother
press conference, letters to the Governor and Secretao-Bowu, appropriakltctions bein_g
taken by the state (:iu.cluis carbon filter installation and new mopitocin&)-and a well
planned r.omnmnity m,eetini: that the Governor is invited to participate in, I wanJJ.!2
.e .. mllb .. asiu that the most important recommendation presented lzy I;PA 's contracmr i!!
.1.283, calling for future periodic monitorine for PCB air releases, was !\'OT imptcmente.d...b.):
the state or EPA. ln my professional opinion this was a ullou, and scientifici'liY...wt.!fil!ll..d
decision by the state and EPA that ~urificed protection of public health to deyious.
t.2Itcrrns, like wanti112 to avoid eettine data that would conclusively dem.QJ.U.1til1.U9
}\'anen County residents and the broader public that the W111nn County FCB LJ.rulml
was dangerous. un~.:af e. and a source of uncontrolled environmental releases. J_he
recommeodAf.ion for future periodic monitoring and the test results from 1983..ro.ruud hP,ye
!oci,cally resulted io the ~tate taking the proper precautionary step of instalJing ou:hM
filters on all landfill vent,. Thl~ matter de..~uvt~ the ,itrongc.~t pos~ihle action h~"' th~
\Vorking Group to s11feguard the interests of Warren County nsident~..filLthat efftctivs
drulxification of the landfiU is actu.1lly accomplished as :,oon as po,sible, The GoyerW21
should be requested to detecmi.De why the recnmmendatiop of EPA's: ~ontractor to cond~Kt
future monitor)o2 for PCB emissions ''"' not implemented,
The report was dated August 16, 1983,.indicating that complete data were ~vailable to EPA
relatively soou after the onsite testing had been done in 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.
1
Page 3 of the report was Secµon 3 Recommendations and included the following: "In the future,
n is recommended that periodic monitoring be performed to determine tht trend in PCB
emission rates from the gas vents and lcuhatc access ports on the landfiH 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 dete<.,-tion
limits." It appeus 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, indicating that the contractor recognized
that in later times PCB emissions and releases offsite were plausibl~. In other words, the
contractor was coJTect in recognizing the appropriateness of experimentally, through further field
testing, detennining the "trend" of PCB emissions. This implicitly recognized the positive
detections of PCBs in vents and 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 conta,ned no information on the design or construction of the land.fill,
which the published paper had presented. But the contractor report did note that: "Local
residents and the Warren County Health Department have expressed cone-em about the possibility
of airborne PCB emissions from tl1e landfill 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 ... " This makes it even more questionable why the
full contractor 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. Of 42
specific measurements in ambient air, however, only two were for the nearby house.
There is absolutely no statement iu th.e entire report that in any way supports the contention
recent1y 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 report. The pubJished paper indicated four positive detections in
ambient air and clearly gave the locations of three of the.mas: beside main vent, fence Jine
down~ind, 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 rudkating that
one of six measurements at the nearby house was above detection limit is inconsistent vvith data iu
the report that indicates that only two measurements were taken at the nearby house. What is
most perplexing 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 th.an 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 10 ng/cm.
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
contractoi-report. Let me emphasiz.c that the contractor's methodology of assuming a finding of
less 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 cJear 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 variation in detection limits was made understandable in the contractor report, because the
data given showed that sampling times and, hence, sample volumes varied someVwilat, with
unanticipated lower volumes resulting in higher detection limits in some cases. In an cases, where
positive detections in ambient air were found, the detection limits we.re the lowest, maldng 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 di.ffe.rent 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 ncitatioo 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). ln 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 sp~cific test in which no reliable data were obtained. But the published paper said
that ND represented "nondetectable." This definition misrepresented the actual meaning of some
data. For example, for the lower leachate access port, the pub.lishe<l 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 iufercnce 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, \vb.ich
were calculated by assuming that ND = 0 and that <DL = DL. But using the actual 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 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 avenges and other figures are too low, because rounding was not done properly.
For example, the average PCB levels for small veut E were reported as 0.24 and 0.4, but 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," without,
however, explaining what the weather conditions were. The relative humidity for the following
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 the report presented no detailed analysis of how weather conditio.ns might 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 off site which could exist
at other times. Th.is supported the study's recommendation for additional future testing. For both
periods during which monitoring was done for the nearby house the wind 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 toy opinion, poor study design.
The contractor report made an important observation about the finding of Aroclor 1260 but not
t 242 in ambient air: "It is puzzling that Aroclor 1242, the major component of the vent emissions,
was not also detected in these sample~." lhis is the issue raised recently by EPA However, the
contractor 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, Mth the only
reason gjvell as "due to the low temperature and high humidity conditions that prevailed duriug
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 level of PCBs at the higher height is signilicmt.
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." Presumably this ·w-as an enor (not caught in
peer review), and was really in 1983, but it was de.finitely after the contractor petformed the
major portion of the ""ork. 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 sign.ificaat \•vay. The
coutractor report's presentation of the data showed that gas fl.o,,· rates increased siguHicautly
from 9:45 AM to 3:00 PM, with a 32% increase over that period. This would logically suggest
that gas fl.ow increased as temperature increased (no climatic data was given for this day in the
report), supporting my contention that ~ir releases of PCBs increase with increasing temperature
and also supports the repon's recommeudation for subsequent monitoring at the landfill . The
modeling work by the co.o.tractor cited by EPA only 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 \'ent, which resuhed in higher detection limits for the
fonner ver~us the latter1 because the quantities of PCBs in the former were substantially smaller.
Such a situation could have been predicted, and at the very least this problem would have been
4
corrected in subsequent monitoring by increasing the sampling rate and volume (as was done for
th.e ambient monitoring).
l found it unusual that several significant statements made in the Conclusions sec6on \\-ere not
contained in any form Vritbin 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 ill 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. Not 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, namely th.at ambient PCB levels were only found
"at or below n:tlniruum detection limits" while, in fact, the report's data showed positive detections
as high as seven times 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 in order to protect or serve its ov.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.
s
. . . ' fill~ f$L ~Mm✓ Cfft~ ,;lJ ~~v·
William L. Meyer, Director \J}»-
e American i,.;nem1ca1 ::,oc1ety
ychlorinated Biphenyls
\ Solid Waste Management Divisiof lj
/ To:J)z. Ii\,\:'~ ~ . : Doi,: R,[> /9,:,
1!/t5 t-5 A M@ Wl{Jf:Jtft'/;u6 jov' ~ b.W· M.
Please: _ Draft a reply for my signature _ For your inf omiation
_ Take appropriate action See me about attached
_ Approve _ Handle and report to me ne foam (PUF). The HV sampler
1tional Hi-Vol shelter and pump
,fan inlet head to accommodate a
ge. The sampling head was com-
housing which held a 10-cm diam-
Note and return attached material to me
Remarks:
pheric environment from gas vents and leachate access
ports. The other three consisted of two uncontrolled
private landfills and one municipal landfill in Indiana, each
of which contained large numbers of PCB-containing ca-
pacitors. ·
Materials and Methods
Air sampling was performed with low-volume (L V)
and/ or high-volume (HV) sampling systems previously
described (4-6). The components of the LV sampling
system consisted of a battery-operated, constant flow
sampling pump (Du Pont Model P-4000A) and a glass
cartridge containing a 22-mm diameter X 7.6-cm long
986 Environ. Sci. Technol., Vol. 19, No. 10, 1985
·allflex 2500 QAST quartz) followed
ridge containing a 62 mm diameter
fF plug. The General Metal W orlcs
Model PS-I sampler is essentially
sampler used in these studies.
ing pumps were calibrated with a
, (catalog no. 66-242-f-l) before and
riod. The HV samplers were cali-
by means of a calibrated venturi
ed to the inlet. Flow audits were
prior to and at the termination of
y an independent team using two
:alibrated by the National Bureau
:lean filters and PUF plugs were
l :initial operating conditions.
precleaned by Soxhlet extraction
~ly described (4), vacuum dried,
1ropriate glass sampling cartridges
conditions. The cartridges were
sed aluminum foil and stored in
jars padded with clean PUF for
he sampling sites. Exposed filters
were completely wrapped in pre-
1 the jars with the PUF cartridge.
al gloves and prerinsed tongs were
mpling cartridges when PUF plugs
!ed in the laboratory and for atta-
;>ling systems in the field.
md filters were Soxhlet extracted
1yl ether in hexane following the
. (4, 6), the extracts reduced to IO
anish concentrators according to
1e PCBs determined by electron
aphy following EPA Method 608
uantification of Aroclors 1242 and
ere performed by the technique
Vebb and McCall (8). All solvents
··---..---·-·--... --•/or analytical reagent grade. NBS
Standard Reference Material 1581 (Aroclors 1242 and 1260
in motor oil and transformer oil) were used for calibration
purposes. Recovery of Aroclors 1242 and 1260 from PUF
plugs fortified with SRM 1581 at three levels (0.06, 0.6,
and 6 µg/plug) averaged 93%. One laboratory blank and
one laboratory "spiked" PUF plug were analyzed with each
20 samples. In addition, ca. 10% of all samples analyzed
were field blanks which had been transported to and from
the monitoring sites.
Continuous measurements of wind speed, wind direc-
tion, ambient air temperature, and relative humidity were
obtained with Meteorology Research, Inc., portable
weather stations. Since the landfill sites were subject to
.J
Published in Environmental Science and Technology, October, H/oo, pp. \Joti-\J\:11, by the American 1,;nern1ca1 :::ioc1ety
Measure.ment of Fugitive Atmospheric Emissions of Polychlorinated Biphenyls
from Hazardous Waste Landfills
Robert G. Lewis• and Barry E. Martin
U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711
Donald L. Sgontz and James E. Howes, Jr.
Battelle Columbus Laboratories, Columbus, Ohio 43201
■ Four landfills known to contain large quantities of po-
lychlorinated biphenyls (PCBs) were monitored for at-
mospheric emissions: Three of these were uncontrolled
and contained large numbers of electrical capacitors, many
of which were scattered on the surface and leaking PCB
askarel fluids. The other is a state-of-the-art PCB waste
landfill designed to exceed the requirements of the Toxic
Substances Control Act of 1978 (ToSCA) for PCB disposal
Both high-volume and low-volume air sampling equipment
were utilized at each landfill to monitor air levels of PCBs
on site, upwind and downwind. In addition, vent ports
were monitored at the controlled site. Simultaneous,
collocated sampling was performed for quality assurance
purposes and to obtain information on sampling perform-
ance and comparability. High atmospheric PCB concen-
trations were measured at the uncontrolled sites, while air
levels were at or near background at the ToSCA-designed
landfill. PCBs were detected at low levels in gas vents at
the latter site.
Introduction
The disposal of polychlorinated biphenyls (PCBs) is
strictly regulated under the Toxic Substance Control Act
(ToSCA). Specifically designed chemical waste landfills
with impermeable liners are required and are subject to
approval by the U.S. Environmental Protection Agency.
The only access to the external environment in the case
of ToSCA landfills is through open vents and ports re-
quired for leachate monitoring and for relief for gases
generated within the landfill from decaying organic matter.
Prior to 1978, however, many PCB-containing articles were
disposed of in municipal landfills or at uncontrolled
chemical waste disposal sites.
PCBs possess sufficiently high vapor pressures (lo-4-10-0
kPa) to be emitted directly into the air surrounding haz-
ardous waste disposal sites through volatilization from
contaminated surfaces (1, 2). They also may be released
from controlled landfills through vents along with more
volatile gases (3). To test this premise, four PCB landfills
were monitored in this study. One was a ToSCA-designed
facility in North Carolina which was studied to determine
if PCBs were being emitted into the surrounding atmos-
pheric environment from gas vents and leachate access
ports. The other three consisted of two uncontrolled
private landfills and one municipal landfill in Indiana, each
of which contained large numbers of PCB-containing ca-
pacitors.
Materials and Methods
Air sampling was performed with low-volume (L V)
and/or high-volume (HV) sampling systems previously
described (4-o). The components of the LV sampling
system consisted of a battery-operated, constant flow
sampling pump (Du Pont Model P-4000A) and a glass
cartridge containing a 22-mm diameter X 7.6-cm long
986 Environ. Sci. Technol., Vol. 19, No. 10, 1985
cylinder of polyurethane foam (PUF). The HV sampler
consisted of a conventional Hi-Vol shelter and pump
modified by addition of an inlet head to accommodate a
PUF sampling cartridge. The sampling head was com-
prised of an aluminum housing which held a 10-cm diam-
eter particulate filter (Pallflex 2500 QAST quartz) followed
by a glass sampling cartridge containing a 62 mm diameter
X 7.6 cm cylindrical PUF plug. The General Metal Works
(Village of Cleves, OH) Model PS-1 sampler is essentially
identical with the HV sampler used in these studies.
The Du Pont sampling pumps were calibrated with a
Du Pont calibrator pack (catalog no. 66-242-f-l) before and
after each sampling period. The HV samplers were cali-
brated once each week by means of a calibrated venturi
tube which was attached to the inlet. Flow audits were
conducted in the field prior to and at the termination of
monitoring activities by an independent team using two
laminar flow elements calibrated by the National Bureau
of Standards (NBS). Clean filters and PUF plugs were
used to simulate actual.-initial operating conditions.
The PUF plugs were precleaned by Soxhlet extraction
with acetone as previously described (4), vacuum dried,
and loaded into the appropriate glass sampling cartridges
under clean laboratory conditions. The cartridges were
wrapped in hex~e-rinsed aluminum foil and stored in
carefully cleaned glass jars padded with clean PUF for
transport to and from the sampling sites. Exposed filters
from the HV samplers were completely wrapped in pre-
rinsed foil and placed in the jars with the PUF cartridge.
Disposable latex surgical gloves and prerinsed tongs were
used for handling the sampling cartridges when PUF plugs
were loaded and unloaded in the laboratory and for atta-
ching them to the sampling systems in the field.
Exposed PUF plugs and filters were Soxhlet extracted
together with 5% diethyl ether in hexane following the
procedure of Lewis et al. (4, 6), the extracts reduced to 10
or 1 mL in Kuderna-Danish concentrators according to
analytical needs, and the PCBs determined by electron
capture gas chromatography following EPA Method 608
(7). Identification and quantification of Aroclors 1242 and
1260 in the samples were performed by the technique
originally described by Webb and McCall (8). All solvents
were pesticide quality or analytical reagent grade. NBS
Standard Reference Material 1581 (Aroclors 1242 and 1260
in motor oil and transformer oil) were used for calibration
purposes. Recovery of Aroclors 1242 and 1260 from PUF
plugs fortified with SRM 1581 at three levels (0.06, 0.6,
and 6 µg/plug) averaged 93%. One laboratory blank and
one laboratory "spiked" PUF plug were analyzed with each
20 samples. In addition, ca. 10% of all samples analyzed
were field blanks which had been transported to and from
the monitoring sites.
Continuous measurements of wind speed, wind direc-
tion, ambient air temperature, and relative humidity were
obtained with Meteorology Research, Inc., portable
weather stations. Since the landfill sites were subject to
/
□ CLEAN EARTH/TOPSOIL
~ ARTIFICIAL LINER
~ LEACHATE COLLECTION SYSTEM
§j CLAYLINER WATER TABLE
ORIGINAL
GROUND
....__/SURFACE ------
Figure 1. Cross-sectional drawing of controlled PCB landfill in North Carolina.
the Comprehensive Environmental Response, Compensa-o■HOUSE
A MAINVENT
8 SMALLVENT
E SMALL VENT tion and Liability Act ( .. Superfund"), all samples were
collected, handled, and transported under standard
chain-of-custody procedures.
Results and Discussion
Controlled Landfill. In 1978, an unprecedented spill
of PCBs along 387 km of roadway occurred in central
North Carolina. Some 40000-120000 L of transformer
fluid consisting of Aroclors 1260 and 1242 in chloro-
benzenes were illegally and surreptitiously dumped along
the shoulders of the roads. Over 4 years of litigation were
required before a disposal site for the 30 000 m3 of con-
taminated soil could be located in a sparsely populated
area of the state. Because of the great amount of public
concern over the safety of the disposal site, a state-of-
the-art landfill designed to exceed the requirements of
ToSCA was constructed in late 1982. The EPA-approved
(Superfund) site, located on a 4 ha of land in a rural area,
measures 75 m X 145 m and has a maximum depth of
about 7 m. The contaminated soil is encapsulated within
0.6-m (top) to 1.5-m (bottom and sides) thick layers of
highly impervious, compacted clay, augmented with 10-mil
(0.25-mm) and 30-mil (0.75-mm) plastic liners on the top
and bottom, respectively. The landfill is properly sloped
and equipped with sump pumps and a leachate collection
system for monitoring purposes. It is also provided with
a gas vent which protrudes 1.5 m into the landfill for relief
of methane and other gases generated by bacterial decay
of organic matter contained in the soil. A cross-sectioned
drawing of the landfill is shown in Figure 1.
Several months after closure of the landfill,local resi-
dents voiced concerns that gases emanating from the vent
pipe and (as yet uncapped) leachate collection pipes may
have been introducing PCBs into the surrounding atmos-
phere. In response, a study was undertaken in Jan and
Feb 1983 to monitor these emissions and the ambient air
at the site.
Only the LV samplers were used in this study. The
vents and leachate access ports were sampled by placing
the PUF cartridge inlets into the pipes or ports and sealing
the openings with plastic bags to assure maintenance of
positive pressures. Sampling was performed for 8 h at
reduced flow rates of 1.2-1.4 L/min so as not to exceed
the volumetric flow rates of the vent pipes. The sampling
efficiency of the L V sampler employing PUF cartridges
had been previously shown to be essentially quantitative
for collection of Aroclor 1242 in natural gas, which is
97-98% methane (9). Soil temperatures within the landfill
were presumed to be nearly constant at 4-5 °C (thermic
temperature regime); therefore, emission rates were es-
sentially independent of ambient air temperatures.
l 1000m
0-._ ------l
C UPPER LEACHATE ACCESS PORT
D LOWER LEACHATE ACCESS PORT
0 SAMPLERS
145m
75m -..__--o._.__ __ • B
130m 3&m 36m -0 39,m 160ffl o, , 0---0----;.•~o-----+---o
--__:::.o-in, D. -
..,....--_.i:r---c•; -_r}-~------------' LEACHATE ~---~
WEATHER STATION N----Figure 2. Sampling arrangement for monitoring at the controlled landfill
when winds were from the north. Array was rotated with wind direction
so as to monitor at the perimeter of the landfill and at half the distance
for the main vent to the perimeter.
Ambient air sampling was performed with an array of
samplers operating at 3.8 L/min and located from 1 to 200
m upwind and downwind of the main vent as shown by
the example presented in Figure 2. Air samples were
collected at 1.2 m aboveground at each of the 13 locations
designated by open circles. Simultaneous samples were
also collected at 4.6 m above ground at the perimeter of
the mounded landfill (72 m downwind of the main vent
in the arrangement shown in Figure 2) so as to be on
line-of-sight with the opening of the main vent. The spatial
arrangement of the samplers was alternated as necessary
at the start of each sampling period to reflect average wind
direction. That is, downwind samplers were placed in a
fanned-out array at half the distance from the main vent
to the perimeter, at the perimeter, and at the tree line
(100-130 m downwind). Upwind samplers were placed
accordingly. One sample was taken at the same location
in the yard of the nearest house (1 km away) during each
sampling period. Sampling was performed from 0900 to
1700 Eastern Standard Time on 3 days and from 2100 to
0500 on the fourth day. Ambient air temperatures ranged
from -1 to +14 °C, wind speed from 0.04 to 6.6 m/s, and
relative humidity from 46 to 95%. No vent sampling was
performed on these days, and all vents were left open.
Analytical results from the gas samples collected from
five vents are presented in Table I. It should be noted
that the lower leachate removal pipe extends below the
landfill. The two small pipes were installed temporarily
to release gas bubbles in the upper plastic liner. PCB
concentrations in the gases (principally methane) ema-
nating from the main vent ranged from 105 to 141 µg/m3
measured as Aroclor 1242 and from 1.8 to 2.1 µg/m3
measured as Aroclor 1260. A typical gas chromatogram
of the PCB mixture found in the main gas vent is shown
Environ. Sci. Technol., Vol. 19, No. 10, 1985 987
.
Table I. Controlled PCB Landfill Vent Monitoring Results
PCB concentration, µ.g/m3
Aroclor 1242 Aroclor 1260
location range av range av
main vent (A) 105.7-141.5 120.2 1.8-2.1 2.0
upper leachate access 0.8-2.8 2.6 0.3-0.6 0.5
port (C)
lower leachate access ND-o.09 0.04 ND-o.08 0.05
port (D)
small vent (B) ND-o.07 0.05 <0.02-<0.3 <0.02
small vent (E) <0.02-0.67 0.24 <0.02-1.3 0.4
• Letters in parentheses refer to position identification in Figure
2. b Average of three to four measurements; 7-8-h samples.
1:1 AROCLOR 1242 ANO 1260
PCB IN GAS VENT
Figure 3. Gas chromatograms of standard mixture and sample from
main gas vent at controlled landfill.
in Figure 3 along with the 1:1 Aroclor 1242-Aroclor 1260
standard used for quantification. Collocated samples
collected in the main vent agreed within 6-9%. Concen-
trations found in the leachate collection ports were much
lower, ranging from nondetectable (ND) to 2.8 µg/m3
Aroclor 1242 and from ND to 0.5 µg/m3 Aroclor 1260.
Detection limits were 0.01-0.02 µ.g/m 3• Analyses of
transformer oil and soil samples prior to interment showed
a 4:1 ratio of Aroclor 1260 to Aroclor 1242. The greater
volatility of the latter mixture apparently accounted for
the relatively higher concentrations found.
Ambient air data are given in Table II. Only four of
the 39 ambient air samples analyzed contained detectable
quantities of PCB (MDL = 6 ng/m3). Three samples were
positive for Aroclor 1260 only (at 11, 12, 50, and 71 ng/m3)
and did not appear correlate with proximity to the vents.
The two maximum levels were found 98 m downwind of
the main vent.
Gas flow measurements made at three different times
showed flow rates of 4.8-6.4 (average 5.7) L/min from the
main vent. No flow was measurable from the leachate
ports or small vents. The average gaseous PCB emission
rate from the landfill, therefore, was estimated to be 12.1
ng/s. By use of these emission parameters and meteoro-
logical conditions that prevailed during the study, standard
dispersion models were applied to calculate downwind
PCB concentrations for comparison with field measure-
ments. Two EPA models (10, 11) were employed to cal-
culate estimates of maximum hourly concentrations under
a full spectrum of meteorological conditions and estimates
of the range of hourly ambient concentrations that would
occur at downwind distances of 50, 100, and 150 m under
the meteorological conditions that probably controlled
988 Environ. Sci. Technol., Vol. 19, No. 10, 1985
Table II. Ambient Air Monitoring at Controlled Landfill
location
beside main vent
on site, downwind
on site, upwind
fence line, downwind
off site, downwind
off site, upwind
nearby house
air concentration, µg/m3
Aroclor 1242 Aroclor 1260
<0.006
<0.006
<0.006
<0.006
<0.006
<0.006
<0.006
<0.01-0.01"
<0.01
<0.01
<0.0l-0.07b
<0.01
<0.01
<0.01-0.01'
• One of six measurements above detection limit. b Two of 13
measurements above detection limit (0.05 and 0.07 µg/m3). · 'One
of six measurements above detection limit.
dispersion during the field monitoring. The predicted
maximum 1-h concentrations downwind of the vent under
prevailing and worst case conditions ranged from 4 x 10~
ng/m3 at 14 m to 1 x 10-7 ng/m3 at 50 to 150 m. The 8-h
concentrations would be expected to be about 10-a ng/m3•
These values are far below the detection capability of the
sampler employed (or that of any known sampler).
Uncontrolled Landfills. Three disposal sites in the
vicinity of one city in Indiana have been the subject of
recent concern because they contain large numbers of
PCB-containining transformers which were dumped there
prior to 1972. One of the sites, designated here as site 1,
is about 8 ha in size and located on an abandoned farm.
Site 2 is a small, rural site of about 0.2 ha, surrounded by
mobile homes. Site 3 was a municipal landfill, some 3 ha
in area, located in a /!Uburban area. At each of these sites
capacitors were stre·ym across the ground surface (some-
times in mounds) arid were visibly leaking askarels con-
taining Aroclor 1242 into the soil and nearby streams. The
total quantity and depth of burial of the capacitors is
unknown.
Both LV and HV samplers were employed to monitor
PCB atmospheric emissions at the three uncontrolled
landfills. The air measurements at the sites were per-
formed at localized areas (hot spots) where leaking capa-
citors were evident and at other locations to determine
upwind (background) and downwind levels. Three dif-
ferent sampling approaches each using PUF cartridges for
collection of PCBs were used. The LV samplers were set
up at hot spots to sample during 8-h daytime periods at
3.8 L/min with intakes positioned 120 cm above ground.
The HV systems were set to sample at 226 L/min for
8-24-h periods at hot spots and at upwind and downwind
points. The intakes at the HV sampler were 180 cm above
ground. Where line power was unavailable, gasoline-
powered generators placed downwind of the HV samplers
were used. Arrays of five L V sampling systems placed
from 2 to 180 cm above ground were used to determine the
vertical concentration profiles at hot spots. Detection
limits were ca. 10 ng/m3 for the LV sampler and ca. 50
pg/m3 for the HV sampler.
Three or four days of monitoring was performed at each
site during June and July 1983. Results from single-level
(120 or 180 cm above ground) monitoring are presented
in Table III. The following summarizes these results:
At capacitor disposal site 1, airborne PCB concen-
trations measured at 120-180 cm above five hot
spots during the day (0900-1700 central daylight
savings time) ranged from 0.4 to 18 µ.g/m3• Levels
along the downwind perimeter of the site ranged
from 0.2 to 1.8 µ.g/m 3• Upwind PCB concentrations
ranged from <0.05 to 0.09 µ.g/m3•
Ambient air PCB concentrations measured at
120-180 cm above two hot spots at site 2 ranged from
Table III. Range of PCB Concentrations (µg/m3) in Air at Uncontrolled Sites, June-July 1983
site 1
location daytime
hot spots 0.4-18.0
downwind 0.3--0.5
upwind <0.05--0.10
meteorology
temperature range, °C
wind velocity range, m/s
relative humidity range, %
Table IV. Vertical Profile Air Measurements at
Uncontrolled Landfills
distance
air concentration,• µg/m3
above site la site lb
ground, cm October July July
2 271-520 577-1053 602-1108
30 27-33 56-120 111-157
60 8.6-18 30-58 4o-62
120 2.9-5.7 17-30 15-21
180 1.3-2.3 6.4-1.3 8.6-10
•Average daytime levels over a 4-day period.
24 h
8.3-13.0
0.60-1.3
0.08--0.09
19-42
0-2.3
62-83
site 3
July
367-955
53-159
28-69
16-33
6.8-21
0.6 to 19 µg/m3 during the day. Near residences
adjacent to the site, levels ranged from <0.04 to 0.2
µg/m3.
At the municipal landfill (site 3), daytime PCB air
levels measured at 120-180 cm above three hot spots
ranged from to 193 µg/m3. Upwind concentrations
were fairly constant at ca. 0.05 µg/m3, and levels
measured downwind of the landfill ranged from 0.3
to 0.8 µg/m3. There were a number of residences
around the perimeter of this site.
Generally, the airborne PCB levels measured at hot spots
correlated with the quantity of exposed capacitors.
Vertical emission profiles at hot spots are given in Table
IV. Air concentrations decreased with distance above
contaminated surfaces. Levels at 2 cm above ground level
were from 40 to 100 times higher than the levels at an
elevation of 180 cm, while those at 120 cm were twice as
high. PCB emission rates during July 1983 were probably
maximized by the unseasonbly warm (19-42 °C), dry
weather which prevailed throughout the study period.
Sampling data from site 1 during Oct 1982, when tem-
peratures ranged from 13 to 30 °C, showed PCB levels
about half of those obtained during the summer.
Typical gas chromatograms of downwind and upwind
samples from site 1 are shown in Figure 4. Chromato-
grams of hot spot air samples taken at several heights are
presented in Figure 5.
Both the LV and HV samplers (including one com-
mercial version of the latter) performed well throughout
the study. Sampler pumps were calibrated before and after
each sampling period. Flow calibrations ranged from + 1.9
to-7.9% for the LV samplers and from +8 to-7% for the
HV samplers. Pre-and postflow readings agreed within
±5% in over 90% of the cases. Independent flow audits
indicated average flow accuracies of -2.8 % · for 20 L V
pumps and +5.2% for seven HV samplers. Field blanks
analyzed with ambient air samples collected at each landfill
site showed no PCB (measured at Aroclor 1242) above the
minimum detectable level of 0.02 µg per plug. The blank
sampling cartridges were carried through all field handling
operations except attachment to the sampling devices.
During the field study, pairs of LV and HV samplers
were operated for the same time period at the same sam-
site 2 site 3
daytime
0.6-33.8
<0.04--0.07
24 h daytime
6.3-193
0.08--0.20
0.08--0.20 <0.04--0.05
19-38
·0.1-2.7
37-83
AROCLOR 1242
DOWNWIND
AIR SAMPLE
SITE 1
STANDARD
24 h
21.5-77.4
0.3--0.8
0.08--0.09
22-42
0-2.2
24-70
UPWIND
AIR SAMPLE
SITE 1
Figure 4. Gas chromatograms of standard and ambient air samples
at uncontrolled landfill.
AROCLOR 1242
STANDARD
AIR SAMPLE AT
2cm ( 1 :40 DILUTION)
AIR SAMPLE AT
60cm
AIR SAMPLE AT
120 cm
Figure 5. Gas chromatograms of standard and air samples at several
heights above hot spots at uncontrolled landfill.
pling location to estimate the reproducibility of the mea-
surement methods. Measurements were also made with
collocated L V and HV samplers to compare results ob-
tained by the two methods. As can be seen from the data
in Table V, good agreement between pairs was obtained.
The average difference calculated from all the paired LV
sampler measurements was 7.2% while that for the HV
Environ. Sci. Technol., Vol. 19, No. 10, 1985 989
·l
Table V. Collocated Sampler Comparisons
paired LV samplers,• µg/m3 paired HV samplers,b µg/m3 paired LV and HV samplers/" µg/m3
% difference % difference % difference
sampler A sampler B in pair sampler A sampler B in pairs sampler A sampler B in pairs
9.4 11 15.7 12 14 15 8.7 7.1 +20.3
8.8 8.6 2.3 11 12 8 7.0 6.5 +7.4
11 6.8 47.2 37 61 49 8.5 11.6 -30.8
11 12 8.7 98 89 9 5.2 9.9 -62.3
5.1 5.3 3.8 30 47 44 11.0 12.3 -11.2
7.9 9.1 14.1 20 23 14 8.5 13.5 -45.5
18 19 5.4 45 45 0 18.5 28.0 -40.9
77 72 6.7 11.0 21.0 -62.5
6.2 6.0 3.3 40.0 49.0 -20.2
85 89 4.6
11.2" 20" -27.3d
• Located 30 cm apart. b Located l m apart. 'Data corrected to account for difference in height of intake above ground. dAverage.
Table VI. Comparison of Active and Passive Sampling Data
air concentration, µg/m3
distance above site la
ground, cm active passive active
2 1060 980 670
30 120 53 90
60 37
120 19 14 17
180 5.1/5.2
• Average.
samplers was 20%. Since the inlets of the HV and LV
samplers were not located at the same heights above
ground, it was necessary to apply a correction factor in
order to achieve reasonably accurate comparisons between
values obtained from collocated pairs of HV and LV sam-
plers. For this purpose, corrected HV values (C180) were
calculated by
where C180 and C120 were the PCB air concentrations
measured by the collocated HV and L V samplers, re-
spectively, and V180 and V120 were concentration values
obtained from vertical profile measurements with the L V
samplers at 120 and 180 cm above ground, respectively.
After these adjustments, the L V /HV sampler comparison
averaged -27 .3 % , with the L V sampler generally giving
lower results.
A limited numer of experimental passive devices (12)
were also exposed at hot spots on site 1 on 2 of the 4 days
of sampling. The passive sampling devices (PSDs) were
3.8 cm diameter x 1.3 cm stainless-steel cylinders con-
taining a series of diffusion screens and plates on each end.
Tenax GC (0.4 g) was used to collect PCB gases diffusing
into the devices. The sampling rate for PCBs was esti-
mated at 30 cm3 /min on the basis of trichlorobiphenyl.
The devices were transported to and from the exposure
sites in sealed cans, which were placed in a larger can
containing activated charcoal. Cyclohexane was used for
extraction of the PCBs from the PSDs. Collocated expo-
sures with the L V samplers showed reasonably good
agreement, as can be seen from the data presented in Table
VI. The detection limit for the PSDs was only ca. 5 µg/m3
for 8-h exposures, however. Efforts are currently under
way to improve sensitivity by means of supercritical fluid
extraction and concentration.
Temporary remedial actions were taken during
1983-1984 at sites 1 and 2 to remove all exposed capacitors
990 Environ. Sci. Technol., Vol. 19, No. 10, 1985
site lb average
passive active passive % difference P / A
340 865 660 -24
125 105 89 -16
55/100 37 77 +48/108
18 14 -22
5/16 5 10 +100
+16.8°
Table VII. Range of PCB Concentrations• (µg/m3) in Air at
Uncontrolled Sites after Temporary Cleanup, Aug 1984
hot spots
downwind
upwind
location
meteorology
site l
3.1-4.6
0.4-1.4
0.2--0.3
temperature range, °C 14-32
wind velocity range, m/s 0-1.3
relative humidity range, % 48-92
• 24•h samples.
site 2
2.7-3.1
0.1--0.2
0.Hl.1
Table VIII. Vertical Profile Air Measurements at
Uncontrolled Landfills after Temporary Cleanup, April
1984
distance above
ground, cm
2
30
60
120
180
air concentration,•
µg /m3
site l site lb
2.3-3.2
1.1-1.8
0.9-1.4
0.7-1.4
0.4--0.6
11.5-21.3
4.1-5.8
1. 7-3.1
1. 7-3.l
1.5-2.5
• Average daytime levels over a 4-day period.
and obviously contaminated surface soil. Following this
cleanup, limited additional air monitoring was performed
during a 4-day period in Aug 1984. The results of HV
sampling at both sites are presented in Table VII. Vertical
profile measurements (using the LV samplers) at two
previously monitored hot spots on site 1 are given in Table
VIII. Significant reductions (by an order of magnitude)
of PCB air levels at the hot spots were noted postcleanup.
However, downwind levels at both sites 1 and 2 appeared
unchanged, suggesting that the landfill proper is still
...
contributing PCBs to the surrounding atmosphere.
Conclus(ons
The results of these studies demonstrate that fugitive
emissions of PCBs into the atmosphere can occur at un-
controlled landfills. At the three sites, PCB air levels
measured at hot spots on the landfills greatly exceeded
ambient background levels, thus indicating that PCBs
from the leaking capacitors were being emitted into the
air. Concentrations that exceeded background levels were
also observed at sampling locations downwind of the
landfills, even after removal of exposed capacitors and
obviously contaminated surface soil. By contrast, air
emissions of PCB from a well-designed chemical waste
landfill were found to be negligible.
All PCB sampling systems were found to perform well.
The L V samplers offered an advantage over the HV sam-
plers when electrical power was not available (as was the
case at most of the sites monitored). However, limited
battery life would not permit 24-h sampling with the LV
pumps. The experimental passive sampler, which can
readily operate unattended for 24 h, shows much promise
if its sensitivity can be increased by 100-fold through im-
proved extraction and analysis methods.
Acknowledgments
We than Donald E. Johnson of Southwest Research
Institute, San Antonio, TX, for valuable laboratory support
in preparation and analysis of PUF cartridges, Jack C.
Suggs of the U.S. Environmental Protection Agency, Re-
search Triangle Park, NC, for modeling assistance, William
F. Barnard and Jack A. Bowen of the U.S. Environmental
Protection Agency, Research Triangle Park, NC, for per-
forming field audits, James Gray of EPA Region IV,
Athens, GA, for field support at the controlled landfill, and
Ralph Riggin of Battelle for analysis of the passive sam-
pling devices.
Registry No. Aroclor 1242, 53469-21-9; Aroclor 1260, 11096-
82-5.
Literature Cited
(1) MacLeod, K. E.; Lewis, R. G. In "Sampling and Analysis
of Toxic Organics in the Atmosphere"; American Society
for Testing and Materials: Philadelphia, PA, 1980; Pub-
lication STP721, pp 56~9.
(2) Weaver, G. Environ. Sci. Technol. 1984, 18, 22A-27A.
(3) Murphy, T. J.; Formanski, L. J.; Brownawell, B.; Meyer,
J. A. 184th National Meeting of the American Chemical
Society, Kansas City, MO, Sept 1982; American Chemical
Society: Washington, DC, 1982; ENVR 70.
(4) Lewis, R. G.; Brown, A. R.; Jackson, M. D. Anal. Chem.
1977, 49, 1668-1672.
(5) Lewis, R. G.; Jackson, M. D. Anal. Chem. 1982, 54, 592-594.
(6) Lewis, R. G.; MacLeod, K. E. Anal. Chem. 1982, 54,
310-315.
(7) Fed. Regist. 1979, 44, 69501~9509.
(8) Webb, R. G.; McCall, A. C. J. Chromatogr. Sci. 1973, 11,
366-373.
(9) Jackson, M. D.; Hodgson, D. W.; MacLeod, K. E.; Lewis,
R. G. Bull. Environ. Contam. Toxicol. 1981, 27, 226-229.
(10) U.S. Environmental Protection Agency "NTIS Tape of
User's Network for Applied Modeling of Air Pollution
(UNAMAPt. EPA, 1980, Version 4, NTIS No. PB81-
164600.
(11) Turner, D. B.; Busse, A. D. "User's Guides to the Interactive
Versions of Three Point Source Dispersion Programs:
PTMAX, PTDIX, and PTMTP" 1973, U.S. Environmental
Protection Agency Report EP A/DF /OOH (NTIS No.
PBSl-164667).
(12) Lewis, R. G.; Mulik, J. D.; Coutant, R. W.; Wooten, G. W.;
McMillin, C. R. An~l. Chem. 1985, 57, 214-219.
Received for review December 19, 1984. Accepted April 5, 1985.
Although the research described in this article was funded wholly
or in part by the U.S. Environmental Protection Agency through
Contract 68-02-3745, it has not necessarily reflect the views of
the Agency, and no official endorsement should be inferred.
Mention of trade names for commercial products does not con-
stitute endorsement or recommendation for use.
Environ. Sci. Technol., Vol. 19, No. 10, 1985 991
l pea AIR aMIS&IQN§ ANP HEALTH RISKS
EBQM XNS \YAAAJ:N QQMNTY
Summary
pea L&NDFILL
Joel S. Hirschhorn, Science Advisor
Warren County PCB Landfill Working Group
November 27, 1996
Data obtained from a 1983 EPA 5t'Udy showed conclusively th.at uncontrolled releases of
PCBs into the air were occurring. Neither EPA or the state analyzed the data properly, and EPA
made:: incorrect statements indicating there Wc!.S 110 problem, even though no analysis Qipported
the statements. In act, the levels of PCB~ found by EPA in the air nc31' the landfill and in the yard
of a residential house more than a hill' mile from the landfill were $.eVeral ~s gre.ater than the
level of he21th significance found in EPA' s o~n risk assesmic=uts. The PCB lovels found i.o the
winter of J 983 were significantly above the one in one million excess cancer death risk based
co»centration presented m .EPA d.atabsses. PCB emission levels in wann~ periods and in later
times during the past 14 years since the PCB wastes were buried in the widfill cow.d Juve been
significa.ctly higher. qo~e over long times to relatively low levels of PCBs; could also ca~
noo-can=er heahh effects, especially in children. The PCBs re1e:1sed into the air could also result
in PCBs being deposited on nearby lands and, therefore, contaminate crop~: local vegetable
gardens, lild dairy and meat products ftom cattle grazing 0t1 local lands, lead.mg to exposure
routes other than inhalation.
An analysis of rlae only sta~ documents refe"ing to the 1983 study hy EPA and the
on{~ infonnatio,, gi...,ui to th, public has shtJWn tnat tht stat~ lntendonally misrepresented the
findihgs of tit~ 1933 tests for PCB air rdtases from th~ landfill For a.ampl~ tl,e highest
/~els of PCBs fo,md at the landfiU's main vent were not reported b_y the ~ttztt:, and the state
indicated that 110 mea.surabi~ amounts of PCBs had been fou.nd in the air arONnd tire sit~,
which was not the cau.. The state has persi.stently deadvt:d the public obout PCB air r~lt!!ase.s
and, more impona11dy, tht significant.public health rifks resulting from th~,n.
The rcslllt., rcporud here !UpplJ still more support for the state t2kin£ seriously its
commitment to detoxify the Warren County PCB Landfill and to make a commitment for
supplying the n«~suy fuuding very quickly. Tberc u o.ow abuodaut proof th.at the
landfill bas not been sale and secure, that the criticslly important bottom clay and plastic
liner system lcsked almo,t immediately, that the lcschate collectioa system never wor_ked
effectively, aud that PCB, hive leaked dinctly into ihe air aod leachate iuto the
surrounding soils. A number of new tests are rccoinmtild~ to &ssess he3.lth risks.
I
Bsclc;royod
My revi.:w of the PCB files provided by the sta.te indicued Yery little attention bad been
given over the years si:nce the landfill construction was completed in l 983 to the: potential for
human exposure to PCB air emissions from the lmd:fill. Many people may have believed lhat
PCB$ do not pose hazards because they are not volatile organic compounds (VOCs). However,
although PCBs are not classified as voes, they do po$$ess sufficiently higb vapor pressures to
rcleuc potc::ntially significant vapors into the air, if no pollution control technology is u.sed to
control such emissions.
Tne one, most important document found in the state files was a copy of I professional
published paper entitled "Measurement of Fug±tive Atmospheric Emissions of Polychlorinated
Biphenyl:. from Haz.ardous Waste .Landffils" (ILG. Lewis et al, Environm=ital Science and
Technolog)·, vol 19, no.10, 1Q85). The two lead authors were affiliated \'with EPA's Researeh
Triangle Park facility. No document was found i:n the state filts that provided auy analysis of the
infornution and results in this published paper, especially with regard to the Warren County PCB
Landfill This was especially si&nificant,. bc;cause the paper provided data 0.11 the Warren County
faciliry, probably the only data ever obtamed on PCB air rel~ses from the landfill.
The published paper noted in its iDtroduction that "PCBs poi~SS su.ffi.:ientl)' high vapor
pressurc ... to be emitted directly into the air surroundin~ hazardous waSte dispostl sites through
volatiliz.1.tion from conta.minated swfac::s. They uso .Ill1)' be released from controlled landfills
through ve:its, along with more volatile gases."
The paper presented the result.s of field testing at four PCB landfills, includmg the Warren
County facility, which "was srudied to determine if PCBs Yvere being emitted into the surrounding
atmospheric environment from gas vents and leachate access ports." The paper characterized the
Warre-..1 Cou.oty Landfill as "ToSCA-designed" and referred to it as 1 "state-of•the-art landfill
designed to exceed the requirements ofToSCA" These statements referred to the federal Toxic
Substances Co:c.uol Act, the key federal law covering pCBs. But the paper indicated that the
1.a.udfill had a perforated pipe le.c~te colle::tion system, which in fact was not installed., a.nd did
not recognize that the state had received waivers from c:rtain landfill requirewc:Dts, raking doubts
about the paper's accuracy in dcscn"bing the landfill as s:tate-of-tbc:-art. The authors clearly
wanted to use the Warren County Landfill as a control landfill against which to compare data
obtained for other Jes~ ~ph.isticated PCB land:fiils ("in the vicinity of one city .in lndima") that
were described as "UDcontrolled landfills" where PCB materials were du.mp~ or disposed and
were probabfy Superfund cleanup sites.
It should be coted that the experimental field work used soph.iiticated and accurate
mettods for collecting and masuring PCB levels in air. Also, the field work was conducted in
Jamary and February 1983, ~ch was som~ months after the PCB wastes were buried in the
landfil~ before the leacilate collection system pumps were first turned on, &JJ.d before the landfill
C()t'lstruction was officially considered complete.
2
It is also important to note an imponant inconsistcicy in the aatements made in the
published paper, because non-professional people who may read the paper could be misinformed
or confused. There were two statements about the significance of the findings for the W men
County facility. The paper's initial summary said " ... air levels were at o:r nea.r background at the
ToSCA-designed landfill. PCBs were detected at low levels in gas vents at the latter [Warren
County] site." In the paper's section ·with conclusions, in referring to the Warren County facility,
it was said that "air emwi.ons of PCB from a well-designed chemical waste landfill were found to
be negligible." It i~ im.portant to note these two statements are not equivalent, because low
i·~ not the same u ne:J.i;ible. Neglipl>le means inconscqu=nrial or insipiliicant, but .a level that
is measured may be low without being either incoo5equcnt.ial or insignificant -with respect to some
important potential qfcct of PCB emissions. Moreover, dnwing a conclusion that measured
PCB emissions were "n:gligi'ble" requires much more analysis than concluding they are low,
because one must answer the question: negligiole for 'What effect'? Ihe easier task is to conclude
that tht emissions were low, because that could be logically based on a comparison with similar
data for the other landfills studied. However: to conclude th.at a level was negligible implies use
of som.c uthc:r criterion or effect, which normally would be for health risks. 1n fact, the published
paper pre$Cnted no analysis whatsoever in justifymg any conclusion in rebtion to health risks.
The present rq,ort provides such an analy~s.
It should be noted that the paper paid particuhr attention to the history of the Warren
County Land.fill and .included reference to "the great amount of public concern over the safety of
the disposal gj1e." Moreover, the paper &aid: "Several months ifter closur~ of the landfill, local
residents voiced concems that gases emanating from the vi:::it pipe and (as yet uncapped) leachate
collection pipes may have been introducing PCBs into the surrounding atmosphere. In respouse,
a study \vas undertaken in Jan and Feb 1983 to monitor these emi&siOil.S 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 arid public concerns about health eff'ects. It is also reasonable to believe
that the all the data from the EPA study and l highly objective, professional evaluation of the data
would have been given to local residents. This Scic:oce Advisor, therefore, also has closely
examined what information was comn,urucated by the state to the public.
Analysi, of Dau
Data were obtained for PCB emissions (for Arochlors 1242 and 1260) at the main vent:
the upper and lower leachate access po~s., and two small vents ( created by placing pipes in
surface bubbles in the thin plastic liner on top of the landfill). Measurements were also made ''in
the yard of the nearest house (1 km away)." This is a little over onehalfmile away .from the
landfin.
The follo,..-ing 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
........ _,,,... , .... -
n~:7 T Q~. )1 AON
'
micrograms/cubic meter (ug/ctn.) for Arochlor 1242. In trying to compare this level with
the other highest levels found al the other three PCB landfills is difficuh, be~u~ the ~udy
used different modes of measurement. A big diflerence is the height at which PCBs were
measured.. For the W UTen County landfill, the measurements at the maitl vent uc
somewhat difficult to C<Jmp~ to ones made at different hei~ts above an opcu landfill
location. Different heights mean that the potemial for diluting PCB vapors increases 'l\ith
incrc:ising height above the PCB waste. The published paper neva-made any explicit
~aiysis of the data from the different landfills. Howi;v~, the paper focused on results
rroro measurements at 120 to 180 cm for the other three widfills, which is somev..bat
an.dogous to the main vent pipe condition at the Warren County landfill For this
comparison, the: ma.~ level found at the main vent was actually higher than lllOst of
the m.a.x:imum levels reported over hot spots (i.e.: areas ofrugh PCB level.5) at the otl1er
three PCB landfills entDincd in the study, with the o~er, corresponding values being
18 O, 33. 8, and 193 ug.lcm. But these other levels were found for field tests conducted m
the surnIDeT of 1983, and the paper showed that PCB levels were very much higher in
June/Jul:, thau m October, wtth the av~a.gc increase bcing about 200%. Thi, ~_gests
that the ma,cimumlevel of 120.2 ug/cm found in Jan ./Feb. in Warren County could easily
be 200~--, or more greater if measured in the mmmer, or perhaps some :3.50 ug/cm. In
()t}ier words, tl,e high leveb.found at th~ mailt vt!nt at the Warre.n County Landfill
~trt quirL comparabk, and perhaps even grt:att!r than the /ev~ls[Oltnd a.how the otli~r
three u.ncontr-olled ladfil.ls, contrary '" the s1«tement made in tnt published papa that
th~ levdJ wl!rt! "low."
• It is important to note th.at 'the srudy also found that only the main vent was releasing a
positive gas flow, but there was no measurable gas flow for the leachate collection pons
and small vents. 'lbis means that only the main. vent wu serving u a source of pCB
releases into the air during the wiut;r period of the study. Th.is £.act does not change the
accuracy of the measurements of .PCBs at the other locations: but only that there was no
r:o=asural,le natural flow of gas out of those other openings at that time. The study
measured the acrual mass .flow or flux rate: for PCB releases from I.he main vent as 12.1
nanograms/second (ng/s). In other words, any staume.nts by government officials tltat
no PCB~ wcr~ king rekasedfrom th,: Wa"en County Landfill were tokll/y
contradictory to ilu acruolfkld data obtained in early 198.3. The EP.-f st"dJ' mea.sllr~d
u1tcontrolled rdea.seJ of PCBs from the landfui which probably would he signific@tly
higha during warmu paiod.s..·
• The next b.ighest levels wc:re found at the upper leachate access port (2% of 1242 and
2 5% of IZ60). lbis is con~tent with contaminated leachate residing in the upper
leachate collection system at the ti.me.
■ Much lower levels were found at the lower le:schate access port (.0j% of 1242 and 2.5%
of 1260). For both PCBs, however, there were positiv~ readings above the very low
detection limits reported. br otha words_. rhe,-e were reliablt fut dings of PCB ,,apors
from the {qwa leachate collection syst~m below the main clay and plllstic bottom liner
system. This usdicald that PCB contaminated kadr.au had readr~d the lower
leachtlt~ collection sysum i1t early 198J, becauH tlser~ il 110 other pUUt1ible
ex,planatiOlt/Dr flndi1tg PCBs ln tlr~ air drawn from th~ a.cc~s pip~ EPA'sfuuiing
Wlli cons~t with lt!llking of contami.naud l~ch~ through both the clay layer and
plastic bottom liner into tlit! Iowa-leachak r,su,iiiori11g and collection layu and sump.
■ Even hjgher levels of PCBs were found at the two smaller vents, with the:: vent with the
highest readings showing levels in the range fOlmd for the upper leachate access pipe,
■ .i.\Jthougb most of the measurema1ts at the closest house were below detection limits, one
of the sjx roeasurc:ments was at 0.0 l ug/cm for Arochlor 1260 (the more tox:ic PCB). The
key question is: is this conCCDtration of PCB ofbealth significance? To answer this
question one cm consult several EPA risk assc&SIDent·rype databases. Bo1h EPA Regions
3 and 9 maintain sucb databases and th~· contain the levels of PCBs itt air that pose an
excess cancer death rate of one in a million ( or 10-,.) for residential c:xposure.1 Those
concentrations arr: 0.0008 l and 0.00087 ug'cm in the two EPA databases. Since the
m~asured level at the house was 0.01 1 the data show that the cancer risk kvcl at the house
,i.·a;; about 10 times greater, or approximately 10·5 risk. In other words, the wiuter-time
high read.in~ at the house tlut was over one.half mile away was of considerable
significance. Al.so. the other findings that were below the detection limits of0.006 and
0.01 uglcm for Arochlors 1242 and 1260, rcspcctiv:ly, arc also significam. The reason is
thst the appropriate EPA methodolo!)· is to use onebalfthe detection limits when
ass~ssin! health risk, rather than a$.Sllme that a nondetect is :1 zero concentration. Thus, it
is proper to assume that most of the n:adings at the hou~ would have been 0.003 and
0.005 ug/cm.., and these arc .a.l.so above the 10-a risk l~vel of0.00081 and 0.00087 and
C-Orrespond to risks of3 to 6 X 10·0. In otlur K,'Ords, all oftlufUtdinzsfrom tlu
published pa~r shr.,w that levels of PCBs found at the residence closesz to the Wam:n
County La,,dflll in tlce winter of 198S -wert o//cealth significance and, ill/act,pcsd
an wnacceprable k>ng term cancer mk. In all probflhili.ty rht PCB levds /QUnd of/site
would have l>etrr considuab!y higher l11 warmer pakxls, and maJ• also have l,acreased
ov,r rime.
• The Stud)' also found measurable PCB levels in ambient air at various other locations,
particularly a uumbet ofreadiugs at the fence line and doWPwind, with the mucimUlll level
fouod at 0,07 u~cm, v,hich is som.e 100 times greater than the 1 a~ cancer risk level, or a
risl of 10-4, which is a very high risk level 11w tin ding was even more evidence that PCB
relel\seS from the landfill were occ:.uring.
■ TI1e paper did not pa)' close att~tion to the differ~ces found in measured levels '?f
1The 10·' cancer risk level is the: b~ critcriou to use: becaus; .it is the JJ)()st used basis for
cleanup d;cisions in the federal Superfund program -when residential exposures are appropriate.
5
·00 .d
Arochlor 1242 versu~ Arochlor 1260. It is known th.at the vaporization rates decrease
Stgn.incantly -with mcreasins 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 l 00 times
gre.ater than for 1260, one would also expect more 1242 when leachate is the source of
PCB -vapors. for tbe most pan, this relationship existed in the data rcponed. For
c;\amplc, for the main vent data the avcraic level was 120,2 ug/cm for 1242 but only 2
ug/cm for 1260. What merits some con~idcration, howi:vcr, is that ova the longer term.
th~ more slowly vaporizing but more to,ac Arochlor 1260 will be expected to represent a
higher fraction of all the PCBs emined from the landfill
Jn(ormatian Provided By The 5tase Hu Beep \\:'.tone
~-three pertinent docUII1-'"D.t6 have been found in the £les provided by the state. First,
the state's description of the lindfill and it~ chronology contains a st.atcment that in Jmuuy 1983
"EPA monitors p5 venting from l&ndfill 1Dd report, no significant miissions of PCBs." Use of
th~ t~rm significant is IU:e use of the tenn negligll>le by EP~ discussed earlier in this r¢i>on. The
se~gly simple statement is in fact incorrect and misleadmg.
Second, the ~nd page from '\-Vb.at apparently was oniy a two pasc actual rep on &om
EPA about the testing has been found in the: file, provided by the sti.tc. 2 The conclusions
presented in this one page section r:veal a superficial analysis of .incomplete data and a clear
a.tt:mpt to downplay any h~ risk issue r:lated to uncontrolled air releases of PCB&. It
cc:rtairJy would have been Dermal for EP ~ persomiel to prepare some type of report for the state,
especially s.ince the study of PCB emissions was reponedly done because of citizen conc:ms
10uc undated page was found; it is titled Section 2 CoDclusions and the page number is 2
and preseutw four conclusions, indicating that th~ first and only other page may b2ve been a brief
des-."ription of the fieJd work by EPA. Hand written statements at the top of the page arc:: ''Aiz
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 ofl983 or early 1964, perhips
before all the data was fully assessed. The first conclusion noted Wt the main vent was ''the
principle =-ource of emissions " The average values given for the two Aroi::hloTs match those in
the published paper. The first condusio·n al.so said "These coucc:ntntions arc 5Ubstanti~Jly lower
tha!l the cuTTcnt occupational standards for worl-place atmos-pheres ... " But workplace standards
are set for short time exposure and Acute health effects. The 5ee0zid conclu3ion referred to
ambient .PCB levels, but did not correctly refer to levels found above detection limits. The third
conclusion referred to th.e results of mathematic-t modeling, md stated that levels would not be
signific:mt, but no r:n.cution 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 of methane and by "removal of water &om the site'' that
should "reduce emission rates substAntially ... But the state says that methane is still being
produced and the water was not removed.
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Third, a page titled ''PCB l.ANDFILL MlSCEilA.NEOU~ ~AM.r'u:~·· preparea oytne
state's Division of Solid Waste Management Division, and given in a documdl.t entitled Sampling
Analysis, and Leach3.te Removal Activity 1982-1993 (delivered to the Working Group in April
· 1994 ), contains four results of gas measurements iD. January l 983, which is the EPA work. The
probiem 1s that the data do not match the data in the published paper or the information in the one
page of conclusions a.pparcntly prepared by EPA3 Some especially significant discrepmcies are:
■ Toe state reported the highest level of PCBs found at the "gas vent exhaust•• (surely the
main vent) 3S .. 3.0 PPB" (three parts per billion), which equates to 3 ug/c.m, in compa.'"lS-On
to the .acnal maxirnnm level reported by EPA of 120 ppb in the published paper and 123
ppb m the one page of conclusions. Even if the state argued that it never closely ex.anrined
the published paper it had in its possession for many years, rt surely had the short report
prepared by EPA for the state so it could address public con=rns.
■ The State reponed for "ambient air samples., the result of "none detected: w but the state
failed to r~or1 the finding of PCBs in tbe air at the location of the house about a half a
mile from the Landfill, which is a very significant distance to find sucil measurable levels,
nor the positive findings at the fenc:line, as reported in the publi~cd paper. 111c
statement in the one page conclusions page from the EPA rcpon that ambient PCB levels
"were: found to be at or below minimum detection limits" was definitely not in agreement
with the data reported in the published paper, that inchlded four readinss significantly
ab\1Ve the detection licit. The only plausi"ble, acceptable expl3llation might be that the
brief EPA rep on was prepared prior to completion of EPA' s :malysis of ~l of its .field
dau. 11iis would be consj~~t ~i.tb. the deme by the state to receive the finding$ of the
EPA srudy as soon as possible in order to address the consider.able public oppo:.i.tion of
Watten County residents to the land.fill. In any event, the state had the published paper
that d~ariy revealed the positive findings of PCBs at the fciceline ind the nearby house.
• The state reported for th~ ''leachate collection pipe exhaust" a result ofle~ thazi on~ part
pc;r billion. Smee EPA mC-4~red PCBs at the both the upper 2nd lower leachate wllection
acc:ss port$, the siate)s mformatiou is at best incomplete and at wor~ mi.skadi:Jig. The
State v.:ould logically h.ave had a problem with cxplainiog any positive findmg of PCBs
from the lowef access pon. The one page of EPA conclusions did not incklde any data
for the leachate collection access ports, raising the question of why the state reported less
than one part per billion., especially since the state had the publi&hed paper tlut includc:d
the maximwn value of 2. 6 ppb given for the leachate access pons.
3Jt may be significant that the data reported were given for Januacy 6 and 12 only, but that
the published pap~ said that the study lad been undeltak~ in January and February, suggesting
that not all the d3U became re:;ogn.ized by the state, even thou!h it was published in the paper by
the EPA scientists in 1985 and the state office had th.at paper for many years.
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HO~..:! H~V L L l 966L-l~-~
Becau5t there is no evidence that t/te tidua.l EP.-4 rqx,rt o,. the published papu had
bun provided IQ the gmaal public or tht Working Group by the stat~, tJta~ discrepancies in
the onlJ uiformation made avoilable tkmonstrate thilt tltc state ln~ntionally misrttpruazred
thcjusdings of the 1983 tats/or PCB air rtktUesfrom th, la.ndflll. This wa.s dont: most
recentl)l in 1994. Se-,,era/ ~oplu oftne 198S publlshtd paper w~rtfou11d in statttfilu OIi the
landfil{ witlt o marki111g tltat tlu papa had bear rectlvtd l111986. .,,Cll tlccfaas show that tlse
stau Jau -steadfast!)· tkcdaJed the public olwut tht data and, mort: importantly, tht
significance ofthefUtdings with rtsptct to public h~alrh risks. All PCB emission! could ha·1;•t
hea. prew!1ttt!d at 1'Wtimal e.ost b1 using some form of carbon adsorpti01t tJeo,,ic~ at all lamlflll
gas exit pons.
Copsbuiqm
The con:e.rns of Warren County residents about uncontrolled relea9es ofPCBs into the air
emanating from the Warren County PCB Landfill were well founded and, m .&.ct, proven by the
1983 measurements made by EPA. but incorrectly disregarded by EPA as well as the state. In
fact, the rer...,ord shows that the state has explicitly xmsrepresexaed the facts of the EPA study in an
attempt to widermine the concerns of Warren County residents about the h~alth risks of PCB air
emissions. Although 1ru1ny rc,idenu have bceu very concerned about. drinki.ag witcr being
c;ontamin2ted, all tht available data indic~te th~t public health risks resulting from PCB air
emissions have probably been the most si;nificant threat for resident, lhin: relatively close
to the landfill.
It is disturbing tha,t EPA scientiSts made exp licit st:itements de~gned to cou.nter the
concerns of citiuns and that those State~ts were not !.upported either by the facts or any
am.l>·sis. Of course, EPA itselfhJd giv~ the state not only approval to construct the Iand£ll, but
also financing for it, so it was not a completely impartial party, In fact, the levels of PC~s
mt!./1.SUrt!d in 1985 wae neitlru low or negligible, as EP.-4 claimed. Tiu rwo c/tief
co,cst!q,u11a.s of r~ching the wrong conclllsio,is was that no t!mission control t~cJrnology wa.s
used to pr~vent PCB 11ir rele11~s and no odditional mcmitoring W"-S carried out If EPA had
come ro the conc/11sion that sig,riflcant kv~ls of PCBs Wert being emitted from th~ landfill.
the serious ~on urns of local resuknts would have b~tn fully supported hy the federg{
government. It would ltavt: been apprupriate /Dr EPA, on rht basii of Its initial ftndiags, to
have co,idu.c.ud anothu roMttd of more atensive air moniroring in the summer of 1983,
e..sptcially at >, oniesiks withi11 one to mi/t:$ of the landfill.
As to the issue of PCB health effects and monitoring, it should be noted that the federal
g0v emm~t had examined the issue of whether exposure to the origiul PCB spill materials on
North Carolina roads resuhed in increa~s in PCB levels in breast milk. The study was completed
in 1982 and published.in 1983 (W.J. Rogan et al, Chromatographic Evidence of PolycbloriJated
Biphenyl E:-q,oi;ure From a Spill, Journal Americ:m Medical Association, voL249, no.8, pp. 10~7-
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1058). The researchers at the National Institute ofEnvironm~tal Health Sciences concluded that
the data for 12 exposed women that had been part of a larger study .indicated that some pan of
the PCB leveh found in their bodies correlated with the types of PCB& spilled OD the roads. The
women had been exposed to PCB vapors from spill locations along roads. It would have be:n
very useful to monitor the PCB levels in br1:ast milk in women living near the W a.rrc::n Coanty
landfill, but that did not happen.
The levels of PCBs measured during the 1983 winter period around the landfill and,
especially, in the area of the resid~,e closest to the landfill, were ofhealth significance and
cone.cm. There is every rea.son to believe, on the basis of scientific principles, that emissions of
PCBs from the Warren County PCB Landfill have been significant for over 15 years. Release
rates would probably have been greater in wanner periods and may have changed over time a$
more time was aYailable for vaporization of PCBs ·wi'thin the landfill, as compared to the earl)'
J 983 period~ just a few months after the wastes were buried i!l the landfill. Although local
residents repon having asked the state over the years to we some: t)pc of a.ir pollution control
system. such as carbon adsorption: the state: never implement~ any control method.
In addition to cancer risks, however, attention must also be given to non-cancer bealt.'li
effects that could result from long periods of exposure to relatively low PCB levels. Also,
exposure during pregnancy is a threat. Research 3t Wayne State University and published in th~
New England Jou.ma! of Medicine iD September 1996 reported developmental effects in eleven-
year old childr::i whose mothers had con.sum~ PCB contaminated fish in.:the 1980s while
pregnant. At birth children had smaller beads and lower weights, a:id later-' children had lower IQ
scores. poor rcadmg comprehension. memory problems and shorter attention spa.n. Similar results
have been fou.o.d in several animal studies and in &tudies of Taiwanese children accidentally
exposed to PCBs. The damage to children was deemed similar to the effects ofleBd poisoning in
children .
The air rele:ise of PCBs also raises queStions about other exposure routes. For example,
air releases of PCBs implies that some PCBs would be deposited on the local surrounding lands,
some of ·which are used for agriculrural purposes) suggesting that crops;, vegetables gro\W in
household gardens, and dairy and meat products from cattle grazing on local land$ could be
sources of PCB exposure throu~ ingestion, not only for local residents but perhaps for others.
There is clearly a need for the state or EPA to conduct several types oftests. including the
following: .
■ Current PCB emissions rates from the m.am vent and any other points open to the
atmosphere should be determined using the most sensitive and reliable testing methods.
■ Testing of PCBs io human tissues among adults and children who have lived near the
landfill for long times should be conducted.
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■ Health effects surveys should be conducted for long term nearby rc:sidents, especially
children bome by mothers that lived near th.c site during pregnancy.
• There should be so.o::ie t~sting of locally grown fruits and vegetables (and pemaps canned
locally grown produce knov.n to have: been grown some years ago).
lf PCBs are mil being released from the lmdfill, then an engineering study of using some
type of carbon adsorptioD ~)'Stem should be immediately initiated.
Finally, the rault, reported here supply still more support for the state t»king
seriously iu commitment to dnol.ify the Warren County PCB Laodfall and to make a
commitment for napplying the necessary funding very quickly. There is oow abW1dant
proof that the lsndfill has not been safe and ,ecure, that the critically important bottom
cl.3~ .and plutic lineT ,ystem leaked, that the leacb1te collection system never wor1'td
effectively, 2nd thJlt PCBs h2ve leaked direcdy into the air and ltach:at.e into the
,urrounding soil!.
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~--tF'A Environmental Consultants
=;::::.;=:Feria~ and As=~,=~
MEMORANDUM Bf A #95-017
TO: PCB Landfill Working Group
FROM.: Patrick BamC3, Science Advisor
Joel O Kimrey, P.G., Senior Hydrogeolog.ist
DATE: December 2, 1996
SUBJECT: Air Emissions of PCB and Associated Health Risks
We have performed a cursory review of the U.S. EPA re.search report on "fugitive Atmosphere
Emissions of PCB's from Hazardous Waste Landfills", ~ well as the review of that repon
prepared by Joe! 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 regardless of the
testing results. They failed to draw the most important conclusion of their study, which is that
even so-called controlled landfill r:prcsents potentially significant health risks.
It is difficult to believe that th: fa,ili,y WU not designed to include gas filt::rs at the main vent
opening. I believe that the community should demand an immediate explanation from the State of
this apparent disregard for th; safety of the citizens of Afton. Moreo,,er, I recommer:d that
community leaders demand, i.n no uncertain terms, that:
1. The main vent or any uncapped opening to the landfill be fitted with an acti-.·ated carbon
adsorption type . filter within i2 hours. . The filters should allow for influent and efi1uent
sampling
2. In addition to the health related sampling recommended by Joel Hirschhorn, additional
sediment sampling ahould be performed by the EPA or the State which include5 deposits at
the mouth of each major surface drainage feature within 1/2 mile: of the site. The PCB· s
which have been depo~ited by air emissions may have accumulated in these surface drainagt:
fearures and thus may still pre~ent a threat to the environment
The Hollister euilding • 3535 Lawton Road• Suite 111 • Orlando, Florida 32603
Office(407)8Q6-8608• Fax(407)896•1822 -
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• • State of Norfh 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: BFA 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 environment." It would also be helpful
to the staff if BF A submitted the qualifications, expertise and experience of personnel providing
the statements and response to our request.
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10"/o post-consumer paper
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UNITED STATES.ENVIRONMENTAL PROTECTION AGENCY
APR 2 0 3983
I.
DATE: APR I 8 lS63
SUBJECT: Draft Final Report on Ambient Monitoring for PCB' s at the Warren County
(North Carolina) Landfill
FROM: Barry E. Martin, Chief <d'~ ~
Field Monitoring Section, EMTB, /£:.Mn, EMSL/RTP (MD-76)
TO: Doyle Brittain
EPA, Region IV College Station Road
Athens, GA
Enclosed is a copy of the Draft Final Report on Ambient Monitoring
for PCB's at the Warren County ~orth Carolina) Landfill submitted to
me by Battelle Columbus Laboratories, Columbus, Ohio. Please review
and provide your comments to me so we can finalize this task with
Battelle.
If I can be of further assistance, please call me at FTS: 629-3076.
Enclosure
cc: T. Hartlage (MD-76)
·A Form 1320-6 (Rev. 3-76)_
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DRAFT FINAL REPORT
ON
AMBIENT MONITORING FOR PCBs AT THE
WARREN COUNTY (NORTH CAROLINA) LANDFILL
by
D.L. Sgontz, W.E. Bresler, L.A. Winker
and J.E. Howes, Jr.
Battelle Columbus Laboratories
Columbus, Ohio 43201
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Contract No. 68-02-3745
Work Assignment No. 10
Project Officer
Barry E. Martin
Environmental Monitoring Systems Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 2m1
April 8, 1983
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SECTION 1
INTRODUCTION
Approximately 40,000 cubic yards of PCB-contaminated dirt excavated from
along roads the central piedmont area of North Carolina has been disposed of
in an approved hazardous waste landfill in Warren County (NC). Local
residents and the Warren County Health Department have expressed concern
a~out the possibility of airborne PCB emissions from the landfill being
transported to neighboring areas, thus threatening the public welfare.
In answer to this concern, a study was performed to monitor airborne PCB
emissions from the landfill and ambient air levels on and surrounding the
site. The specific objectives of the study were:
o to determine if PCBs are being emitted from vent pipes on the
1 andf i 11.
o to determine if PCBs are present in the ambient air downwind of
the vent pipes. /
o to determine if PCBs are present in the ambient air in the
vicinity of the nearest residence, approximately one-half mile
away.
o to quantify the actual concentration of PCBs, if any, being
emitted from the vent pipes.
o to quantify the actual concentrations of PCBs, if any, being
transported off the landfill.
The study was performed at the request of the North Carolina Division of
Health Services and was conducted according to a plan developed by EPA,
Region IV and EPA/EMSL personnel. Battelle-Columbus Laboratories personnel,
assisted by Jim Gray of EPA Region IV, performed the field sampling program.
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Southwest Research Institute performed the PCB analysis of the polyurethane
foam sampling cartridges. The following sections describe the landfill site,
the sampling and analytical procedures that were used, and present the
results of the study.
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SECTION 2
SITE DESCRIPTION
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The landfill is located in Warren County, North Carolina on an
approximately 20 acre tract of land owned by the State of North Carolina.
The landfill proper covers an area of approximately 75m x 145m. In the
construction, plastic pipes were installed to vent gases:and aqueous leachate
from landfill. The locations of the vents on the landfill are shown in
Figure 1. The main vent is 4 in. in diameter, extends approximately 1.2m (4
ft.) above the ground, and is located in approximately the center of the
landfill. Two leachate vents are located near the northeast corner of the
landfill. Two small vents have been added after construction to relieve gas
pressure under the plastic cover on the landfill. One of the vents is
located approximately due west of the main vent and the other is located near
the leachate vents.
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N1 /2 mi. ~ from 1 andfi 11
House
B
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Vent Identification
A-Main Vent
B-Sma11 Vent
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C-Upper Leachate Vent 0-Lower Leachate Vent
E-Small Vent
\ 0 Leachate
Q OE
D Q
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Figure l. Vent locations on Warren County (NC) Landfill
Pond
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FIELD MONITORING
SECTION 3
EXPERIMENTAL PROCEDURES
The field monitoring program was conducted over the -period January 26 -
February 1, 1983. Sampling was performed to determine PCB emissions from the
5 landfill vents and ambient air PCB levels on and in the vicinity of the
landfill. The monitoring schedule was as follows:
January 26 -vents and ambient air (daytime)
January 27 -vents only
January 28 -vents only
January 29 -ambient air only (daytime)
January 30 -no sampling due to weather conditions
January 31 and
February 1 -ambient air onfty (night time)
All PCB monitoring was performed with DuPont P-4000A battery-operated
pumps equipped with sampling cartridges consisting of a 20mm i.d. x 10cm long
borosilicate glass tubes into which was fitted a 22nm dia. x 7.6cm long plug
of polyurethane foam plug. The PUF sampling cartridges were connected to the
pumps with a short section of Tygon tubing as shown in Figure 2. Sampling
was performed according to the procedure described in Appendix A.
The vents which were sampled are identified in Figure 1. Sampling was
performed by placing the PUF cartridges into the vent pipes and sealing the
vent openings with a plastic bag or tape to restrict gas flow. Nominally,
sampling was performed for 8 hours at a flow rate of 1.2 -1.4 L/min.
Ambient air sampling was performed with an array of samplers located as
shown in Figures 3 and 4. Figure 3 shows the sampler placement for the
ambient air monitoring conducted on January 26 from approximately 1000 to
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SAMPLING CARTRIDGE
1t5V ADAPTOR/
CHARGER PLUG
=-
TIMING SMTCHES
DRIVE IELT
OFF-ON SWITCH
Figure 2. DuPont P-4000A pump and sampling cartridge.
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;. Weather
Station
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6A 68 6C
Figure 3. Ambient air sampling locations on January 26, 1983.
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·1 Figure 4 . ..
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=-
J I 0 N
0 0 0
SA
4A
2A
58 048 0 7
28
4C •-
SC
Ambient air sampling locations on January 29,
8
1983.
©
MRI
Weather
Station
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1700 hrs. EST. Two samplers were located upwind of the main vent; one on-
site approximately midway between the vent and the north fencelirie {Location
7) and the other off-site {Location 8). Two samplers were located near the
main vent (Locations 2A and 28); one on each side at a distance of 1 meter.
An array of 12 samplers were located downwind of the main vent in
approximately a 90° quadrant. Samplers were placed at three locations {4A,
4B, and 4C) approximately midway between the main vent and the south fence
line. Along the south fence line, samplers were placed at three locations
(SA, SB and SC). At each location, sampling was performed at 4 ft. and 15 ft.
above ground level. The sampling locations (6A, 6B, and 6C) were off-site
approximately 200 meters from the main vent. ·one sampler was placed near the
residence which is approximately 1/2 mi. west of the l~ndfill. With exception
_of the downwind fence line points, ambient air sampling at all other
locations was performed at 4 feet above ground level. The sampling pumps were
operated at a nominal flow rate of 3.8 L/min.
\ Sampler pla~ement for the ambient air monitoring conducted on January 29
is shown in Figure 4. Samplers were deployed in the same general pattern as
used on January 26, however a change in wind direction required a shift in
the specific sampling points as shown. Sampling on January 29 was performed
from approximately 0900 -1700 hrs. EST.
Night time ~am.pling was pdrformed on January 31 -February 1 using the
same sampling pattern and sampling locations as on January 29. Sampling was
started at approximately 2100 hrs., January 31, and was to be terminated at
approximately 0500 hrs., February 1. However, most of the DuPont pumps
failed after 2-3 hours of operation due to the low ambient temperature
(""30°F) and the high relative humidity (~95%). Consequently, very few valid
samples were obtained.
PCB ANALYSIS
Analysis for PCBs in the PUF cartridges was performed according to the
procedure given in Appendix 8. The steps in the analysis procedure included;
1) Soxhlet extraction of the foam plugs with S% ether in hexane; 2)
concentration of the extract to 1 ml and 3) determination of PCBs in the
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extract by electron capture-gas chromatography using EPA Method 608(l).
Identification and quantification of Aroclor 1242 and 1260 in the samples was
performed by the technique described by Webb and McCall(2).
METEOROLOGICAL MEASUREMENTS
Continuous measurements of wind speed and wind direction were performed
during the field monitoring period with a MRI portable weather station. The
ambient temperature sensor on the unit"'did ,rot function, thus continuous
ambient temperature data were not obtained. The weather station was located
east of the landfill in an unobstructed area. Ground level elevation at the
weather station location was approximately the same as the center of the
l andfi 11.
Ambient temperature, relative humidity, and barometric pressure readings
were taken approximately hourly during sampling periods.
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PCB MONITORING DATA
SECTION 4
RESULTS AND DISCUSSION
The results of the PCB monitoring at the Warren County landfill are
presented in Tables 1 through 6. Tables 1 through 3 giv~ the concentrations
of Aroclor 1242 and 1260 {in nanograms/standard cubic meter*) measured in the
vent emissions on January 26, 27, and 28, respectively. The results show
that the main vent is the predomi~ate source of PCB emission from the site.
During the study period, the average concentrations of Aroclor 1242 and 1260
. observed in the main vent emissions were 123 and 2 µg/scm, respectively. The
PCB emission rates from the main vent based on these average concentrations
and the average flow rate· (measured by EPA) are: 12 ng/sec of Aroclor 1242
and 0.19 ng/sec of Aroclor 1260. PCB emissions from other vents on the site
were significantly lower than f~om the main vent.
The ambient air monitoring results obtained during the study are. shown
in Tables 4,5, and 6. On January 26, vent and ambient air monitoring were
performed concurrently. Thus, the ambient air monitoring data for this date
(Table 4) are probably not representative since the flow from the vents was
restricted during the sampling period.
The daytime ambient air monitoring data for January 29 is shown in Table
5. PCBs were not detected at any sampling location downwind of the main
vent. Aroclor 1260, at a concentration near the minimum detection limit was
found in one of the upwind samples (Location A-7).
* Standard conditions -2s0c. 76Cmn Hg
,·-~ ~ ......., a-., 1-J a.-, L-1 .__, ....., ....., L-1 1--' ....., ........... __, ...... .._. ~ ....... L-tl TABLE 1. VENT MONITORING RESULTS -WARREN COVNTY (NC) LANDFILL(a) Sampling Date January 26, 1983 Sampling Location Samellng Period, Hr EST Sampl Ing Avg Sampling Total Sample guantltfl PCBs In PUF1 ng Code and Description StarE £na Time, mlns. Rate, sec/min Volume, scm Aroclor -242 Aroclor 1260 V-A Main Vent 1010 1700 410 1408 0.58 82,100 V-8 Small Vent west of Hain Vent 1010 1701 411 1237 0.51 35 -V-C Upper leachate Vent 1005 1701 416 1424 0.59 1270 V-D Lower Leachate Vent 1005 1701 (b) (b) (b) ND V-E·Small Vent near Leachate Vents 1010 1701 411 1460 0.60 400 a) ND -PCBs were not detected fn sample. Minimum detectable levels of Arochlor 1242 and Arochlor 1260 In the cartridges are estfmated to be 10 ng and 15 ng, respectively. b) Sample pump malfunctioned during sampling period. 1200 ND 360 ND 780 PCB Cone. In Alr1 ng/scm Aroclor 1242 Aroclor 1260 141,552 2,069 69 <29 2,153 610 667 1300 ,.. ,,
!I• H :.,; ' --, ,. ____ .._ 1,-..11 .,__, ~ ----.J' t..-.J . '--' TABLE 2. VENT MONITORING RESULTS -WARREN COUttTY (NC) LANOFILL(a) Sampling Date January 27, 1983 Sampling Location Samellng Period, llr £Sr Star[ (nil Sainpl Ing Avg-.sa,npl ing Total Sample guantlty PCBs In PUF1 ng Aroclor 12~2 i'troclor 1260 Code and Description Time, mlns. Rate, sec/min Volume, scm V-A Hain Vent 0900 1100 480 1359 0.65 76700 V-8 Small Vent West of Hain Vent 0900 1700 480 '1159 0.65 ND V-C Upper Leachate Vent 0900 1700 480 1410 0.68 1920 V-D Lower Leachate Vent 0900 1700 480 1330 0.64 ND V-E·Small Vent near Leachate Vents 0900 1700 480 1259 0.60 NO a) ND• PCBs were not detected tn sample. Minimum detectable levels of Arochlor 1242 and Arochlor 1260 1n the cartridges are estimated to be 10 ng and 15 ng, respectively. 1380 NO 320 51 ND PCB Cone. In Alr1 ng/scm Aroclor 12~2 i'troclor 12&0 118,000 2123 <15 <23 2824 471 <16 80 .,,. <17 <25
~f~lf.~ ,:,.~ (·. :'1 ...... ,., ............ . ;·· ~t'-' '• : . :, . '. ,. I.,_; ,.__, .. __.. ...... .... ...... ..... ..... ~ ..... ..... .... .... Sampling Location Code and Description -V-A-1 Hain Vent(b) V-A-2 Hain Vent(b) V-B Small Vent West or Main Vent V-C Upper Leachate Vent V-0 Lower Leachate Vent V-E Small Vent Near Leachate Vent TADLE 3. VENT MONITORING RESULTS -WARREN COUNTY (NC) LANOFILL(a) Sampling Date January 28, 1983 Samellng Period, llr EST Sampl Ing Avg Samp 11 ng Total Sample gu,,nt lt_y PCDs In PUF I ng Start End Time, rnlns. Rate, scc/,nln Volume, scin Aroclor 1242 Aroclor 1260 0900 1700 400 1254 0.60 69300 1130 0900 1700 480 1347 0.65 68700 1150 -0900 1700 480 1326 0.64 42 NO 0900 1700 400 1388 0.67 510 206 0900 1700 480 1324 0.64 61 54 0900 1700 480 1279 0.61 18 18 a) ND -PCBs were not detected In sample. Minimum detectable levels or.Arochlor 1242 and Arochlor 1260 In the cartridges are estimated to be 10 ng and 15 ng, respectively. b) Co-located samplers. ....... ~ _. ...__. L--' f. PCO Cone. In Alr1 ng/scm Aroclor 1242 Aroclor 1260 115,500 1883 ,,.. 105,692 1769 66 <23 761 307 95 84 ,, 30 30
.. ~ b,1 l •i, •ii.... ..... .... ------~ ... -. ----·:r,•·· =•·i• ~.,.~ ..... llffi,:l ·"•lr'l'.:I.Ll._,■l'li4J.....,,■wH-41 ••·•• •· It •• 1t,.1Lti,..,..a_,L,..._a-•~.,.,1L............J .... ,.___.. t,k'ftt•f. \=\·:1?•~°'.I: ,~n !frl, •{ ~,_., :,1:_:1 . , , ;_ . --. .._. ·-····-···--·-·:t/l?': · 1•:·· }:~f:I\:-1\+:t:::\\i:;: ,·,-· · TABLE 4 AflllENT AIR W>NITORING RESULTS -WAIIIIEN COUNTY (NC) LANOflLL (•) SN11'LING DATE· JIINUARY 26. 1903 . . .. ···-····--···· .... ·-··--------....... __ ......................... ·-· ....... ·-· ·-........ -·· .... -............... _ ..... ....... -..... Total Sall(lle ....... . .. --·· Av~J. So1111pl1119 :ca _co_n!\ ln .. Mr., .!'fsc-. ti-Sarapllng Location Sa1141llny Sa~l 1119 Pcrlod1 llrCST S,1111111 lll!J QuantltY. PCOs In PUF, ni Coda ind Description Height,■ tut En~ Time, ■Ins R• te, scc:/•I n Volwne, sea Aroclor 1242"-Aroclo·r· liill roclor l42 Aroc or I 60 ... ----·-----------Beside tt.ln_Vent 2A I• ~est of lllilln ventf 1 4 1005 1700 415 390!1 2P-1 1 • e1st of Nlq vent c 4 1005 1700 415 3799 2U-2 I • cut of ■aln vent c 4 1005 1700 415 3865 On-Site ~!!.~J.!!.~ 4A 49■ fro■ Nin vent I 230"f 1 4 1005 1710 425 3844 40-1 4911 fro• 11iln vent iP 100" ~ 1 1010 1711 421 3811 48-2 49• fr0111111aln vent I 180" 4 1010 1:1 (b) (bl 4C 49• fr011 inaln vent I 140" 4 1005 (b) (b Fencellne llownwln~ -SA 98~ fro• Nin vent 9 230° 4 1007 1700 413 3744 SA 9&1 fr011 Nin vent I 230" 15 1000 1702 422 3822 50 9°'11 fro■ iuln vent 9 100" 4 1008 1706 418 3811 58 9P■ fr011 lliln vent I 100• 15 1000 1708 428 3083 5C 9&1 fr011 , .. tn vent I 140" 4 1010 1710 420 3824 SC 911n1 fro■ Nin vent I 140" IS 1000 17ll 433 3826 Off-Site Downwind 6A 200. fro■ aaln vent I 230• 4 1014 1702 408 3844 68 200ra fro• Nin vent I 180" 4 ioo9 (b) (b) (b) 6C 200. fr011 1111 In vent I 140" 4 1020 1708 408 3904 A-3 House west of l•ndflll 4 1025 1730 425 3845 A-7 49■ upwind of Nin vent I 360" 4 1000 1700 420 3894 A-8 Offslte, upwind of inaln vent 4 1015 1702 407 3894 1360• ..,. --••----·••·~r·• •·•• •·•••• _ .............. ········--•··-· .................. -·--·· ........ ---· .. I•> NO -PCBs were not detected In sa,1ple. Hint-detect1ble levels of Aroclor 1242 and Aroclor 1260 In the PUF c1rtrldges tre estl1111ted to be IDng •nd 15 ng, respectively. NA • PUF cutrld!II wu not 1111 lyzed for PCBs. (b) S1niple puq, •lilfunctloned during 11111pllng period. (c) Co-loc1ted s1111plers. 1.62 ND 20 ·6 12 1.60 NO NO <6 <10 1.60 NO HO <6 <10 1.63 NO NO <6 <ID 1.60 NO NO <6 <10 l:l ND ND ND NO 1.55 NO 110 •6 71 1.61 NO 80 <6 50 1.59 ND NO <6 <10 1.66 ND NO <6 •10 1.61 NO NO <6 <10 1.66 NO NO <6 <10 1.57 ND ND <6 <10 (b) NA NA --.. 1.59 ND ND •6 <10 1.63 NO NO <6 <10 1.64 ND ND <6 <10 1.58 ND ND <6 <10 r
" 't@' w. ···1 i:·1 · . ~ ,.. ... _ ·• ;,, , 1 ~11r .!t1~!f1 . . . . : ... ,, :r:-i; ,1 ... i 1~~. -Wt ·dt.i.:1~,~. _ J -~ _ ~ r _:-. I J1.i .. ,.:; .. '..lo -· . 'tt~r:-;~ .. ·: . °'·11<lf1-1I~:: ~;::'~I('•':. ' .. ........ ,,.., ... ,. .. I 11 -....,., ... ...... --------r TABLE-5 Al1111ENT AIR 14JNITORING RESULTS• WARREN COUNTY (NC) LANDFILL(•) SAMPLING DATE· JANUARY 29, 1983 ··-··-·-.. ·····-,,.---·------.-..---··-.......,,,. ........... ·-----··---·----... --·-------·---··--·-· --·--· ···-........ , ··-Saq,llng Loc•tlon S1qilln9 Sa~llng Period, HrEST Saq>ltng Avg. Saq1ltng Total Saqile iuantlti PCBs In PUF1 n' PCB Cone. In Air, ng[scm Code ind Description Height,■ tut End T1111e, alns Rite, scc/aln Volume, sc■ roclor 1242 Aroclor 260 Aroclor 1242 Aroclor 1260 Beside Hlln Vent 2A lm·north of 11111n ventl 1 4 0905 1713 488 3725 1.82 NO ND c6 clO 2B-1 1• south of 11111n vent~ i 0905 1715 490 3830 1.88 ND ND <6 clO 2B-2 I• south of Min vent 0905 1714 489 3818 1.87 ND NO <6 <10 On-Site Downwind 4A 43111 froa 11111n vent i 3IO"f l l 0905 1712 487 3685 1.79 ND ND <6 <IO 48-1 3311 fro■ aaln vent i 270° c 0905 1710 485 3735 I.Bl ND ND <6 <ID 48-2 33■ from 11111n vent i 210• c 0905 1707 482 3753 I.Bl NO ND <6 <10 4C · 40m fr01111111n vent I 225• 4 0905 1705 480 3722 1.79 NO NO <6 <10 Fencellne Downwind SA 85• fro• 1111n vent I JJO• 4 0905 1715 490-3770 1.85 NO ND <6 <10 5A 85m fro■ 11111n vent I 310" 15 0905 1717 492 3853 1.90 NO ND <6 <10 5B 66m from main vent I 210• 4 0905 1708 483 3773 1.82 ND NO <6 <10 5B 66m fr011111111n vent I 270° 15 0905 1111 486 3870 1.88 ND NO <6 clO 5C BDm froca 11111n vent I 225• 4 0905 1705 480 3792 1.82 NO ND <6 <10 SC 80. froa 11111n vent I 225° 15 0905 1707 482 3778 1.82 ND NO <6 <10 Off-Site Downwind 6A 134m from inaln vent i 2B0° 4 0905 1705 460 3752 1.80 ND ND <6 <10 68 132m froa 11111n vent i 210• 4 0905 1709 484 3823 1.85 ND NO <6 <10 6C 152■ from Nin vent I 240• 4 0905 1713 488 3839 1.87 ND ND <6 <10 A-3 House west of landfill 4 0930 1705 455 3366 1.53 ND ND <6 <IO A-7. On-site, 32m upwind of Nin 4 0905 1708 483 vent i 100• 3790 1.83 ND 20 ND 11 . A-8 Offslte, 74m upwind of Nin 4 vent i 100• 0905 (b) (b) (b) (b) NA NA •--~~-.. ••--·•~••-r•••-~-------••-•-•---•·•••·••••••.,••••••-••••-•-•-•••••••-• ·--~•-----------------------•---------------(•) NO -PCBs were not detected In sanple. Kini-detectable levels of Aroclor 1242 and Aroclor 1260 1n the PUF c1rtrldges •re estlm1ted to be JOng •nd lSng, respectively. NA -PUF c1rtrldge WIS not Analyzed for PCBs. (b) Simple puq> inalfunctloned during simpling period. (c) Co-located s•111Plers. .............. -'
~ ....... ....... ...... ....... ~ .._.. .._.. .... .._.. ....... i....t ~ i...J TABLE 6 , PCB HOOITOIIING RESULTS -WARRlN COUNTY (NC) LANDFILL (a) SA11PLING DATE -JANUARY JI -FEBRUARY 1, 1903 i.-a ~ ~-~-~-•..._., L..-.. I• 1, ·····•-··---··· 0-111 .......... , lllol ea 11 • •■ t •·111 I• .....
.... , I. 0 'I" Ill
.... , •••••• _, •1•1,1•1 .... ,._11·1 ••t tl·r• •----·•·-••t .......... _ ... _......, _____ II •
.-.1111111 ••••··•••1 ~• I 1"0'
,_ Sa1npl Ing locat Ion Sainpl Ing San!llnf Perlod1 HrEST Sa■ipllng Avg. S111pl Ing Code and Description Height,■ hr End Thne, ■Ins Rate, sec/min Beside Hain Vent 2A lm north of Nin vent 4 0117 (2/1) 0530 (2/1) 253 3896 On-Site Downwind 4A 43m from inaln vent t Jlo• 4 2100 rill) 0530 (2/1) 510 3998 48 3Jm from Nin vent t 210• 4 0120 2111 0530 (2/11 250 3882 4C 40m from Nin vent t 225• 4 0120 2/1 0530 (2/1 250 3944 ·------· .,.. _ _. ...... ·---···· ---.--------·-------· ----..--------·--··· (1) ND -PCBs were not detected In s1111>le. Hlnl-detectable levels of Aroclor 1242 ind Aroclor 1260 1n the PUF cartridges ire est1Nted to be lOng and l5ng, respectively. NA -PUF cartridge was not analyzed for PCBs. (bl Low flow Indicated during sampling period; sample volllllll! questionable. Tota 1 Sa111ple iuantltt PCBs In PUF1 n' PCB Cone. In Alr1 n~m Volume, scm roclor 1242 Aroc1or260 Aroclor 1242 Aroclor ·2Dlf 0.99 ND ND <10 <15 (b) ND ND <5 <8 2.04(bl 0.97(b ND ND <10 <15 0.99 NO NO <10 •15 ,.
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T.he limited data obtained during nighttime sampling on January_ 31 -
February 1 is shown in Table 6. PCBs were not detected in any ambient air
samples. However, most of the data are questionable because of malfunction
of the DuPont pumps due to the low temperature and high humidity conditions~
METEOROLOGICAL DATA
The results of wind speed, wind direction, ambient temperature, relative
humidity, and barometric pressure measurements performed at the Warren County
landfill during the period January 26 -February 1, 1983 are presented in
Appendix C.
VENT FLOW RATE MEASUREMENTS
Gas flow rates from the vents on the landfill site were measured by
EMSL/EPA/RTP personnel on March 2, 1982. The measurements were performed by
sealing the vents and determining the volumetric flow of the exit gas with a
bubble meter. Flow data for the main vent are given below. No flow was
detected from the other vents on the landfill.
Time
0945 hrs.
1200 hrs.
1500 hrs.
Main Vent Exit Gas Flow
F\pw, sec/min
(25 C, 760nm Hg)
4854
6000
6400
Avg. 5751
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DISPERSION MODELING
In order to obtain confirmation of the ambient air concentrations
measured during the field monitoring, standard dispersion models were used to
calculate downwind concentration of PCBs using emission parameters and
meteorological conditions that prevailed during the field monitoring program.
Two EPA UNAMAP models, PTPLU and PTDIS, respectively, were employed to
calculate 1) estimates of maximum hourly concentrations under a full spectrum
of meteorological conditions and 2) estimates of the range of hourly ambient
concentrations that would occur at down wind distances of SOTI, lOOTI, and 150TI
under the meteorological conditions that probably controlled dispersion
during the field monitoring on January 29.
The following parameters were either used explicitly in the modeling or
provided guidelines from which maximum and minimum limiting concentrations
could be calculated.
PCB emission rate from main vent* --12.1 ng/sec
Main vent gas exit velocityk* --0.012 m/s
Vent gas temperature (estimated) --288.2K (ls0c)
Vent diameter --0.102m (4 inches)
Height of vent above: ground --11• 2m
Observed ambient temperature during
monitoring (1/29/83) --minimum= 274.2°K (1°c)
maximum= 286.2°K (13°c)
8-hr. average= 282.2°K (9°c)
Observed wind speed during
monitoring (1/29/83) --minimum= 0.72 m/s (1.6 mph)
maximum= 2.3 m/s (5.1 mph)
8-hr. average= 1.6 m/s (3.5 mph)
* Average of emission measurements made on January 26, 27, and 28.
-ic* Average of flow rate measurements made by EPA on 3/2/83.
Since the terrain sloped downward from the location of the vent pipe to
the ambient monitoring locations, each model was run for two scenarios to
bracket the expected actual concentrations. One scenario treated the vent as
standing 1.2 meters above a flat terrain while the second scenario placed the
vent exit at a height of 5.2 meters above a flat terrain.
The one-hour concentration predictions of the model were converted to
eight-hour averages by multiplying by a factor of 0.6. This factor was
selected after a review of the EPA publication, Workbook of Atmospheric
Dispersion Estimates (AP-26) by 0.8. Turner (pp 37-38).
The maximum one-hour PCB concentrations predicted by the PTPLU model
under the two scenarios are shown in Table 7.
TABLE 7 PREDICTED MAXIMUM ONE-HOUR DOWNWIND PCB CONCENTRATIONS
FOR VARIOUS VENT HEIGHTS
Scenario
Vent 1.2m
above flat
terrain
Vent 5.2m
above flat
terrain
Maximum
1-hr. Conce~tration
(ng/m)
4.0 X 10-G
1.4 X 10-7
Distance
to Maximum
Concentration,m
14
75
Conditions Producing
Maximum Concentrations
Wind Speed Atmospheric
(mps) Stability Class
0.3 4 (neutral)
0.5 4 (neutral)
Using the PTDIS model, the average wind speed observed during the
monitoring period on January 29, Class 4 stability, and the 0.6 conversion
factor, the estimated ranges for 8-hour average ambient concentrations at the
three downwind distances calculated. The results are shown in Table 8.
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TABLE 8 PREDICTED 8-HR. DOWNWIND PCB CONCENTRATIONS FOR JANUARY 29, 1983.
Distance
Downwind from
the Vent (m)
50
100
150
Range of 8-Hour
PCB Ambient Co~centration
(ng/m)
1.5 -8.0 X 10-8
2.0 -2.5 X 10-B
1.25 -1.35 X 10-S
The concentration range limits were taken from the model output for the
two vent height scenarios.
A wider concentration range estimates can be obtained by using the
maximum and minimum one-hour concentrations calculated for the two scenarios
under all combinations of the three wind speeds (minimum, maximum, and
average) and the six stability classes. The concentration limits predicted
by the model for the three downwind points for these conditions are shown in
Table 9.
TABLE 9 RANGE OF ONE-HOU~ CONCENTRATIONS FOR VARIOUS WIND SPEEDS
AND ALL STABILITY CLASSES
Monitor Distance Minimum 1-Hour Maximum 1-Hour
Downwind from PCB Concentration PCB Concentration
Vent (m) (ng/m3) (ng/m3)
50 1.5 X 10-lQ 4.5 X 10-7
100 7 .Q X 10-9 2.Q X 10-7
150 3.5 X 10-9 1.0 X 10-7
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For each downwind location the conditions which yielded the maximum 1-
hour PCB concentration were; a 1.2m vent height, a wind speed of 1.6 m/s and
Class 6 (very stable) stability. Under this set of conditions the PTPLU
model predicted that the maximum PCB concentration would be 4.8 x 10-7 ng/m 3
and would occur at 37m downwind of the vent.
In summary, the dispersion models predict that downwind PCB levels under
prevailing and worst case meteorological conditions should be significantly
lower than concentrations that could be detected by the monitoring techniques
employed in this study. Thus, the monitoring data for January 29 are
consistent with the modeling predictions in that PCBs were not detected in
any downwind ambient air samples.
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SECTION 5
QUALITY ASSURANCE DATA SUMMARY
PUF CARTRIDGE CLEAN-UP CHECKS
All PUF cartridges were pre-cleaned before being used for PCB sampling.
One cartridge from each batch of 20 clean cartridges was re-extracted and
analyzed for PCB contamination. The batch of cartridges was considered
acceptable for sampling if the PCB level in the check sample is <10 ng.
FLOW RATE CALIBRATIONS
The flow rate of the DuPont pumps was calibrated with a bubble meter
before and after each sampling period using a DuPont Calibrator system. The
flow rate calibration data are summarized in Table 10. Average flow rates
for the sampling period were calculated from the pre-and post-sampling
calibration data.
PERFORMANCE AUDIT
A flow rate audit of the DuPont sampling pumps used during the study was
performed by W.F. Barnard, EMSL/EPA/RTP.
QUALITY CONTROL SAMPLES
A set of 18 quality control samples consisting of PUF cartridges spiked
with various quantities of Aroclor 1242 and Aroclor 1260 were analyzed with
the vent and ambient air samples. The QC samples were prepared by BCL using
NBS/SRM 1581 (Aroclor 1242 and Aroclor 1260 in oils). Results of the
analysis of the QC samples are given in Table 11.
--·~------... -.,. ··---
.,_
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' f TABLE 10. DUPONT PUMP FLOW CALIBRATION DATA
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I Date Pump Sampling Calibrated Flow Rate, sec/min · Avg Flow
S/N Location Before Sampling After Sampling Rate,scc/min
[ 1/26/83 A-083 V-A 1370 1446 1408
A-080 V-B 1230 1243 1237
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A-118 V-C 1370 1478 1424
4789 V-D 1397 (a)
A-062 V-E 1388 1531 1460
[ A-089 2A 3748 4069 3908
A-121 28-1 3710 3888 3799
A-088 28-2 3722 4007 3865
i 4803 4A 3760 3927 3844
A-038 4B-1 3728 3894' 3811
A-032 4B-2 3752 (a) , A-127 4C 3710 (a)
A-061 5A(4) 3705 3782 3744
A-125 5A(15) 3736 3908 3822
t
4696 58(4) 3728 3894 3811
A-092 58(15) 3710 4056 3883
A-087 5C(4) 3748 3901 3825
A-037 5C(15) 3751 3901 3826
A-126 6A 3788 3901 3845
5136 68 3794 (a)
A-120 6C . 3800 4007 3904
A-143 A3 3782 3908 3845
A-094 A7 3754 4034 3894
4779 AS 3801 3987 3894
1/27/83 A-118 V-A 1301 1416 1359
A-079 V-B 1306 1411 1359
A-062 V-C 1301 1519 1410
A-120 V-0 1276 1383 1330
9806 V-E 1209 1309 1259
1/28/83 9806 V-A-1 1206 1301 1254
A-062 V-A-2 1252 1441 1367
A-037 V-B 1245 1408 1326
A-118 V-C 1283 1492 1388
A-083 V-0 1242 1405 1324
5138 V-E 1242 1305 1274
a) Pump malfunctioned during sampling period.
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I TABLE 10 • DUPONT PUMP FLOW CALIBRATION DATA (Cont'd.)
.
I Pump Sampling Calibrated Flow Rate, sec/min Avg Flow Date
I S/N Location Before Sampling After Sampling Rate,scc/mir:i
I 1/29/83 A-126 2A 3692 3758 3725
A.:037 2B-1 3710 3949 3830
A-079 28-2 3787 3848 3818
I 4803 4A 3681 3688 3685
A-088 48-1 3698 3771 3745
4779 48-2 3710 3795 3753
I A-092 4C 3692 3753 3722
A-080 5A(4) 3721 3820 3771
A-118 5A(l5) 3704 4002 3853
I 9806 58(4) 3669 3877 -3773
A-062 58(15) 3681 4058 3870
5138 SC ( 4) 3687 3896 3792
' A-083 5C(l5) 3692 3864 3778
A-127 6A 3779 3724 3752
A-061 68 3768 3878 3823
I A-094 6C 3768 3910 3839
A-089 A3 3710 3022 3366
A-121 A7 3779 3802 3790
l A-032 AS 3687 (a)
1/31/83 5117 2A 3731 4060 3896
( 2/1/83 4696 4A 3738 4258 3998
4789 4B 3772 3992 3882
5942 4C 3743 4144 3944
I All other pumps used on this date malfunctioned during
sampling period.
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I TABLE 11 QC SAMPLE ANALYSIS RESULTS(a)
I Sample No. Aroclor 1242 Aroclor 1260
I Added,ng Found,ng % Recovery Added,ng Found,ng % Recovery
I 1 60 64 107 0 37
6 60 52 87 0 32
I 5 600 680 113 0 ND
13 600 530 88 0 85
' 8 6000 3700 62 0 190
9 6000 3200 53 0 ND
l 10 0 ND 60 70 117 '
14 0 ND 60 180 300
4 0 ND 600 515 86
7 0 ND 500 600 100
2 0 ND 6000 4700 78
12 0 ND 6000 4000 67
15 120 90 75 60 120 200
17 120 85 71 60 70 117
11 400 260 65 200 170 85
16 400 460 115 200 260 130
3 4000 1820 46 2000 1530 77
18 4000 1320 33 2000 2950 148
a) NO -Not detected. Minimum detectable levels of Aroclor 1242 and
Aroclor 1266 are estimated to be lOng and 15ng, respectively.
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FIELO ,BLANKS
Eight field blanks were analyzed with the ambient air samples. The
blanks were PUF cartridges that had been carried through all field operations
except sampling. PCBs were not detected in any of the blanks above the
minimum detectable level i.e. 10 ng for Arochlor 1242 and 15 ng for Aroclor
1260.
CO-LOCATED MONITORING
Co-located monitoring of the main vent was performed on January 28. (See
Table 3 for results). Concentrations determined from the co-located monitors
differ by 9% for the Aroclor 1242 and 6% for the Aroclor 1260. Co-located
ambient air monitoring data cannot be evaluated since PCB levels were below
minimum detectable levels in all paired samples.
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REFDIDiCES
1. Federal Register, Vol. 44. No. 233. l"!rtmday, Deceuber 3, 1979, Pgs. 69501-
69509.
2. Webb, "R.S. ·and McCall, A.C.~ •Quantitutiv~ PCB St~ards for Electron
Capture Gas Chromatography", Journal of Chromatogr~ic Science, l!, Pgs.
366-373, July 1973.
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APPENDIX A
PROCEDURE FOR PCB SAMPLING WITH
DUPONT P-4OOOA PUMPS AND PUF CARTRIDGES
(1) Calibrate the flow rate of the DuPont pumps before sampling with a
DuPont Calibrator system.
(2) At the field site, place pumps at designated sampling locations. Record
pump S/N and corresponding sampling location I.D.
(3) Using latex glove·s, remove a clean PUF cartridge from its sample bottle,
carefully unwrap the aluminum foil from the cartridge. Fold aluminum
foil, replace in sample bottle, and tightly close the bottle cap.
Connect the PUF sampling cartridge to the DuPont pump sampli-ng inlet
using a short piece (12-18 in.) of Tygon tubing. (Note: Clean latex
gloves must .he worn at all times when handling the PUF cartridges). --.
(4) Using metal three-prong clamps that have been rinsed with ·s&J hexane,
mount the PUF cartridges orl the sampler support rod in a vertical
position with the inlet pointing downward. Record cartridge height
above ground.
(5) Turn pumps on and begin sampling period. Record starting clock time.
During the sampling period check pumps at least every 2 hours for proper
operation. Record any abnonnal conditions.
(6) After sampling for the specified time, tenninate sampling period by
turning pumps Dff. Record clock time that pump was turned off. Just
before turning pumps off, push test button on pump and check low flow
light and the elapsed time indicator lights. If low flow light comes
on, it indicates that a low flow condition existed during the sampling
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period, e.g., Tygon tubing crimped, cartridge plugged, pump stopped,
etc). Record results of the low flow check. Record elapsed time from
the pump timer as a check on the clock time.
(.7) As soon as possible after termination of sampling, remove the PUF
cartridge from the Tygon sample line (using latex gloves), wrap
cartridge in its original aluminum foil wrapping, and place in the
original sample bottle. Cap tightly, label bottle with sampling data
and sample I.D. and seal the bottle cap with a strip of "Evidence Tape".
(8) Re-calibrate the flow rate of the DuPont pumps after completion of
sampling.
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APPENDIX B
PROCEDURE FOR ANALYSIS OF PCBs
IN PUF CARTRIDGES
I. Equipment and Reagents Required for PUF Sample Extraction 1. Glassware
500 ml boiling flasks
300 ml capacity Soxhlet extractors
3 ball condensers
500 ml Kuderna-Danish apparatus
15 ml receiver tubes
Snyder columns
Filter tubes (Corning 9480-32)
Pre-scored (1 ml, 5ml) amber glass vials with teflon-lined caps
9" long dispos~ble transfer (Pasteur) pipets
Wash all glassware with Alconox; rinse with deionized water,
acetone, hexane, and deionized water; then fire in kiln (500 C)
2. Equipment
Extraction Apparatus, Multi-Unit Heater (CMS 119-362)
Blunt-end forceps
Surgical tongs (approximately 12") ·
Stearn bath
Nitrogen blow-down evaporator
Glass wool (Heater overnight at 350 C in muffle furnace)
Boiling granules (Heater overnight at 500 C in kiln)
Teflon wash bottles
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3. Reagents
Burdick and Jackson, Distilled in Glass Solvents:
Acetone
Hexane
Ethyl Ether (Preserved with Ethanol)
Sodium Sulfate, 12-60 mesh, Anhydrous (Baker 5-3375) (Heated
overnight at soooc in kiln).
II. Sample Receipt and Extraction
1. Log samples in log book. Note any damage to sample or
irregularities (i.e., EPA chain of custody tape broken).
2. Prepare 5% ethyl ether in hexane. Prepare by case lot of hexane.
Remove 200 ml of hexane from freshly opened bottle and add 180 ml
of freshly opeDed ethyl ether (preserved with ethanol).
3. Rinse condenser towers with 5% ether/hexane.
4. Wipe off lab bench wit~ 5% ether/hexane.
5. Add 300 ml of 5% ether/hexane to 500 ml boiling flask. Add boiling
granules (no more than 3 granules).
6. Dim lights in laboratory before removing first sample. Rinse a
large sheet of aluminum foil with 5% ether/hexane. Be sure to use
waste rinse container. Place foil, rinsed side up, on lab bench.
Use this for forceps and tongs. Rinse forceps and tongs with 5%
ether/hexane.
7. Carefully remove sampling cartridge from jar .and unwrap aluminum
foil. Handle cartridge minimally, placing it on its own aluminum
foil wrapping.
8. Note in project log book any breakage or damage to sampling
cartridge.
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9. With pre-rinsed forceps, carefully remove the foam plug (PUF) from
the sampling cartridge.
10. Place the PUF in the Soxhlet, and connect the Soxhlet to the 500 ml
boiling flask. (If hi-vol sample, also place corresponding
particulate filter in Soxhlet with PUF plug). Wet the joint with
5% ether/hexane. Place the forceps on _ the aluminum foil wrapping.
Label the boiling flask with sample I.D.
11. Taking the pre-rinsed tongs, adjust the PUF in the Soxhlet to wedge
it midway along the length of the siphon. Rinse the tongs into the
Soxhlet with the 5% ether/hexane. Rinse the forceps, glass
sampling cartridge, and aluminum foil wrapping with 5% ether/hexane
into the Soxhlet. Place the forceps and tongs on the aluminum foil
sheet. Dispose of the aluminum foil wrapping and place the glas
cartridge aside for washing and recycling.
12. Connect the Soxhlet to the condenser, wetting the glass joint with
5% ether/hexane for a good seal.
13. Repeat the process for the day's samples being sure to include a
solvent blank, field blank, and a control sample.
14. Check water flow to condenser towers, and turn on heating units.
15. As samples begin to boil, check Soxhlets making sure they are
filling and siphoning properly (4 cycles/hour). Allow samples to
cycle overnight or for a minimum of 16 hours.
16. Turn off heating units and allow samples to cool to room
temperature. Be sure the lights are dim.
17. Set up Kuderna-Danish (K-0) with receiver tubes. Add one boiling
granule to each set up. Label the K-D's with the sample I.D.
18. Pack filter tubes with glass wool and sodium sulfate. Place tube
in neck of K-0.
19. Carefully remove Soxhlet and boiling flask from condenser tower.
Drain remaining solvent into boiling flask.
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20. Carefully pour sample through filter tube into K-0. Rinse boiling·
flask 3 times with hexane. Swirling hexane along sides of boiling
flask. Once sample has drained, rinse down filter tube with
hexane.
21. Attach Snyder column to K-0 and rinse Snyder column to wet joint.
22. Place K-0 on steam bath and evaporate sample to approximately 5 ml.
Do not let sample go to dryness.
23. Remove sample from steam bath, rinsing Snyder column with a minimum
of hexane. Allow sample to cool.
24. Remove sample from K-0, making sure to label receiver tube.
25. Rinse nitrogen blow down spouts with hexane and place samples so as
to further concentrate. Transfer samples to pre-scored vials using
transfer pipets. Rinse receiver tube 3 times making a quantitative
transfer. Concentrate samples to 1 ml or per instruction from
analyst.
26. Make a master list of all samples prepared, date received, and
processed.' Give the l~st and sample extracts to the GC analyst.
GC Analysis (EPA Method 608)
1. Analyze samples using the following GC operating conditions.
Column: Supelcoport 100/120 mesh coated with
1.5% SP-2250/1.95% SP-2401 packed in
glass (180 cm x 4 mm ID)
Carrier:
Column
Temperature:
Detector:
5% methane/95% Argon at 60 ml/min
200 C, isothennal
ECO
2. Calibrate the system daily with a minimum of three injections of
calibration standards which hav~ been referenced to NBS/SRM 1581
(Aroclor 1242 in oils)
3. Inject 2-5 µL of the sample extract using the solvent-flush
technique. Smaller (1.0 µL} volumes can be injected if automatic
devices are employed. Record the volume injected to the nearest
0.05 µland the resulting peak size, in area units.
4. If the peak area exceeds the linear range of the system, dilute the
extract and reanalyze.
IV. Quality Control (QC)
1. Analyze one laboratory blank per each batch of 20 samples.
2. Analyze one laboratory spike per each batch of 20 samples.
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APPENDIX C
METEOROLOGICAL DATA
The results of the meteorological measurements performed at the Warren
County Landfill during the PCB monitoring period are given in Tables C-1
through C-6.
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TABLE C-1. METEOROLOGICAL DATA FOR FIELD MONITORING PERIOD(a)
Date: January 26, 1983
Time Wind Speed Wind Direction Ambieit Rel. Humidity Bar. Press.,
hrs. EDT mph Deg. (Compass) Temp, F % in Hg
0000-0100
0100-0200
0200-0300
0300-0400
0400-0500
0500-0600
0600-0700
0700-0800
0800-0900
0900-1000
1000-1100
1100-1200
1200-1300
1300-1400
1400-1500
1500-1600
1600-1700
1700-1800
1800-1900
1900-2000
2000-2100
2100-2200
2200-2300
2300-2400
3.3
3.0
2.8
1.6
0.1
0.7
0.2
1.3
1.9
1.9
150
120
135
150
150
80
105
95
75
60
58
46
48
49
29.95
29.90
29.89
29.89
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
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TABLE C-2. METEOROLOGICAL DATA FOR FIELD MONITORING PERIOD~a)
Date: January 27, 1983
Time Wind Speed Wind Direction Ambienl Rel. Humidity Bar. Press.,
hrs. EDT mph Deg. (Compass) Temp, F % in Hg
0000-0100 1.7 90
0100-0200 0.8 90
0200-0300 1.8 15
0300-0400 1. 7 30
0400-0500 1.3 30
0500-0600 1.9 15
0600-0700 2.6 30
0700-0800 2.7 90
0800-0900 2.8 75
0900-1000 4.1 45 43 88 29.93
1000-1100 6.9 45 44 81 29.93
1100-1200 8.5 60 47 66 29.90
1200-1300 8.2 60 45 71 29.87
1300-1400 9.0 60 46 68 29.86
1400-1500 6.8 60 . 46 65 29.86
1500-1600 8.0 60 45 67 29.86
1600-1700 8.7 45 44 78 29.84
1700-1800 7.8 45
1800-1900 9.3 45
1900-2000 7.8 45
2000-2100 8.5 45
2100-2200 11.1 45
2200-2300 9.4 45
2300-2400 9.2 45
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
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TABLE C-3. METEOROLOGICAL DATA FOR FIELD MONITORING PERIOD~a)
Date: January 28, 1983
Time Wind Speed Wind Direction Ambiefbt Rel. Humidity Bar. Press.,
hrs. EDT mph Deg. (Compass) Temp, F % in Hg
0000-0100 10.9 45
0100-0200 12.7 45
0200-0300 12.9 45
0300-0400 12.9 45
0400-0500 12.6 45
0500-0600 11.4 30
0600-0700 12.0 30
0700-0800 11.5 30
0800-0900 10.4 25
0900-1000 9.5 15 37 87 29.82
1000-1100 10.3 360 38 83 29.84
1100-1200 10.9 15 40 75 29.85
1200-1300 11.9 15 46 64 29.82
1300-1400 11.6 360 49 54 29.80
1400-1500 11.5 360 50 49 29.80
1500-1600 10.9 366 50 43 29.80
1600-1700 7.5 360 48 43 29.81
1700-1800 14.8 360
1800-1900 2.3 360
1900-2000 1.5 315
2000-2100 1.2 300
2100-2200 1.7 30
2200-2300 1.1 30
2300-2400 0.8 50
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
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TABLE C-4. METEOROLOGICAL DATA FOR FIELD MONITORING PERIOD{a)
Date: January 29, 1983
Time Wind Speed Wind Direction AmbieTI,t Rel. Humidity Bar. Press.,
hrs. EDT mph Deg. (Compass) Temp, F % in Hg
0000-0100 1.2 345
0100-0200 1.2 315
0200-0300 1.3 300
0300-0400 (b) (b)
0400-0500 (b) (b)
0500-0600 (b) (b)
0600-0700 (b) (b)
0700-0800 (b) (b)
0800-0900 (b) (b)
0900-1000 (b) (b) 34 86 29.99
1000-1100 1.6 90 45 57 29.99
1100-1200 2.1 180 49 44 29.97
1200-1300 3.6 150 55 33 29.92
1300-1400 3.5 180 56 32 29.89
1400-1500 3.9 1Bp 55 39 29.86
1500-1600 5.0 195 54 42 29.84
1600-1700 5.1 195 50 49 29.84
1700-1800 3.7 180
1800-1900 2.3 180
1900-2000 2.2 180
2000-2100 1.8 195
2100-2200 1.4 210
2200-2300 1.6 210
2300-2400 0.4 180
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
b) Data missing due to instrument malfunction.
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TABLE C-5. METEOROLOGICAL DATA FOR FIELD MONITORING PERIOD{a)
Date: January 31, 1983
Rel. Humidity Bar. Press., Time Wind Speed Wind Direction Ambient
hrs. EDT mph Deg. (Compass) Temp, 0f % in Hg
0000-0100 1.1 330
0100-0200 1.1 345
0200-0300 0.5 355
0300-0400 1.6 315
0400-0500 0.9 345
0500-0600 0.7 330
0600-0700 0.3 345
0700-0800 0.7 325
0800-0900 0.3 315
0900-1000 2.2 360
1000-1100 5.1 5
1100-1200 4.8 5
1200-1300 4.5 360
1300-1400 5.3 300
1400-1500 3.5 345
1500-1600 3.0 2515
1600-1700 2.5 270
1700-1800 0.3 270
1800-1900 0.8 240
"1900-.2000 1.2 360
2000-2100 1.0 180
2100-2200 0.6 240 40 87 29.84
2200-2300 0.3 165 39 92 29.84
2300-2400 0.9 180 36 95 29.84
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
Time Wind Speed
hrs. EDT mph
0000-0100 0.4
0100-0200 0.7
0200-0300 1.0
0300-0400 1.0
0400-0500 0.5
0500-0600 0.5
0600-0700
0700-0800
0800-0900
0900-1000
1000-1100
1100-1200
1200-1300
1300-1400
1400-1500
1500-1600
1600-1700
1700-1800
1800-1900
1900-2000
2000-2100
2100-2200
2200-2300
2300-2400
Wind Direction Ambie'bt Rel. Humidity Bar. Press.,
Deg. (Compass) Temp, F % in Hg
150 36 91 29.83
195 32 95 29.84
180
360 31 89 29.84
5
5 30 29.91
a) Ambient temperature, relative humidity, and barometric pressure data are
single readings taken during the time period. Wind speed and direction values
are hourly averages calculated from continuous monitoring data.
F'CB l.1.IDRKil'·,JG i:;R□UF· Fax : 91'~J-2':,7-1000 Nov 5 '97 11:01 P.02
~ MEETING ANNOUNCEMENT
The Joint Warren County/State PCB
Landfill Working Group will meet
Tuesday,
November 18, 1997*
at 6:30 p.m.
at the Warren County Office.
* Please note date change
Co.cHAI/tS:
Fax:[phone]
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
7 20 fUOCE:WAY 5TRE:~
WARRENTON, N ,C, 27589
PHONE QI Q-257-1 Q-48 • F'AX 919-257-1000
DOWE /J. JIUJtnLL
MVR"f J.AM:ASTl!R
FAX COVER SHEET
TO:
FROM :
Laura Butler
Tommy Cline
Nan Freeland
Mike Kelly
Henry Lancaster
Bill Meyer
Sharon Moore
Jim Warren
Doris Fleetwood, Secretary
PCB Working Group
DATE: November 5, 1997
Number of pages (including cover sheet): 2
919-733-5317
919-733-1431
919-832-9100
919-715-3605
919-715-3060
919-715-3605
919-733-2120
919-493-6614
JOINT WARREN COUNlY/STATE PCB LANDFILL
WORl<ING GROUP
AGENDA Regular Meeting
Warrenton, NC
I. Welcome
11. Roll Call/Introductions
111. Reading and Approval of Minutes
IV. Report of Committees
V. Unfinished Business
VI. New Business
VI I. Other Business
VIII. Adjourn
ENRIRONMENTAL JUSTICE ENFORCEMENT ROUNDTABLE
POSTER SUMMARY ABSTRACT FORM
Joint Community and State Work Group to Study the PCB Landfill in Warren County,
NC. Provide Site Investigation, Detoxification Pilot Study, and Pursue Detoxification of
The Landfill.
In 1982, a Toxic Substance Control Act (TSCA) landfill containing polychlorinated bi-phenyls
(PCBs) was built in Warren County to hold approximately 40,000 cubic yards of dirt from along
North Carolina roadways which had been contaminated by the illegal spraying of PCB oil.
The State of North Carolina committed to pursuing detoxification of the landfill when the,
technology became available. In 1995, a Warren County PCB Landfill Working Group (WG)
was established to pursue detoxification. This group, with active members from the community,
state agencies and environmental interests, was awarded one million dollars to study the
feasibility of detoxification. With the assistance of two Science Advisors hired by the WG, a
joint partnership between the community and state has been working very hard on doing an
extensive site evaluation and a pilot scale demonstration on two different treatment technologies
for detoxification. Based on the pilot scale testing, a technology was chosen for detoxification
and the company is currently preparing a Phase 2, draft preliminary design plan. The WG is also
preparing a plan to obtain funding from the General Assembly for the detoxification.
Poster presented by:
Michael A. Kelly
NC Div. Waste Mge
401 Oberlin Road
Suite 150
Raleigh, NC 27605
Ph 919-733-4996, ext. 203
Patrick Barnes
Science Advisor
3655 Maguire Blvd
Suite 150
Orlando, FL 32803
Ph 407-896-8608
Will require a table, no other AV equipment
Funds are available for travel.
Do not plan to submit a scholarship application.
Beginning Balance: Expenditures: ACCOUNT 2170 2210 2521 2712 2714 2715 2718 2724 2725 2728 2731 2811 2840 2850 2860 3110 3900 4522 5900 6961 6961 6989 6989 6989 6989 6989 6989 PCB LANDFILL FUND BUDGET CODE 24300 FUND 2103 Temporary Employee Electricity Rent/Lease -Motor Vehicles Diners Club (AIR TRAVEL BILLED DIRECTLY TO STATE) In-State Transportation -Ground Out-State Transportation -Ground Out-State Other (Parking, Tolls) In-State Meals Out-State Meals Out-State Misc. (Baggage) Travel (WORK GROUP & SCIENCE ADVISORS/PRIOR TO CONTRACT) Telephone Postage Printing Advertising General Office Supplies Other Materials & Supplies Computer (FAX) Other Expenses Contract (Warren County) Contract (Warren County {$23,161.00} Contracts (Science Advisors) Contracts (ETG Environmental) Contracts (Canadian Comm. Corp.) Environmental Investigations Soil & Materials Engineering Southwest Lab of Ok. Total Expenditures To Date Ending Balance Date 11/14/97 $1,000,000.00 $10,510.00 $181.76 $84.36 $20,051.32 $334.84 $23.24 $11.50 $68.00 $6.00 $11.00 $837.48 $6,921.92 $948.91 $2.86 $401.19 $60.95 $5,766.46 $554.38 $34,787.43 $25,000.00 $17,485.59 $219,587.89 $166,400.00 $125,286.00 $74,358.49 $44,320.44 $49,060.00 $803,062.01 $196,937.99
OTHER MISC. ENCUMBRANCES -NON-CONTRACT Lab Analysis -Southern Testing GN Engineering Fence Disposal Non-Hazardous ECOFLO -Remaining encumbrance on PO# 1690000412) VWR Scientific Products (PO#1640008105) Total Misc. Encumbrances $1,200.00 $1,210.00 $5,000.00 $5,000.00 $2,300.00 $477.89 $15,187.89
PCB LANDFILL CONTRACTS Expenses Contract Amt. Diner's Amt. Remaining Contract Name Contract Amount To Date Minus Expenses Club Charges in Contract 536961 Warren County $ 25,000.00 $ 25,000.00 $ $ Warren County $ 23,161.00 $ 17,485.59 $ 5,675.41 $ 5,675.41 536989 S&ME $ 44,321.00 $ 44,320.44 $ 0.56 $ SW Lab $ 50,400.00 $ 49,060.00 $ 1,340.00 $ 1,340.00 Env Invest $ 74,359.00 $ 74,358.49 $ 0.51 $ 0.51 Canadian Comm $ 141,786.00 $ 125,286.00 $ 16,500.00 $ 16,500.00 ETG Env $ 255,420.00 $ 166,400.00 $ 89,020.00 $ 89,020.00 Hirschhorn $ 136,796.00 $ 105,645.24 $ 31,150.76 $ 9,196.10 $ 21,954.66 Barnes $ 154,035.00 $ 113,942.65 $ 40,092.35 $ 7,570.04 $ 32,522.31 Totals $ 905,278.00 $ 721,498.41 $ 183,779.59 $ 16,766.14 $167,012.89 SUMMARY Beginning Balance: $1,000,000.00 Total Expenditures to Date $803,062.01 Total Misc. Encumbrances $15,187.89 Remaining Contract Amounts $ 167,012.89 Total$ Amount Used to Date $ 985,262.79 Ending Balance: $14,737.21
FP.Ot 1 HI SCHHO~t-J 30 1 S:l4S:l 1 237
November .12, 1997 ................................................................................. by fax (2 pages)
To: Steve Detwiler
Mike Kelly
Pat Barnes
Fron1: Joel Hirschhorn
Re: SUGGESTED TOPICS FOR NOVEMBER 14 KICK-OFF MEETING ON PHASE II
DETOXIFICATION PROJECT
General goal for meeting: to develop a l>l)ecific work plan that details all the activities and the
specific outputs for the final Phase 11 report.
At this meeting alJ major assumptions, tradeoffs, and particulars should be thoroughly discussed
and consensus decisio.us reached on how to proceed. Any issues \-\-1th RFP ~ould be thoroughly
addressed.
A detailed table of contents for the final report should be developed.
A detailed schedule for completion of the project should be developed, including interim
deliverables and review procedures, and a regular fo1m of communication. A procedw-e for
haudling changes in the work plan should be agreed to.
As to the Phase IT repo1t beins; prepared, the followin~ are imuortant priorities
TI1e repo1t should communicate in words, figures, and data a technically complete but easily
understood picture of what a full-scale detox project for the landfill would consist of and look
like. All impacts on the local community should be clearly identified. An Executive Summary
should be conceived as serving as the basis for presentations to lawmakers and others on the
Phase II project/report.
TI1e report should have sufficient details to support a credible cost estimate for the entire detox
project, with clear statements to describe the assumptions and unc-ertainties for the estimate. The
report should also present the detox project in terms of clearly de.fined and described discrete
phases or ~1ages, beginning with a fin.al design phase, \\lith a reliable cost estimate for each phase.
Supplemental site investigation work to be conducted during the final design phase should be
scoped out in order to resolve uncertainties about contamination outside the land.fill that might
requrre detox.
p _ I
FRrn 1 HI SCHHOl?r·~ 3[1 1 S:➔4':.~l 1 237
Several levels of potential cleanup performance objectives for PCBs and dioxins/fiuans should be
selected to assess different levels of detox and their associated costs. For example, one scenario
could use the stringent performance standards used in Phase I, while another might use the
numerical levels likely to be used in a standard state regulated cleanup. The impact of different
pertormance levels on volumes of material to be detoxified and costs must be specified.
A site perimeter air monitoring system should be designed and appropriate action levels defined.
Special attention should be given to landfill excavation and material handling processes and
procedures and how particuJates will be effectively contTolled. The need to address water in the
landfill and mixing of wastes with varying contamination levels prior to treatment should also be
addressed. It may be appropriate to assume certain amounts of,\.ater removal by the state.
An early phase should be performance verification or demonst:rntion for full-scale equipment at
the site du1ing a trial production nm. The maximum amount of excavated materials to be used
should be identified, as well as the general protocol ·with special emphasis given to air pollution
control equipment and effective functioning of a perimeter air monitoring system.
An emergency response plan should be developed and any special costs identified, such as
necessary training foT local hospital persom1el. Special attention should be grven to local residents
w:ithio about five mHes of the site.
A plan to use locally available labor should be developed, ~.,ith special costs identified, such as
technical training for skilled and semi-skilled positions. Use oflocal finns for supplies should also
be examined. A reasonable estimate for the economic contributiou to Warren County from the
proje~t should be given.
The use of a Citizen Ad\isory Board with its own independent technical consultants should be
included in project design and cost estimates. The CAB would pro"ide oYersight throughout
project duration.
A plan to use the project to serve local educational institutions should be developed based on
cooperation with the CAB. For example, site tours, presentations by site manageTs, and possibly
ex-po1t of data from monitoring stations to schools or libraries should be considered.
2
..BF A Environmental Consultants
Barnes, Ferland and Associates, Inc.
MEMORANDUM
TO: Steve Detwiler
Mike Kelly
Joel Hirschom 4
FROM: Patrick A. Barnes, P.G. --~ ~
DATE: November 12, 1997
SUBJECT: ADDITIONAL TOPICS FOR DISCUSSION AT THE NOVEMBER
14 PHASE II DESIGN MEETING
In addition to the topics mentioned in Joel's memo dated November 12, 1997 the Phase II
design team should be prepared to discuss the following detoxification site design
concerns:
1.
2.
3.
4.
5.
6.
7.
8.
Area required for project implementation including site layout and work zones
Site operations and logistics -~
-C' /"7-C/t<',, V r.A ,--.-, ,,,r . ·r' '~ -....) I Cl L-Cv ( ,; " '~ f\j : '-\.., '-'--' ~ • I /
Construction of contamination reduction facilities if necessary /
Temporary storage facilities
Other potential temporary and permanent horizontal and vertical construction
Stormwater management ,/
• Ponds
• Need for infrastructure
,,, ~1.JC;1_c;,r:;& t: ~-
Phasing of fill removal and clean fill placement
Detailed estimates of quantities to be removed in each phase ·
9. Site plan showing anticipated final topography of each cell as it is closed ~ fJ,i J ~ {,0 , -~,r' r: /::c!J;,j . ;:}c.) .
I 0. Permits necessary -local, state and federal '
~~~
,1v\.o-.. ', \-c:, .. ', ~
3655 Maguire Boulevard • Suite 150 • Orlando _ Florida 32803
Office [phone] • Fa x [phone]
FAX FAX FAX FAX
November 5, 1997
MEMORANDUM:
TO: JOEL HIRSCHHORN
PATRICK BARNE
FROM: MIKE KELLY
SUBJECT: MEETING WITH ETG
FAX FAX FAX
/
I have spoken with Steve Detwiller with ETG in regards to a meeting with
them on Phase II. We tentatively agreed to November 18th at 10:00 am here in
Raleigh. Since there is a Working Group Meeting that night at 6:30, I felt this
would be a good time since you all would be in town for that meeting. The 1 0am
time should give everyone time to arrive that morning.
Steve indicated that he would contact ICF Kaiser and let them know. They
need to visit the landfill, and could do that Tuesday afternoon and Wednesday,
although Steve indicated that if they go up on Wednesday, we would not really be
needed.
Please let me know if this is OK with you.
Thanks.
CASTER
Q~ \1~ ~t81'G,JL-
l-\f..)C A-Y'\W'&t_,
PUBLIC STATEMENT OF DR. JOEL S. HIRSCHHORN,
SCIENCE ADVISOR, JOINT STATE-WARREN COUNTY PCB
LANDFILL WORKING GROUP -November 1, 1997 Community Meeting
The extensive activities of the Science Advisors have made it clear that detoxification
technology to remove the Wa"en County PCB Landfill is feasible, practical and effective.
The promise made many years ago by the Governor on behalf of the State to detoxify the Landfill
when technology became available can and should now be fulfilled. Today, it can be officially
announced that the detoxification technology offered by ETG Environmental, Inc. of West
Chester, Pennsylvania has been tested on PCB materials from the Landfill and that it has been
determined to be safe and effective. Another technology had also been tested, but using a number
of evaluation criteria ETG's BCD technology was found to be superior. The next scheduled step
is for ETG to conduct a Phase II preliminary design of the potential full scale use of their
technology at the Landfill. The main purpose of the Phase II work is to provide more refined and
accurate cost estimates for the entire detoxification job. However, the work already completed
has fully shown that safe and effective detoxification technology is available, and we know that
the full cleanup cost will probably be in the range of $25 million.
In order to address many community concerns the Science Advisors conducted an extensive site
investigation. Based on an examination of file records and other available information the Science
Advisors also caused the U.S. Environmental Protection Agency to officially investigate whether
the State ofNorth Carolina, as owner and operator of the Landfill, had actually satisfied a number
of important federal regulatory requirements. Both the investigation of EPA and the site
investigation have conclusively shown that the Landfill is inadequate and NOT safe and ~.JL
effective. The EPA has belatedly ordered the state to take certain corrective actions to bring the "!;~ ~
landfill into regulatory compliance. Our site investigation found that the landfill has allowed water 1¥1'~·
to enter aod )e~ve it. There is some evidence that toxic materials have already leaked and gone T
.5Wtside the landfj11, including findings of dioxins in groundwater and PCBs in air. ~ i\S
The Science Advisors have considered comments from the State's Division ofWaste Management ?'T'°
of DENR, but have found them lacking scientific merit and, therefore, have no reason to change IJ1J1'
· the conclusions in the site investigation report about the poor quality of the leaking Landfill. _j_
All people in the community can unite around the one most important technical and political
truth: the time has come for the State of North Carolina to keep its promise and provide the
necessary funds/or detoxification of the Wa"en County PCB Landfill Clearly, the State did
NOT construct a state-of-the-art landfill. The Landfill is oflow quality, has failed to meet federal
regulatory requirements for years, and poses a long term threat to public health and environment.
The only effective pewanent solution is detoxification. The best way to address EPA's notice of
noncompliance is through detoxification. By using detoxification technology the State can "do
the right thing" and restore environmental justice to Warren County. Talk, studies, and reports
need to be replaced by action. Residents of Warren County musf(unite to aggressively demand
funding for detoxification. Without stron ublic demand for fun · g on1 band-aid fixes for the
lan · and toxic waste and its victims · be left in Warren County.
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
PUBLIC MEETING -NOVEMBER 1, 1997, 1 P.M.
WARREN COUNTY COURTHOUSE
"FORGING AHEAD FOR A CLEAN ENVIRONMENT
FOR THE CITIZENS OF WARREN COUNTY"
AGENDA
1:00-1:15 ........................................ WELCOME AND OPENING REMARKS
Moderator
Working Group CO-Chair
State Of North Carolina/Dept. of Environment and Natural Resources
1:15-1:45 ...................... PRESENTATIONS BY THE SCIENCE ADVISORS
Patrick Barnes, Site Investigation
Joel Hirschhorn, Technology Assessment and Evaluation
1:45-2:15 .................. PRESENTATION BY ETG ENVIRONMENTAL, INC.
Landfill Detoxification Technology
2:15 -3:00 .............. COMMENTS/QUESTIONS/COMMUNITY CONCERNS
THANK YOU FOR ATTENDING
----···--··._, v1,uv1
MOVING TOW ARD CLEAN-UP OF
THE FAILING PCB DUMP
r • V£.
PUBLIC MEETING: SATURDAY, NOVEMBER 1 AT 1 P.M.
WARREN COUNTY COURTHOUSE
Come ask the Science Advisors and other experts:
► ls the landfill leaking?
► How far can PCBs and dioxins travel in the water and air?
► Is there an immediate or long tenn threat to our health?
► Can the dump be cleaned up safely?
► What technology has been chosen?
Will the state really spend $25 million to protect Warren County?
WE CAN GET THIS TOXIC MENACE
OFF WARREN COUNTY'S BACK. ••
WE ARE ON TARGET FOR DETOXIFICATION
BUT WE NEED YOUR HELP/
Statement to the Citizens of Warren County
from Henry Lancaster, Deputy Secretary
North Carolina Department of Environment and Natural Resources
November 1, 1997
As the Deputy Secretary of the Department of Environment and Natural
Resources, I would like to take this OI?l?2\tunity to welcome you to this
meeting--a meeting that represents -t'ffitt'Joint working efforts of some dedicated
Warren County citizens, representatives of environmental groups, and state
government officials. It's a day that the Joint Warren County /State PCB
Landfill Working Group has been working toward in their efforts to have the
PCB Landfill detoxified.
Before these folks tell you about their efforts and plans, I would like to
briefly explain to you how we got to this point.
In early 1993, it was brought to the attention of the Department of
Environment and Natural Resources that the PCB landfill contained a
significant amount of water. Former department Secretary Jonathan Howes
immediately established a process to bring this problem to the attention of
Warren County and propose a solution. This was in keeping with the state's
commitment and responsibility to ensure the maintenance of the landfill and
protect the safety of Warren County citizens.
A public meeting was held right here in Warren County to discuss the
situation. Several Warren County communities reiterated the state's
commitment to detoxify the PCB landfill rather than extract the water as the
more appropriate means of ensuring the long-term safety of the citizens living
here. Despite the department's concern with water in the landfill, both then
and now, it worked with Warren County to establish a partnership of citizens,
environmental groups and state staff to form the Joint Warren County/State
PCB Landfill Working Group to both ensure safety and detoxification of the
landfill.
With the help of Senator Frank Balance, financial support for the
Working Group was obtained from the General Assembly in 1995. A few
months later, independent science advisors were hired, and the Working Group
has been diligently pursuing detoxification since that time.
We're present today to hear the findings of the science advisors and
listen to comments from ETG, the company selected by the Working Group to
develop a full-scale plan for detoxification of the PCB Landfill. The state does
'
not concur with all of the findings of the science advisors, but we are still
committed to the ultimate goal of detoxification. I am reconfirming this
commitment by the department's new secretary, Wayne McDevitt, to detoxify
the PCB Landfill here in Warren County.
~
I woul(¼like to offer both my congratulations and appreciation for the
efforts of the 'working Group; and I put strong emphasis on the "working" part.
In addition to working toward detoxification of they landfill, they have traveled
long distances, put in many long hours, and have had to learn to work together
as partners to complete the often difficult and complex tasks required to move
toward their ultimate goal. Thanks to the efforts of the Working Group, we are
moving in that direction.
The work is by no means finished. We have a lot of difficult tasks
remaining, the most difficult one being funding for detoxificatio e
General Assembly.
We are encouraged by the accomplishments of the Working Group and
will continue to work together as partners for detoxification. The department is
committed to a strong partnership with the Working Group and Warren County
to successfully fund and implement the selected detoxification technology to
ensure the long-term safety of Warren County citizens. Let us remind
ourselves that nothing good comes without a lot of hard work, so let's continue
to work hard together to get the detoxification job done.
10/20/1997 14 :35 ':H '325721:,04 CHAF'EL'::;l]I_ITHEF'tll I 1::iHr::;
October 20, 1997 , ~ ~~
Warren PCB Landfill: Is Pumping Instead of Detoxifying a Done Deal?
In a Jt.Jt1e 6, 1994 letter to Governor Jim Hunt from Heman R Clark, who served as
Hunt's $e(;retary of crime control and public sat ety during the 1982/83 PCB lsndfilf
protest movements, Clark states that detoxification would be a ushameful waste of
much tax money" and tor not much money the state could end logical opposition to the
landfill $imply by pumping the water out of it Clark's letter is significant becau!e for
both thft state and the EPA, pumping continues to be central , detoxification peripheral
based on contingencies.
In fact, ~ark's letter may be even more significant than former Assistant Secretary of
Crime Control and Public Safety David Kelly's December 1978 statement that "plt>lic
sentiment would not deter the state's . plan to purchase private land In Warren
Countt, [for a PCB landfill]. Although this was the statement that impetted hundredS of
Warren:cttizens to attend the EPA Public Hearing on January 4, 1979, Kelly was simply
being hbnest publicly telling the truth . PCB burial in Warren County was a done deal
Clark's ·1etter, however, was meant to be a private statement to Hunt on how he could
get out of his detoxiflcation promise Both statements show a rust, to decision-making
withoufregard for facts, without regard for scientific and technological truth, and
without regard for tha expression of public sentiment through democratic mechanhsms.
Beca~ Clark's letter contains what continues to be the emphasis ot EPA and state
official! (pumping), it is worth quoting·
Our PC.8 . [sic] landfill in Warren County won't go away.
Now the "protestors" are saying we broke our promise to
"detoxify" (which would be a shameful waste of much tax money).
I do think you should consider having the water pumped out
of the lam1flll .... There nave been no leaks but we can·t 88.Y there
never will be. It may not be a dangerous condition but
it sounds bad. For a relatively small appropriation, the dehydranon
can be done. Bill Meyer [,] the highly competent chief of [the] Solid Waste
Management Section, knows exactly what needs to be done. As long as
the water remains inside the liner, the protesters have a logical basi~ to
continue their expert agitation . If there is anyway [sicJ I can help tn
explaining this need to the General Assembly, please let me know
Kelly's public statement implied that the burial of PCBs in Warren County was a done
deal, at least as early as December, 1978. However, it took EPA and the state four
years ttl rewrite regulations needed to legally justify the approval or the PCB landfill
and to use force to open it in 1982.
It remains to be seen if pumping instead of detoxifying is yet another done deal, a deal
jett1sonlng Into tne past Hunrs promise to detoxify, leaving Warren w ithout l'J. future. But
no deat is done until it's done. Make a difference. Attend the PCB Working Group1s
Community Meeting at the Warrenton Courthouse, Nov. 1, •t 1 :00 p.m.
~(~«:-,
KenAwruccto
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director October 20, 1997
Mr. Patrick Barnes
BF A ENVIRONMENT AL, INC
3655 Maguire Blvd., Suite 150
. Orlando, FL 32803
Dear Patrick:
Enclosed are comments from the Division of Waste Management on the Draft PCB Landfill Site
Investigation Report, as well as copies of additional information and studies done for or by the
division. Comments on specific sections are listed with reference to the individual section
numbers from the report. I have also attached the following documents:
1) Analytical data roll-up, QA Evaluation: The division contracted Mr. James A.
Ploscyca of ENVIRONMENT AL EFFICIENCY to go through the laboratory data and compile
into tabular form the information from the lab reports. The results are now all listed by media and ·
can be compared quickly and easily. Mr. Ploscyca has also completed a Quality Assurance
Laboratory Data Evaluation on the dioxin data.
2) Methane Monitoring: Last spring and again this fall, division personnel grided off the
surface of the landfill, plugged the top eight inches of soil cover and checked for methane gas.
The results of this testing are presented in tabular form / report.
3) Weather station: A weather monitoring station has been installed at the landfill, and
includes water level monitoring in the north borehole in the landfill. We anticipate hooking up the
south borehole on October 20. Temperature, wind direction and barometric pressure are likewise
monitored. The report includes a description of the system, and data from the first two weeks of
monitoring.
Please include these comments in the final report.
( ' ' {!er~l f)~ \ V ~~ A. Kelly, Cfilv[M, RE
Deputy Director
COPY: Dr. Joel Hirschhorn, Warren County Working C __ .
·-··-.
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled / 1 0% Post-Consumer Paper
DIVISION OF WASTE MANAGEMENT
DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES
COMMENTS ON THE DRAFT PCB LANDFILL SITE INVESTIGATION REPORT
October 20, 1997
SECTION 2.0
2.3. LANDFILL DESIGN: It should be noted that a leachate collection system (LCS) was
installed in the landfill. While it is true that the original set of construction drawings for the
landfill showed perforated piping as a component of the LCS, the Environmental Impact
Statement (EIS), with the final design plan, was publicly noticed and approved by the
Environmental Protection Agency (EPA). This final plan did not show a perforated pipe in the
system. The leachate system has not necessarily operated properly, it is possible that the sand
component of the LCS is functioning properly and as designed, however the lack of flow in the
system is most likely due to improperly sized pumps which do not operate on a continuous basis,
the low moisture content of the landfill contents and the relatively low permeabilities of the landfill
soils themselves. Also, the comment that analysis of the water in the landfill compared to
seasonal rainfall indicates water is leaking into and out of the landfill is only one possible
explanation of the water level fluctuations in the landfill.
2.4 REGULATORY COMPLIANCE: The division questions how analysis ofhydroraphs for
water in and outside the landfill "found that there had been significant violations of federal
regulatory requirements with regard to monitoring and landfill design, construction, and
operation". There were no significant violations found which supports any "release of hazardous
substances that happened because of design or construction deficiencies, or because routine
monitoring had not detected the releases, or both". EPA makes no comment as to any real or
imagined release, nor made any comment on construction deficiencies.
SECTION 4.0
4.2 LANDFILL FACILITY: All PCB analysis done on soils taken from the landfill, and prior to
the material being placed in the landfill, have shown various levels of PCBs. This is consistent
with what one would expect from oil hap-hazardly dumped along miles of roadway.
The dioxin data can be considered inconclusive due to the nature of and low detection
levels of dioxin compounds found. Analysis of the dioxin data through quality assurance
evaluation shows that dioxin was found in many different places, including OCDD in every
groundwater sample collected at the site, as well as, in many of the field and laboratory blank
samples. The presence of dioxin in so many of the "blanks" indicates a probable contamination
1
problem in the laboratory. Additional sampling should be done, particularly in M W-5D and M
W-lA, where dioxins were found in higher concentrations (noted in Section 4.3).
4.5 OFF SITE SOILS AND SEDIMENTS: It is significant to note that a larger number of
samples were taken off site in the soil and sediment under the belief that ifPCB's had escaped (or
were escaping) from the landfill through air emissions, they would be detected in the soils
surrounding the landfill where the heavy molecules of PCB (being carried by dust particles) would
fall out. No PCB's were detected in any of the samples, with the exception of a split sample from
the Leachate Collection Pond EPA analyzed in which they found .1 ppm.
4.6 AIR TESTING FOR PCB's: As noted in the report, there were three separate sampling
events that occurred from February through August 1997. One of the sampling events utilized
low flow Gil-air pumps over a period of several days and the other two events utilized high
volume air monitoring systems during two different 24 hour periods. On the recommendations of
the Science Advisors, an attempt was made to pull at least 1,500 liters of air through the Gil-air
pumps, however, the average amounts were approximately 1,200 liters, and it was on one of these
samples that PCB's were found in concentrations of approximately 3,000 ng/cubic meter. The
subsequent high volume sampling events, where over 150,000 liters of air were pulled through the
filters, no PCB's were detected. Three of the high volume samplers were placed in approximately
the same area as the one sampling pump that showed "hot" during the February testing. The
report concludes that releases would occur in locations where there were breaches in the surface
containment system, such as holes in the plastic liner or cap. While this conclusion is somewhat
valid, it does ignore the other observations and physical realities of the landfill.
There is no evidence of a catastrophic failure of the cap. In February, there were no signs
of cracks, stressed or dead patches of vegetation or gas detected in the numerous locations
checked by the state. Furthermore, methane testing done again this fall likewise did not detect
any gas corning from the landfill through the cap (see methane reports, conclusions, attached).
The conclusion that the liner has failed thus allowing PCB's to escape deals only with the plastic
liner and ignores the presence of five feet of compacted, saturated clay, which covers the landfill
as the "cap". Methane gases do not readily migrate through saturated soils, rather they choose
the path ofleast resistance, which would be a nonsaturated zone. For example, in municipal solid
waste landfill monitoring, gas is never detected in the saturated zone. Further, the transport and
fate mechanisms of the pollutant in question, PCB's, have been totally ignored in the analysis.
PCB's are large, heavy molecules which have a high affinity for sorption onto clays. It is therefore
questionable how PCB's are becoming unbound from the clays and silts in the landfill, entering the
gas phase at relatively low temperatures and then flowing, uncollected, through over five feet of
saturated, compacted, clayey material.
If in fact the PCB's detected in the one "hot" air sample did indeed come from the landfill
as a result of a belch or puff as described in the report, there is no explanation why none were
detected in the vent pipe or on the air pump sampler located beside the one that showed positive,
2
as it was downwind from the positive one. If the landfill belched or a sudden puff occurred, at
least some of that gas should come through the vent pipe which was designed for the release of
such gases. It is not plausible to believe that such a high dose of PCB's would occur in only one
spot and none even be detected in the other samplers so close to the hot spot, particularly in the
air sample being pulled from inside the landfill through the vent ( directly inside and before the
carbon filter). The high concentration found in the one sample was most likely due to lab
contamination.
As stated in the report, there is no way in which we can tell what releases through the air
. may have occurred in the early l 980's. The EPA study done by Robert G. Lewis and Barry E.
Martin, after closure of the landfill found detectable PCB's in 4 of 39 ambient air samples, and
through two dispersion models showed that any concentrations downwind would be below the
detection capability of any known sampling equipment. The conclusions indicated that "emissions
of PCB .... were found to be negligible." Subsequent testing in 1983, as suggested by that report,
likewise did not show any evidence of air emissions, and therefore no continuous monitoring was
done by the state.
4.7 LANDFILL INTEGRITY: There is absolutely no evidence that the "landfill has lost its
integrity and its ability to safeguard against future releases of PCB's and Dioxins." This is an
opinion of the Science Advisors and not supported by facts.
4.7.1 Top Liner: This section is devoted entirely to discussion of the 10 mil plastic liner over the
clay cap. No mention is made of the clay cap. The plastic liner was certainly not in the best
shape, however, it should be noted that based on the evaluation by S&ME it was in "fair
condition". Pinholes were found in the sample taken from the north bore hole, but no pinholes
were in the sample from the south bore hole. Only one spot appeared to have not been welded,
although it was obvious that several places on the seam had been breached by root vegetation.
The seams in some spots have deteriorated over time, probably due to the loss of plasticizer in the
parent material, or deterioration of the chemical composition of the original solvent used in 1982.
By reviewing the lab test results on the PVC liner, it appears to be in adequate shape, and aging as
expected. The seams did show shear strength and low peel strength, while the other properties
were consistent with aging due to the loss of plasticizer, particularly the increase in tensile
strength and a decrease in the elongation at break strength.
The report states ''given that only two locations were inspected and both were in poor
condition, it is likely that a significant portion of the synthetic cap has lost all practical
integrity". S&ME concluded that the cap system "appears to be providing satisfactory
performance". The report further ignores the presence of the compacted clay barrier layer and
vegetative cover portion of the system. This almost five foot thick layer has permeabilities on the
order of 10 -8 cm/sec. S&ME said the surface of the clay appeared to be in good condition and
that the permeability tests are indicative of well compacted clays. They also st~te that the perms
are lower than typically specified (10 -7 cm/sec). The cap has a healthy stand of vegetation
which would rield high amounts of evapotranspiration, and is graded to shed water.
3
Observations of the landfill and the results of the cap inspection, at those two points, do not point
to a cap system that has lost all practical integrity.
4. 7.2 · WATER IN THE LANDFILL: When analyzing the hydro graph data, one must also
consider several other influences on the recorded levels. Primary is the influence of barometric
pressure as well as the type and placement of the pipes from which the water level data is taken.
The sensitivity of the recording instrument is also a factor. Low barometric pressure will cause an
increase in water levels and high barometric pressure will cause a "decrease" in the water level.
Barometric pressures were obtained for 1995-1997 for RDU and plotted versus the water levels
. in the leachate pipe and the riser. In all cases, the water level moves with the barometric pressure.
This is not to imply that water could not be entering the landfill, rather how and how much must
be further evaluated. The state has already recorded a 13 inch change in water level in less than
48 hours. The spikes in the rainfall and the months chosen should also be carefully examined.
Infiltration may not be due to movement through the cap, but through other entries like the
leachate collection pipe, animal burrows, or other "point" penetrations of the liner. Data collected
from lysimeters beneath a cap system at the city of High Point, NC, which have been monitored
for over one year, do not show any infiltration during the warm months, regardless of the amount
of rainfall. Runoff and evapotranspiration exceed rainfall. Only during the dormant winter
months, December-February, are small amounts of infiltration registered through a two foot
vegetative layer.
The report states "the increased stress on the bottom liner system coupled with several
other complicating factors has apparently resulted in a breach of the bottom liner system". It is
assumed that the "stress" is from the water. There is, however, no evidence of a catastrophic
breach of the bottom liner system. The report fails to acknowledge that the bottom liner system
includes a leak detection zone which is monitored monthly and has never detected a leak, and that
there is a five foot clay liner system with 10 -8 cm/sec permeability on top of the PVC liner.
The analysis on the "delayed rise" is incomplete. It neglects evapotranspiration, additional
rainfall, runoff, etc. In addition it neglects the two feet of clay under the PVC liner, the one foot
of bridging material, and the additional 12-14 feet of unsaturated landfill soils, that water would
have to traverse to reach the phreatic surface. An analysis of the moisture contents of the landfill
soil samples gives no indication of a zone of saturation, wetting front, or other indication that
there is a change in moisture content in the landfill upper zone. Most of the moisture contents are
less than the field capacity of the soils.
Leakage rate: Assuming an effective porosity (specific yield) should be confirmed by
analyzing the geotechnical test results on the landfill contents. A more meaningful, and
representative number could be generated. The approximate ten inch fluctuation over a six month
period can easily be attributed to changes in barometric pressure. As mentioned previously, the
state has measured a 13 inch fluctuation in less than 48 hours, during a period of no rain, and a
very dry cap.
4
'y ' ...
It should also be noted in the report that the rainfall data for the Arcola station is as
follows:
1992-47.95 inches
1994-40.28 inches
1996-60. 5 8 inches
1993-43 .80inches
1995-56.85 inches
1997-20.86 inches (6 months)
4.7.3 BOTTOM LINER: Pictures 1, 2 and 3 actually show vandalism done to the bottom liner
during construction. The vandalism is to the plastic liner only, and was repaired. The clay
bottom liner was not harmed. Pictures 8 and 9 show water trapped in the landfill during the final
. stages of remedial activities. Picture 10 actually shows pieces of filter fabric washed by the
torrential rains, and is not a picture of the PVC liner. There is no evidence to indicate that the
bottom liner is not intact. Even if there are potential problems with the PVC liner, as discussed
with the top liner, the report neglects the existence and contribution of five feet of compacted
clay, and the fact that the leak detection zone under the bottom liner has never shown the
presence of any water.
SECTION 5.0 CONCLUSIONS:
It was a forgone conclusion that the PCB levels vary in the landfill. However, there was
not one piece of evidence for PCB contamination outside the landfill. It should be noted that low
levels of PCB's were found in the landfill leachate. No PCB's were found in any samples,
groundwater, soil, or sediment outside of the landfill, with the exception of the one sample in the
pond area where EPA found .1 ppm PCB. The "reliable data" being used by the Science
Advisors indicating "some limited impact of the landfill on subsurface materials immediately
outside the landfill" is the presence of dioxins in two monitoring wells. Even the presence of
these various compounds do not correlate, and after evaluation of the Quality Assurance of the
dioxin data, the results are highly suspect as dioxin was also found in the lab and field blanks. It
would certainly be appropriate to re-do some of the dioxin testing, particularly in monitoring wells
5-d and 1-a. Due to the low solubilities of dioxins in water, it does not seem feasible that the
landfill would be contributing to dioxin found in monitoring wells 5-d and 1-a without also
showing some PCB's, as PCB's were found in measurable quantities in the leachate from the
landfill. Thus if one compound were leaking out, why not the other?
SECTION 6.0: RECOMMENDATIONS
The variations of PCB concentrations in the landfill probably have no effect on the
detoxification process, as most processes, including the BCD, are often utilized for sites with
greater than 10,000 ppm of PCB's, which is more than 10 times any concentration found in the
landfill. Probably of greater concern will be the wet zone at the bottom of the landfill as the
process will be affected by sudden volumes of water which could cause an immediate temperature
drop in the process. This should be studied in the Phase II report.
5
,.
State of North Carolina
; Department of Environment,
Health and Natural Resources
Division of Waste Management m .
DEHNR James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director October 15 , 1997
Mr. Patrick Barnes
BF A ENVIRONMENTAL, INC
3655 Maguire Blvd., Suite 150
Orlando, FL 32803
Dear Patrick:
Enclosed are comments from the Division of Waste Management on the Draft PCB Landfill Site
Investigation Report, as well as copies of additional information and studies done for or by the
division. Comments on specific sections are listed with reference to the individual section
numbers from the report. I have also attached the following documents:
1) Analytical data roll-up, QA Evaluation: The division contracted Mr. James A.
Ploscyca of ENVIRONMENTAL EFFICIENCY to go through the laboratory data and compile
into tabular form the information from the lab reports . The results are now all listed by media
and ca~ be compared quickly and easily. Mr. Ploscyca has also completed a Quality Assurance
Laboratory Data Evaluation on the dioxin data.
2) Methane Monitoring: Last spring and again this fall , division personnel grided off the
surface of the landfill, plugged the top eight inches of soil cover and checked for methane gas.
The results of this testing are presented in tabular form / report.
3) Weather station: A weather monitoring station has been installed at the landfill, and
includes water level monitoring in the north borehole in the landfill. We anticipate hooking up
the south borehole on October 20. Temperature, wind direction and barometric pressure are
likewise monitored. The report includes a description of the system, and data from the first two
weeks of monitoring.
Please include these comments in the final report.
Sincerely,
v(~J:i~Cl ·
Michael A. Kelly, CH
Deputy Director
COPY: Dr. Joel Hirschhorn, Warren County Working Group
r
P.O. Box 29603, Raleigh, North Carolina 27611-9603
An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
,.
DIVISION OF WASTE MANAGEMENT
DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES
COMMENTS ON THE DRAFT PCB LANDFILL SITE INVESTIGATION REPORT
October 15, 1997
SECTION 2.0
2.3. LANDFILL DESIGN: It should be noted that a leachate collection system (LCS) was
installed in the landfill. While it is true that the original set of construction drawings for the
landfill showed perforated piping as a component of the LCS, the Environmental Impact
Statement (EIS), with the final design plan, was publicly noticed and approved by the
Environmental Protection Agency (EPA). This final plan did not show a perforated pipe in the
system. The leachate system has not necessarily operated properly, it is possible that the sand
component of the LCS is functioning properly and as designed, however the lack of flow in the
system is most likely due to improperly sized pumps which do not operate on a continuous basis,
the low moisture content of the landfill contents and the relatively low permeabilities of the
landfill soils themselves. Also, the comment that analysis of the water in the landfill compared
to seasonal rainfall indicates water is leaking into and out of the landfill is only one possible
explanation of the water level fluctuations in the landfill.
2.4 REGULATORY COMPLIANCE: The division questions how analysis ofhydroraphs for
water in and outside the landfill "found that there had been significant violations of federal
regulatory requirements with regard to monitoring and landfill design, construction, and
operation". There were no significant violations found which supports any "release of
hazardous substances that happened because of design or construction deficiencies, or because
routine monitoring had not detected the releases, or both". EPA makes no comment as to any
real or imagined release, nor made any comment on construction deficiencies.
SECTION 4.0
4.2 LANDFILL FACILITY: All PCB analysis done on soils taken from the landfill, and prior
to the material being placed in the landfill, have shown various levels of PCBs. This is
consistent with what one would expect from oil hap-hazardly dumped along miles of roadway.
The dioxin data can be considered inconclusive due to the nature of and low detection
levels of dioxin compounds found. Analysis of the dioxin data through quality assurance
evaluation shows that dioxin was found in many different places, including OCDD in every
groundwater sample collected at the site, as well as,in many of the field and laboratory blank
samples. The presence of dioxin in so many of the "blanks" indicates a probable contamination
1
problem in the laboratory. Additional sampling should be done, particularly in M W-5D and M
W-lA, where dioxins were found in higher concentrations (noted in Section 4.3).
4.5 OFF SITE SOILS AND SEDIMENTS: It is significant to note that a larger number of
samples were taken off site in the soil and sediment under the belief that if PCB's had escaped (or
were escaping) from the landfill through air emissions, they would be detected in the soils
surrounding the landfill where the heavy molecules of PCB (being carried by dust particles)
would fall out. No PCB's were detected in any of the samples, with the exception of a split
sample from the Leachate Collection Pond tP A analized in which they found .1 ppm.
4.6 AIR TESTING FOR PCB's: As noted in the report, there were three separate sampling
events that occurred from February through August 1997. One of the sampling events utilized
low flow Gil-air pumps over a period of several days and the other two events utilized high
volume air monitoring systems during two different 24 hour periods. On the recommendations
of the Science Advisors, an attempt was made to pull at least 1,500 liters of air through the Gil-
air pumps, however, the average amounts were approximately 1,200 liters, and it was on one of
these samples that PCB's were found in concentrations of approximately 3,000 ng/cubic meter.
The subsequent high volume sampling events, where over 150,000 liters of air were pulled
through the filters, no PCB's were detected. Three of the high volume samplers were placed in
approximately the same area as the one sampling pump that showed "hot" during the February
testing. The report concludes that releases would occur in locations where there were breaches in
the surface containment system, such as holes in the plastic liner or cap. While this conclusion is
somewhat valid, it does ignore the other observations and physical realities of the landfill.
There is no evidence of a catastrophic failure of the cap. In February, there were no signs
of cracks, stressed or dead patches of vegetation or gas detected in the numerous locations
checked by the state. Furthermore, methane testing done again this fall likewise did not detect
any gas coming from the landfill through the cap (see methane reports, conclusions, attached).
The conclusion that the liner has failed thus allowing PCB's to escape deals only with the plastic
liner and ignores the presence of five feet of compacted, saturated clay, which covers the landfill
as the "cap". Methane gases do not readily migrate through saturated soils, rather they choose
the path of least resistance, which would be a nonsaturated zone. For example, in municipal
solid waste landfill monitoring, gas is never detected in the saturated zone. Further, the transport
and fate mechanisms of the pollutant in question, PCB's, have been totally ignored in the
analysis. PCB's are large, heavy molecules which have a high affinity for sorption onto clays. It
is therefore questionable how PCB's are becoming unbound from the clays and silts in the
landfill, entering the gas phase at relatively low temperatures and then flowing, uncollected,
through over five feet of saturated, compacted, clayey material.
If in fact the PCB's detected in the one "hot" air sample did indeed come from the landfill
as a result of a belch or puff as described in the report, there is no explanation why none were
detected in the vent pipe or on the air pump sampler located beside the one that showed positive,
2
as it was downwind from the positive one. If the landfill belched or a sudden puff occurred, at
least some of that gas should come through the vent pipe which was designed for the release of
such gases. It is not plausible to believe that such a high dose of PCB's would occ11r in only one
spot and none even be detected in the other samplers so close to the hot spot, particularly in the
air sample being pulled from inside the landfill through the vent ( directly inside and before the
carbon filter). The high concentration found in the one sample was most likely due to lab
contamination.
As stated in the report, there is no way in which we can tell what releases through the air
may have occurred in the early 1980's. The EPA study done by Robert G. Lewis and Barry E.
Martin, after closure of the landfill found detectable PCB's in 4 of 39 ambient air samples, and
through two dispersion models showed that any concentrations downwind would be below the
detection capability of any known sampling equipment. The conclusions indicated that
"emissions of PCB .... were found to be negligible. " Subsequent testing in 1983, as suggested by
that report, likewise did not show any evidence of air emissions, and therefore no continuous
monitoring was done by the state.
4.7 LANDFILL INTEGRITY: There is absolutely no evidence that the "landfill has lost its
integrity and its ability to safeguard against future releases of PCB's and Dioxins." This is an
opinion of the Science Advisors and not supported by facts.
4.7.1 Top Liner: This section is devoted entirely to discussion of the 10 mil plastic liner over
the clay cap. No mention is made of the clay cap. The plastic liner was certainly not in the best
shape, however, it should be noted that based on the evaluation by S&ME it was in "fair
condition". Pinholes were found in the sample taken from the north bore hole, but no pinholes
were in the sample from the south bore hole. Only one spot appeared to have not been welded,
although it was obvious that several places on the seam had been breached by root vegetation.
The seams in some spots have deteriorated over time, probably due to the loss of plasticizer in
the parent material, or deterioration of the chemical composition of the original solvent used in
1982. By reviewing the lab test results on the PVC liner, it appears to be in adequate shape, and
aging as expected. The seams did show shear strength and low peel strength, while the other
properties were consistent with aging due to the loss of plasticizer, particularly the increase in
tensile strength and a decrease in the elongation at break strength.
The report states "given that only two locations were inspected and both were in poor
condition, it is likely that a significant portion of the synthetic cap has lost all practical
integrity". S&ME concluded that the cap system "appears to be providing satisfactory
performance". The report further ignores the presence of the compacted clay barrier layer and
vegetative cover portion of the system. This almost five foot thick layer has permeabilities on
the order of 10 -8 cm/sec. S&ME said the surface of the clay appeared to be in good condition
and that the permeability tests are indicative of well compacted clays. They also state that the
perms are lower than typically specified (10 -7 cm/sec). The cap has a healthy stand of
vegetation which would yield high amounts of evapotranspiration, and is graded to shed water.
3
Observations of the landfill and the results of the cap inspection, at those two points, do not point
to a cap system that has lost all practical integrity.
4.7.2 WATER IN THE LANDFILL: When analyzing the hydrograph data, one must also
consider several other influences on the recorded levels. Primary is the influence of barometric
pressure as well as the type and placement of the pipes from which the water level data is taken.
The sensitivity of the recording instrument is also a factor. Low barometric pressure will cause
an increase in water levels and high barometric pressure will cause a "decrease" in the water
level. Barometric pressures were obtained for 1995-1997 for RDU and plotted versus the water
levels in the leachate pipe and the riser. In all cases, the water level moves with the barometric
pressure. This is not to imply that water could not be entering the landfill, rather how and how
much must be further evaluated. The state has already recorded a 13 inch change in water level
in less than 48 hours. The spikes in the rainfall and the months chosen should also be carefully
examined. Infiltration may not be due to movement through the cap, but through other entries
like the leachate collection pipe, animal burrows, or other "point" penetrations of the liner. Data
collected from lysimeters beneath a cap system at the city of High Point, NC, which have been
monitored for over one year, do not show any infiltration during the warm months, regardless of
the amount of rainfall. Runoff and evapotranspiration exceed rainfall. Only during the dormant
winter months, December-February, are small amounts of infiltration registered through a two
foot vegetative layer.
The report states "the increased stress on the bottom liner system coupled with several
other complicating factors has apparently resulted in a breach of the bottom liner system". It is
assumed that the "stress" is from the water. There is, however, no evidence of a catastrophic
breach of the bottom liner system. The report fails to acknowledge that the bottom liner system
includes a leak detection zone which is monitored monthly and has never detected a leak, and
that there is a five foot clay liner system with 10 -8 cm/sec permeability on top of the PVC liner.
The analysis on the "delayed rise" is incomplete. It neglects evapotranspiration,
additional rainfall, runoff, etc. In addition it neglects the two feet of clay under the PVC liner,
the one foot of bridging material, and the additional 12-14 feet of unsaturated landfill soils, that
water would have to traverse to reach the phreatic surface. An analysis of the moisture contents
of the landfill soil samples gives no indication of a zone of saturation, wetting front, or other
indication that there is a change in moisture content in the landfill upper zone. Most of the
moisture contents are less than the field capacity of the soils.
Leakage rate: Assuming an effective porosity (specific yield) should be confirmed by
analyzing the geotechnical test results on the landfill contents. A more meaningful, and
representative number could be generated. The approximate ten inch fluctuation over a six
month period can easily be attributed to changes in barometric pressure. As mentioned
previously, the state has measured a 13 inch fluctuation in less than 48 hours, during a period of
no rain, and a very dry cap.
4
It should also be noted in the report that the rainfall data for the Arcola station is as
follows:
1992-47.95 inches
1994-40.28 inches
1996-60.58 inches
1993-43.80 inches
1995-56.85 inches
1997-20.86 inches (6 months)
4.7.3 BOTTOM LINER: Pictures 1, 2 and 3 actually show vandalism done to the bottom liner
during construction. The vandalism is to the plastic liner only, and was repaired. The clay
bottom liner was not harmed. Pictures 8 and 9 show water trapped in the landfill during the final
stages of remedial activities. Picture 10 actually shows pieces of filter fabric washed by the
torrential rains, and is not a picture of the PVC liner. There is no evidence to indicate that the
bottom liner is not intact. Even ifthere are potential problems with the PVC liner, as discussed
with the top liner, the report neglects the existence and contribution of five feet of compacted
clay, and the fact that the leak detection zone under the bottom liner has never shown the
presence of any water.
SECTION 5.0 CONCLUSIONS:
It was a forgone conclusion that the PCB levels vary in the landfill. However, there was
not one piece of evidence for PCB contamination outside the landfill. It should be noted that low
levels of PCB's were found in the landfill leachate. No PCB's were found in any samples,
groundwater, soil, or sediment outside of the landfill, with the exception of the one sample in the
pond area where EPA found .1 ppm PCB. The "reliable data" being used by the Science
Advisors indicating "some limited impact of the landfill on subsurface materials immediately
outside the landfill" is the presence of dioxins in two monitoring wells. Even the presence of
these various compounds do not correlate, and after evaluation of the Quality Assurance of the
dioxin data, the results are highly suspect as dioxin was also found in the lab and field blanks. It
would certainly be appropriate to re-do some of the dioxin testing, particularly in monitoring
wells 5-d and 1-a. Due to the low solubilities of dioxins in water, it does not seem feasible that
the landfill would be contributing to dioxin found in monitoring wells 5-d and 1-a without also
showing some PCB's, as PCB's were found in measurable quantities in the leachate from the
landfill. Thus if one compound were leaking out, why not the other?
SECTION 6.0: RECOMMENDATIONS
The variations of PCB concentrations in the landfill probably have no effect on the
detoxification process, as most processes, including the BCD, are often utilized for sites with
greater than 10,000 ppm of PCB's, which is more than 10 times any concentration found in the
landfill. Probably of greater concern will be the wet zone at the bottom of the landfill as the
process will be affected by sudden volumes of water which could cause an immediate
temperature drop in the process. This should be studied in the Phase II report.
5
~ MEETING REMINDER
The Joint Warren County/State PCB
Landfill Working Group will meet
Tuesday, October 7, 1997
at 6:30 p.m.
at the Warren County Office.
Joint Warren County/State PCB Landfill Working Group
draft October 7, 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. Tuesday, October 7, 1997 by co-chair Dollie Burwell. The meeting was held at the office of
the Working Group.
NEW BUSINESS
.',
Ms. Burwell advised that the main purpose of this meeting was to discuss the public meeting sched~_led.;(~r
November 1, 1997 and to discuss the noncompliance order issued against the State. She then asked if
anyone else had other items to be discussed. Ken Ferruccio stated that he thought we would get a review
of the comparative analysis report. It was agreed that the comparative analysis report would be given first,
followed by the response to the noncompliance order and then the discussion of the public meeting.
Comparative Analysis
Joel Hirschhorn reported on the comparative analysis. He advised that the report used the selection criteria
specified in the RFP. The RFP selection criteria are as follows:
I) The ability to meet Phase I performance criteria as demonstrated through Phase I test
data. For post-treatment solids the principal preliminary remediation goals were 20
ppb for total PCBs and I ppt for dioxin TEQ. The air emission performance goals
were 8x10·4 micrograms per cubic meter (ug/cm) for PCBs and 5xl0·8 ug/cm for
dioxin TEQ.
2) The quality of the Phase I test report.
3) The ability of the vendor to provide full-scale equipment at the Warren County PCB
Landfill site.
4) The ability of the vendor to provide a safe, reliable and cost-effective full scale application
of the selected technology at the Warren County Landfill. The RFP further clarified the
goals and objectives of the test. In addition to the meeting the performance criteria,
feasibility would also be determined by considering the safety of the technology, the rate of
detoxification, the cost per unit of detoxification and the reduction in long term potential for
environmental releases from residual of tl}e treatment process.
5) The quality and cost of the proposal for providing Phase II services.
Mr. Hirschhorn said that based on these criteria ETG Environmental, Inc. (ETG) comes out on top. In
almost all areas of the selection criteria ETG was judged superior to EcoLogic. He added that ETG has
a less complicated process that is less vulnerable to human error and therefore safer for the community.
Mr. Hirschhorn advised that EcoLogic has probably not met the stringent dioxin cleanup criteria used in
this project in previous projects. Adding that in an EPA report the thermal desorption unit "did not perform
to design specification" and the company "experienced material handling problems" and the company does
not seem to have been able to perform commercial projects at a profit, so may be experiencing uncertain
financial conditions. Based on this and other information the Science Advisors agree that ETG is the best
draft October 7, 1997 Meeting Minutes
Page 2
qualified company for receiving the Phase II contract.
Jim Warren said that this report is very helpful and includes the technical reasons for why ETG was chosen.
Deborah Ferruccio asked if the Working Group is at a point where a formal recommendation can be made
to the State. Mr. Hirschhorn replied yes.
Ken Ferruccio said that in the report it was stated that the EcoLogic process was not as safe as ETG's
process.· .When hydrogen is used there is greater vulnerability than when it is not used, said Mr. Hirschhorn.
The ETG process does not use hydrogen.
Mr. Warren made the motion to accept the recommendation by the Science Advisors. Ms. Burwell
amended the motion to include having the members polled due to the lack of a quorum and if any member
has questions that they are authorized to contact Mr. Hirschhorn. The motion was second with the
amendment.
Order of Noncompliance
Bill Meyer reported on the noncompliance order issued by EPA. He advised that a response is due to EPA
by November 28, 1997 and that the State would have one year to begin implementation of the actions
included in the response. Mr. Meyer said that the State will propose to EPA that they would like to do
some extensive monitoring so that would have constant water measurements. Patrick Barnes asked if the
water measurements will have a readout tape. Mr. Meyer responded that the weather station does have a
readout tape and ifit shows no i'ncrease in the water level there should be no problem with tying dewatering
with detoxification.
Ms. Burwell asked does the ETG process work better in wet or dry soil. Mr. Hirschhorn said that ETG
has addressed the water issue and concluded that it did not pose a problem. Mr. Barnes asked why would
not the water be pumped. If you don't pump the water it must be monitored intensively, said Mr. Meyer.
Mr. Barnes said that he feels that water in moving in and out and that no pumping it is an environmental
health risk. He added that from a technical prospective, the water should be removed. Mr. Hirschhorn
added that the question is not whether to remove the water, but when. The landfill should not be dewatered
until the legislature has given funding for the detoxification because dewatering will decrease the chances
of getting the funding said Mr. Hirschhorn. Mr. Meyer agreed that the question is when to dewater and
added that later will increase the option of detoxification. He continued by saying that it will take about
one (1) year to get the water in the landfill to a one foot level. Mr. Barnes agreed adding that the soil will
not yield the water that quickly, but hopefully the water can be removed faster than it is coming in.
Mr. Hirschhorn asked the State if they have thought about putting in a temporary liner? That is an option
said Mr. Meyer. He, Mr. Meyer, went on to say that we need to decide to pump or not to pump because
we must submit a plan to EPA. Mr. Meyer suggested that there is about six months before the General
Assembly convenes. In that time we can roll out a plastic liner, submit a full scale plan/design, implement
a RFP that will take three to four months and submit a design for a reconstructive top. Mr. Meyer said that
EPA may say that everything the State is doing is contingent upon getting funding for detoxification and
suppose the State does not supply the funding. This plan will be put in place if the funding is not obtained
said Mr. Meyer. He added to satisfy EPA requirements the State will purchase a pumping system to
determine the rate of release to the leachate collection system.
draft October 7, 1997 Meeting Minutes
Page 3
Ms. Burwell added that she believes that there will be detoxification, but that nothing is guaranteed. To
have a contingency plan will not hurt our efforts for detoxification. We must be responsible, but not closed
minded because we have a good case to submit to the legislature she said. Ms. Ferruccio said that the
responsibility factor is important; there was not pumping before because of the State's plan to spray the
water back over the landfill. She added that monitoring is going to show that the landfill is not a threat and
the $20 million will not come ifthere is no risk. Ms. Burwell said that it is better to go to EPA with a plan
than for EPA to tell the State what must be done. Mr. Warren agreed and stated that this discussion should
continue when more of the members are present to express their opinions.
Mr. Hirschhorn then made a point about the health risks. He noted that water is leaving the landfill but
there is no evidence that it poses a health risk. He added that the real health risk is from PCB air emissions.
Ifwe do not get funding for detoxification then the landfill must come into compliance he said.
Ms. Burwell recommended that Bill Meyer put his response to the noncompliance order in writing so that
the Working Group can review it before it is submitted.
Mr. Barnes added that because we did not detect sufficient discharges does not mean they are not present.
To not make an immediate move to dewater the landfill would be irresponsible and the actual removal will
take some time. Mr. Barnes continued by saying that the water that is leaving the landfill is taking
contaminates with it and we do not know what the resulting health risks are. He said as Advisor to the
Working Group he suggests that we move quickly toward dewatering; the RFP process will buy some time,
but should not be used as a delay.
Mr. Hirschhorn added that even with detoxification the water will have to be pumped. However, there is
no immediate rush to dewater die landfill he said.
Mr. Warren said that we want to be responsible and we must make sure that the timing will not jeopardize
the bigger picture of detoxification.
After additional discussion the Working Group agreed with asuggestion made by Mr. Warren, that the
State should prepare a proposal in time to be reviewed by the Science Advisors before being submitted to
EPA. Afterwhich additional discussion can continue if needed.
Public Meeting
The Working Group agreed that the public meeting would be held Saturday, November 1, 1997 at the
Warren County Courthouse at 1 p.m.. Ms. Burwell asked Mr. Barnes to fax some ideas to the office. It
was agreed that letters of invitation would be sent to local and surrounding counties elected officials and
would include questions that will be answered at the public meeting. The Science Advisors, the co-chair(s),
the State, and the representative(s) from ETG will make presentations. Mr. Hirschhorn advised that he
would be working with ETG on their presentation. Ms. Burwell appointed Ms. Holcomb to be on the
committee for the public meeting. Holcomb advised that she and the secretary would get assistance from
other members of the Working Group.
ADJOURNMENT
The meeting was adjourned at 9 p.m. and the next meeting was scheduled for November 12, 1997 at 6:30
p.m ..
FROM 91971~3 6~5 SOLID WASTE O!U 11.03 .1997 16:09
Jam~s B: Hunt, Jr,, Governor
Wayr\e · cDevltt, S cretery
Wllllem · • Meyer; D ector
MEMO
TO:
FROM:
SUBJEC:
DUM:
WA
Npvember 3, 1997
I.
....... -~ ·i
·:4
S-Tc:;. oe:·
OUP, SCIENCE ADVISORS
. A you are aw e, the Division of}Veste Management is required by the EPA as a
condition fthe permit or the PCB landfi)l to conduct ,emf-annual mo~itoring of the landfill.
' '
The first art of the tes ng for this year w$s done during the Site Investigation Work which
started (o site) in Feb BJ')',
W will be se ng a crew out to tl)e landfill within the next two to three weeks to do the
I
second ro nd of sampH g. I em encloslna' tho sampling locations we plan to use. and you \\ill
note that e have adde additional points. :specifically six of the monitoring wells installed this • I
sprlns'Wh ch are clo•es to the landfill, '
testina req, rement calls for P~B's, specific conductance, ·pH and temperature. ,
' !
'
Copy: ; Bil Meyer
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November S, 1997
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MEMORANDUM:
TO: JOEL ffiRSCHHORN
PATRICK BARNE
FROM: MIKE KELLY
SUBJECT: MEETING WITH ETO
I
I I
I I
I
FAX FAX
I have spoken ~ith Steve Detwiller wit~ ETG in reaard to: a meeti g with
the~ on Ph_nse II. W~ tentative~y agreed to N~~ember 1 .. ~:th at lO~OO am lre. in
Raleigh. Smee th~re 1s .a Workmg Group Me~1ting that mght 613_0, I fel thts
would be a good time smce you all would be tp. town for that e♦tmg. T e l Oam
time should give everyone time to arrive that 'llornlng. ·
. Steve indicated that he would contact l<fF Kaiser and I tl)em kno}. They
need to visit the landfill, and could do that Tu,sday afternoon an~ Wedn,sday,
although Steve indicated that if~ey go. up onjWednesday, w wpuld not really be
needed. . · 1 I
Please let me know if this is OK with ypu. I
Thanks. i
COPY: WORKING GROUP
BILL MEYER
HENRY LANCASTER
9!.: 11 lU,I "!.0 · 11 .. 010 31S~M 01705 ~09£!.ll616 WO~~
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l"hOoe; \1:11~) 490•0747 fa•: (919) 49;3-6614
E•M&il ·.o.e1dress: NC•WAANOPOBOX.COM
' I
MEMO
November 11, 1997
To: Wurkiug Group & Science Advisors
From: Jim Warren ·
Subject:. Plea,e read prior lo meeting
A few thoughts and request fur a 1.:ouple of things on the agenda for Tueinlay.
First, I want to thank all of you for R successful community meeting. I also suggest we send a
formal thanks to Dr. Purcell for doing an excellent job with good spirit; she's a strong ally
For the upcoming Working Group meeting, I ask that we allow sufficient time to discuss the
future roles of Patrick and Joel. In panicular, l'm not clear on whether we hllve decided whether
Joel's contract continues in 1998. We heard from Mike Kelly that we have $25,000 saved fl-om
hiring ETG for Phase tl so we need to look at·how to budget our finite resourl:e~ as we pursue
continued ·funding for the War.king Group itself along with Doris and the-facilitie!!.
(At this point in particular, I think the WG should be closely apprised of our resources; to that
end, 1 request that DWM bring a current accounting of WG finances .)
.I do not yet know what are all the -scientific duties· and support we'll need in the near and
intermediate future,· although I have several thoughts on this. I hope we can discuss this fu lly on
Tuesday so we can best plan and coordinate our activities on various fi'onts . I suggest we lay out
11 wriLltm. evolvint; linu:=line for Lhe m:xt t:ighl monlhs; T ror one would appreciate a visual image
as we discuss our approach and activities.
I feel that we would be malcing a grave mistake to not continue utilizing both scientists to the
de!;fee net;essary to ensure our btst shot to obtain funding for detoxification. They have both
done an excellent Job for us and arc_ a vital part of the team . You don't unhltch one of your two
hones ju.st shy of the mountain top.
Pat has the lead on the community build•ng aspect; J think Joel could be helpful in suppo11 of that
task. A bigger questio_n for me is getting the funding from the state. Although I'm no expert on
the legislature, I do know we will have to make a very strong case to some cormnittees an,d
probably.some individuals ---with Stm. Ballance's guidance and assistance I hope: ·
We wiU need both Pat and Joel for this work in order to fully support the senator's efforts. We
already know there arc state challenges about the failure of the dump. Since we have consistently
P:02
Advisory 8oanf: Or. F'1ulCOflnet1 e Ellan Connett• Fat Co5tner •Dr.Gerald Drake• Bi lie Elmore • Atv. t&aiah M!IClison • WiUiam San1our • P&t1,1J Macbowe1:
tlOU-·lc-97 20: 41 t~C WARtl TEL:[phone]
chosen to de-emphasize failure and focus on feasibility, it rnakes sense to gird ourselves as
strongly as possible for the feasibility selling points, especially since the technology, our choosing
of it, and its price tag will certainly be crucial elements of interest and likely challenge from
legislators, olhcr detox companies iiml utheri1 . Jut:l ii1 uur technulugy ex.p~rt ~nd it would seem
unwise to proceed without him.
Folks, setting $25 mi11io11 from the state of North Carolina will be a monumental effort . We must
have every resource available to have a reasonable chance of succeeding . We heard Sen. Ballance
---nothing'~ certain in thd political world. We must do everything we can to support his efforts.
Sad as it is, there are mariy in the state government who continue to undervalue the good pe.op1e
of Warren County.
Although I haven't yet talked with any of you about this, I feel very stron~fy that these are
importzmt ---even vital ---decisions for the success of our project and for helping this
community.
I look forward tu maximizing our efforts launched 11t the community meeting.
* Can the citizerui llil<l llcience 1idvii1ors please meet I hour prior to the mttin meeting at this veiy
important time and discuss upcoming community matesies? Or have a conference call earlier
Monday? (not as good economically)
P:03
FF:OM •
To:
From:
Subject:
Date:
STATE OF NORTH CAROLINA
WASHINGTON Ol"P'ICE
444 NORTH CAPITOL BTPU'.!'.T, SUIT!'. 332
WASHINGTON, D. C. 20001
202-0;!4·11830
Bill Meyer; Mik~)t1.
Jim McClcskcyf /"o/
NGA ''Environmental Justice" Document/ Viarrcn County Landfill
October 2, 1997
The National Govemor's Association "Center for Best Practices" prepares
occasional summaries of Federal / State policy issues of general interest to states. The
attached draft on Environmental Justice has been provided to us for advance review.
NGA staff hope to finalize it early next week.
The document cites the Wal1'en County landfill on page 2 as the origin of the
concept of environmental justice nationally. NGA staff will modify this as we request. I
have some concern with the drafl and have "marked up" the section on the Warren
landfill on the last page of the attachment. I am also told by staff that ifwe have strong
concerns they will remove the reference altogether.
The intended audience for this is Govornor's staff in all states, and potentially
Congressional staff although this is not a lobbying document per se. You will see the
overall thrust is critical of current Federal implementation of environmental justice
objectives with respect to state programmatic priorities and prerogatives.
Please take a look at this and let's discuss --202/624-5833.
Thanks for your attention to this.
cc: Richard Whisnant
Richard Rogers
FF:CIM 1 0.0 2 .19'::17 10 :0'j
Natural Resources Policy Division
Center for Best Practices
Contact: Debbie Spiliotopoi1los, 202/624-7895
September 30, 1997
Federal Environmental Justice Actions Threaten State Programs
Summary
Environmental justice addresses concerns that minority and low income communities bear ~
disproportionate adverse effect from pollution and identifies appropriate actions to eliminate such
biases. Title VI of the Ci vii Rights Act of 1964 (Title VI) prohibits federally-funded programs an d
activities from discriminating on the grounds of race, color, or national origin . As federally delegated
programs, state environmental permitting programs are covered by Title VI and have recently been the
~ubject of complaints under Tille VI for facility siting decisions.
Recent foderal interpretations of Title VI hold states responsible for local laws and land use decision,
and require states to address community demographics as a basis for approving permit s. ln addition ,
the federal government considers subjective, emotional impacts in environmental justice claims as .=,
busis for denying permits. This interpretation completely alters the traditional stHte role in land use an d
environmentul law, and requires states to perform assessments well beyond the scope of any
environmental luw or risk federal interference in state programs and reductions in federal funding. IL
addition, the numbers of environmental justice complaints are increasing, with man y filed by national
environmental advocacy groups.
Federal Title Vl interpretations threaten stale programs in the following ways.
• Shift the burden of proof of nondiscrimination to state permitting agencies.
• Delay the permitting process regardless of a state's efforts to include affected communities ir,
decisionmaki ng.
• lf successful, reduce or eliminate the federal funding available to a state's environmental agen cy
and can revoke a state permit.
Already, federal interpretations of Title VI are affecting state permitting activities by delaying th e
permitting process imd requiring additional studies. Although the U.S. Environmental Protecti on
Agency (EPA) is developing guidance on this issue, it is being done in a closed process without state-
input. EPA and other federal agencies need to develop n clear, enforceable approach to this sensitive,
and important issue that respects the limitations of current law and acknowledges the importance of
f-tates in !__his proces~.
Thi~ Issue Brief explores the federal interpretation of Title VI and its potentially significant and far-
reaching impact on state environmental permitting programs. It examines the recent court decision i:
and administrative actions that are helping to define federal policy and how they can affect stat e
F F: 0 M
edernl Envlronmcnt ,11 Ju~tlcc Actions Threaten State Progrnms ~4~
programs. ll also presents thl~ recommendations of state officials who pm1i ciplited in a ~ 199"i
roundtahle on facility siting and environmental justice, hosted by the NGA Center for Best Practices .
The states ugreed that EPA and other federal agencies involved in developing the Agency's position on
Title VI and facility siting should do the following.
• Rccogni:r..e the limitations of current environmental laws .
• Respect state and local land use decisions and laws,
• Acknowledge the state role in environmental justice policy
• Refrain from imposing cumulative exposure requirements that are not supported by adequate datu .
Concept of Environmental Justice
Environmental justice seeks to prated minority communities from a disproportionate adverse effec t
from pollution. The concept of environmental justice emerged in the late 1970s with grassroot~.
organizations and as an offshoot of the civil rights movement. Environmental justice gained nat iona:
attention in 1982 with u first national protest triggered by the siting of a polychlorinated bipheny:
(PCB) landfill in North Carolina, The 32,000 cubic yards of PCB contaminated soil resulted fro m the
cleanup of illegul dumping along 21 0 miles of roadway in the state. The lan dfill site was located in
WEmen; the poorest and most predominantly bh1ck county in the state . The community had man :
concerns regarding how the facility was sited, based on both technical criteria and community
involvement. Together. local residents and national civil rights leaders protested the facility's location
and form of disposal. Although the demonstrations were not successful, they spurred nationa:
awareness, a number of studies of the issue, and underscored the need for stakeholder involvement it~
siting decisions.1
Legal decisions and programmatic analysis of the issue have occurred only in the last few years. A:-a
result, determining what makes up u minority community, how we define the larger community. and
what constitutes adverse impact remain questions to be addressed in the courts and by EPA and the
U.S . Department of Justice.
1£nviro11me11tal Law h Poorly Suited to Addressing Environmental Justice Co11cems, Most
environmental laws h1tve environmental goals that do not translate to the socioeconomic goal s
associated with environmental justice concerns. Environmental laws require compliance with
emissions goals and other environmental parameters that are designed to protect human health and the
environment. Those regulations that address human health specifically offer minimum protections that
apply to the population as a whole. ror example, the. Resource Conservation and Recovery Act would
preclude siting a waste facility near a municipal drinking water source or a school. Environmental
laws contain no provisions for examining the qualities of a particular neighborhood .
Another limitation of environmental laws prevents environmental deterioration in pnstme or near-
pristine locations. Provisions of the Clean Water and Clean Air Acts have antidegrndation policies to
increase proteclion for unpolluted rc~ources. Thus a rrntional park may have stricter disclrnrge limit~
than more developed areas. This doctrine isolates and conccntrnlcs pollution sources into zones of
development while discouraging new pollution sources in less developed areas. In addition, the y
create a special need to prevent cumulative. environmental impacts in developed areas from exceeding
safe lin~its . Tbei;c non<leterioration biases muy con11ict with environmental justice concerns, especially
when minori!ies trnd low-income populations live in areas of high industrial development.
FF: 0 M 10.0 2 •. 1 '3':.'7 10 =~~1';1
Page 3, Federal Environmental Ju.~ticc Actions Thrcaton State Progrnms
Federal and state environmental laws do no govern the land use decisions central to environmental
justice concerns, which are made at the local level so that communities have a direct say in what
happens in their neighborhoods. Land use controls include zoning and other planning controls,
municipal and county government referendums, all of which have opportunities for publi c:
participation. Beyond these controls, local land use decisions are driven by the free market. an d
industry will site facilities based on infrastmcture, labor s1,1pply, land costs, and a host of other fact ors,
Enforcing Environmental Justice
Because environmental laws do not address environmental justice issues, environmemal justict
complaints have been based upon on Title VI of the Civil Rights Act of 1964 in the form of
administrative complaints and civil suits. Internally, the federal government has addressed
e.nvironmental justice in Executive Order 12898, titled "Federal Actions to Address Environment al
Justice in Minority Populations and Low Income Populations." EPA is also developing policies to
address the influx of Title VJ administrative complaints to the Agency.
Title VJ of the CMl Rights Act of 1964. Title VI codifies the equal protection and nondiscrimination
guarantees of the U.S. Constitution by ensuring that any program funded by the federnl governmen:
docs not contribute to discriminatory practices.
No person in the United S1ates shall, 011 the ground of race, color, or national o·rigi11,
bt'. excluded from par1icipatio11 in, be denied the benefits of, or be subjected 10
discrimination under any program or activity receiving Federal financial assisran ce. 1
Title VJ is enforced by the twenty-six agencies that distribute federal funds and issue rules an d
regulations . Title VI applies to states, localities, and other entities that receive foderal funding for
distribution in the forms of grants and programs. Title VI has traditionally addressed issues of di rcc
funding for educational programs, disaster relief, or building grants that may have a direct impL,ct or!
individuals or communities. lf u funded recipient is judged in violation of Title VJ, injunctive penalties
can include orders to desist program activities or reduced federal funding.
A new use of this 33 year-old luw applies Title VI to state environmental and permitting programs.
Since most stale programs have dele.gated authority from EPA and receive substantial federal fund ing.
However, Title VJ normally addresses federally funded actions where the rec.ipient owns and hlls
control over the facility or construction in question. State permitting programs perform neutrai
assessments to determine the applicability of the site in terms of environmental conditions only . Land
use control and siting decisions ure determined by t~e private landowner and local land use rnstricti om
Forty-four Titles VI administrative complaints have been filed at EPA since 1993 und many of these
involve environmental permitting. Of these complaints, EPA has accepted fourteen, achieved
voluntary compliance in four, dismissed two, and is considering the remainder. EPA has not sent an ;1
formal complaints to the U.S . Depai1ment of Justice for litigation .
Anyone &an file a Title VI administrative complaint or civil suit.) The open process allows activists to
claim injusticc.1, for alleged victims of discrimination that have not filed their own complaints.
Recently, a numhcr of c.nvironmcntal justice advocates and other environmental group.s have file d
,·omplaint:s in an effort to stop planned facilities that were approved by locel and state governments.
For example, Greenpeace, which has an international mission to halt polyvinyl chloride production. has
FROM p . -
Page 4, Pcdcral Environmcntnl .lu~ticc Action.~ Threaten State Programs
worked with the Tulane Environmental Law Center to stop the Shintech polyvinyl chloride facilit y by
claiming environmental racism.4
Rrecutive Order 12898.~ Executive Order 12898 requires each fe.deral agency to make environmental
justice part of its mission. The exe.cutive order requires federal agencies to address "disproponionately
high and adverse human health or environmental effects of its programs, policies, and acti viti es on
minority populations and low-income populations in the United States." The key differences in thi.;
mandate from Title VJ is its applicability to federal agencies, the importance of discriminatory effect of
policies or decisions, and the wider scope of environmental justice to address di5;crimination based on
income as well as race.
The order sets up nn intcrngcncy working group on environmental justice to provide guidance fo r
identifying adverse human health or environmental impacts, cooperating on research efforts, und
coordinating with agencies on their environmental strategies.
EPA's environmental ju5;ticc strategy created the National Environmental Justice Ad visory Council
(NEJAC); a group of stakeholders with interests in environmental justi ce. Although the NEJAC
represents an advisory commitlee under the Federal Advisory Committee Act, the current
configuration has token state representation, Of the 27 council members, there is only one
representative from a state agency, This grot1p reports directly 10 the EPA Administrator and is
suppo11ed by staff from EPA's Office of Environmental Justice, which is part of the Office of
Enforcement and Compliance Assessment. Most of the NEJAC's decisions have represented case-by-
case opinions.
EPA 's Activities Developing a Title l'I Policy . In response to the influx of Title VI administrati ve
complaints regarding environmental permitting, EPA has set up a task force composed of EPA
program office representatives and U.S. Department of Justice officials. This task force is determining
how to interpret Title VJ claims and is examining a few of the administrative cases to deve lop
strategies to address the issue.
Although EPA's activity has major implications for state programs and environmental justi ce
advocates alike, the task force is closed and has no input from states or other stakeholders. EPA may
issue the task force determinations us internal EPA guidance for deciding Title VI complaints. No date
has been set for public review or comment on task force activities or guidance.
Environmental Justice Cases and Their Impacts on States
The administration's interpretation of the state responsibility under Title VI can he inferred from a few
actions and an Amlcus Curia(! brief. The Title VI suit was filed in Chester, Pennsylvania by a group of
citi7,ens against the Pennsylvania Department of Environmental Protection for approving the permit of
the SRS solid waste fac ility.<' On behalf of EPA, the U.S. Department of Justice filed an Amicus Curiae
(friend of the court) brief in support of the plaintiffs in the Chester suit. An amicus brief does not have
the weight of an EPA policy, but it represents the first indication of EPA's position on Title VI and
state environmental permitt ing programs. The amicus brief makes the following points.
• Enyironn1ental justice claims can be based on discriminatory impact without proof of
discriminatory intent, Although the Chei;ter decision stated that civil com1 cases require proof of
FF.:OM
P11gc ~. Pcdcrnl Environmcntnl Justice Ac\i(l1l~ Thrcn1cn Srntc Prugrnms
intentional discrimination defined by case law, rather than the unintentional effect of
discrimination ullowed in on ndministrntivc decision under federal regulations, this decis ion is;
under uppcnl with arguments held September 25, 1997. The Amicus Curiae brief opposes thi s
decision .
• States must oversee land use and siting decisions. The amicus curie brief considers states
obligated to ensure that their environmental permits do not have discriminatory effects, regardles s
of the state 's role in facility siting. The amicus brief' s interpretation changes the nature of state
and local relationship by making stitles responsible for overseeing local zoning and site planni ng
decisions.7 Traditionally, siting u facility nnd all other land use decisions arc controlled by local
and regional planning boards, zoning commissions, and county councils. These local authorities
determine the number, pluccment, and types of facilities that may be sited in an area.
• State.~ must perform demographic analyses during permitting process
/The stale] has w1 obli(:alion under Title VI and EPA regulations to insure that ils
approved <f a pamit docs not subjecf a minority community to disproportionate and
adverse human health, environmemal, and other effects, Solid waste permit Qf )p/icmions
specifv 1he precise !ncatio11 <fa proposed facility, and therefore, {the state] ... is a ware of,
or should he aware of the geographic area rha1 ,viii be affected by the operation of the
{', ·1 · /I .,ac1 .11y.
The asse11ion that states should perform demographic and disparate impact anal yses when issu in g
environmental permits represents a significant departure from current environmental prog rams.
Environmentul laws assume equal protection of all communities based upon environmentftl
standards, and the permitting process ensures only the structural and environmental suit ability of u
facility .
Federal Policy Broadly httcrpretl· Em•irommmtal Justice Impacts: The Ward Valley Low Level
Radioactive Waste Fadlify, Ward Valley, Californi<l. EPA's and th e U.S. Department of In terior
(DOJ)'s response to siting u low-level radioactive waste facility in Ward Valley, California ind icates
that federal ngencies are using a very broad interpretation of discrimina tory impact that includes
cultural impacts. The Agencie~ base their concerns on claims of emotional distress well beyond the
human health and environmental impacts covered by laws and regulation s. Thi s federal action
potentially could affect any facilit y siting. Do these cultural impacts have the same weight as the
human health effects that traditional environmental analyses address? If so, how can states meas ure
cultural impacts? Until these questions are answered, even the most stringent state permi tt in g
decisions will be vulnerable to environmental justice claims.
California was extremely sensitive to minority impacts when it permitted the Ward Valley Low Leve!
Radioactive Waste Facility, After a thorough analysis, California determined that Ward Valley was the
safest location for siting a low-level radioactive waste facility due to its low rainfall and risk of seismic
iictivity. The state worked with Native American history and Tribal representatives to determine the
~ite most consistent with Native American cultural concerns. Taking representatives '
recommendations, the state identified an already disturbed site 20 miles from the nearest r~servation .
The site was technically superior to the alternative Silurian site and provides a greater margin of public
health and safety protection.
F f.:OM 10.02.1 '?'37 1,c1 :11
Page 6, Pcdcrnl Environmcntnl Justice Actions Thrcnten Stale Programs
The stute condllctccl thorough archcological and ethnographic studies that included a Native American
observer in a complete archeological survey. The analysis included ethonobotanic walkovcm; and
protection of key species of concern to certain tribes. The state worked closely with Mojave and
Chcmehuevi Indian Tribes on a number of other analyses, and determined the absence of sacred sites
in the valley.
Despite this extensive analysis, Ward Valley has been the subject of an environmental justice claim by
the Fort Mojave Indian Tribe, Greenpeace, and the Bay Area Nuclear Waste Coalition, based on
general emotional impacts of siting 1rnywhere in the Colorndo River Valley . These groups successfull)
lobbied EPA and the D01 to explore their claims and perform a supplemental environmental impacl
statement. EPA and the Department's investigation has blocked construction of the facility because
DOI owns part of the proposed site and will not sell it to California until the environmental justice
claim is resolved. 10
Ironically, the four-year delay of a disposal facility increases the potential human health risks or,
minority communitie.s where the waste is temporarily stored or alternatively disposed. The absence of
the regional facility sited for Ward Valley has forced many generators to dispose of their waste in c
commercial facility in Barnwell, South Carolina, an area where 55 percent of the population is Africur:
American . In addition, the trunsportation of waste to South Carolina has potential environmental
impacts along transportation routes.
Michigan Title VI Suit Halts Permitting Process. NAACP v. Engler represents a civil rights Cl\Se tha:
found no racial discrimination yet halted the permitting process based on environmental concerns no1
before the court. 11 As a state case, NAACP v. Engler does not set a federal precedent, but it ha ~
received significant national attention because it illustrates the potential effects of Title VJ suit~.
The suit was filed unde.r a state civil rights law that is modeled on Title VI. The NAACP and min ority
residents of Flint sued the state for approving air permits for the Genesee Power Plant. ln the decision.
the judge dismissed the civil rights issues raised in the complaint and stated that the issue was nm
about race. However, the judge also uddressed environmental protection issues not before the cou n .
and determined that federal and state permitting requirements failed to protect the human health of 11
community.12 The de.cision requires the state to perform cumulative risk assessments for the current
environmentul background before approving permits for new pollution sources. This case is under
appeal and may have substantial modifications made to the original decision,
State Recommendations Regarding EPA 's Policies on Title VI and Permitting
:Pourteen Governors' environmental justice advisors developed the following recommendations during
a May 1997 rouncltable on facility siting and environmental justice that was hosted by NGA' s Center
for Best Prnctices. Noting the far-reaching effects of EPA's environmental justice guidance an d
administration initiatives on stfllc permitting programs, the states agreed that EPA and other federn l
agencies involved in developing their position on Title Vl and facility siting should do the followin g.
Recognize the Limitations of Current Enviromnental Laws. Stales must adhere to environmenta l
protection laws and regulations. Yet current EPA interpretations of state responsibility go beyond th::
scope of any environmental law and threaten states with delays and loss federal funding due to Title VJ
Pngc 7, Pcdcnil Environmental Justice Actions Threaten State Programs
complaints. States believe that EPA is incorrectly interpreting Title VI in its emerging policy and has
gone well beyond the scope of Execl1tive Order 12898 by suggesting states consider subjective impacts
such as emotional distress (in the Ward Valley Case).
EPA's broad interpretution of Title VI will have far-reaching and unintended effects, affecting issues
beyond the purview of EPA and state environmental agencies. Thus, any process for addressing the
implications of Title VI in permitting should be reviewed by state, local , and federal agencies
responsible for all aspects of land ll~C, economic revitalization, and job development efforts.
Respect State and l.,ocal Land Use Decisions and /..aws. Federal environmenti1l justice policies mu1;t
respect state and local land use plans and accommodate brownfield and economic de velopment
initiatives. Federal interpretations of Title VJ hold states responsible for the autonomous decisi ons of
local governments, and recommend that stales perform demographic analyses well beyond the scope of
current laws (in the Chester Case). Traditional land-use decisions are by-right or limited by zoning,
local planning controls, and county or municipal government decisions . These decision s are made at
the local level with no interfere.nee from states . EPA policies that require states to oversee local
decisions using demographic anal yses are an inappropriate way to modify traditional land-use pl anni r:g
processes.
Acknowledge the Importance of the State Role in .4ny E11vironmental Justice Policy. States stress
the need for full public involvement, including state interests, in the development of any kind of
guidance or policy regarding environmental justice and recommend EPA address the issue of
environmental justice in a public process, including workshops with affected state stakeholders. Stales
suppot1 involving affected communities in land use and perll'1itting decisions. Jn fact, a number of sta t~
programs actively reach out to involve communities in decisionmaking in an open process. State~ a,c,
concerned that EPA is developing a policy behind closed doors that will have significant effects upon
state progrnms and local land use authorities.
Refrain Prom Imposing Cumulatfre E;rposure Requircme11ts That Are Nol Supported by Adequate
Data. EPA needs to address the cumultttive impact of multiple facilities in permitting standards rath er
than police local land use planning and economic development activities. EPA needs to collect more
data before atlempting to impose policies based on cumulative environmental impacts . Although ma ny
people bclie.ve that multiple facilities operating within current discharge limits increase health risks,
there is a liHk duta und few analytical methods that measure the cumulative risks of multiple
exposures.
Conclusion
The federal government's interpretation of Title VJ in recent cases threatens state and local righ ts and
has been developed outside of any stututory authority. Governors need to be aware of the sign ificant
i1npac1s that EPA's policy will have on state authority and ensure that any federal environment al
justice policy is base.d upon laws and respects the state role. In addition, EPA should be encouraged 10
support furiher research on cumulative health risks rather than work on far reaching policies in secre t
F F:OM
Pngc B, Fcdcrnl Envlronrncn111l Juslict. Actions ThrcAtcn Stale Programs
Appendix
Title VI Complaint Process
Thl.~ section offers a hrief overview of the complaint process for Title VI. Claims can be made againi:t
stales under Tille VJ by filing administrative complaints or civil suits in the District c0ur;.
Administrative compluinls rely on the EPA or other administrative agency's regulations. In an
ttdministrative complaint, the burden of investigation is on the administrative agency's Office of Ci v;l
Rights. D Civil suits must be based on Tille VI statute and supporting case law. ln a civil suit, the
plaintiff has the burden of investigation and remains actively involved in the suit.
Admi,iistrative Complai11ts. In an administrative complaint, the complainalll needs to identify un
unjustifiable disparate impact on a minority community compared with the community at large.
Unlike civil court litigation, EPA' s administrative review does not require proof of intent. Claim s
must show that that the defendant's actions result in the effect of discrimination. This is an important
difference, as proving intentional discrimination is very difficLtlt . A discriminatory impact could result
from Ltsing standard crite.ria or practices. The complaint must be filed within 180 days of the allege d
discri111ination . Once a complaint is made, EPA begins a preliminary investigation to determine if the
complaint will be accepted , rejected, or referred to another appropriate federal agency .
If the complaint is accepted, the EPA Office of Civil Rights will notify the complainant and the EPA
official in charge of the assistance agreement. The applicant can then submit a written rebutt al or
denial of the allegations, and the plaintiff is given an opportunity to respond. If EPA judges an
administrative complaint. the Agency will attempt an informal resolution for achieving voluntary
compliance before issuing an administrative order. EPA may also refer a case to the U.S. Depa1i1nent
of Justice for litigution. 14
Civil Court Suih·. Unlike federal agency administrative complaints, civil suits must prove intent ion al
discrirninution becuuse they follow the staltlte rather thun the agency regulation.1~ Court decisions have
identified three points required to prove the discriminatory intent under Title VI.16 These points must
be provod in civil suits and arc applied generally in administrative inveslig1:1tions . First, the! claim must
identify the practice that causes a disparity and prove a tangible effect. Second, the defendant mu st bC!
unable to show legitimate, substantive reasons for pursing the practice or activity . Third, there mu st be
a less-discriminatory alternative to the challenged activity or an unjustified reason for the impact.
Endnotes
1 Robert D. Bullard, Dumping in Dixie: Race, Class, and Envirnnmental Quality (Boulder, Colorado: Westview
Prei;s, 1990), pages 35-38.
2 Pub.L. 88-352, Titl·c YI. §601, July 2, 78 Stat. 252.
·' 40 CFR §7 .120(11).
4 llllp: //www.gre,enpcacc.orgrusa/actne1/sllin1ch.html, J 8 August 1997,
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Page 9, Pcdcrnl Environmcnl1\I Justice Actions Threaten Stntc Programs
-~ Federal Regis/a 59, no. 32 ( 16 Februnry 1994), 7629-7633.
'' Ches/er Residents Crnu:enrcdfor qualiry living, er.al., v. James M. Seif, No. 96-3960, lJ. S. Distrir.:t Court E.D.
PA (5 November 1996).
7 Brief of United Stntes as Amicus Curiae in Opposition to Defendants' Motion to Dismi1,s, Chcsrer lfrside,:t.1.
e1.r1I., v Seif er.al., No. 96-3960, U.S. District Court E.D. PA (23 August 1996), page 19.
~ ibid, page 20.
0 John Pierson und Peter Baldridge, Memorandum to Cross Medin Division of US Environmental Protection
Agcn~'.Y Region 9 (Coliforni11 Department of Health Services, 12 March 1997), Page 3.
rn "GAO Concludes Most Ward Volle y SEIS Issues Previously Addressed: New Information Favors Fncility,"
/,,()w Level Waste Forum, Volume 12, Number 6 (Washington, DC : Low Level Waste Forum c/o Aflon
Associates, July 1997).
11 NAACP er.al. v. Jolin li11Kler, ct.al., Cftsc Number 95-38228-CV, Stale of Michignn , Circuit Court for tht
County of Genesee, (29 Mny 1997).
12 ibid., p. 47 .
11 Sec e.g., EPA 's regulmions covering administrntive review, located in 40 CFR §7 . l 0-135
14 40 CFR §7. I(). 7. l 35.
1.i Guardians i\ssoclat/011 v. Civil Ser vice Commission of Clry of New York, 463 U.S. 582, 77 L. Ed. 2d 866, 10:,
S, Ct. 3221 (1983).
11' A/e.m11der v. Choa/e, 4(19 U.S. 661 , 666-667 (l 985).
FF:OM F. 1 _
Fcdcrnl Enviromncnlfll Justice. Actions Threaten State Programs
~4,<-
programs. It also presents the recommendations of state officials who participated in a 'C 1997
roundtable on facility siting and environmental justice, hosted by the NGA Center for Best Practices .
The states agreed that EPA and other federal agencies involved in developing tbc Agency's position en
Title VI and facility siting should do the following.
• Recognize the limitations of current environmental laws.
• Respect state and local land use decisions and laws .
• Acknowledge the state role in environmental justice policy
• Refrain from imposing cumulative exposure requirements lhat are not supported by adequate data
Concept of Environmental Justice
Environmental justice seeks to protect minority communities from a disproportionate adverse effect
from pollution. The concept of environmental justice emerged in the late 1970s with grassroots
organizations and as an offshoot of the civil rights movement. Environmental justice gained nat ion,:l
attention in 1982 with a first national protest triggered by the siting of a polychlorinaled biphenyl
(PCB ) landfill in North Carolina. The 32,000 cubic yards of PCB contaminated soil resulted from the
cleanup of illegal dum ing ~I ng 210 miles of roadw~ in.,_thc state. The landfill site was locate d in ~ l I'\ rt I ti r:U, r$, -Warren; 44i poor . . The community had man y
concerns regarding how the facility was sited, based on both technical criteria and community
involvement. Together, local residents und national civil rights leaders protested the facility's locntion
and form of disposal. -A-ll~ettglt tlte 6!.HAQIH:ti;,atiQ.I~• 111,r.-nr-1 ,wce1.8"1tl, ~~~-spurred national
awareness, a number of studies of the issue, and underscored the need for stakehol er involvement ii·,
siting decisions. 1
t!A~h'o........,.)J'Vlh'ct -nu~ pr~/.ris.
Legal decisions und programmatic analysis of ~issue,have occurred only in the last fe w years. As a
re sult, determining what makes up a minority community, how we define the larger community, and
what constitutes adverse impact remain questions to be addressed in the courts ond by EPA an d th~
U.S . Depanment of Justice.
Enrironmcntal Law ls Poorly Suited to Addressing Enviroumental Justice Concerns. Most
environmental laws have environmentttl goals that do not translate to the socioeconomic goflls
associated with environmental justice concerns. Environmental laws require compliance wi th
emissions goals and other environmental parameters that are designed to protect human health and th;:-.
environment. Those regulations that address human health specifically offer minimum protections tha l
apply to the population as a whole. For example, the Resource Conservation and Recovery Act woul d
preclude siting a waste facility near u municipal clrinking water source or a school. Environmentui
laws contain no provisions for examining the qualities of a particular neighborhood.
Another limitation of environmental laws prevents environmental deterioration in pristine or near-
pristine locations , Provisions of the Clean Water and Clean Air Acts have antidegradation policies to
increase protection for unpolluted resources. Thlls a national park may have stricter discharge limits
than more developed areas. This doctrine isolates and concentrates pollution sources into zones of
development while discouraging new pollution sources in less developed areas. Jn addition, they
create El spe.cial need to prevent cumulative environmental impacts in developed areas from exceed in g
safe lin:iits . These nondeterioration biases may conflict with environmental justice concerns, especi all y
when minorities and low-income populations live in areas of high industrial development.
Environmental
fllolenoy
Quality Assurance
Laboratory Data Evaluation
for
State of North Carolina
DEHNR
Solid Waste Management Division
prepared by
James A Ploscyca
Environmental Efficiency
[phone]
prepared for
Mr. Michael Kelly
North Carolina DEHNR
Solid Waste Management Division
P.O. Box 27687
Raleigh, North Carolina 27611-7687
October 2, 1997
,.: .
Envlronmental
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Introduction:
In early August, 1997, Mr. James A. Ploscyca of Environmental Efficiency was contracted to
compile and tabulate various environmental data associated with the Warren County Landfill site.
This compilation of data was completed and presented to Mr. Kelly at a meeting which took place
on September 2, 1997.
Review of the tabulated data indicated that the most common contaminant being detected in the
samples was Octachlorodibenzodioxin (OCDD). This compound was reported in every
groundwater sample collected at the site, but was also detected in many of the field and laboratory
blank samples. In an effort to verify the validity of the OCDD results, Mr. Ploscyca was requested
to evaluate the data for possible field or laboratory contamination.
The evaluation utilized a USEP A, Region IV document entitled "Data Validation Standard
Operating Procedures for Polychlorinated Dibenzodioxin and Polychlorinated Dibenzofurans"
September 1996, as guidance. The primary focus of the data evaluation was Section VII of the
document (See Attachment I) which addresses method blank evaluation.
Summary of Findings:
The following tables list samples by analytical groupings referred to as Sample Delivery Groups or
SDGs. The laboratory utilizes SDGs to track internal laboratory quality control associated with
particular samples. Each sample grouping has one or more Method Blanks associated with the
analysis of samples. The table lists samples in a particular SDG and then the associated Method
Blank results.
The most common compounds detected in the samples were HPCDD and OCCD and the third
column in the table lists their respective concentrations in each of the samples and blanks. A
designation of "Plus" in the third column indicates that additional compounds beyond HPCDD
and OCCD were detected in the sample.
The values listed in column 4 represent the concentration levels found in the blanks multiplied by
a factor often. The EPA data validation document (See Attachment I) states:
"Any compound detected in the sample that was also detected in any associated blank is not
reported if the sample concentration is less than ten times (J Ox) the blank concentration. "
If the sample exceeded the Blank cutoff level, column five indicates an "R" flag which signifies
that the sample results are rejected due to serious deficiencies in the ability to analyze the sample
and meet quality control criteria. The presence or absence of the analyte cannot be verified.
Page 18 of the EPA document also indicates that data qualification should be based upon
comparison with the associated blank having the hiehest concentration of a contaminant.
2
...: .
""C nvlronmental
..l..Atlolenoy
Associated blanks include the extraction method blanks.
The highest water extraction blank was BL0414WB with HPCDD and OCCD concentrations of 4
and 140 pg/L respectively. A level of 140 pg/L ofOCDD indicates a severe laboratory
contamination problem which may be reflected in the reported sample concentrations.
Samples with a "RR"qualifier indicate they are rejected since their concentrations are less than
1 Ox the levels found in the highest extraction blank. The highest soil extraction blank was
BL04 l 4SA with HPCDD and OCCD concentrations of 1. 1 and 31 ng/Kg respectively. Samples
qualified with an asterisk (*) appear to be valid reported concentrations according to the EPA
(lOx) rule. Unfortunately, the "R" or "RR" flag was determined to be applicable in the majority of
cases.
In conclusion, it is my recomendation that extreme caution be used when attempting to utilize this
data to make important environmental decisions. There is clear evidence of widespread sample
contamination during sample processing at the laboratory. The presence of this contamination
makes it difficult, if not impossible, to rely on the generated data with any degree of confidence.
Since the scope of contamination was so broad, (not limited to merely a couple of blank samples),
it is difficult to have confidence in the data set as a whole, since it may not accurately reflect
actual field conditions.
There were two water samples, JDH and QAR which yielded relatively high concentrations of
analytes compared to the other samples collected. It may be prudent to take a closer look at these
locations if additional analytical work is performed.
Please do not hesitate to contact me at ( 919) 6 7 6-694 7 if you have any questions or comments on
this report.
Sincerely,
~vis--
James A Ploscyca
Principal, Environmental Efficiency
3
Environmental
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SDG# Sample/Blank
29087 DMA
HESS
LESS
BL0414SA (Blank)
29087 ASH
JD
JAD
MMM
RAJR
RR.AM
BL0414WB (Blank)
HPCDD
OCCDConc.
1 ng/Kg
47 ng/Kg
2.2 ng/Kg
432 ng/Kg
1.7 ng/Kg
245 ng/Kg
1.1 ng/Kg
31 ng/Kg
ND
13 pg/L
4.5 pg/L
42 pg/L
3.8 pg/L
24 pg/L
2.1 pg/L
14 pg/L
4.5 pg/L
30 pg/L
ND
20 pg/L
4 pg/L
140 pg/L
4
Blank Cutoff Qualifier
R
R
R •
R
R
11 Blank
310
(Highest Soil Blank)
-
R
R
R
R
R
R
R
R
R
-
R
40 Blank
1400
(Highest Water Blank)
D nvlronmental
1..Atlolanoy
SDG# Sample/Blank
29087 ALB
BB
BT
JDW
KTB
PSG
RBAB
RPS
TB
BL041 4WA (Blank)
HPCDD Blank Cutoff Qualifier
OCCDConc.
2.9 pg/L R
22 pg/L R
6.8 pg/L R
48 pg/L R
3.2 pg/L R
18 pg/L R
4 pg/L R
22 pg/L R
4.8 pg/L R
26 pg/L R
4.6 pg/L R
32 pg/L R
3.9 pg/L R
18 pg/L R
4 pg/L R
37 pg/L R
11 pg/L R
357 pg/L RR
4.2 pg/L 42 Blank
33 pg/L 330
5
Environ mental
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SDG# Sample/Blank
29087 AJ
ADJ
AW
cc
CEH
DRK
JDH
JOK
RDRJ
RPAB
RPF
BL0414WA (Blank)
28760 ADF
MB
BLO3 l 0WF (Blank)
28760 DM
IBv1
BLO31 0SC (Blank)
HPCDD
OCCDConc.
7.5 pg/L
54 pg/L
10 pg/L
88 pg/L
19 pg/L
150 pg/L
7.5 pg/L
99 pg/L
4 pg/L
17 pg/L
ND
29 pg/L
1041 pg/L
10053 pg/L
Plus
ND
18 pg/L
5 pg/L
17 pg/L
10 pg/L
98 pg/L
ND
2lpg/L
4.2 pg/L
33 pg/L
3.0 pg/L
20 pg/L
6.1 pg/L
40 pg/L
ND
10 pg/L
ND
2.7 ng/Kg
ND
1.8 ng/Kg
ND
2.4 ng/Kg
6
Blank CUI.off Qualifier
R
R
R
R
R
R
R
R
R
R
-
R
*
*
-
R
R
R
R
R
-
R
42 Blank
330
RR
R
R
R
Blank
100
-
R
-
R
Blank
24
Environ mental
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SDG# Sample/Blank
28760 KM
MM
N1AB
PMB
WM
BL03 1 0SC (Blank)
28760 JABP
JABT
BLO3 l 7SD (Blank)
28760 JABB
NlAP
N1AT
BL0317SD (Blank)
28835 CB
MS
BL03 ! 7SD (Blank)
A1 02932#1
HPCDD
OCCDConc.
ND
1.4 ng/Kg
ND
2.6 ng/Kg
2 ng/Kg
76 ng/Kg
0.5 ng/Kg
24 ng/Kg
.3 ng/Kg
Ing/Kg
0.3 ng/Kg
2.4 ng/Kg
15 ng/Kg
249 ng/Kg
Plus
21 ng/Kg
789 ng/Kg
Plus
ND
0.7 ng/Kg
79 ng/Kg
1660 ng/Kg
Plus
21 ng/Kg
697 ng/Kg
Plus
6 ng/Kg
219 ng/Kg
Plus
ND
l.l ng/Kg
2.3 ng/Kg
125 ng/Kg
l.3 ng/Kg
70 ng/Kg
ND
I.Ing/Kg
7
Blank Cutoff Qualifier
-
R
-
R
R
RR
R
R
R
R
3 Blank
24
*
RR
*
*
Blank
7
*
*
*
*
RR
RR
Blank
RR
RR
RR
RR
Blank
11
Envlronmental
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SDG# SamplelBlank
28835 AR
BHB
NCB
SD
BL0317SD
AI02934#2
28835 CA
CBT
DA
DJ
IMB
JSB
KB
PAB
RSB
BL0317WF
AI02941#2
HPCDD Blank Cutoff Qualifier
OCCDConc.
2.7 ng/Kg R
137 ng/Kg RR
2.2 ng/Kg R
26 ng/Kg RR
1.8 ng/Kg R
62 ng/Kg RR
2.7 ng/Kg R
55 ng/Kg RR
0.4 ng/Kg 4 Blank
1.2 ng/Kg 12
ND -
52 pg/L R
ND -
11 pg/L R
ND -
52 pg/L R
ND -
24 pg/L R
ND -
44 pg/L R
ND -
49 pg/L R
3.3 pg/L -
56 pg/L R
ND -
12 pg/L R
ND -
22 pg/L R
ND Blank
10 pg/L 100
8
Environ mental
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SDG# Sample/Blank
28844 AB
ADD
CD
LB
MR
PJD
PJR
SLB
BL0317SD
Al02932#l
28844 EZM
NOV
BLO317WF
AI02941#2
28844 QAR-Reanalysis
BL0325WB (Blank)
Al02972#1
29081 TMSS
HPCDD Blank Cutoff Qualifier
OCCDConc.
1.5 ng/Kg RR
86 ng/Kg RR
Plus
0.5 ng/Kg RR
6.0ng/Kg R
Plus
2.3 ng/Kg RR
125 ng/Kg RR
Plus
1.7 ng/Kg RR
31 ng/Kg RR
Plus
0.9 ng/Kg RR
35 ng/Kg RR
3.1 ng/Kg RR
53 ng/Kg RR
Plus
1.2 ng/Kg RR
45 ng/Kg RR
Plus
1.8 ng/Kg RR
83 ng/Kg RR
Plus
ND Blank
I.I 11
6.5 pg/L RR
4lpg/L R
Plus
9.4 pg/L RR
541 pg/L RR
Plus
ND Blank
10 pg/L 100
85 pg/L *
1407 pg/L *
Plus
2.4 pg/L 24 Blank
6.4 pg/L 64
4.6 ng/Kg RR
546 ng/Kg *
9
Environmental
tflolenoy
SDG# Sample/Blank
A103029 #2 (Blank)
HPCDD Blenk Cutoff Qualifier
OCCD Cone.
Could not Locate in Datapak -
Environ mental
fflolenoy
Attachment 1
Selected Pages of USEPA Document
DATA VALIDATION STANDARD OPERATING PROCEDURES FOR
POLYCHLORINATED DIBENZODIOXIN AND POLYCHLORINATED DIBENZOFO"R.ANS
ANALYSIS BY HIGH RESOLUTION GAS CHROMATOGRAPHY/
HIGH RESOLUTION MASS SPECTROMETRY
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
Prepared by:
SCIENCE AND ECOSYSTEM SUPPORT DIVISION
OFFICE OF QUALITY ASSURANCE
ATHENS, GEORGIA 30605-2720
SEPTEMBER 1996
.. \ -
JoA~v-~ -.Approved by: *~ ~Bennett
Environmental Scientist Region IV QAO
'\
TABLE OF CONTENTS
OBJECTIVE
APPLICABILITY
PRELIMINARY REVIEW
VALIDATION DATA QUALIFIER DEFINITIONS
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
XIII.
XIV.
xv.
XVI.
XVII.
XVIII.
Data Validation Documentation
Holdjng Times
Mass Res olution Check
GC Column Perforrnance Check (Window Defining Mix)
Init i al Calibration
Continuing Calibration
Method Blank Analysis
Perfonnance Evaluation Samples
Matrjx Sp ike/Matrix Spike Duplicate (MS/MSD) Analysis
Du p lj c ate Sample Analysis
Target Compound Identification Criteria
Compound Ouantitation and Reported Detection Limits
Dilut i ons
Reanalyses
Second Column Confirmation
Internal Standard Recoveries
Toxicity Equivalency Factor
Overall Assessment of Data
PCDD/PCDF Validation SOP
Rev. #: o
Date: September 1996
Page 7 of 34
VALIDATION DATA QUALIFIER DEFINITIONS
The following definitions provide brief explanations of the
qualifiers assigned to results in the data validation process.
J The analyte was positively identified; the associated
numerical value is the estimated concentration of the
analyte in the sample.
R · The sample results are rejected due to serious
deficiencies in the ability to analyze the sample and
meet quality control criteria. The presence or absence
of the analyte cannot be verified.
U Not detected above the Detection Limit (DL).
PCDD/PCDF Validation SOP
Rev. #: O
Date: September 1996
Page 18 of 34
VII. METHOD BLANK ANALYSIS
A method blank should be extracted with each batch of
samples. The matrix for the method blank should be similar
to the associated samples.
Criteria:
1. The method blank should be analyzed on each DB-5 column
instrument used to analyze the associated samples. In
addition, a blank must be analyzed each 12-hour shift,
after the analysis of the continuing calibration and
prior to the analysis of the samples. This blank may
be the associated method blank, a method blank
associated with a different batch, or a system blank.
The use of instrument blanks is acceptable for DB-225
column analyses.
2. Laboratory method blanks should not contain any
2,3,7,8-substituted PCDD/PCDF in amounts greater than
the concentration of the lowest calibration standard.
Non 2,3,7,8-substituted compounds or other potentially
interfering compounds should not be present in amounts
greater than the concentration of the lowest
calibration standard, assuming a response factor of 1.
Action:
1. If the appropriate blanks were not analyzed with the
frequency described above, then ·the data reviewer
should use professional judgement to determine if the
associated sample data should be qualified. The
reviewer may need to obtain additional information from
the laboratory.
2. If a target compound is found in a blank but not found
in the sample, no action is taken. If the contaminants
found are interfering non-target compounds at
significant concentrations, then this should be noted
in the report narrative.
3. Action in the case of blank contamination depends on
the circumstances and origin of the blank.
Qualification should be based upon comparison with the
associated blank having the highest concentration of a
contaminant. Associated blanks include the extraction
method blanks, the 12-hour shift blank(s) and the
Region IV blind blank. Field and equipment blanks are
PCDD/PCDF Validation SOP
Rev.#: O
Date: September 1996
Page 19 of 34
not used for data qualification.
Any compound detected in the sample that was also
detected in any associated blank is not reported if the
sample concentration is less than ten times (10x) the
blank concentration. Typically, the quantitation limit
is raised to the concentration found in the sample.
If the compound is present in the sample in an amount
less than the detection limit (DL), then the DL should
be reported with the U flag. If the compound is
present in the sample in an amount greater than the DL
but less than 100, report the next highest amount,
using one significant figure, with the U flag. If the
compound is present in the sample in an amount greater
than the DL and greater than 100, report the next
highest amount, using two significant figures, with the
U flag.
If use of the lOX rule causes elevated detection limits
to be reported for any congeners, apply the MB"
qualifier to these congeners. The B qualifier flag is
to be applied to these congeners on the internal Form I
only. The B qualifier is not to be reported on the
final Data Report Sheet.
Additionally, there may be instances where little or no
contamination was present in the associated blanks, but
qualification of the sample was deemed necessary.
Professional judgement should be used in these
situations. An explanation of the rationale used for
this determination should be provided in the review
narrative.
4. If gross contamination exists (i.e., saturated peaks),
all affected compounds in the associated samples should
be considered to be unusable (R flag), due to
interference. This is a contract issue and should be
regarded as an action item.
5. If an instrument blank was not analyzed following a
sample analysis which contained an analyte(s) at high
concentration(s), sample analysis results after the
high concentration sample must be evaluated for
carryover. Professional judgement should be used to
determine if instrument cross-contamination has
affected any positive compound identification(s).
PCDD/PCDF Validation SOP
Rev. #: O
Date: September 1996
Page 20 of 34
6. Blanks or samples run after a Region IV blind spike,
matrix spike or standard should be carefully examined
to determine the occurrence of instrument or syringe
carry-over. Since the efficiency of sample transfer
can vary dramatically according to apparatus and
operator techniques, professional judgment should be
used in each case to determine whether sample or blank
results are attributable to carry-over. Professional
judgement should be used to determine if blank results
which are possible artifacts of carry-over should be
used in determining contamination.
7. When there is convincing evidence that contamination is
restricted to a particular instrument, matrix, or
concentration level, professional judgement should be
used to determine if the lOX rule should only be
applied to compare contaminated blanks to certain
associated samples (as opposed to all samples in the
case).
Landfill Soils Sample lnfonnatton Code-> JABT-Re JABB-Re JABP-Re NIAT-Re NIAB NIAP-Re OMA SLB+ POND AB POND LB+POND PJO ADD Sample Location-> North Borino North Borino North Borina South Borino South Boring South Boring SEEP 3 2 1 Sand Filter Carbon Filter Deoth-> Top Middle Bottom Top Middle Bottom Matrix-> Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Carbon Dioxins & Furans (ng/Kg) 2,3 7 8-TCDD 1 2 3 4 6 7,8-HpCDD 20.8 79.38 14.53 609 2.11 20.89 1 08 1.77 1 53 1.71 3.08 0.453 OCDD 788.85 1657.17 248.94 218.65 76 84 696.97 47 03 83.446 86 27 31 23 52.6 5.994 2 3 7 8-TCDF 27.41-52.3 2305---1 2 3 7 8-PeCDF 14.72 18.94 2 3 4 7 8-PeCDF 11.01 29.88 59.56 26.02 1 2 3 4 7 8-HXCDF 153.47 166.51 26.21 623.16 1 06 366.42 --0.28 1 2 3 6 7 8-HXCDF 28.53 24.77 52 47 0 37 49 1 1 2 3 7 8 9-HXCDF . -33.1 2 3 4 6 7,8-HXCDF . 41.11 123 4 6,7 8-HoCDF 165.99 189.71 25.19 597.78 1.02 444.67 0358 0.3 0.5 0.92 0.516 123 4 7 8 9-HpCDF 90 52.51 10.33 428.65 199.95 OCDF 693.44 469.35 75.47 2894.22 2.29 1414.42 0.276 0.43 1.53 2.6 0.362 Comments Reanatvsis Reanatvsis Reanalvsis Reanal\l!Sis QCQK? Reanatvsls :x OK QCOK? QCOK? OCOK? QCOK? QCOK? QCOK? QCOK? QCOK? QCOK? QCOK? "'Cid nol confirm .. Old nol confirm 51.mlgoles OU both arelyses PCBs rua/al Aroclor 1260 44.1 90.3 60.7 267.8 385.7 150.5 ND ND ND ND ND ND Comments Bias Noted Bias Noted Bias Noted Bias Noted Bias Noted Bias Noted Pests & Herbs (ug/g) ND ND ND BNA's lua/Kal ND 1 4-dichlorobenzene 1967 -Phenanthrene 1000 -67 Anthracene -467 Fluoranthene 1067 9000 3233 1800 t-'Vfene 800 6433 3467 -1833 Benz !al anthracene -12333 6167 Chrvsene 6600 3800 Benzo (b) nuoranthen 5833 1800 Lab ID Number 970996 970997 970998 970999 971000 971001 971412 970967 970970 Comments PCBs+ PCBs+ PCBs+ PCBs+ PCBs+ PCBs+ ND ND voes (ullfl\al Lab ID Number 970972 970973 ND ND -Barium (mg/Kg) 69 35 46 Chromium {mQl1<o) 9.8 TCLP Barium /mall l 0 86 0.56 0.34 Page 1
Landfill Leachate Sample Information Code-> QAR+ EZM NOV Sample Location-> North Well (Inlet) Outlet South Well Matrix-> Water Water Water Dioxin• & Furans (oa/L) 2,3,7,8-TCDD ---1,2,3,4,6,7,8-HpCDD 84.84 6.485 9.42 OCDD 1407.17 41.02 540.74 2,3,7,8-TCDF -- -1,2,3,7,8-PeCDF ---2,3,4,7,8-PeCDF --3.72 1,2,3,4, 7,8-HxCDF 68.21 -75.21 1,2,3,6, 7,8-HxCDF --11.74 1,2,3,7,8,9-HxCDF -- -2,3,4,6,7,8-HxCDF ---1,2,3,4,6,7,8-HpCDF 65.99 -77.97 1,2,3,4, 7,8,9-HpCDF 28.99 -40.48 OCDF 264.53 3.55 387.68 Comments Reanalysis QCOK? QCOK? QCOK? PCBs (mg/L) Aroclor 1260 0.006 ND 0.0006 Comments Peats & Herbs (mg/L) ND ND ND BNA's(uwt.l Lab ID Number 970978 970981 970077 1,4-Dichlorobenzene ND ND 26 voca (ug/L) Lab ID Number 970985 970083 970984 Acetone 46 3 8 2-Butanone --24 Chlorobenzene --30 1,4-Dichlorobenzene --21 See comment See comment Metals Barium (mg/L) 0.28 0.03 0.28 Chromium_(mg/L) -- -Lead 0.05 -0.05 Page2
Grol.n<twotor Sam ?le Information C:0-.> BB JOH ALB RPAB RBAB+ RPF Jrr,N CEH PSG JOK MMM BT cc /WJ/JDA RDRJ RA.JR "'! ASH DIIKOSW-2 RRAMOSW◄ •RPS o..uu-sa-locatl~> MW-1 MN-1A MW-2 MW-3AIDl MW-3S MW-◄ MW-4A MW-5S MW-SD MW-6 r.N/-7S MW-7D MW-6 MW-9 MW-105 MW-100 MW-11 MIN-12 -on-BG O'NN~BG Davl•BG Motrtx-> --Wotw Wot• -Water Water Wat• W■ter Water Wotw Watw Water Water Water Waler Water -Water Wot• Wot• Water Dlo-& ,.,,_ Inn/LI 2 3 7 &-TCDD 24.05-1 2 3 7 &-PoCDD 5.99 1.2 3,◄ 7 &-H>cCDO 10.72 1 2 3,8 7 &-H>cCOO 3◄.35 1.2.3 7,8 ~H>cCDO 27.3◄ 123487&--oo 8.77 10◄1.2 2.87 10.13 3.115 4.07 3.88 4.59 2.13 3.2 7.52 10.38 4.115 4.52 7.49 ◄.03 OCOD 47."9 10053.3 21.82 97.75 18.23 21.11 21.51 16.89 31.6◄ 18.09 14.06 17.64 99.02 87.53 18.82 3048 5◄.2e 13.09 29.38 19.83 38.99 2 3 7 &-TCDF 1.2.3 7 &-PeCOF 2 3 4 7,&-PeCOF 1.2.3 4 7 IHl>cCDF 29.18 1 2 3 8 7 &-H>cCDF 7.27 12378~DF 2 34 8 7 &-H>cCDF 1.2.3 4,8,7 &-.-;OF 3.29 198.9 2.13 1.88 1.53 3.85 4.12 3.0◄ 2 2.88 3.47 2.3◄ 123◄78~HDCOF 10.44 OCOF 4.35 82e.83 8.38 7.7◄ 5.85 COlrlMf'II -R-ed as EMPC lince al QC aitert■ for Dmll:ive ldentttlcatlon nol: mat. EMPC= Eltln-.t.ct Mulrru,, Pc1Wttt1l Concfflratlon .-cae Iman.I NO NO ND NO NO NO NO NO NO NO ND NO NO NONO NO NO NO NO ND NO 1 c-■ sa--■behd Ccud not locate RAM l'eteall-larbs1n..-L NO ND ND NO NO ND NO NO NO NO ND NO NO NOH) NO NO NO ND NO ND 1 ~•atua,u LllblD_, 971387 971389 9713111 971383 9713115 971397 971399 971401 971403 971405 971406 971407 97140◄ 971402 971408 971398 971398 9713g◄ 9713112 971300 1 ND ND ND ND NO NO ND ND ND ND ND ND ND 971400 NO ND ND NO ND NO 1 eon-n-1 TIC TIC TIC TIC TIC NOffl) TIC voe, .. _, LllblD-971443 971445 971447 971449 971451 971453 971455 971457 971459 971481 971482 971483 97141!() 971458 971-971454 971452 971450 971448 971◄◄8 ND ND ND NO NO ND NO ND ND Data Doto ND ND 971458 ND NO ND ND ND ND COlrlMf'I Law Lewi of Acetone In .,,,_ of the ..... -TIC tne-• -· NONO .... e.rl'""'"""LI 0.06 0.07 0.06 o.ou 0.06 0.06 0.0◄ 0.1 0.11 0.06 0.09 0.06 0.06 0.06 0.05 0.03 0.08 0.07 0.07 -um•~ 0.01 0.01 P■ge3
Field QA.QC Samplelnfonnation Code-> ADF MB JEN CBT KTB TB CAN AW JO Sample Location-> Blank Blank Trip Blanl Blank Blank Blank Trip Blank Blank Blank Comments Equip. Rinsate Drilling Water Day One Equip. Rinsate Soil Equip. Rinsate Sub-Pump Rinse One-Shipment 4/9 Sub-Pump Rinse Bailer Saml>lina Blank Matrix-> Water Water Water Water Water Water Water Water Water Dioxins & Furans (Dalli 2,3,7,8-TCDD ----1,2,3,7,8-PeCDD -------1,2,3,4,7,8-HxCDD -. . . . --1,2,3,6,7,8-HxCDD -. . -. --1,2,3,7,8,9-HxCOO -. . -. -. 1,2,3,4,6,7,8-HoCOD 3.05 6.13 . 4.82 11.37 18.57 4.52 OCDD 20.43 39.62 10.7 25.56 357.64 150.06 41.69 2,3,7,8-TCDF . . -. . -. 1,2,3,7,8-PeCDF -. . . . . 2,3,4,7,8-P.CDF . . . . --. 1,2,3,4,7,8-HxCDF -. -. . . -1,2,3,6,7,8-HxCDF -. . . . . -1,2,3,7,8,9-HxCDF -. . . . --2,3,4,8,7,8-HxCDF --. . -. -1,2,3,4,6,7,8-Hp(;OF 1.9 . . 2.48 2.89 5.77 . 1,2,3,4,7,8,9-HoCOF -. -. -. -OCDF . . . 2.46 30.91 9.05 . Comments PCB1(mg/L) ND ND ND ND ND ND ND Comments Pests Ima/LI ND ND ND ND NO ND Herbs (mg/\.) ND ND ND ND ND BNA's (ug/L) ND ND ND ND ND Lab ID Number 970994 971383 971384 971385 971388 Comment VOCs IUGl'LI ND ND ND Toluene 97 . -. . -Xylenes 12 . . ---Acetone 97 --23 79 -2-Sutanone 43 ---7 . Lab ID Number 970995 970884 971439 971440 971465 971441 971442 Comment Metals Barium (mall) 0.05 0.02 -0.04 . Chromium (mall) -. . . -Page4
Stream Sec11ment ,, Sample Information Code-> BHB CB MS MR AR+ NCB SD PJR CD Sample Location-> Sed. 1 Sed. 2 Sed. 3 Sed. 4 Sed. 5 Sed. 6 Sed. 7 RCUS RCUS -Comment Near 1st Occurrence South Confluence Above Bridge Below Bridge Matrix-> Soil/Sed. Soil/Sed. Soil/Sed. Sed. Sed. Sed. Sed. Sed. Sed. Dioxins & Furans (ng/Kg) 2,3,7,8-TCDD ---------1,2,3, 7,8-PeCDD ---------1,2,3,4, 7,8-HxCDD ---------1,2,3,6, 7,8-HxCDD ---------1,2,3,7,8,9-HxCDD ---------1,2,3,4,6, 7,8-HpCDD 2.22 2.35 1.36 0.92 2.73 1.81 2.65 1.2 2.29 OCDD 26.34 125.4 69.56 34.95 137.46 62.33 54.51 45.26 124.56 2,3,7,8-TCDF -1,2,3, 7,8-PeCDF ---------2,3,4, 7,8-PeCDF ---------1,2,3,4, 7,8-HxCDF ---------1,2,3,6, 7,8-HxCDF ---------1,2,3, 7,8,9-HxCDF ---------2,3,4,6, 7,8-HxCDF ---------1,2,3,4,6, 7,8-HpCDF -0.42 0.27 --0.23 0.43 0.24 0.28 1,2,3,4, 7,8,9-HpCDF ---------OCDF ------0.55 --Comments PCBs (ug/g) ND ND ND ND ND ND ND ND ND Comments Page 5
Surface Soil Sample lnfonnation Code-> BJ RB SB MBR BR Sample Location-> SurS-1 SurS-2 SurS-3 SurS-4 SurS-5 Matrix-> Soil Soil Soil Soil Soil PCBs (ug/g) ND ND ND ND ND Page6
Background Surface Soils Sample Information Code-> TMSS LESS HESS Sample Location-> OSW-3 OSW-2 OSW-4 Matrix-> Surface Soil Surface Soil Surface Soil ---•-Dioxins & Furans (ng/Kg) 2,3,7,8-TCDD ---1,2,3,4,6, 7,8-HpCDD 4.59 1.66 2.16 OCDD 546.1 244.9 432.6 2,3,7,8-TCDF ---1,2,3,7,8-PeCDF ---2,3,4,7,8-PeCDF ---1,2,3,4,7,8-HxCDF ---1,2,3,6,7,8-HxCDF ---1,2,3, 7,8,9-HxCDF ---2,3,4,6,7,8-HxCDF -------1,2,3,4,6, 7,8-HpCDF ---1,2,3,4,7,8,9-HpCDF ---OCDF ---Comments PCBs (ug/g) ND ND ND Aroclor 1260 ---Comments Pests & Herbs (ug/g) ND ND ND BNA's (ug/Kg) ND ND ND Lab ID Number 971409 971410 971411 Metals Barium (mg/Kg) 86 33 37 Chromium (mg/Kg) 22 20 20 Lead (mg/Kg) 20 -9.8 TCLP Barium (mg/L) 0.63 0.75 072 Page 7
Surface \Nater t, Sample Information Code-> RSB KB 1MB ISB DA CA DJ+ Sample Location-> SW-1 UTDS UTUS RCDS RCUS RCUS SW-2 Comment Due South of MW-6 Above Below Matrix-> Water Water Water Water Water Water Water Dioxins & Furans (pg/L) 2,3,7,8-TCDD -------1,2,3,7,8-PeCDD -------1,2,3,4, 7,8-HxCDD -------1,2,3,6,7,8-HxCDD -------1,2,3,7,8,9-HxCDD -------1,2,3,4,6, 7 ,8-HpCDD -3.31 -----OCDD 22.3 56.33 43.8 49.04 51.75 51.95 24.14 2,3,7,8-TCDF -------1,2,3, 7,8-PeCDF -------2,3,4,7,8-PeCDF -------1,2,3,4, 7,8-HxCDF -------1,2,3,6,7,8-HxCDF -------1,2,3,7,8,9-HxCDF -------2,3,4,6,7,8-HxCDF -------1,2,3,4,6,7,8-HpCDF -------1,2,3,4,7,8,9-HpCDF -------OCDF -------Comments PCBs (mg/L) ND ND ND ND ND ND ND Comments Page 8
Well Boring Soils Sample Information Code-> PMB HM WM KM OM MM TM OSW-3 LE OSW-2 HE OSW-4 Sample Location-> Davis-BG MW-7 MW-11 MW-1 MW-12 MW-5 Davis-BG Alston-BG O'Neal-BG Comment @Water Table @ Water Table @ Water Table @Water Table @ Water Table @ Water Table @ Water Table @ Water Table @ Water Table Matrix-> Soil Soil Soil Soil Soil Soil Soil Soil Soil Dioxins & Furans (ng/Kg) 2,3,7,8-TCDD ------1,2,3,4,6,7,8-HpCDD 0.57 -0.3 ---OCDD 24.15 1.8 1.02 1.39 2.65 2.64 2,3,7,8-TCDF ------1,2,3,7,8-PeCDF ------2,3,4,7,8-PeCDF ------1,2,3,4,7,8-HxCDF ------1,2,3,6, 7,8-HxCDF ------1,2,3,7,8,9-HxCDF ------2,3,4,6,7,8-HxCDF ------1,2,3,4,6,7,8-HpCDF 0.19 -0.24 0.22 --1,2,3,4,7,8,9-HpCDF ------OCDF ---0.25 --Comments No Data Found No Data Found No Data Found PCBs (ug/g) ND ND ND ND ND ND Aroclor 1260 Comments Pests & Herbs (ug/g) ND ND ND ND ND BNA's (ua,Kg) ND ND ND ND ND Lab ID Number 970986 97089 970987 970988 970992 Metals Barium (mg/Kg) 240 150 250 170 130 Chromium (mg/Kg) 20 22 18 --Lead (mg/Kg) -----TCLP Barium (mg/L) 1.63 1.88 1.39 1.46 1.3 Page 9
Chart Leachate vs. QC Samples Landfill Leachate vs. Field QC Samples 90 -----------------------------------------80 70 60 0 0 0 a. 50 Ji= 00 ....: vi ~ 40 c,; "4 .... 30 20 10 0 84.84 1 2 3 0 4 5 6 X Page 10 Columns 4-10 are Field QC Samples 7 8 9 10 (. l■Series1 I
Contamination Matrix Landfill Leachates Field QA/QC Samples Dioxins & Furans (pg/L) I 1,2,3,4,6,7,8-HpCDD 84.84 6.485 9.42 3.05 6.13 -4.82 11.37 18.57 4.52 OCDD 1407.17 41.02 540.74 20.43 39.62 10.7 25.56 357.64 150.06 41.69 2,3,4,7,8-PeCDF - -3.72 1,2,3,4,7,8-HxCDF 68.21 -75.21 1,2,3,6,7,8-HxCDF --11.74 1,2,3,4,6,7,8-HpCDF 65.99 -77.97 1.9 - -2.48 2.89 5.77 -1,2,3,4, 7,8,9-HpCDF 28.99 -40.48 OCDF 264.53 3.55 387.68 ---2.46 30.91 9.05 -PCBs (mg/L) Aroclor 1260 0.006 ND 0.0006 1 ,4-Dichlorobenzene ND ND 26 voes (ug/L) Acetone 46 3 8 97 --23 79 -2-Butanone - -24 -7 Chlorobenzene --30 1,4-Dichlorobenzene --21 Toluene 97 - -- - -Xylenes 12 --- --Page 11
3-01 -1 997 HJ 02PM FROM
COMPARATIVE EVALUATION OF THE TWO PHASE I
REPORTS ON DETOXIFICATION TECHNOLOGY TESTING
OF MATERIALS FROM THEW ARREN COUNTY, NORTH
CAROLINA PCB LANDFILL
Prepared by:
Joel S. Hirschhoro, Ph.D., Hirschhotn & Associates
in association with
Patrick A Barnes, P.G., BFA Environmental, Inc.
October 1, 1997
1.0 Introduction
In response to a Request for Proposals to evaluate treatment technologies on soils
extracted from the PCB Landfill. Warren County, North Carolina, issued by the Division of Waste
Management ofDENR on January 31, 1997, two proposals were selected for funding. The Rfp
had clearly identified two detoxification technologies as meeting the requirements established by
the Joint State/Warren County Working Group; these were Base Catalyzed Dechlorination (BCD)
and Gas Phase Chemical Reduction. The RFP notified potential proposers that the J>rnject was
divided into two phases and that nmltiple companies might be chosen for Phase I, but that only
one compsmy would _be awarded a contract for Phase U.
Section 2.1.4 of the RFP specified the following selection c1iteria for choosing one
company for the Phase Il part of the RFP:
a. The ability to meet Phase I performance criteria as demonstrated through Phase I
test data. The performance criteria were presented in Section 2.5 oftbe RFP. For post-
treatment solids the Principal Preliminary Remediation Goals ,vere 20 ppb for total PCBs
and I ppt for Dioxin TEQ. The Air Emission Performance Goals were 8x10-1 J.nicrograms
per cubic meter (ug/cm) for PCBs and 5xto•K ug/cm for Dioxin TEQ.
b. The quality of the Phase I test repon.
c. The ability of the vendor to provide full-scale equipment at the Waneu County
PCB Landfill site.
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d. The ability of the vendor to provide a safe, reliable and cost-effective full scale
application of the selected technology at the Wa1Ten Cowity Landfill. Section 2.2 of the
RFP further clarified the goals and objectives of the testing, particularly iu tenns of
determining feasibility for full-scale deto,rification and thnt, in addition to the meeting the
performance criteria, feasibility would also be determined by considering the safety of the
technology, the rate of detoxification, the cost per unit of deto·xi:6.cation, the reduction in
long term potential for environmental releases from residuals of the treatment process.
e. The quality and cost of the proposal for providing Phase ll services.
This report by the two Science Advi~ors for the Working Group is the cODJJlarative
evaluation of the two Phase I reports submitted in this project and is provided to the Working
Group aud the Division of Waste Management for the pwpose of assisting with the selection of
the Phase ll contractor. All reports and responsc-s to questions submitted by the two companies,
ETG Environmental. Inc. (ETG) and ELI Eco Logic International Inc. (EL), have been
considered in preparing this report. The format is to present a discussion of the relative pros and
cons, or advantages and disadvantages, of each company's proposed technology for each of the
above selection criteria. Finally, a summary comparison and recommendation is presented in the
last section..
l.O l\1eeting the performance criteria
2. J Post-treatment solids -total PCBs
ETG conducted four test runs and in all four cases the total PCBs were reduced to levels
Jess than 20 ppb. The average of the four runs was 0.8 ppb. A consideration is the variation in
PCB levels in the i-oput (raw feedstock) materials, which in this case averaged 508 ppm Because
nondetects (NDs) are often reported, detection limits are also a factor jn evaluating results. In
comparing two the companies the is.we that arises is if NDs ue reported but the detection limits
(DLs) are different, then the NDs are not exactly the same. With higher DLs the NDs are less
impressive, because the potential level ofundetected PCBs is higher. Another way of looking at
this issue is to realize tb.at with lower DLs it is possible to have positive hits or findings of PCB
isomers while if higher DLs were used, then those findings would not be present.
EL conducted three test runs and reported NDs for all three results; however, the DLs
were significantly h.igh.er than in the ETG testing, primarily because smaller size samples were
used in the EL testing (i.e., 0.010 kg versus 0.030 kg for ETG). The only scientific way to b~tex
compare the two sets oftest data, therefore, is to recalculate the total PCB levels by using the
worst possible case in which it is assumed that the NDs are actually equal to the DLs. This has
been done and the recalculated levels for both companies' data are given in the follow:ing table by
using tl1e data given in the respective reports. It can be seen that by following this procedure, that
the recalculated avenge for ETG in.creases to 1.84 ppb and for EL the average changes from
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what might be interpreted as zero to 3.63 ppb. Thus, while it is correct to say that both
companies were able to meet the pe.tfonnance criterion, it is also correct to conclude that ETG
performed better than EL, particulady because ETG conducted four runs while EL presented data
for three runs. Additionally1 the average PCB level in the raw materials tested was 237 ppm for
EL but 385 ppm for ETG, ~bich makes the ETG results even more significant, because a higher
fraction of PCBs were removed.
Company/sample Original totalPCBs (ppb) Recalculated total PCBs (pph)
ETG WCl-3 .74 1.33
ETGWCl-4 2.55 3.06
ETGWC2-3 0(ND) l.80
ETGWC2-4 O(ND) 1.18
ETG average 0.8 1.84
EL 1 O(ND) 4.10
EL2 O(ND) 3.40
EL3 O(ND) 3.40
EL average O (ND) 3.63
2.2 Post-treatment solids -dioxin TEQ
ETG reported data for four IUllS, with an average dioxin TEQ of 0. 91 ppt, however one of
the runs had a value of 2. 96 ppt, but this was for the sample \\-1th the highest level of PCDs. In
fact, ETG had optimized its process based on a much lower level of chemic-al treatment {BCD)
additive, which would explain why 111. this one run both the PCB and dioxin TEQ l~vels were the
highest in the residual treated solids. In fact, the TEQs for the other three runs were exceptionally
low, with an average of about .23 ppt, which is insignificant. It sh.ou.ld also be noted tliat even the
2. 96 ppt level is very low and th.at EPA and most states have not approached this lC\·el for djox.iJ.l
cleanups. For examp.te, for the Koppers Superfund site cleanup in Morrisville, North Carolina the
dioxin clean.up level was 7,000 ppt.
EL reported data for three runs. However, the dioxin analy~e~ were redouc for nms 1 and
3, but not run 2, because of overly high detection limits in the origmal testing. Also, some dioxins
were originally found in run 2 material, despite high detection levels, because ofbjgh dioxin levels
th.at resulted from run 2 representing a process failure due to too low a temperature ;n the TR..~
desorption unit that did not allow removal of dioxin~ for chemical reduction in the second high
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temperature stage. This is discussed in length later in this report. The original TEQ values for
ruus l and 3, based on using detection limit values was reported by EL as 15 ppt and. 32 ppt,
respectively. If the value for nm 2 is included, then the average for all tb_ree runs in the original
data is very high at 142 ppt, and with the data from the retesting it is 127 ppt. The data are
summarized in the following table.
It is shown how comparable data can be used from both companies, io te.rms of either data
from all runs or only the best runs, and for EL for original and revised data. For example, tlte
average for the two best EL runs can be compared to the average of the three runs of ETG that
represented their best process perfonnance. In other words, if all test data are considered for
both companies, theo. EL clearly f.ails to meet the penormance criterion, and if only the best runs
are considered for both companies, then EL meets the c-riterion but ETG has superior
perfonnan.ce. From a community perspective, it is valid to judge the companies on the basis of all
their data, because they are responsible for suboptimal nms.
Average Dioxin TEO Levels (ppt)
TF.ST RUNS ETG ECOLOGIC ECOLOGIC
original data re\ ised data
·-
Allnms .91 142 127
· Best runs .23 24 .50
It should be noted that the average dioxin TEQ level in the raw materials for EL runs 1
and 3 (the best runs) was 186 ppt, and 175 ppt for the three best runs ofETG. Proportionally,
ETG had slightly better performance (i.e., 99.89% versus 99. 73% removal).
2.3 Air release.s -total PCBs
ETG reported data for three runs in terms of both stack discharges and modeling results
for a property liue assumed to be 200 feet from the equipment, which is a proper procedure for
addressing an exposure co.ncentration (and that had been deemed appropriate at the pre-bid
conference for the RFJ>). In fact, the performance criteria bad been established on the basis of
exposure concentrations for a very low risk level. The average of the ETG data was .87x10·4
ug/cm, or about one-tenth the performance criterion of8x1o·'ug/cm.
EL reported data for three runs in terms of stack gas concentrations only, for which the
average was l.26xl0·• ug/crn, which is below the petformance criterion at the stack, and which
automatically makes it below the criterion at any distance to an exposure point.
The ETG data fot the stack concentrations were significantly higher than for the EL data.
However, air sampling methods and equipment were not identical and, therefore, a direct
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comparison of stack data alone is not necessarily complete. The Dl8lD problem is that an air
sampling procedure that is more efficient and effective in removing material and obtaining low
detection levels will have a higher probability of detecting conta.Iilinants. for example, sampling a
larger volume of gas will increase the probability of detecting contaminants. .For example, the
stack gas flow rate in th.e ETO tests were about three times larger than in the EL testing,
suggesting a higher sensitivity in the ETG air testing. Jt must be emphasized that the performance
level set for this testing was e>..1.remely low and stringent and that the data from both cowpanies
indicates that no health hazard would be caused by PCB air emissious from the detoxificatio.n
process. Indeed, in all probab.illty there may be greater concern about potential PCB air releases
from site excavation and matelial handling piior to treatment in equipment, but 1his issue should
be addressed in the Phase Il work.
Based on available information it can be said that both companies are comparable on this
sub-criterion.
2.4 Air releases -dioxin TEQ
ETG reported stack and model data for thl'ee runs. The model data had an average of
.52xto-i< ug/c.m. about a tenth of the perfonnance criterion.
EL reported that no diox:ins/furans we(e found above detection limits, but tJ1at the highest
possible level was l.7do·~ ug/cm, which is higher than the petformance criterion. Thtrefore, EL
wd that ''Due to these sampling and analytical constraints, it is not pos!,ible to demonstrate th.e
ability of the ECO LOGIC Process to med the dioxin TEQ performance goal .. '' The highest
possible EL level is some 1000 times greater than the performance goal. However, if EL would
have modeled its data to address levels at some reasonable exposure point, then it would have
been able to show compliance, because its stack level was similar to that found by ETG.
The Science Advisors conclude that ETG has the advantage on this sub-criterion.
3.0 Quality of the Phase I report
Making a professio.naljudgment about the quality ofa technicaJ report can involve many
considerations. Certainly. tbe reports should present the information 1·equi.red in the R.FP in a
user-friendly format. Additionally, however, the quality of the repo.rt can be considered to be
higher wheJJ there is considetable attention to particu.Luly important issue> and when additio.nal
information is provided to usist the understanding and evaluation of the testing. lt must alSQ be
noted that EL submitted a draft report which was then modified in re~onse to vMious questions
and comments to produce a final report, while ETG submitted only one initial final report.
Therefore, to some extent the one submission by ETG is comparable to the second submission by
EL that corrected deficiencies in the original draft report.
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As an important example of a d.i.fference in presentation quality, consider the Tables 4-5
and 4-6 in the ETG report, which presented in easily understood tabular form the primary data 01\
treatmeDt effectiveness for PCBs and dioxins/.furans for all the test runs, and for all the individual
i~mers or congeners in each category. A reader could immediately see how the post-treatment
levels compared to the original raw material levels, and when nondects wete reported tile
detection limits were also presented. In contrast, the EL report presented the analogous data iu
two separate tables (Tables 8 and 9), and the contractor had to be instructed to provide detection
limits in the final report, and neither table presented the data for all the individual isomers or
congeners in the useful way employed by ETG.
Another factor was that ETG presented more in.formation than was strictly required. For
example, ETG presented the results of testing to show that their process bad actually destroyed
PCBs and also obtained data on particulate levels in emissions and water content in raw feed
materials.
It must also be noted that the quality of the report is merely a surrogate fur the quality of
the bench-scale testing. In this sense, it is important to note that EL conducted three runs versus
four for ETG, and that one of the EL runs (run 2) was essentially a failure because of a11 operalot
enor that caused the initial TRM desorption part of the process to function poorly due to a low
temperature that did not separate dioxins/furans for chemical reduction in. the second part of the
process. A major aspect of any type of technology testing is to see how well a company conducts
itself and operates its o~n equipment to demonstrate a very hlgh level of competence that
provides confidenc-e to potential clients that the very best performance will be obtained in full-
scale usage. The main guestion tha! mmts attention for this aspect of the EL testmg is why 1he
senior persons in charge of the test did not identify the low temperature problem dwins the_l!W.
pe.-iod and repeat the test run, This was especially important because only three runs were used
Also, iu discussing this event EL has referred to a minimum temperatnre in the TRM unit
of ssonc, but the unit is supposed to operate at 600°C according to the information in the EL
report. EL did .not provide detailed data for nm 2 on exactly what temperature was used or for
how long a suboptimal temperature existed during the run. except that the temperature dropped
to 500"C. However, it reported average mill temperatures of 595°C, 572°C, and 628"C for test
runs t. 2, and 3 respectively. It is interesting that two of the runs did not have average
temperatures of 600°C. The fact that the average temperature in run 2 was above the 550''C
minimum that EL has mentioned also raises a question of uncertainty about what actually
occurred in run 2 to so thoroughly cause no treatment of the dioxin contamination . The
information suggests that out of the total of 15 minutes in the TRM unit even a !ml.all amount of
time at suboptimal temperature is sufficien.t to cause a complete failure to remove ruoxiu
contaminants from the feed material, which is a serious sensitivity to Jow temperattue excursions.
EL also had a problem with an important part of its dioxin testing, which it blamed on the
testing laboratory. However, much of what has been said by EL simply does not hold up under
close scrutiny. Part of the competence of a co~any in the remedjation technology busjness is
P. 7
3-01-1997 10 05PM FROM
expertise for obtaining the best analytical services. If a company provides incomplete or
misleading information to a ch.emical analysis laboratory, then the laboratory may perfom1 poorly
In the EL testing, some of the most critical dioxin testing was inferior because of high detection
limits that resulted from unusually small sample sizes for the testing. EL claims that th.is resulted
from its telling the laboratory that there were high PCB levels, and that this caused the laboratory
to use lower than normal sample quantities. There are two problems, however. First , tlle overall
PCB levels in the raw materials (information given .in the RFP) were not exceptionally high for
PCBs. Second, certainly there would be no rational reason why EL would want the laboratory to
believe that PCB levels were high in their treated materials. EL also said so.methlng that any
experienced professional who deals with dioxin testing of solids knows is inconect, namely that a
target value of 1 ppt dioxin TEQ is impossible to obtain or verify for method 8290. This .is plain
wrong; as any examination oftest results for this method clearly shows, including the dioxin test
data obtained for the project's site investigation work. as well as the dioxin testing for ETG .from
the same laboratory used by EL. In the opinion of one of th.e Science Advisors, who does
considerable work with dioxin contamination and cleanup and who discussed this is.sue with both
companies, EL did not exhibit a high degree of knowledge and experience in trus area. ETO
verified that at no time did it change its instructions to the analytical laboratory that both
companies used, nor is their any logical basis for believing that actions taken for EL samples
would have affected ETG work in the very large laboratory. The one key fact th.at seems to
explain the cause of the dioxin testing problems faced by EL was the infonnatiou it provided to
the laboratory which caused them to use irregular, low sample volumes for testing.
Another issue is that EL did not clearly rqnesent what materials it tested 1elall'-e to the
materials it had received. EL wd that it received three 5-gallon buckets but that only two were
used. But no information was provided to indicate exactly what materials were tested in EL's
three runs. In contrast, ETG clearly indicated what nuteriaJs had been received and tested in each
of their four runs ..
The professional judgment of the Science Advisors is that the ETG repo1t followed the
requested format of the RFP more closely than the EL report, and that the ETG repo11 was in
general easier to follow and presented key information in a more concise manner than the EL
report. As the above discussion indicates, the conclusion is that the quality of the ETG report c\Jld
its testing was better than the EL report and its testing.
4~0 Ability to provide full-scale equipment
Both companies BJ:e in the positio11 of roob"t technology vendors, namely that ejtbe, an
existing piece of equipment could be tran~orted to the site and used, or u.ew equipment would be
constructed for the particular job. Both companies have indicated that they would need up to six
months to provide necessary equipment, which is consistent with industry practice for large
cleanup projects. But there is more to consider for this evaluation criterion. The a.bility to
provide full-scale equipment is legitimately related to the stability and viability of the company,
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because some significant investment is necessary for a large project, which this one would be
potentially. ETG is actually part of a business that is well established commercially and quite
substantial financially, and it has performed in similar remediation appJicatious for U. S clients
over some years.
Interestingly, in the BCD treatment technology aren.a, wh.ich. is based on compan.ies
obtaining licenses from EPA, .ETG has outlasted other companies. In contrast, EL is more of a
sta1t-up technology developer that has had few clients (and none in the U.S. for actual full scale
work) and is not the same level of a stable, .financially successful company with a lo.ng commercial
track record as ETG. There may also be some significance to the &ct that ETG is a U.S.
company located nmch closer to North Carolin.a, while EL is a more distant Canadian company.
It is also of some relevance that a very recent study for a major federal Superfund sit~ at which
dioxin is a major. contaminant (the Escambia Treating Company site in Pensacola, Fl.orida)
examined potential treatment technologies, and the EPA contractor doing the Remedial
Investigation/Feasibility Study screened out EL and its technology at the earliest stage of
technology evaluation, but included BCD treatment and cited ETG as the source of the BCD
technology. While EL has performed treatability and demonstration tests in the U.S. it has not yet
secured any actual remediation project. In contrast, ETG is the vendor cleaning up the South em
Maryland Wood Treatment Superfund site, where it will treat some 145,000 tons of material.
This job is closer to the W men County project than any work that EL has perfonned.
The Science Advisors conclude that overall the ability to provide necessary full-scale
equipment for the Warren County project is better for ETG than for EL.
5.0 Safety, reliability, cost, and long term releases
5.1 · Safety
There are two major ways to look at the safety issue. First, the intrinsic nature of the
technology can be assessed in terms ofinher~t ha:urds. For example, any process that utmzcs
hazardous materials is fundamentally more hazardous than one that does not use any hazardous
material~, and one that operates at either higher pressure or temperature than another one poses
more potentia.1 for unsafe situations.
The second approach is to c-onsider how vulnerable a process is to human error, because
most ~unsafe conditions and accidents relate to human error. Some technologies are inherently
safer because they are much simpler than other technologjes, for example. As for treafa.b.ility 01
demonstration testing, it is presumed that a company will logically use its best trained aod
qualified personnel. If human errors occur in testing, it does not portend well for full-scale
company operations.
ETG technology operates at a lower temperature than the EL p.rocess, roughly about
8
P .9
rKUM
onehalflower temperature. The ETG process also operates under vacuum conditions, while the
EL process operates at ambient pressure, and this reduces the potential for system leaks and
discharges of contaminants into the environment. The EL technology uses hydrogen gas, which is
intrinsically hazardous, while the ETG technoJogy uses no hazardous materials, vi.1th the exception
of sodium hydroxide which is corrosive but not ~mbustible or toxic. The EL process also
utilizes a bath of molten tin, which raises a safety concern.
Although EL has made a good argument that industrial processes have used hydrogen
very successfully, there is still an inherent hazard that cannot be entirely dismissed, especially
when one recognizes that safety issues generally are centered on unusual, uninte.oded and
unforseen incidents or accidents .. While process control instru.m.en.tation and monitoring
equipment may be u&ed, the problem in the real-world are low probability events that consist of
several things going wrong to create an actual problem. For example, for everyone of the nine
factors that EL has cited to assure the safety of using hydrogen it is possible to identify a
condition that nullifies the &.ctor. For example, EL says that no open flames or smoking are
permitted onsite, but any experienced professional has probably seen just such human beh.avior \)0
actual industrial sties where the prolul>itions exist. Similarly, leak proof process "essefa in the
field can be rendered unsafe by, for example, a bullet piercing a piece of onsite equipment. The
use of nitrogen purging to avoid mbcing with oxygen can fail when someone uses a ·wrou.g gas
tank or makes a wrong connection.
On the issue of human error, it is. also relevant that in the bench-scale testing for this
project, there was a clear, admitted case of human error in the EL test, ·when a temperature was
not properly controlled in run 2 in the TRM unit. EL also acknowledged a second "operator
error'' when th.e excess gas burner that was supposed to be operated at 800°C was actually
operated between 300 to 400°C, apparently for all the runs. The company also had ·problems with
equipment, including a micro-GC instrument that was supposed to be used but was not
operational, and a broken mill shaft which happened twice and caused delays.
Another safety issue is the potential for the air pollution control system to function
effectively to prevent wiacceptable discharges of hazardous substanc.es. In this regard, the ETG
report paid considerable attention to this issue and provided extensive discussion of how the
company would employ the most sophisticated technology to collect and treat dust.
The Science Advisors conclude. that, assuming that either cotnpany would empf oy the best
industrial safety practices in design and operation of their equipment, the ETG technology has atl
advantage over the EL process.
5. 2 Reliability
Re)jabUity can mean many different things, but one key engineering concept is whether a
process technology will offer the best performance under varying field and raw material
9
3-01-1997 10:08PM FROM
conditions. In other words, some technologies are more sensitive or vulnerable to variations in
key conditions or parameters and become less reliable because there are upsets created. Son'.le
technologies are very complex: with multiple steps or stages and the need for very complex
process control and monitoring equipment. All of these issues can reduce reliability. The use of
computers and sophisticated equipment has not e]iminated major problems in industrial processes.
An issue of concern in the current project is the degree to which the detoxificatio.u technology
may become unreliable because of high water content in feed materials, for example. To some
degree it seems as if the EL process would be less sensitive to water content, but in fact a dose
examination of discussions of this topic by the contractors reveals essentially the same prnblem.
That is, both processes can handle higher moisture levels, but both would be negatively impacted
in terms of throughput, efficiency and processing time. Moreover, ETG actually measure,d water
content and concluded .that no dewateting of materials will be required.
An important fea.ture of the ETG process is that there is solid phase BCD treatment of
PCBs and dioxins in the thermal desorption part of the process and then more BCD liquid phase
treatment of oily condensate, if necessary. Their test results showed that the solid phase
detoxification was successful. In contrast, in the EL process there is no detoxification of PCBs
and dioxins in the first stage thennal desorption unit, and detoxification is dependent on first
separating the contaminants into a vapor phase that then undergoes high temperature reduction.
As the testing showed, the EL process was vulnerable to poor performance wb.en the thermal
desorption stage was not operated at optimal conditions and, therefore, dioxins were not
detoxified.
It is the op in.ion of the Science Ad\'lSors tha,t the ETG process is intrinsically simpler and
less prone to problems created during full-scale use that would reduce reliability.
5.3 Cost
EL has said that it foresees a cost of $300 to $350 per ton, \,ased on processing 100 to
200 tons per day with a 70 to 80% availability, leading to a project duration of 90 to 123 weeks.
The availabiJity rauge used by EL is not impressive and may indicate its experience in actual
projects where there has been significant down time. This cost does NOT include ce1tain
acti\i.ties, such as excavation, performance testing or disposal of processed solids, but it DOES
include system mobilization and commissioning, all waste preparation. and processing, lab costs
for process outputs analysis and system demobilization.
ETG has said that its estimate of$390 per ton pertains to a processing rate of 300 to 400
tons per day with 100% availability. ETG's cost is all inclusive and includes excavatio11. and
backfilling of soil, which the EL estiin.1te did not. ETG has also indicated that if less stringent
cleanup performance standards were used, then the cost could be decreased by some 35% if more
typical criteria were used for PCBs and dioxins. In fact, it is highly probable that the state would
use its normal cleanup criteria and that the ETG cost would likely be less than $300 per tou. It
10
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3-01-1997 10:08PM FROM
should be n.oted that there is less intrinsic capability to reduce operating costs in th~ EL proce.ss,
as compared to the ETG process, and that EL did not offer a similar obseivation. Note that the
processing rate for ETG is about twice as .high as the EL figure, meaning that total project
duration might well be reduced by 50% and require about one year rather than two years.
The Science Advisors conclude that for cost and cost-effectiveness the ETG nrocess is ..
superior to that of EL.
5. 4. Long term rele~ses from residuals
Any detoxification technology will create certain t}'J)CS ofresiduaL, byproducts or waste
effluents that might pose longer term risks because of releases. Both companies hav~~ paid
sufficient attention to this issue and provided similar discussions about the safe and effective
handling of all process residuals and wastestreams, and neither has an advantage. The more
confidence there is in the company's ability to rednce residual levels of PCBs and dioxins to tht!
lowest possible levels, then there is minimal concern about long tenn releases from post-treatment
residuals replaced on the landfill site.
6.0 Quality and cost of Phase Il proposal
The initial proposals that responded to the RFP included a proposal for the Phase II work.
For the most part, both companies submitted comparable proposals that addressed the
requirements of the RFP. Both companies teamed with large, expeiienced environmental
engineering firms for the Phase II \vork. However, the cost of the ETG Phase n work wa!l
significantly less at $89,000, while EL proposed a cost of $115,000.
The Science Ad,isors conclude that ETG offers a significant cost advantage for the Pha~e
n work, especially in light of currently limited funding for all aspects of the current project. 111at
is, the saving of$2S,000 offers the potential ofbei11g able to accomplish other fimctions and n~eds
prior to the state legislature authorizing funds for the full detoxification of the landfill.
7.0 Summal'y comparison and recommendation
The following table presents a simplified summary of the conclusions reac.:hed for the
individual evaluation criteria. Rather than using an artificial a.nd subjective numerical rating
system, the Science Advisors have indicated a net advantage .in tenns of a + sigt, for the company
with the best capability. When both companies were comparable, both received a +.
11
3-01-1997 10:09PM FROM
.......
SELECTION CRITERION ETG ECOLOGIC
Performance
solids -PCBs +
solids • dioxin TEQ +
air-PCBs + +
air -dioxin TEQ +
Quality of Phase I report +
Ability to provide full-scale equipment +
Safety, reliability, cost, long term effects ++++ +
Phase II proposal, quality and cost +
As can be seen from the table, m most categories ETG was judged to have an advantage.
This is not to say or imply that Eco Logic and its technology was inferior, poor or· completely
unacceptable, but only tl1at, m this particular testing and for this specific applicatio.n., ETG has a
number of advantages, as presented in the previous discussions. On the basis of visiting the te.;t
sites, having discussions with company personnei and examining the reports, the Science
Advisors agreed that ETG seems a more engineering oriented company, while EL seems more
R&D or science oriented, with less of a practical, engineering constructio.n focus.
Also, a close examination of all documents provided by EL .indicated the follo\\->:ittg ( l) the
c,ompany probably has not met the stringent dioxin cleanup criteria used in this project in previous
projects; (2) the September 1994 EPA report on the thermal desorption unit found that it "did not
perform to design specifications" and that the company "experienced material handling probJems;"
and (3) the company does not seem to have been able to pe1foTU1 commercial projects at a profit
aud may be experiencing uncertain financial conditions. On the latter po.int, the last two annual
reports from EL indicate that the company has continued to be unprofitable, despite rising
revenues, while the information supplied by ETG indicates a medium si.ze environmental services
company that .is profitable. For example, the highest revenue stream for EL in 1996 was less tl1an
$5 million annually (for which the annual loss was nearly $12 million), while the company that
ETG is a division of grosses about $SO million and is profitable.
In conclusion, the Science Advisors agree that ETG is the best. qualified compan}'
for receiving the Phase II contract and advise the Working Group to accept this selection
and to formally communicate its recommendation to the Division of Waste Management.
12
P . 13
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'I
,·u-CHAJM :
Fax :91•9-.257-11):11:1
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
7 20 RIDGEWAY STREET
WARRENTON , N .C . 27589
PMOHE 9 I Q-257-1948 -FAX Q 19-25 7-1000
/XJUJJ! 1$. •rm. nLl
KJ:.~'1( r LANCASTJ!II
FAX COVER SHEET
TO ·
FROM :
DATE:
Mike Kelly
Doris Fleetwood, Secretarv
PCB Working Group ·
October 1, 1997
Number of pages (including cover sheet): 13
9]9-71 5-3605
t"-I I '
COMPARATIVE EVALUATION OF THE TWO PRASE I
REPORTS ON DETOXIFICATIOSTECBNOLOGY TESTIXG
OF MATERIALS FROM THE WARREN COlJNTY, NORTH
CAROLINA PCB LANDFILL
Prepared by:
Joel S ftirschhoro , Ph.D , Hirschhom & Associates
in Lssociation Vt.ith
Pat.rick A Bunes, PG., BFA F.nvironmental, Inc
October 1, 1997
1. 0 Introduction
In respoose to a Request for Propows to evaluate treatment technologies on soiJs
eX1racted &om the PCB Landfill. Warren County, North Carolin.a , issued by the Divi5ion of V. aste
Management ofDENR on January 31 , I 997, two proposals were .;elected for funding. Th~ Rf P
had clearly identifi~ two d@toxification ttchnologies as meeting the requ.iremellts e~ablished °ti~
the Joint State.M'arrcc County Working Group: thes.e were Base Catalyzed Ded1loririat1◊n (B CD)
a.ud Gas Phase Chemical Reduction. The llFP notin~d potential proposers that the p, 01ect wa ;
di\.ided into two pha.i;es and that muhiple companies might be chosen for Phase I. but that onh
oue cornpllly would be awarded a contract for Phase D.
Section 2. l . 4 of the RfP specified the following selection c1iteria for choosing one
i.:ompany for th~ Phase D part of the RFP:
a. The ability to meet Phase I performance criteria as dem011strated through Pha3e I
te~ data. The pcrfonnance criteria were pre~t~d in S~on 2. ~ of th~ RFP. For post•
treatment solids the Princip..t Preliminary Remediation Goals were 20 pph for total PC Bs
and J ppt for Dioxin TEQ. The Air Enriwon Performance Goals were 8x10--4 1nicrograms
per cubic meter (ug/cm) for PCBK and ~x10·11 ug/cm for Dioxin TEO.
b. The quality of the Phase I test report.
c. Th.e ability ofthe vendor to provide fuJJ.iCaJ.e equipmt.nt at the Warren County
PCB Landfill site.
Fax:[phone]~))
d. The ability of the vend.or to provide a safe. reliable and co••effectiv( full ~ale
application of the selected teclmoJogy at the Warren Cowity w.dtiD. Section 2 2 of the
RFP further clArified the goals and objectrves of the tei;r.mg, particularly in terms of
determining feasibility for full-scale deto,citication md that, 111 addition to the meeting thf'
performaoce criteria, feasibility would also be determined by considering the §afety of the
technology, the rate of detoxification, the cost per unit of detoxification, the reduction in
long term potential for =,viro.o.ment2l releue, from relidual§ of the treatment process
e. The quality and coat of the proposal for providmg Phase ll set'\-ices
This repon by the two Science Advisors for the Work-mg Otoup is the companti:vc
evah.l•tion of the two Phase I reports submitted in this project an_d is provided to the Workinia
Group au.d the Divi~on of Waste Management for the pwpose of usisting with the selection of
the Phase ll c011tractor: All repons and responsc-s to queSlioM mbmitted by the two comp1U1ies.
ETG Eoviroomental. me. (ETG) and ELI Eco Logic International Inc. (EL), hav.a been
,onsidered m preparing this report The format is to present a discussion of the relative pros au<l
cons. or ,dvantages aad disadvantage,, of each company's proposed technology for each of the
above selection criteria. Finally, a sw:nmary compari&on and recommendation is prestt1ted in the
last section..
2.0 1\leetinc tbt performance criteria
2 I Post•treat:ment solid!!. total PCBs
ETG conducted four test ruu and in all four cases the total PCBs were reduced to level,;
Jess than 20 ppb. The average of the four runs was 0.8 ppb. A consideration is the variation in
PCB levels in the input (raw feedstock) materials, which in this case averaged 50& ppm. Becttusc
non.detects (NDs) arc often reported, detection limits are also a factor in evaluatmg results. In
cowparins two the companies the iMue th.a.t uiaes is ifNDs are reported but the detection limits
(DLs) arc diffe1cnt, then the NDs are not ~•ctly the same. With •er DLs the f•,rO!-are less
impressive, because the pOtCl)tial level of undetected PCBs is higher. AncYTher way of loolini at
this issue is to realize that with lower DLs it .i& possi"blc to have positive hits or finding~ of PCB
~mers. while if higher OLs were used, the.n those findmas would not be pre'4!ftt
EL conducted three test ruu and reported NDs for all three results; hov,.,,ever, the DU
were •6.cantly higher than m the ETG testing, primarily beeau&e smaller size samples were
used in tbe EL testing (i.e., 0.010 kg versus 0.030 kg for .ETG). The only scieotinc way to h~Lc1
compare the two seti oftest data, therefore. ii to recalculate the total PCB levels by \Ising the
worst possible case i:n which it is 15SWDed that the NDs are actually equal tc tbe DLs Thi& has
l>eett done Gd the recalculated levels for both companies' data are given in the following table b)
using the data given in the re..qpcctive reports. It can be seen that by following thi~ protedur~ that
the recalculated average for £TG increases to 1 84 ppb and for EL the average changes from
2
F{ E: i.1.IDFl I r·.11; f:3F:DUF' F'. Ct4
wlw might be mterpreted as zero to J .63 ppb. Ihu!ii, '\Wile it is corr~ct to ,ay that both
comp~ies were able to meet the perfonmnce criterion, it is ~so correct to conclude th:at LTG
performed better than £L, particularly because ETG conducted four runs while EL presented data
for throe nms. Additionally, the •verage PCB level in the raw materials tested was 23"7 ppm fr,r
EL but 385 ppm for ETG, •ch makes the ETG results even more significant, because a higher
fraction of PCB, were removed.
Company/sample Original total PCBs (ppb) Recalculated total PCBs (pph)
ETGWCl-3 .74 1.33 --
ETGWCl-4 2.~S 3.06
ETGWC2-3 O(ND) l.80
ETGWC2-4 O(ND) l.18
ETG avc:nge 0.8 1.84
...
EL l O(ND) 4.10
EL2 O(ND) 3 40
EL3 O(ND) 3.40
EL average O(ND) 3.63
2. 2 Post-treat.ment solids -dioxin TEQ
ETG reported data for four runs, with an average diox:in TEQ of 0. 91 ppt, however 011e of
the runs had a value of 2. 96 ppt, but this wa.s for the sample with the highest level of PCBs. h
fact, £TG had optimized its process based on• much lower level of chemical treatment (BCD)
additive. ~ch would e,cplam why in this one run both the PCB and dioxm TEQ l,.wels were t})e
highest in the residual treat~ .olids. In fact, the TEQs for the other thr~ runs were exceptionilH:,
low. with m average of about .23 ppt, which ic mcignifieant. It should ,_J~ be noted that even rh e
2. 96 ppt level is very low and that EPA and most states have not approached this !1:vel to,· d;o~
cle1DUps. For examplt, for the Koppers Superfund site clean11p in Morrisville, North Cuohna th-:-
dioxin cleanup level was 7.000 ppt.
EL reported data for three runs. However, the dioxin analy~!. were redone for run s. 1 ,wd
3, but not run 2, because of overly high detection limits in the original testing. Also, scme dioXlll s
were <>riginally found in run 2 materit.l, dei.pite high detection levels, becauk ofb,igb dioxin levels.
tlut resuhed .&om nm 2 repttsc~ a prous.s. f.ailure due to too low a tetnperatu.re in the TJt\1
desorption unit that did not allow removal of dioxins for chemical reduction in the second hi~h
3
Fax:[phone]
tempenture stagt. This is discussed in length later in this report The orip).tl TEQ \'alues for
IW1s 1 and 3, based on uAing detection. limit values was reported by EL as 1.5 ppt and 32 ppt,
respectively. If the value for nm 2 is included, then the average for all three runs in the original
data is very high at 142 ppt, and with the d~ta from the retesting it is 127 ppt. The data are
summarized in 1he following table
It is mown how comparable data can be used from both compani~ in terms of either d..at a
from all runs or only th~ belt runs, and for EL for original and revised data. For example. the
averige for the two best EL runs can be compared to the average of the three runs of ETG that
represented their be'1 procesg perfonnance. In other words, if an test data are considered for
both compam~s. tha>. EL cl.early &ils to meet the performance criterion, and if only the best run "
ate considered for both compao.ies, then EL meets the criterion but ETG has superior
performance From a community perspective, it is valid to judge the companies on the ba~is of ali
their data, because they are respollSl'ble for mboptimal nms.
verage oxm e pt
1 J TF,STRUNS ETG ECOLOGIC ECOLOGIC
original d.tta revised data
A Di . TEQ Lev ls (J> )
Allnms .91 142 127 I
Be• nm& .23 24 50
It should be noted that the average dioxin TEQ level in th~ raw materials for EL runs l
and 3 (the best nm~) was 186 ppt, and 11, ppt for the three best runs ofETG. Proportionally,
ETG had dightly better perfomwlce (i e.~ 99.89% versus: 99. 73%, removal)
2.3 Air releases• total PCBs
ETG reported data for th.tee runs in tmns of both stack discharges and modeling r~sult s
for a property line assumed to be 200 f.eet from the equipment, which is a ptt"J'.)et -procedure fo,
addressing an exposure concentration (and that had been deemed appropnate at the pre-bid
conference for the llFP). I:n &ct~ the performance criteria h.ad been ~•bliahed on the basi; of
exposure concentrations for a very low risk level. The average of the ETG data was .8"x 10-•
ug/cm, or about one-tenth the perfonm.nce criterion of 8xI0"'ug.'cro.
EL reported data for three runs in terms of stack gas concentrations only, for which the
average was l.26x10·• ugic.m, whiclt i£ below the perfonnance criterion at the ~ack, a.nd \\hlcb
autoinatically makes it below the criterion at an)' distance to an exposure point
The ETG data for the: st.aclc ;oncentutions were significant})' higher than for the EL data
However, air sampling methods and equipment were not identical and, therefcie. a dJr~":t
4
F'I: E i.1JCIF:f •••. I t·,j1~ I 3F'CIUF' Fa> :919-2::,7-1C1C11:1
co~arison of stack data alone is not nocessarily complete. The nwn problem .is that an air
sampling procedw-e that u more eflicieot and eifecttve in removing material and obttining low
detection k\'els will haYe a higher probability of detecting contamml!lts foi-ex.an1ple. samphng a
larger volume of ga, 'will increase the probability of detecting coatammams For example. the
Stack gas flow rate in the ETG tests were about three times Larger th.n in the EL testin~
suggestin,. a h."igbe:r scn,:itivity in the E TG air t~sting. It u,us.t he emphasind that tlie p~ortniilce
level tet for thi, teating was e).,,-ueniely low and 1tringent and that the data from both <;Ol.llpames
iudicatei that no health hazard would be caused by PCB air emissious from the deto,ri:fica1ion
proces&. Indeed. in all probability there may be greater concern about potential PCB air releas~s
from site excavation and material handling prior to treatment iD equipm.ent , but this iss~e should
be addressed iJl the Phase ll work .
Baged on available infon:nation it can be aid that both ~ompmies .ire co~&rlilble 011 this
sub•criterion.
2.4 Air releases -dioxin TEQ
ETG reported stack and model data £or tluee run$. The model data had an aver•g~ of
.52xJ0"" ug/cm, about a tenth of the performance critenon
EL reported that no dioxins/furan.li wore found above detection limits, ln.t that the highest
possible level WIS 1. 7x10•!-ug/cm, which is higher than the perl'ormance critenon. Thtrcfo,e, E i.
said that "Due to these sampling and analytical conmamu, it is not pos&ible to demonstrate the
ability of the ECO LOGIC Process to meet the dioxin TEQ perfonunce goal . '' The highest
possible EL level is BOIDC 1000 tim:s greater than the performance g-oal. However if EL would
have modeled its data to adcm,$ l8Vels at some rea'°1Uble exposure point. then it would ha" e
b(-en able to show compliance, because iu .tack level was simiw to that found by ETG
The Science Advisor~ conclude that ETG has the advanuse on this sub-criterion
3.0 Quality of the Phase I report
Making a professional judgmlfflt about the quality of a technical r~ort can involve man y
considcrat;on3. Cenamly. the reports mould proaent the information required in the RFP in a
user-m.eu.dly format . AdditMJ11a.Dy, however. the quality of the rc::pQrt ctn be ~onsidered to be
higher Men there is considerabJe attention to particubrty important js..~e, and when additio.nal
informatM>D ill provided to u.ii91l the uaderstanding and evaluation of the testing. It mu~ aLS-O be
noted that £L submitted a draft report which was then modified in response to variou~ questions
and commeots to produce a final r-eport, while ETG submitted only one jnitial final repon
Therefore, to some ment the oo.e submission by ETG is comparable to the second Nbmission by
EL that conoctod defici.cnci~s in the origin.al draft report
5
As an important exa.q,le of• difference in presentation quality, consider the Tables 4-~
and 4•6 itt the ETG report, which p~sented in eanly understood tabular form the primary data ou
treatmeDt effectivenes, for PCB$ and dioms/furans for all the test runs_ and for all the individual
isomers or coogenen m each category. A reader could immediately see how the post-treatment
levels coiq,ared to the original raw material levels, and when nondects we~ reported tbe-
detccti.on limits were aho presC'oDted. ID contrast, the EL rq,ort presented the analogous data 111
two separate tables (Tables 8 an.d 9), and the contractor had to be instructed to provide deteC(ion
limils in the final report, and neither table preseuted the data for all th,: in(liv;.dual isomers or
congeners in the ~ful way employed by ETG.
Another factor was that ETG pre&ented more information than wa.s $trlctly requited. For
example, ETG presented the rctults of testing to mow tut their process bid aet\l&lly d~troy~d
PCBs and ako obtained data on particulate levels in emiasioas and water content in raw feed
materials.
It Dll1St also be noted that the quality of the report is merely a surrogate for the quality of
the beneh•scale testing. In this sense, it i! important to note that EL conducted three nms vc1su s
four for ETG, and that one oftbe EL runi (nm 2) was euentially a failtll'e because of an operato,
error that caused the initial TltM desol])tion pan of the process to function poorly due to a fow
tempcratu.lc that did not separate dioxinslfurUlB for chemical reduction in the second part or the
J)rousa. A major aspect of any type of technology testing is to see how well a company conduct ::.
itself and operate!' its oVYn equip~ to demonstrate a "ery high level of e-0mpetcnce that
provides COUDdenc-e tQ potelltial clients that the very hen performance will be obtained in full-
scale usage. Jhc JPljp 'lP,gtiop tbl11nrot~ attention for this aspect oftbe.E.L..a~..e...~b)'.ili
senior perSOfts in clime ofth.e test did not ideptify the low lRJl>stltJlri. JUpblem durini t~ .. .l~st
period and r~eat the test run Thi£ wu especially important becauae only three nws were u~<l
Also, in discussing this ~ent EL has referred to a minimum temperatw-e in the TRM UJJit
of 5 5O"C, b-ut the unit is supposed to operate at 6OO°C according 10th~ information in tht EL
report . EL did llOt provide dnailed data for run 2 on exactly what tempen1ture "'u used or fo :
how long a suboptimal temperature existed during the run. except that the ternperatu1e dropped
to 50O"C However, it reported average mill temperatures of 595°C, 572•c, and 628"C for tes t
nms 1, 2, and 3 respectively_ It is interesting that two oftbe runs did not have average
temperatutes of 600°C. The &et that the average temperature in run 2 was above the S 50''C
mmimum th.at BL has me11tioned al,o raise, 1 q_ue.gt.lon of uneertmfy about what actually
occurred in nm 2 to so thOJoughly cause no treatment of the dioxin contaminatioD. The
information suggests that out of the total of 15 minutes in the nM u.nit even a mi.all amount of
time at suboptimal teu,perature is sufficient to cause a complete &ilure to rem(lve d:io,ciu
cootaminauts from the feed material, which is a ~eriou.s sensitivity to low tcmperanue exrursions
EL also had a problem with Ul important part of its dioxin testing, which it blamed ou the
testing laboratory. Howc-vcr, much of what has b"° said by EL simply does uot bold up l.llde:
close s,crutmy. Part of the competence of a co~any in the: remediation technology busines, i~
6
F : t l_1JC1Fl n.11:; 13FTIUF· Fax :919-2::,7-10I:iei F·. C(
expertise for obtaining the best analytical ,ervices. If a company provides incomplete or
misleading information to a ehemical analysis laboratory. then the laboratory may perform poor!)
In the EL testiag aome of the most critical clioxm testing was inferior because of high det~ction
limits that resulted. from unusually mall sample sizes for the testing. £L c.lai.~ that this resuhed
&om its telling the laboratory that there were high PCB levds, and that this caused the laboratory
to use lower than normal sample quan®t$. There a.re two problems, however First. r.he ovenll
PCB levels in the r,lw materw& (information given m the RFP) were n.ot exceptionally high for
PCBs. Second, certainly there would be no rational reason why EL would want the laboratory to
believe that PCB levels were 'hit,h in their Uuw4 anaterial~. EL also said somethmg that any
eq'erienced professional who deals with dioxm iesting of solids knows is iDcorrect, namely that a
target vll.le of I ppt dioxin TEQ is itnpom'ble to obtain or verify for mtthod 8290. This is pbin
wrong, u any eiamination oftest results for this method clearly abows, includin,g the dioxin t~st
data obtained for tbe project 's site mvestiption work. as well u the diox:m testins for ETG from
the saroe laboratory uged by EL. In the opinion of one of the Science Advisors, who does
considerable work with dioxm contamination and cleuup and ~o discussed this issue with both
companies, EL did not cxhil>it a high degree of knowledge and experience iu tbjs area. ETG
verified that at no time did it change: its instructions to the analytical laboratory that both
CQU1panies used, nor i, their uy logical bas.is for believing that actions takeTJ for EL sample$
would have dfected ETG wark in the very large laboratory. lhe one key &ct fut seelll!-to
explain the cause of the dioxin testing problems faced by EL was the iufonnatiou it pTovided tC1
the laboratory 'fll-bi~h ctl.lSed them to l.lie irreguhr, low sample vommes fo1 testiilg.
AAother i.s'Ue is that EL did not clearly represcut what material~ it te~~ n:latl'-e to the
materials it bad received. EL ;aid that it received three s.gallon buckets but that only two wcr.:
used But no information was provided to indicate exactly what materuls were tested in FL·,
three runs. In contra.st, ETG cle.arly indic1ted whit materials had been received and teSt~d in cAC:h
oftbei:t four nllli
The professional judgment of the Science Advisors is that tht ETG report followed the
reque!.t.ed form.at of the RFP more closely than the EL report, and that the ETG report was rn
~eDcral easier to follow and presented key infomutio.n. in a more concise manner than the EL
repon As the above discussion indicates, the conclusion is that the quality of the ETG report an d
its testing ·wu better than the EL rf4'ort u.d iu te~g.
4.0 Ability to provide fu.U-scale equipment
Both companie6 arc iti the position of roo5t techuoJogy vendors, n.une]y that ejthe• au
e,ruting piece of equipment oould be trawiported to th.e site and used, or new cquipmeut would be
constructed for the particular job. Both companies have indicated tlsat they would need up to six
months to provide D~S..IW'Y equipment, Ymich ii con&i.!.tent with industry practice for large
cleuup projects. But there ia more to con.sider for this evalution crilerion. The ability t (}
provide full-scale equipment is legitimately related to the stability and ,.,iability of the compatt).
7
becaus.e so~ significant iovedment is necessary for • large project, which this one would be
potentwly. ETG is actually part of a business that is weD established commercially and qwte
substantial financially, 1Dd it has performed in similar remediation applicatioJJ s for c. S clients
over some years.
Inter~stingly, in the BCD treatment technology arena, wbicb is based ou companies
obtallllll8 licenaes from EPA, ETG has outlasted other companies. In contrast, EL b more of a
start-up technology developer that has had few clients (and none in the US for actual full scale
work) and is not the same level of a stable, financially succesdw company with a long comn,ercial
track record as ETG. There may also be some significance to the &ct that ETG is a U S.
company located Dmch close:r to North Carolina., 'Wile EL is a more distant Cauadian company
It is also of some relevance that a very rteerlt study for a major federal Superfund siti;: at which
dioxin is a major contaminmt (the Escambia Treating Company site in Pensacola, Aorida)
examined potential treatment teclmologies, and the EPA oontractor doing the Remedial
lnvestigation/Feast°bility Study screened out EL md iu technology at the earliest stage of
technology evahiation. but included BCD treatment and cited ETG as the source of the BCD
technology. While EL bas performed treatability and demonstration tests in the LI . S. it has not ye1
secured any actual remediation project. In contrast, ETG is the vendor cleaning up the Southern
Maryland Wood Treatment Superfund &ite, where it will treat &<>me 145,000 tons of material
This-job is doscr to the W1.JTCD County project than any work that EL has pi:rfornted
The Science Advlion conclud~ that overall the ability to pro"ide neces&U)' foll-sc ale
equipment for the Warren. CoW1ty project is better for ETG than for EL
S.O Saf~ty, reliability, cost, and long term releasef
5.1 Safety
Th.ere are two major ways to look at the safety issue. First, the intrinsic nature of the
tcc-hnology can be a&8e&Sed in temu of inherent hazards. For example, any process that utiliz:!s
hazardous material$ ii fundamentally more hazardous than one that does not use any haurdou.s.
material', and one that operates at either higher pre&li:UI'e or temperature than anothe1 )n.e pc,~es
more potential for unsafe situations.
The seoo11d approaoh is to consider how vulnerable a process is to hWIUm error, becau~i:
moi.t i.m,a..te conditions and accidents relate to human error S()me technologies are mherentl~
safer becau!le they are much simpler than other technologies.. for ex.ample. As for treatabihty o,
demonstration testing, it is presumed that a company will logically use its best trained aod
qualified per&0nnel If human erron occur in testing, it does not portend well for full-~,;a.le
company operations.
ETG technology operates at a lower temperature than the EL proc.ess, roughly about
8
r·1_ 1:: 1.1JUrl 11·.11J l.:ik:uur· f-ax :919-1~7-lUOO f-'. l i_l
onehalflower tempenture. The ETG proceas also operates under vacuum conditions, while the
EL process operates at ambient pressure, and this reduces the potential for ~~em leaks and
discharges of contmrinaits into the environment. The EL technology uses hydrogen gas. which is
intrinsically hazardous, while the ETG teclmoJogy uses no unrdous materials. ""-ith the exc·,!ption
of sodium hydroidde \Wich is conosive but not oombustiblc or toxic. The EL process ilio
utiliz.es a bath ofmoken tm.. whil;;h raises a safety concern.
Although EL has made a good argument th.at industml processes have used hydrogen
very mcceufully, th.ere is still an inherent huard that cannot he entirely dimrused, esp~ially
when one recopius that u!ety iisues generally are centered on unuirual, unintended and
unfonecn incidents or accidents. While process control mstrumentation and monitoring
equipment may be used, the problem in the real-world are low probability events that consist of
several things going v.TOng to create IJl actua) problem. For example, for everyone oftbe nine
factors that EL has cited to 1811'e the safety of using hydrogen it is possible to identif)· a
conditi.011 that nullifies the &ctor. For example, EL says that no open flames or ~uoking are
permitted onsite, but any experienced professional has probably seen just such human beb.a,;or on
1'-1Ual industrial sties wtlere the prohl'bitions e,cist. Similarly, leak proof pH>c.css "esse~ in th e
field can be rendered unsafe by, for eumple, a bullet piercing a piece of onsite equipment. The
use of nitrogen purgmg to avoid mixing ·with oxygen can &il when som~one UieS a wroug gas
tank or ma.k.es a wrong connection.
Oo the is~e of human error, it is also relevant that in the bench-scale testing for this
project, there was a clear, admitted case of human c;rror in the EL test, when a temperature was
not properly controlled in nm 2 in the TRM unit. EL also acknowledged a second "operator
e1Tor" \\iien the excess gas bwner that wu supposed to be operated at 800°C was ~.:;tualh.·
operated betweea 300 to 400"C, appar~tly for all the runs. The company also bad problems ~1th
equipment, including a micro.Ge instrument that was Npposed to be u~d but wai; not
operational, and a broken mill shaft which happened twice and caused delays.
Another safety issue is the potential for the air pollution control system to functio11
effectively to prevent unacceptable discharges ofhazardo\1$ substances. In this regard. the ETG
report paid considerable ancntion to this issue and provid~ el..1ensi:ve discu~on of ho"' the
company would employ the moat sophisticated technolog)' to collect and treat dust.
The Science Advisors conclude that, aSSuming that either company would employ the bc:..,1
industrial safety practice, in design and operation of their equipment, the ETG technology bas AD
advantage over the EL proceas.
S.2 Reliability
Reliability can mean mmy different th.iog~ but one ke)· engineering concept is whether a
process technology will offer the bc8t performance under varying field a.o.d raw material
9
F{E l.1.ICIFl H-H3 13F:CIUF F·. 11
condition..c._ In other words, some technologies 1r~ more sensitive or vulnerable to variations in
key conditions or parameters and become less reliable because there ilTC upiietS: c~red_ Some
technolo~ are very complex with multiple steps or stages and the need for very complex
process control and monitoring equipment_ All of these issues cao reduce reliability The use of
computers 111d sophisticated equipment has not eliminated major problems in industrial processes
An ~e of concern in the current project iii the degree to which the detoxification technology
may become umeliable because of high water content in feed rmteria.ls, for example. To some
degree it ,eems as if the EL process would be less ~s.rti\'e to water contm~ but in fact a close
elCarnination of discussions of this topic by the contractors reveals ew.mtially the same problem
That is, both prooossea CID handle higher moisture levels, but both would he negatively mipacted
in terms of throughput, efficiency and proce~'ing time Moreover. ETG actually measwd water
content and concluded that no dewat«ing ofm.aterW.s will be required.
An important feature of the ETG process is that there is iolid phase BCD tre,1tro~nt o~
.PCBs and dioxins in the thermal deso-rption part of the process and then more BCD liquid pba~
treatment of oily condensate, if necessary. Their test reimhs ~owed th.t the i0lid phas,:
deto,ancation was successful. In contrast., in the EL proces.s there is n.o detoxification of PCBs
and dioxin5 in the first stage thermal desorption unit. and detoxification is dependent on fir~
separating the contannnants into a vapor phase that then undergoes high temperature reduction.
As the testing showed) the EL process wu vulnerable to poor performance ""hen tb~ thermal
desorption .-tage was not operated at optimal conditions and, therefore, dioxms we,~ not
deto>eified .
It is the opinioll of the Science Advisors that the ETG proces~ is intrinsically ~impler au d
le~ prone to problems created during full-scale U.$C that would reduce reliability
5.3 Cost
EL has said that it foresees a cost of $300 to $350 per ton, based on proce,smg 1 oa to
200 tons per day \\ith a 70 to 80% availability, leading to a project du.ration of90 to 123 we~ks
The availability range used by EL is not impreS.$1\le and may indicate-its experiei1ce in actual
projects where there has been significant down time_ This cost does NOT include certain
acti\.ities.. such as excavation, performance testing or disposal of processed solids, but it DOES
include system mobilization and commissioning, all wa&'le preparation and processing, lab costs
for proces~ output$ anatys.i.s and system demobilization.
ETG has said that its estimate of $390 per ton pertains to a processmg rate of 300 to 400
tons per day with 100% availability ETG's cost is all inclusive and includes excavation and
b3ckfilling of soil, which the EL elitimate did not. ETG has also indicated that if less sningent
cleanup performance standards were used, then the cost could be decreased by wme 3 5% if mok
typical criteria were used for PCBs and dioxins In fact, it is highly probable that the state ,vo\tld
use iu normal c~up criteria and that the ETG cost would likely be less thu S300 per ton . I•
should be o.oted that there is less intrinsic capability to reduce operating costs in the EL µroct~;;,
as compared to the ETG process. and that EL did not offer a similar observation. Note that the
processing rate for ETG is about twice as high as the EL figure, meaning that totlll project
duation might well be reduced by 50% and require about one year rather than two ye.ars.
The Science Advisors conclude that for cost and eost -ef:fectrvcness the ETG prncess i~
superior to that of EL
S. 4 Long term releases from rei.iduili
Any detmcifieation. technology will create ccrt~n t}-pes of residuals.. byproducts ()f wa~tc-
effluent~ that mipt pose longer term riskll because of releases. Both compame~ hav~• paid
sufficient attention to this issue and providod ~ discussions about the safe and effective
handling of all process re,-iduals md wastcstreams, and neither has an advantage. ·ne more
confidence there is in the company's ability to reduce residual levels of PCBs and dioxins. to th~
Jowe~ posml>le levds, theo th.ere is minimal concern about loug term releues from post-trr.atment
residuals replaced on the landfill site.
6.0 Quality and cost of Phase II proposal
The initial proposals that responded to the .RFP included a proposal for the Phas~ lI ,,·or!-.
For the most part, both companies submitted cornpauble proposals that addressed tb i;·
requirements of the RFP. Both companies teamed with large, experienced environmental.
eugineering finm for the Phase n work. However. the cost of the ETG Phase n work \,ae
siguificantly less at $89,000, while EL proposed a cost of $115,000.
The Science Advisors conclude that ETG offers a sigr.ifiCaDt coA advantage for the Phit ~..:
JI work, especially in light of currently limited funding for all aspects of the cutTent project. lb.a1
is, the saving of $2S,OOO offers the i,oteoti.al ofbeiu.g able to accomplish other tk11ctioM :md 11~ed.~
prior to the state legwature authorim.g funds for the full detoxification of the landfill
7 .0 Summary comparison and recommendation
Tbt following table presents a simplified summary of the conclus.ions reached for the
individual evaluation criteria. Juthcr than using an artificial and subjective numerical rating
system, the Sci.cu.cc Advison have indicated a net advantage .in terms of a• sig,., for tbe compa.n,
with the best cap~bility. When both companies were comparable, both rc-cciv~J a ..:. .
11
uct 1 ·:i, r . 1 :,
SELECTION CIUTEIUON ETG ECOLOGIC
Perfomw1cc
solids • PCBs +
solids • dioxm TEQ +
m-PCBs + +
air • dioxin TEQ +
Quality of Pbue I report +
Ability to provide full-scale equipment ...
Safety, reliability, cost. long term eft'ecu ++++ +
Muse Il proposal, quality md cost +
AB can be seen from the table. in most categories ETG was judged to have m advantage
This is not to &ay or imply that Eco Logic and its technology was inferior, poor or cornplctdy
unacceptable, but only that, in this particular testing ud for this specific application, ETG has :1
number of advantages, as presented in the previous discussions. On the basis of visiting the te.;t
s.ites., having di9CUSlions with company personnel. and examining the reports. the Science
Advisors agreed that ETG seems a more engineering oriented company, while EL seems more
R&D or science oriented, with less of a practical, engineering coru.truction focus .
Also, a close examination of all documents provided by EL indicated the followmg ( l) lhc-
company probabty has not met the stringent dioxin cleanup criteru \lsed in this project in previous.
projects; (2) the September 1994 EPA report on the thermal desorption unit found th.2t it "did not
perform to design specifications" and that the company "experienced material handling problems,"
and (3) the company does not seem to have bun able to perform commercial projects at a pro.fit
and may be experiencing uncertain financial conditions. On the latter point, the last two annual
reports from EL iDdicate that the company has continuM to be unprofitable, despite rising
revenue&, ~ the information supplied by ETG indicates a medium siu euvironmental services
company that is profitable. For example. the hiahest revenue stream for EL in 1996 was Jess than
$5 million annually (for which the aDDual loss was nearly $12 million). while the company th11t
ETG is a division of grosses about $SO million and is profitable.
In conclu1ion, the Science Advisors apee that ETG is the be!t qualified compan)
for receivi.n.& the Piute D contract and advile the Workin1 Group to accept thJ5 ~electi.oo
and to formally commuicate iu recommendation to the Division of Wut~ "\tanagem~nt.
l2
Joint Warren County/State PCB Landfill Working Group
draft September 22, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:30 P.M. Monday, September 22, 1997 by co-chair Henry Lancaster. The meeting was held
at the office of the Working Group.
NEW BUSINESS
Triangle Environmental, Inc. Letter
Mr. Lancaster called for discussion on the letter sent to the Working Group by Triangle
Environmental, Inc. (Triangle). Joel Hirschhorn began the discussion by saying that he sent a letter
to Triangle (See Attachment) and phoned them. He added that he was not impressed with what he
learned and that he did not see any bases for honoring their request. Mr. Hirschhorn said that he feels
sure that the Triangle's technology has not been tested full scale.
Deborah Ferruccio added that material for testing cannot be requested under the Freedom of
Information Act. She concluded by saying that what would keep other companies from requesting
material to sample. She recommended that a letter be sent to Triangle to advise them that the process
is closed.
Daria Holcomb asked what could be requested under the Freedom oflnforrnation Act. Mr. Lancaster
responded information only.
Tommy Cline suggested that a letter be sent to Triangle saying that you did not respond to the RFP
within the time allotted, however if the process is reopened then we will contact them. This statement
became a motion and was seconded by Jim Warren and carried.
UNFINISHED BUSINESS
Site Investigation Report
The site investigation report was given by Patrick Barnes with assistance from Mr. Hirschhorn.
Mr. Lancaster noted that the report was marked draft and asked what is needed to make this report
final. Mr. Barnes said if something is not clear in the report or if something has been left out, these
things would be corrected. That would make the report final. Mr. Lancaster asked Mr. Barnes to
summarize the document and then there would be time for questions. He, Mr. Barnes began my
explaining the goal of the investigation, which was included in the executive summary, the first
section of the report. The second section dealt with reviewing the files and learning what was in the
files and what was not. Section three dealt with the procedure followed. He explained that the
sampling plan was followed with a few modifications. Section four dealt with the analysis of the
field-testing results. This section discusses the regional geology, site strata distribution, soil
permeability and groundwater flow. It continues with landfill soils/wastes, leachate, offsite
groundwater, offsite surface water, offsite soils and sediments. It concludes with air testing for
PCBs, landfill integrity, top liner, water in the landfill, the bottom liner, and the Richardson report.
draft September 22, 1997 Meeting Minutes
Page 2
During this discussion, Mr. Hirschhorn noted that there are different concentrations of wastes in the
landfill. He added that during cleanup this could cause some engineering problems. Mr. Barnes said
that there are some variations in concentrations but they are not extreme. Next discussed was the
presence of a dioxin not usually found in PCBs, 2,3,7,8 dioxin. This may indicate that there is
something in the landfill other than ordinary PCB said Mr. Hirschhorn. He added that 2,3, 7,8 was
also found in a sample that Eco-Logic tested. Ms. Ferruccio added that she remembers newspaper
articles that said that a higher form of PCB came from Fort Bragg. She asked the state if there are
any records of what came from Fort Bragg. There is no information in the files on what came from
Fort Bragg said Mr. Hirschhorn. The Working Group has requested this information from Fort
Bragg, but at this time they have not responded to that request.
Air emission was discussed next. Mr. Hirschhorn stated that air testing takes several weeks. He
added that most of the air releases have already occurred. However, there was one sample close to
the main vent that had a very high concentration of PCBs. Dollie Burwell said if most air emissions
have already occurred, is there no way to make a correlation to what is happening now. Mr.
Hirschhorn said there is not enough data to make a correlation. He added that the air emissions now
are "bulging and burping," not a steady flow . Ms. Ferruccio said that years ago EPA found air
emissions and recommended that air monitoring be done. Why did the State not follow that
recommendation? Mike Kelly advised that the State did some testing over a period and found no
emissions, so it was decided not to continue the testing. The air emission was high enough to require
regular monitoring and will be add to the recommendations said Mr. Barnes. Dennis Retzlaff asked
the Science Advisors if they could give a worse case scenario of the health effects of PCB air
emissions. Mr. Hirschhorn responded that there are so many perimeters to consider and there are
standard ways to quantify. He added that a health study should include the people who lived closest
to landfill at the time it was installed, they would be most impacted.
During the discussion of the landfill integrity, Mr. Kelly said that there needs to be more discussion
included on the top liner. Mr. Warren added that information on the clay liner should be included as
well. Mr. Barnes agreed to include additional information about the top liner and the clay liner.
Section five, of the' report, is the conclusion section; Mr. Barnes and Mr. Hirschhorn conclude that:
I) There are significant levels of PCBs and dioxins/furans in the landfill and the
concentrations vary.
2) There is no evidence of off-site contamination in surface waters, sediments,
groundwater or soil.
3) There is evidence suggesting some limited impact of the landfill on subsurface
materials immediately outside the landfill.
4) Contamination was found in two (2) groundwater wells, which indicates some failure
of the containment system.
5) Water is entering and leaving the landfill and taking some contaminates with it.
6) There is loss of containment efficiency in the landfill's top liner.
7) There have been releases of PCBs into the air.
draft September 22, 1997 Meeting Minutes
Page 3
The last section of the report is the recommendations; the Science Advisors recommend the
following:
1) Additional testing, especially of material beneath the landfill. This would determine
the full extent of contamination outside the landfill that may need detoxification.
2) The Phase II contractor should use a contingency figure of an additional 25% of
material that may need to be detoxified.
3) The Phase II contractor should consider different cleanup standards for PCBs and
dioxins.
4) The Phase II contractor should be made aware of the varying chemical composition
of materials in the landfill. This could require blending of materials or a design
to handle maximum possible concentrations of contaminates.
5) In response to EPA requirements for regulatory compliance, the State should
determine if actions they take are effective in removing water trapped in the landfill.
6) Volumes of water extracted from the landfill should be analyzed to determine the
extent to which the leachate collection system needs repair.
After the report was complete it was agreed to give the members two (2) weeks to comment. The
Science Advisors should receive comments by October 6, 1997 and a final report produced by
October 20, 1997.
Technology Assessment and Selection Criteria
Mr. Hirschhorn began by saying that the criteria for selection were developed in the RFP. Mr. Barnes
added that he put together a scoring system based on those criteria. Ms. Burwell said that this is not
the detailed criteria. It is the legal criteria said Mr. Hirschhorn. After discussion it was decided to
wait to make the final recommendation after all the questions submitted to both companies have
received a response. Mr. Hirschhorn agreed to take the lead on a final report which will include a
narrative and a comparative analysis. A draft will be prepared by October 3, 1997 if all information
is received by Wednesday, September 24, 1997.
Legislative Session
Mr. Lancaster advised that they were not successful in getting the additional funds ($125,000.00) to
meet the Science Advisors needs. He will be meeting with Secretary McDevitt to see if the funds are
available to come from within the Department if Environment, Health and Natural Resources.
Other Business
First, Mr. Hirschhorn raised the issue of a request from Mike Kelly to shorten the time given for the
Phase II report. He advised that originally the company was given seventy-five (75) days to produce
the report and now it has been reduced to thirty (30) days. Mr. Kelly responded saying that when
draft September 22, 1997 Meeting Minutes
Page 4
the contract is awarded, the company will be asked if they can produce the report in thirty (30) days.
They are not being told that they must produce the report in thirty (30) days. If the company does
not agreed, then the State would adjust accordingly. He explained that this is an effort to expedite
the process since the State has been accused of delaying the process. After discussion it was agreed
that Mr. Kelly could discuss this with the company.
Next, the Working Group was advised of a letter received from Eco -Logic announcing an open
house they have planned for October 2, 1997. After discussion Mr. Cline made a motion to send a
letter to Eco-Logic to encourage them to come when the Working Group holds it public meeting, if
they are the company chosen for the detoxification. The motion was seconded and carried. Mr. Kelly
agreed to send the letter from the State and the Working Group.
Ms. Ferruccio asked when is the Working Group going to be reconstituted. It was motioned by Ms.
Ferruccio and second by Mr. Retzlaff to send a letter to Secretary McDevitt asking him to
reconstitute the Working Group as soon as possible. The motion carried.
The last item discussed was a date for a public meeting. After discussion it was decided to have the
public meeting on November 1, 1997 with an alternative date of November 8, 1997. Details of the
public meeting will be discussed at the next Working Group meeting.
ADJOURNMENT
The next meeting is scheduled for Tuesday, October 7, 1997 at 6:30 P.M .. Ms. Burwell asked Mr.
Kelly to see if Bill Meyer can attend the next meeting to address the issue of noncompliance. The
meeting was adjourned at 9:45 P.M ..
. 'HIRSCHHORN
,@)~ASSOCIATES ~ A Division of Hygienetics Environmental Services, Inc.
ATTACHMENT
Suite 411
2401 Bluerldgc Avenue
Wheaton, MD 20902
September 22, 1997 ............................................................................... by FAX
To: C. Thomas Hendrickson
From: Joel Hirschhorn
Phone: [phone]
l r1x: [phone]
Re: Request by Triangle Environmental to test materials from Warren County PCB Landfill
I am writing to you in my capacity as a Science Advisor for the Joint Warren Comity/State PCB
Landfill Working Group, and because I have just received a copy of your 15 September letter to
Ms. Burwell and Mr. Lancaster.
I have played a major role in the work on cleanup technology assessment and activities for our
project. I would very much appreciate it if you would fax me as much material as you possibly
can that would provide information on the following points:
I. At the pre-bid meeting in Raleigh on February 17, 1997 for the bench-scale detoxification
technology testing RFP a Lyle Hunnicutt attended. Did that person have some relationship to
your company and the two technologies mentioned in your letter?
2. Can you provide any detailed technical data for the two technologies mentioned in your letter
on their effectiveness in removing and destroying both PCBs and dioxins/furans from soil
matrices?
3. Can you provide any infonnation on exactly where both technologies have been used full-scale
for actual remediation projects and, particularly, whether any of those projects included work on
PCBs and dioxins/furans? If there are such projects, would you be able to supply detailed reports
on how both technologies performed?
4. Nothing in your letter indicates that you would follow the exact protocol and requirements
established in the RFP for the bench-scale testing, which two other companies have complied
with. Are you suggesting that you are familiar with the RFP and would follow the protocol and
requirements, even though your company would bear all costs?
The Working Group is having a meeting this evening and, therefore, I request that you fax
the requested materials to my attention at the Working Group's office in Warrenton as
soon as possible and hopefully before the close of business today; the fax number there is
919 257-1000. I expect to be in the Warrenton office by about 4:00 PM and the phone
number there is 919 257-1948,
r
CO-CJWRS:
r l .ti UJl_lrFl l'•HJ i.JrUUr r . Ul
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
7 20 RIOGEWAY STREET
WARRENTON, N .C . 27589
PHONE 91 Q-257-1948 -FAX [phone]
IXJU/E B, BL:Rll'EU
IIENR Y LJ.J•K;AS'11!R.
FAX COVER SHEET
TO :
FROM:
DATE:
Laura Butler
Tommy Cline
Nan Freeland
Deborah/Ken Ferruccio
M.ike Kelly
Sharon Moore
Dennis Retzlaff
Bobbie Riley
Jim Warren
Doris Fleetwood, Secretary
PCB Working Group
September 19, l 997
Number of pages (including cover sheet): 3
919-733-5317
919-733-1431
919-832-9100
919-257-2604
919-715-3605
919-733-2120
919-257-2897
919-431-1453
919-493-66] 4
r ~:B WC~K IN3 GROUP Fax :919-257-l ~JO
TRIANGLE
ENVIRONMENTAL
.... -. ........ INC.
Ms. Dollie B. BunvelL Co-Chair
Mr. Henry M. Lancaster. Co-Chair
September 15. 1997
Joint Warren County/State PCB Landfill Working Group
720 Ridgeway Street
Warrenton, NC 27589
Dear Ms. Burv,:ell and Mr Lancaster:
13 :20 F·. 02
P.O. Box 41087
Ral&lgh, NC 27629
919 -828-3150
800-849-5715
Fax [phone]
Tri~tngle Environmental, Inc. (Triangle) of Raleigh is leading a team that proposes to
address the Wan-en County PCB Landfill \.Vith appropriate technology tO clean the site
and destroy the PCBs located therein using proprietary processes that already have EPA
nationwide pem1its in place \Ve beliew that we have the most advanced and most cost-
effective technologies for remediating \\-'anen County's PCB LandfilL and ,ve ask that
we have the opportunity to. at our cost. demonstrate this to you and the committee.
We Ltnderstand that the committtt has conducted pilot tests on other technologies and is
anxious to resolve this issue as quickly as possible. Our goal is to offer the committee an
alternative technology that we believe ,,·ill be in the best interest of the people of Warren
County1 without slowing the progress the committee has made. \Ve are requesting a
sample of representatiYe mat.erial under the Freedom of Tnforniation Act and ask that the
cornmittee review and consider the results from our tests so long as we present thern to
you and the committee within 30 days of our receipt of rnaterial.
In order to conduct a hench-scale study to demonstrate the effectiYeness of the technology
to the committee, we would need ,1 sample of approximately 50 gallons of representative
material. Although the process test run would be completed in l to 2 days, confinnation
testing by an independent laboratory ,vould requii-e approxirnately two weeks. \Ve
currently project that the bench-scale test. including the issuance of a final report would
be complete within one month of receiving a sample. We will rnake the necessary
arrangements for pick up and shipment of the sample upon your appro\'al. Our team \Vill
bear all costs associated with the testing and will destroy all PCBs and dispose of the
sample without returning it to the storage facilily in Greensboro or the landfill in \Varren
County.
kST PCBLTIC.OOC
PCB WORKING GROUP Fa<:919-257-1000 13 :20
Our team will bring the best elements of two significant technologies to the Warren
Coumy site. One is the patented METHEX soh·cnt extraction/soil washing technology
developed here in :-.Jorth Carolina by Environrnental Technologies, Unlimited. Second is
the patented PCB destrnction technology, the Solvated Electron Technology (SET)
program developed and patented by Commodore Advanced Sciences_ Inc. (CASI) of
Albuquerque, Nev-.: }.-1exico. Both of these technologies have been thoroughly tested and
verified, and they both hold EPA nationwide permits.
As a brief overview, the solvent extraction process will alk>\V the treatment of the
contents of the landfill to remove the PCI3s from the soil and \.Vater in the landfill and
concentrate it in the solvent to facilitate the destruction of the PCBs by the SET process.
Triangle believes that this step vYill shorten the time required to treat al I the landfilled
material and reduce the total cost of the operation.
The SET process involves the ambient temperature destruction of essentially all PCBs in
the sample by chemical conversion to remo\'e the chlorine atoms from the PCB molecule
and converting it i.nto common salt. There is no incineration and no potential fo r
fo rmation of dioxin or similar materials during the reaction. After th-2 dcstrnction process
is complete, the treated material is suitable for retum to the landfill or for reuse under
proper conditions.
In sununary, we belie·ve that we ha\'e assembled a team with the appropriate resources
and technology to meet the goals of the Warren County PCB Cornmittee in a timely and
cost effective manner. We look fonvard to working with you in this process.
We recognize the impo11ance of this project to the people of Waffen County and to the
people of the State of North Carolina.
Sincerely,
TRIANGLE ENVJRONME:'JTAL, I~C.
·1£.tJL-
. Thomas Hendrickson
Chain:nan
/ra
RST P(:l'll.TR.2 .DOC
SENT BY:ETG ENVIRONMENTAL, me: 9-18-97; 4:23PM ~ West Chester, PA➔
EiG Providing creative environmental solutions
Environmental, Inc.
-■-----IWW'ii'l'l.'rliiMI-J.J.~,--------------------------
September 18, 1997
Mr. Michael A. Kelly, CHMM, CPM
Deputy Director, Division of Waste Management
North Carolina Department of Environment
Health and Natural Resources
401 Oberlin Road
Suite 150
Raleigh, NC 27605
Dear Mike:
Via Fax
[phone]
It was a pleasure to meet you this week, and thank you for your fine hospitality.
Our purpose in meeting was to summarize our activity on the Phase I report for the
Warren County Landfill and we hope that we were responsive to the issues that you
raised. Under separate cover, you should shortly receive a response to the several
technical questions that you faxed to ETG earlier this week. Additionally, ETG will be
prepared to conduct a conference call with you and your technical advisors to further
discuss any issues.
At our meeting, I briefly summarized how ETG has approached the Warren
County Remediation project. During Phase I, our objective was to demonstrate the
BCD/Thennal Desorption Technology obtaining favorable testing results. We elected to
utilize a pilot scale system rather than bench scale, since our company experience shows
that pilot-scale results have better correlation to actual full-scale production. We are very
pleased with the data developed during Phase I testing and we feel that the technology
has been successfully demonstrated.
During Phase II, ETG is teamed with !CF Kaiser, a well respected organization in
the hazardous waste industry. Our objective here was to team with a company that we
have direct hands-on experience working on a project. As I mentioned, ETG and ICF are
teamed on a $30MM project for the 145,000 ton Southern Maryland Thermal Desorption
Remediation project, working for the Army Corps of Engineers. We believe that the
ETG/ICF team is very qualified to perform Phase II design activities.
16 H~19erty Boulevard, West Cheste r, PA 19382-7594 • (6 10) 431-9100 • Fz,x (610) 43 1-9 140
SENT BY:ETG EN VIRONMENTAL, me; 9-18-97 ; 4:23PM west Chester, PA..,
Stpt~mber 18. 1997
On Phase III, ETG has full-scale commercial experience applying the
BCD/Thermal Desorption technology at other projects in the US. We also have
signficant hands-on experience at other remedial sites and our operating group CWTently
handles over 14MM tons per year of waste material spanning over twelve project sites.
Accordingly, ETG believes that we can deliver a highly effective project providing
excellent environmental results within cost-effective parameters.
Mike, we trust that we have been responsive to you in our Phase I report on the
Warren County project. We are prepared to address any additional issues that you have.
We are very interested in Phase II and beyond, and you will have our full support moving
forward.
RAB/ksd
97-093
Very truly yours, /hJ
Ronald J. Bacskai
1 President and CEO
ETG
Environment11l, lne.
... I.. •
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
MEMORANDUM
September 4, 1997
TO: PATRJCKBARNES, 0
FROM: MIKE KELLY
SUBJECT: EVALUATION OFT
•· ---~ >)Wa --□ n
DEHNR
I have reviewed your comments concerning the Phase I reports submitted by Eco Logic
and ETG Environmental. Perhaps I had in error assumed, based on the amount of money
estimated for completing this project, that there would be a detailed report on the comparisons of
these technologies with sound technical and scientific reasons for selection. Although several
good points have been raised (especially in Ted Hortenstine's review), we have not done enough
to make. the appropriate decision on which technology to pursue.
Let me remind you that we are supposed to be looking at the actual "technology" and not
at the companies involved. Many of your comments were directed toward the specific company
(such as more experience in actual projects-which may or may not be accurate), but the decision
needs to be based on the ability of the specific technology to be used to BEST DETOXIFY the
soil in the SAFEST manner possible.
I have already been accused of holding up this process, however, the selection process is
being held up because the job you all contracted for has not been done properly, and it will be
held up even more if I have to do the work to appropriately analyze and select the technology so
that a contract for Phase II to a specific company can be justified. Not only does the contract
need to be justified, we also need to be certain that the choice is the best-because that is what it
is--the choice--to be recommended for detoxification. Many of the questions you mentioned
were actually raised, and for the most part answered, by the vendors themselves. For instance,
use of a lower detection limit in analytical testing does not mean that one treatment technology is
better than the other--it doesn't necessarily have anything to do with the technology except to
look at the results in comparison to the cleanup goals. Also, it is certainly well known that the
cost of a cleanup is directly proportional to the cleanup levels. I mean that is a no-brainer--but
that does not make the treatment technology better than another one. We state what the cleanup
levels are to be. Neither does a draft report from one vendor mean the other's treatment
technology is better. ·
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post-Con6umer Paper
Memorandum to Barnes and Hirschhorn
September 4, 1997
I am working on a list of questions to be sent to each vendor for their response (Patrick, I
have not received the ones you mentioned to me last Friday; Joel, I will send your list on Eco
Logic as is, and extract out of the ETG note your questions in order to avoid sending the other
information on vendor selection recommendation). I also will ask for more specific information
on the safety aspects as that was one primary category we specified in the RFP.
The science advisors were supposed to put together a criteria for evaluation of the
treatment technologies (based on notes/minutes from the last Working Group Meeting), however,
except for the comments presented by Patrick, that has not been done. Please complete this by
the end of next week. I recommend that more emphasis be placed on the technology and
feasibility of full-scale treatment, and most importantly, safety. Since detoxification will be sent
out as a separate and new bid request once funding is available (and it is possible that neither one
of these companies would actually qualify or be selected), it is not nearly as important to judge
the ability of these vendors to "mobilize" as it is to look at the ease of mobilization and safety
aspects of a certain treatment technology.
Please have any additional questions or comments to me by noon Monday so I can ask
the vendors to finalize their report / or answer the questions in order for us to complete the task at
hand. I will ask that they respond by the following week and hopefully by the end of the month
have the contract in place for the Phase II report. I will ask in the contract for the vendor to
provide the draft Phase II within 30 days in lieu of the 75 days in the original RFP since both
vendors were later getting the trials done than we had anticipated when the schedule was laid out,
and I do not think this will be a problem based on the information I have seen; if it is, we will
have to adjust accordingly.
Doris has notified me that there will be a working group meeting on Monday, the 22nd of
September. Does this mean you will have the site assessment report completed by the 15th as
you had previously said? and that it will be presented that night?
Call me if you have any questions.
Copy: Bill Meyer
Henry Lancaster
Dollie Burwell
Pat Williamson
Michael Bryant (P&C)
F'CB l.1_ll]F:f<INl3 13FIIUF·
--· I -\· /, I 1···-1,/\ '-· J_ I l .. '
Fax :91'9-257-1 000 1-·. Ul
a~ible interim uses are as a it pa.sst:d 7-1, with Fisher Yoti.ri.g no. _
7 Warren group~·~7
I . -; optimistic abou t
ruling on PCBs
ly CHARLIE RICHARDS
Deity Dispttcl'i Writer _
WARRENTON -The l()('.ll}-
state working group eo:ooerned
with the man8.i9mfJnt of the
st.ab!'ll PCB landfill in Warm1
. i County took a poaitive pd opti-
utic view Friday of thiJ "'k'•
EPA notice requiring 1Jt9.te
action at the landfill.
· "We ai-e pleued thatEPA
teiipoftdf!d tt, att1 a7!1Clh'fl. or
ooo-compliance," said a formal
st.tt2ment from the Joint War-
1 ren County/State PCB !Aiidfill
Work.inir Group.
The eroup, made up of local
citite~, l'l!present.tives of envi•
ronment&l organization, and
state official!, interpreted the
federal a,ency'g order u, the
atate a.a linkiDi •compliance to
1
1 detolifkation."
The EPA Notice of Non-Com-
1
j plia.nce to the N.C. Diviaion of
Waate Manag•m•nt dealt with
morutoring of the landfill and
t.be remo-val of leachate that hae
accumulated in the landfill.
The key it41m in the NON for
thote concerned about the aafety
I of t.h0 landfill eoi:ataming tht
_ toxic ebetnical PCB ia EPA'• com-
ment that the 1tat.e nHd not
consider replacing a cover '}'I-
t.em if it plmt to exc:avat.e and
destroy th@ PCB, in the neat
futw-e.
"Our goal i8 detoufication of
th~ landfill and •e 1Vill continue
to work toward that end,• 11aid ..
Do~ Burwell, a Wan-en resi-
dent who c.o-che.i.rti the Work.ini'
Group.
'11le formal st.&~ment 1aid the
p-oup erpe& th11 ~te to tnfortn
EPA in itA corre<."ti.ve action pl~
th&t it intends w auk funding
(or detn:rification of th€ landfill
nmt ,ear when the legu,lat'.1re i~
baa m ~on• tnd that tht:
etate will •chooee detomicatior:
over repla~mfnt of the cover
-,.iem." ~,
Since it!l establishment in
1994, tbe Wcrkint Group ha.,;
used a state appropri1ti0n to
hire lciente adViteN and cot -
duct tffu tD detemine the f eet1i-
bility and methociolOKY for d~ti>x -
ific&tion.
~e expect to choo~ B. detox!-
tkat:ion technology by eru-ly fall
8.Dd w comple~ • dcaign plan for
that t.e<.-hnology by t.ht firnt 0f
the year: said t.he utaternent.
Thoae con('erned about th
landfill have been aslrnrec
repeatedly of tht: state's in~nt r,,:
clean up the landfill when fea ~,-
ble, but it h118 also been 8t.ated
oft.et) that a sperial appropn a •
tion will be ~uired of the legia-
latve.
While fonnai quotes on t.te
~t ~vt not yet been obtained.
it hai been estimated it could
coo $215 milliot..
Th! Work.i:og Gl'Oup st.a~ 1t
hope, to '1low the tupay~rn that
the cleall up a the 'niore coat .
e~ective eolution• to the land.fill
problem.
•
F'CB l_1.ll]FK I t'-H3 13F:DUF' Si:ap -03-97 04:07P PCB, from page one thst th~ state replac~ th~ cov,r syrlem over the landfill, in addi-tion to upgrading the pumping &y!3tem for leacha~ removal. The NON Bd&, •EPA does not 1 reoommer.d replAcing -the cov~r sy5Um if North Carolina plans U> ei:cavatt and destroy PCBe in the landfill in the Mat future _'" ·
The one requirement con-
tamed in the NO~ also may be
tncour9.ilng to tht concerned
citizens.
EPA requires the state to i;ub,.
mit a plan within 90 day.s to
tlinti.nate leachate Crom the
landfill.
The first pha21e of the plan
must provide for a pumpin( 11y»-
l ~m to operate on a •more-or-lesa
continuoia basis.•
The 9eeond pha~ would con-
cem replacing ~ cover sy,tem.
But the state can avoid replac-
ing the cover by submittinr an
appli cation {or an altematt!
mtthod 1Jf PCB digpo11al for the ·
landfill soil within a year.
· The EPA imposed no fin~a iD
Thtlt9<iay's n-0~ice. but it ',l,l.ffled
r,f ~sible fulea If the state fail.ii
to implement recorrunendltion1
in a timely manner.
lil addition to an UPCf aded
p\Wlpi.ng eystem and • po81ible
new cover, the NON recommend•
e-d monthly monironng of the
leachate and ,emi-annual moni-
toring of surf ace and &'t'Ound
water.
EPA said the original 1979
permit required the statt to
inatall a leachate collection 1y,.
um, b~t tht state ha, removed
•onJy smill aniount," aince the
landfill wu inst:ill<'d.
It said "there is at lcatit 10 fed
of st.anding liqUJd over the bot-
tom liner."-meiming th• ~lee•
tinn i.y~tem is not perfl'lrm11'i.
NAMES, PHONE NUMBERS, AND FAX NUMBERS
OF REGIONAL PCB STAFF
(PCB Coordinators are in bold type)
September 2, 1997
Region 1
Kim Tisa [phone]
Abdi Mohamoud [phone]
Fax [phone]
Region 2
Dave Greenlaw [phone]
Dan Kraft [phone]
Fax [phone]
Region 3
Ed Cohen [phone]
Charlene Creamer [phone]
Jose' Jimenez [phone]
Fax [phone]
Region 4
Stuart Perry
Craig Brown
Fax
Region 5
( 404) 562-8980
[phone]
( 404) 562-8972
Tony Martig [phone]
Priscilla Fonseca [phone]
John Connell [phone]
Steve Johnson [phone]
(Permit Writer, Geologist)
Jean Greensley [phone] (Permit Writer, Geologist)
Fax [phone]
Region 6
Lou Roberts
Donna Mullins
[phone]
[phone]
::?ME F:HLE I t3H, t·.JC ID :1-919-790 -9827 SEF' Ci2 'J7 -. ....
FAX TRANSMITTAL
COVER SHEET
j URGENT TRANSMISSION
· Please Forward Immediately •~!!! ENGINEERING • TESTING
~.:ti
S&ME, Inc. J. ~.
3100 Spring Forest Rood r,4,rr-
Rolelgh, North Carolina ~o.,:.
[phone] ,,,,,0-1 l
Fox [phone] ~"'
I ~J/t..
TO: H~E keL4' -.. ..J
FIRM: -r,, V 16! 01'.) 6 F WWE: M IHJAGe:-1#->1:
~O CATION: ~IC.I:\ ]I~ -!JbO~
FROM : WAt,,T l;;fck;'.htfn-l
RALEIGH, NORTH CAROLINA
DATE: 9 ; .l_; ~ TIME:~pm
RETURN FAX NUMBER: [phone]
NUMBER OF PAGES INCLUDING COVER SHEET:
(If all pages not rec$ived, call [phone]
COMMENTS: _ ____LH--LLJI~=-------------------------
'
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Tue /NVol<.E.
:TH€ AMruNT
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w/\~ 11 o, Loo , We H Av~ 13,65 tJ PAI b Fob it> 11 134:{o. 5£1--, j
IZEMAIN)M-:to ~ '.PAlb DN '.1~~ )NV~l'-6 IS 5?44-,4_4-_
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Ct¥<t: ) i,JiC> ~ \6, AN b :4 bV Ii&, '
S&M E Project Number: ----~---------...._ ________ _
I
This cover sneet and the documents accompanying tnis telecopy transmission contain information from Se.ME. Inc .. wn,cn is confid&nt1f!! a,•c :.;,;at:
privileged The informat1011 is intended only tor the use of the individual or entity named on~his transmission shtiet If yo:.i ere not the intended rec::i:~~·t .,,,; .:i:~
here!:>y notified that any d1sc1osure. copying. distribution or the taking of any action 111 reliance on th0so documents 1s stnc'.i·1 pronit:,ltecl.
·~·•._:•:I I L 1·· .. II L L..l..'•-'I I, 1·1•._.
♦s&ME.
•
$&ME.Inc.
3100 Spri"9 For~ l\ood
PO Box 58069 (27658-6069)
~l~f9h, Nonh COfot\no 27W4
[phone]
Fax[phone]
MAILING ADDRESS:
HCDF.JIHR -Dllf
DIVISION OF WASTE MANAGEMENT
P.O, OOX 27687
RALEIGH ,NC 27611-7687
FED I D #56-0791580 ...
CLIENT P.O. NO. CONTRACT NO. INDIVIDUAL AUTHORIZING WORK
CONTRACT H 7019 Pl061-96V KR. HIKE KELLY
" WJIH:13755
INVOICE-E 13755
Pl8a&e Mail R8mlttanc11 to:
P.O. Box 651399
Cnarle>ite, NC 2a2as.13g9
Please return one copy
of Invoice with payment
INVOICED AND CHARGED TO THE ACCOUNT C.
•
-CLIENT CODE STATE WORK DATE PERFORMED IN
E01179 1 NC 5/27 /j7•05
TERMS: NET 30 DAYS, 1.5% INTEREST ?EA MONTH THEREAFTER .
OUR DEPT. NO.
051· 0.00 0542-0.00
052-0.00 0543-0.00
05)• 0,00 059w 0,00
0541 11,185.15 9999-51905.85
1, PRE-NOB/MOSILI2ATIOH
LABOR
2. OH-SITE ACTIVI'l'IES ... -··-------------··-·-KQUIPHM/SUPPLIES
LAOOR
MISC. EXPOS~
SUBrolfTR}.C'l'ORS
3. PRroFJ:T HAKAGllMElff
LAroR . : . ,..;.,,. '.
;_·~· ))~ ·,
..... ._1,_i:•~"':-::
. ·•· -\, ... t.",;
'"~•-"-~~?~j-:
' .• •::~M;!!'
OUR JOB NO.
1054-97-670
1 1 ,..._,, h r-:-
. ' ' .4 ,.•
7 , 7 ~:! (, • " :'' +
·,,e 1 s:,•!:>o -
---s~90 S •8~ .. ,,
JOB NAME OR SERVICE RENDERED
· EVALUATE EXISTING INTEGRITY OF SURFACE LHIER/C.U'
WARREN coum PCB LANDFILL
WARREN OJUHTY , MC
FOR SERVICES RENDERED 4/20/97 -5/17/97
@ $ 1,638.00 I $ 1,63 ;),,00 ------.... -. .-.-
SUBTOTAL $ 1163 3.0C
@ $ 2,815.00 I $ 2181 5.00
~ $ 6, 758.()() I $ 6,758.00
@ $ 140.0() I $ 140.0C:
@ $ 5,015.00 I c!: 5,015.00 '{
------------SUBTOTH $ 14,723 .00
1.00 @ $ 725.0() / $ i25.00
SUBTOTAL$ 725.00
INVOICE TOTAL$ 17,091.00
ID:1-919-790 -9827 SEP 02 '97 9:27 No .003 P.O~
II' •. I
DMSlON OF WASTE ~!ANAOEMENT
~BRtN CQJDSTY fCB I1ANPEILL
i
ADDE:',llJJM IP REQUESI EPB PRQPOSAJ..S
DUUA TE J11fli2110on ~bu It I9U
. EVALUATION OF txlSTING INTEGRITY fF SURFICIAL L➔R SYSTEM/CAP
:ITDf PU.MOD
MOBILIZATION
1µBOR I I
1638,00
~iJlPMENT/
StnPLIES o.oo
BUB•
CONTRACTORS o.oo
f'!ISCELLANl!OUS I : o.oo
rotAL
:TEM
OR
: UIPMENT/
'>UPPLIES
nm.
c:ONTR.ACTORS
IISCELt.ANnOUS
'tOTAL
I
I 1638.00 I
PRE•MOB
MOBJLIZA TYON
' 1000,00 I
o.oo
o.oo
0,00
·1000.00
~mpany S&ME, Iuc..
l
ONSITE I
PROJE~ TOTAL ActlVITIES M.ANAG .MENT
6BR.OO I nsloo 9121 .00
' !
2815,00 0, 00 2815.00 1
o.bo ~
5015.00 so1s.oc l
l I 140.00 o. DO 140. 00 i
I I ! l47j8,00 725, DO 17091. 00 1
ON$nE PROJEC'I) I TOT AL
AcnVITIES MANAOEMENT
' ' t 1so1.do 11921.00 l 4t.?? Mi
597a.oo o.ep 5973,00
915,00 o.oo t20395,00
175 .oo o.ol 175.00
l89Qi.. nn 1501.01 21485.00
istanawre .~ ~ /
. I
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;
i l
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-..
INVOICE E 136 os
5&ME, Inc.
-'.l100 Spnng FOl'esr P.ood
P.O. Oox 58069 (27658-806Q)
"°lelgh. Norm Coroli:"la 27604
(Q19) 872·2660
Fax (91Q) 790-9827
Please M~il Rem,nanc,:, to
P.,O. Box 651399
Charlono, NC 23:265-13g;
Please rn1uro ~~!! cop:1
ol invoice with o.1ymoni
MAILING ADDRESS:
• NCDEHNR -DDl
INVOICED ANO CHARGED TO THE ACC OUNT :
• DIVISIO?I or ii.l.STE l{}JIAGEMEtl1'
P.O. BOX 27687
RALEIGH ,llC 27611-7687
FED. 1.D. #56-0791580
CLIENT P.O. NO. CONTRACT NO. INDIVIDUAL AUTHORIZING WORK
CONTR.~CT N 7019 Pl061•96V MR. MIKE KELLY
CLIENT CODE STATE WORK
PERFORMED IN
E0ll 79 l !JC I
TERMS: NET 30 DAYS. 1.5•\: INTERES7 PER rvlONTH TH::F,::.:.:=-TEF;
DATE
4 :s ~i'i.i)~
OUR DEPT. NO. OUR JOB NO. JOB NAME OR SERVICE RENDE RED
051-
052·
053-
0541
0542-
0543-
059-
5,744.44 9999-
1054-97-670
S.l.HPLE hll:1.LYSIS
I\ARREJI comm PCB UJIDFILL
I liARREH COUNTY I llC
FOR SERVICES REJIDERED 2/23 /97 -3,'22/~:
,111,l.LYS!S OF SAMPLES OBT.l.I!IED FROH 2 BOREHOLES LOO LS
FILE COPY
/05t/-C/7--t_c-;D . ' r~
SUBT◊EL S
IIF.'OICE TOT.;L S
,;: ,.., l J
.) : , 11 , •--;
S&ME RALEI GH , NC ID:1-919-790-982 7 SEP 02 '97
........
:i ·.J.. 1-n; --
April 15, 1997
Mr. Michael Kelly, Deputy Director
Division of Waste Management
North Carolina Department of Environment, Health and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
-Reference: Invoice for Laboratory Services
Change Order to Contract
Warren County PCB Landfill
Warren County, North Carolina
S&ME Project 1054-97--670
Dear Mr. Kelly:
Please find attached our invoice number E 13605 for $S7 44.44. This invoice covers the
costs of preparing, shipping, and testing of the soil samples obtained during drilling of the
tVvO landfill borings. The analyses were performed in accordance with our proposal and
your issuance of a change order to the original contrapt. Eight copies of the laboratory
report have been submitted to you previously. Pleas~ call us at [phone] if you
have any questions regarding the invoice, the site activities completed under this scope
of work, or if we can be of further service.
Sincerely,
S&ME, INC.
¾&-c (J deiJ~,_vy-,,~
Walter J. Beckwith; P.G.
Senior Project Geologist
97~b_lnv.ttr
5&ME.. Inc . .3100 Spring Forest l\ood, l\olelgh, North CarollliC 27616, [phone]. Fax [phone]
Molllng addr8ss: P.O. Dox 36069, l\olelgh, North Garollnc 27658-6069
State of North Caro.
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Jonathon B. Howes. Secretary
WIiiiam L. Meyer. Director
March 12, 1997
To: Mr. Walt Beckwith, P.O., S&ME, Inc.
From: William Meyer, Director, Division of Waste Management
RE: Approval of Additional Laboratory Testing, Warren County PCB Landfill
Dear Mr. Beckwith,
This memorandum approves the additional scope of work as prepared L:i. your March 11, 1997
draft memo to Ed Mussler .. The Division approves the additional tests, as outlined in your letter,
on the samples obtained from the two boreholes in the PCB landfill. The said amount of the
change is not to exceed $5744.44 (Fivethousand, seven hundred and forty~ four dollars and fortt;-
four cents) as proposed in your memo.
Please send the finalized scope of work, testing plan, and the appropriate change order
paperwork to my attention.
Sincerely, n;c;;an•::5
William Meyer ~
Director
wm/efm
cc: Mike Kelly
Brenda Rivers
Ed Mussler
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
•1~61., FAX [phone] ._ . ~ An Equol Opportunity Affirrnatlve Action Emc.i,c ver Wfiffjj§Pi11, 50% recycled/10% post-consumer pcpe~
SHH
AUG 29 '97 02=44PM CLAYTON&CLAYTON,PA .
.--,....-, ~-/,~<c/..
Mailing Address:
Post Office Box 41 403
Raleigh NC 27629-1403
THE CLAYTON LAW FIRM, P.A.
A PROFESSIONAL CORPORATION
SMOKETREE TOWER
3100 SMOKETREE COURT, SUITE 420
RALEIGH, NORTH CAROLINA 27604
TELEFAX TRANSMISSION COVER SHEET
DATE: August 29, 1997
NUMBER OF PAGES INCLUDING COVER: 2
TO: PAT WILLIAMSON
TELEFAXNUMBER: 71S~3605
FROM: Dollie B. Burwell
REGARDING: PRESS RELEASE/PCB WORKING GROUP
NOTICE:
P.1
[phone]
Fax [phone]
THE INFORMATION CONTAINED lN TIIIS FACSIMILE MESSAGE IS ATTORNEY PRIVILEGED AND
CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY
NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU
ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS
COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HA VE RECEIVED THIS COMMUNICATION
IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER :SY TELEPHONE AND RETURN THE
ORIGINAL MESSAGE TO THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE.
AUPl..B':l UJ~~lu-i~2~~j~p CLA\'TP~fr;:~~£12Ji' Pf ...;JO. Aug 29 '97 13:33 P. 01 F". 2
' JOINT WARREN COUN1Y
WORKING
Release : Jmmediaiely
EPA NON•COMPLIANCE NOTICE ISSUED TO STATE:
LOCAL WORKING GROUP NOTIFIED
WAR.RENTON-The Joint Warren County/State PCB Landfill Working Group (Working Group)
wu notified 'nlunday August 28. 1997 that the Nonh Carolina Department of Environment, Health
and Natural Resources (DBHNll) Divis.ion of Waste Management had been issued a notice of non-
compliance by the United States Environmental Protection Agency (EPA),
EPA in its letter of non-compliance states 11EP A recolllizes that eliminating the large amount of
leachate that hu ac.cumulated in the Warren County Landtill (WCLF) may take several years due to
the degrmed condition and/or limited capacity of the Leachate Collection System drainase layer and
sump . There may also be more than one contributing factor to leaehat~ production. If the leachate
build-up was due only to stonn water introduce during the operational period. then upgrading the
leachate pumping system would be sufficient to correct the problem. There is some evidence
indicating that the leachate build-up is due in pan to infiltration of precipitation through the landfill
cover system. Therefore, replacing the cover system, in addition to the pump system upgrade may
also be necessary.'' A1Ao in it$ non-(;Ompliance letter EPA indicated that another factor that must be
considered in addreuin,g the leachate management problems is North Carolina's pla.n to detoxify the
WCLF contents and they do not recommend replacing the cover system if North Carolina plans to
excavate and destroy PCBs in the landfill in the near future.
We are pleued that EPA responded to our concerns of'non-compliance. We believe that based on
their two phue continsency plan, that they have considered our request of October 25, J 996 to link
compliance to detoxification.
Since the establishment of the Working Group in 1994, we have hired two Science Advisors, who
have been wisting us in LX>llecting and analyzing data fi-om the landfill and detennining the feasibility
and availability of a technology for detoxification. We have done a site assessment and evaluation,
have had two companies perform pilot studies on soil from the landfill for detoxification and we are
in the process of evaluating the data. We expect to choose a detox.ificatio n technology by early fall
and to complete a design plan for that te<;hnology by the first of the ye.ar, Therefore~ we expect
DEHNR to inform EPA in the required corrective action plan that tbey along with the Working
Group. intend to seek funding for detoxification of the landfill next year when the legislature is back
in session and that they (DEHNR) will take advantage of EP A's otl'er to choose detoxification over
replacement of the cover system,
We plan to recommend to the State a feasible and safe technology that meeti; the requirements for
detoxifying the landfill established by the Go~emor years ago when the landfill was first constructed..
In so doing. we hope to show the tax payers of North Carolina that, in the long run, a detoxification
solution is the more cost-effective solution to all the problems of the landfill .
"Our goal is detoxification of the landfill and we will continue to work toward that end" said Dollie
B. Burwell, Co-Chair of the Workin, Group.
720 Ridgeway Street
Warrenton, N. C. 27S89
Phone [phone] -Fax [phone]
~ ·1 ~c. '
rt-~
Y~-r
ro..:f /1,l C, ~
PCB WJRKING GRC~P Fax:[phone] F·. 01
~CA-if~
J~5
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
CO-CIIAJRS.-
DOUJE B. BURWEU
HENRY LANCASTER
FAX COVER SHEET
TO:
FROM:
DATE:
Laura Butler
Tommy Cline
Nan Freeland
Deborah Ferruccio
Ken F erruccio
Mike Kelly
Herny Lancaster
Sharon Moore
Dennis Retzlaff
Bobbie Riley
Jim Warren
Doris Fleetwood, Secretary
PCB Working Group
August 29, 1997
Number of pages (including cover sheet): 6
Message:
Working Group Members:
919-733-5317
919-733-1431
919~832-9100
919-257-2604
919-257-2604
919-715-3605
919-175-3060
919-733-2120
919-257-2897
919-431-1453
919-493-6614
Please find memos from Joel and Patrick and a press release from the Working Group in response
to DEHNR receipt of a Notice of Non-compliance from EPA. We apologize to those of you who
were not able to participate in the drafting of this press release
F'CB l_1JIJF:fH-ll3 13RIJUF· Fax :91 9-2::,7-1000 Hug 29 '97 1::,:28 P. 02
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
Release: Immediately Date; August 29, 1997
EPA NON-COMPLIANCE NOTICE ISSUED TO STA TE:
LOCAL WORKING GROUP NOTIFIED
WARRENTON -The Joint Warren County/State PCB Landfill Working Group (Working Group)
was notified Thursday August 28, 1997 that the North Carolina Department of Environment, Health
and Natural Resources (DEHNR) Division of Waste Management had been issued a notice of non-
compliance by the United States Environmental Protection Agency (EPA).
EPA in its letter of non-compliance states "EPA recognizes that eliminating the large amount of
leAChate that has accumulated in the Warren County Landfill (WCLF) may take several years due to
the degraded condition an<Vor limited capacity of the Leachate Collection System drainage layer and
sump. There may also be more than one contributing factor to leachate production. If the leachate
build-up was due only to storm water introduce during the operational period, then upgrading the
leachate pumping system would be sufficient to correct the problem. There is some evidence
indicating that the leachate build-up is due in part to infiltration of precipitation through the landfill
cover system. Therefore, replacing the cover system, in addition to the pump system upgrade may
also be necessary. 11 AJso in its non-compliance letter EPA indicated that another factor that must be
considered in addressing the leachate management problems is North Carolina's plan to detoxify the
WCLF contents and they do not recommend replacing the cover system if North Carolina plans to
excavate and destroy PCBs in the landfill in the near future.
We are pleased that EPA responded to our concerns of non-compl iance. We believe that based on
their two phase contingency plan., that they have cons.idered our request of October 25 , 1996 to link
compliance to detox.ification.
Since the establishment of the Working Group in 1994, we have hired two Science Advisors, who
have bren assisting us in collecting and analyzing data from the landfill and determining the feasibility
and availability of a technology for detoxification. We have done a site assessment and evaluation,
have had two companies perfonn pilot studies on soil from the landfill for detoxification and we are
in the process of evaluating the data. We expect to choose a detoxification technology by early fall
and to complete a design plan for that technology by the first of the year. Therefore, we expect
DEHNR to inform EPA in the required corrective action plan that they along with the Working
Group, intend to seek funding for detoxification of the landfill next year when the legislature is back
in se~ion and that they (DEHNR) will take advantage of EP A's offer to choose detoxification over
replacement of the cover system.
We plan to recommend to the State a feasible and safe technology that meets the requirements for
detoxifying the landfill established by the Governor years ago when the landfill was first constructed.
In so doing. we hope to show the tax payers of North Carolina that, in the long run, a detoxification
solution is the more cost-effective solution to all the problems of the landfill .
"Our goal is detoxification of the landfill and we will continue to work toward that end" said Dollie
B. Burwell, Co-Chair of the Working Group
720 Ridgeway Street
Warrenton, N. C. 27589
Phone [phone] -Fax 919-257-lO00
PCB 1.dCIRK I t·~G l3F;[IUF' Fa.:x::919-257-1000
August 29, 1997 ......................................................... by FAX (2 pages)
To: Working Group
Through: Doris by fax wherever possible
hom: Joel Hirschhorn
F·. 03
I\Ci BeEommtndatignybon..t dtnfl_pJJSS xelcast ln_J.f:SR_QDse to ElAJt.JUW)m pliaps.c,.9.oilss
tJ 1ta1t
Smee I wu unable to participate i.n the hutlly called phone conf~tence call I am submitting the~e
conuuettts .
. 1) t have serious concern~ about the statement: "We plan to recommend to the State ll fe:tsible
and nfe techn()logy and show to the tllx psyeu that a detoxilkation solution is the. mote co~t
effective solutiot.t to all the problems of U,e landfill ... My thief concetn is ~yiug that we wiU he
able to show that detox Is the most cost effective soluli011. I am not convinced tlu.t ,-..·e can do
that, .Primai-ily because of the much bjghe:r co~ of deto,c than the ,lterutive oftepairittg t.be
landfill (including fixing I.he le1cbate collection 5)·stem. replacing the eover !-)'stem. and long term
monitt'J ing).
I recommend th•t the prus release ,ue somdhin& likt: ''\Vt pltn to recommend to the
State I feadble • .,d ufe technology ti.tat meet. the 1·equirtmtnt11 for detoxifying the landrdl
established by the Governor yean aao when tltt landf di was fint t(uutruct.ed.''
2) I am concem.ed about the th:nmg of choMing a dclnx tech.nology and the ~utemrnt th3.t thi~
will be done by euly faU. In hct, I hnve already made my choice and accordio! to a phone
con\'eJSation with Pat Btunes he agrees with my selection ofETO. I have not ,eceivcd any
re~ponse to my memo to Mike Kelly some days 11go, asking whether the state could •K'ee ..,,,;th
this choice. My chief con.cem ls that there may be unnecessary delay in making this key dec~iou.
I am particularly di.stutbed by the state'~ icdon& sa.nctloning I delay by Eco Logic in .finali.rinix its
Pl11~c 1 rq,ort. I thln\ we should sel.ect ETG next week 1.11d proceed with the nec(:s~uy
papen"Vork to in..itiate Phase ll. I recommend that Dollie ube this issue directly with tither
Bill or l\l.lke.
3) I w1nt the Working Gtoup to fuUy appreciate the fact that the Er A Notice give~ the state onty
90 days to submit its coirective action plan. I a,u \'t•·y tc:n1ttrdtd that the sta te m•)' takt the
position that it canllot Invoke ddot beuu~e the lrii!il1tun will not h•n fornu1lly
apprc,priated the run funding for dtto1. This posmon wH •rtkul1ttd hy Bill 1'1l'Jff. ,-t •
111ttti11c, Tlltnfore, the corredive 1c:tion plan will prob1bly h:ulude npluenuut of the
cover system , \'1hkh if it ottuu would probably foreclose detox.
l
F·CB l.dCIF.J<I N13 GRCIUP Au,j 29 '97 lS, :30 F·. 04
. EPA 11lso gives one year for the sute to submit An application for obtaining EPA ap r ro\·~l for
detox, which also would seem to 1equfre An initi111 commitment lo detox in the cont 1.:tivt actiou
pl.aJl to be submitted witltin 90 day&.
la ,,iew of Chese ton1pltx And ddiute timing iiuut1 I rtcon,mtnd that tht 11ress rtltUt
i11dude the following: "lht }York01i-G.1ouu notes t.ha .. l Jt ia ntteU.Anl.QLt.b_~idP.mtUSl
fotm • l.b:Jndiilt! tta l.uw!Uo.!U9iu,ruJ__d t t .!> ~ if>~_flJto.,to{ tht.la u d fill 11u.0R,t . .u_ PP uj bk_~
lhuJltllNlltagJgJJ»de lt, inJen.tlo_l1JQ...v.st dttoxifiwlon 1n tht tonec:tJYt-11.ttlon..pJan.J.&
muat 1ubmit to EPA irlt.Qua 90 din. II
Please understand that tWs statement is absolutely crucial
for tile Working Grou1, to 1n1bllcly state, because if this does
not happen, then DEllNlt ,viii probably make a commitment
to replacing the cover system and NOT 1'0 DE'l'OX
Thls is such an Important l8rne that t hope Ou,t no prets reluse will be lnued by the
·work.Ing Group until • majorlty of the \\!orking Group agrtts to n~ce,ury statements.
2
PCB WORK ING GROUP Fax :[phone] Rug 29 '97 15:30 F'. C6
BF A Environmental Consultants -.......,..rz FL O W rz =>~ ...:.:z = Barnes, Ferland and Associates, Inc.
MEMORANDUM BFA #Q5-0l7
TO:
FROM :
DATE: Aueust 29, 1997
SUBJECT: Noncompliance Order and Work.Ing Group Press Release
Given all possible outcomes of the Working Group's request for an EPA CompHimce Inspection .
I believe th.it the Notice of Non-Compliance represents a strong victory for the Working Group
:and the Warren County Community.
The EF A ha!! link~d dtto,d ncaticm to the issue of non-complian~e which was, as far a.s I
understand, the Working Group's chief objectJve under this matter. It i5 obvious ftom tht
detoxification, friendly nature of the notice that we have strong supporters at the top. You
!hould all take a brief mom~nt to pat yourselves on the back.
The liner system, in particular the upper one, is obviously in poor conditiC'ln TI,is hag been
lecag.nized by th.e EPA and they have given the State I year to ~ubmit an application for an
alternative rr!,nediat method to bring this condition into complianc.e. This works very well with
tht current detoxification effort.
I don't believe that EPA has in any way put forth a position which favc,rs a new cap over the
infinitely more superior goal of detoxification. Moreover, the notice docs not in any way force
lhe State to act in a band-aid fashion.
Once aiain, I believe) a.iven the possibilities , this is a very positive outcome,
_____ .._. ..... -
Po■t-lt' Fax Nole 7671
10
3655 Maguire Boulevard • Suite 150 • Otlando, Florid8 32803
Office [phone] • Fax [phone]
,.,
~:B WJRK ING GFlJUP Fax :919-257-l COO Rug 29 '97 15:30 F·. 06
Augnst 29, t 997 ......................................................... by FAX (1 p2ge)
Io: Workin.g Group
I hroug.h: Doris by f.ax wherever possibfo
from: Joel Hi.ucbhom
~<lacnt tp res:om91_ssd1.C!20• •~gut dcpft prcu ql~,!H in rnpow.Jg ElA
U .DUlmRllitPtC nqtitc to HW
I have received anoth~r version of the draft preM releue. However, I still believe that. sotnething
very necessary ls missing. I learned a.tlei my first memo this morning that the legislature VCI)'
recently went out of,ession. Therefore, I recommend using the following language (which I ha,·e
presented and discussed with Dollie on the phone) instead o(the statement presented at the end of
my .first memo:
"The Working Group expects DEHNR to inform EPA in the required conective nction pb.n th,t
it intends to a~k funding fo1 detoxification of the landfill next year \\nett the legisbtrue i& btck in
se~sion. and, therefore, that it will take advantage of EPA '1 offer to choo&e detoxification over
1eplacemet:1.t o{ the cover system."
My objective is to get Bill Meyer to make a cletr commitment to detox and to s~ek funding for
detox in the plan .be submits to EPA. Bill could chooie to submit his plan to EPA and make no
commitment to detoxification. He simply could say that during the remaining period the 5-tatc "ill
examine detox and funding for it ffld either submit ,m application for m 1ltem1te method of PCB
disposal IF it has been fonded, or implement the cover replacement option some time after the one
ycu period.
I 1lso want to eruph.asiie that the state has obtained a major advutage in avoiding detox by the
fact the EPA hts absolutely required the state to fix the leach.ate collection system. In other
words, the ~ate will be moving Along a track to repair the land.fill uther th~ detoxify it. Those
parties opposed to spending $23 million on detox "ill say: look we b1ve alrea dy spent some
money on repairing the ltndfill and the federal EPA has wd we can repl1ce the covu system llio
Together with long term monitoring to ensure th.e pubH.e th.at nothing nasty i& leaking into the
environment, those puties would argue thit for perhaps less than $ l million the landfill will be
fixed and safe.
I still, therefore, oppose the statement ln the revised press release th1t the Working OJoup
belie\:eS i\ cao, tiiow th1.1t 11in the long rul), a detoxificlltion solution b the more co!Jt-c.tfcctive
solution to all the problems of the landfill." I 1tm very, vety experienced in remedy selection for
cleanup sites, including the analysis of alternatives. I do not beli~·e th1tt it is wise to defend detox
on the btsi9 of cost-effectiveness, because it would b~ incredibly difficult to make • det11iled,
quantitative :t.balysis that objectively shows mote dolbr benefits from spending $25 million rath~
tblll pe1h1ps $ 1 million.
.:..•.
SEP-03-97 13 ,34 FROM ,REGION 4 PESTICIDES ID ,404 562 8973 PAGE
MEMORANDUM
REGJON4
Science and Ecosystem Support Division
980 College Station Road
Athens, Georgia ~2720
August 22, 1997
SUBJECT: Results of Air Study at Warren County Landfill, North Carolina
Project Number 97-0345
TO:
FROM:
, ,
/
Beverly Hudson ,,,r")
Remedial Project Man~ ---?
Tim Slagle ~~
Air Team ,,/
/ Jon Vail !l 4~---'/'--
/,.'°'-Superf~tam ·
We have attached the final copy of the results of the August 5 and 6, 1997 air
study that SESD conducted at Warren County Landfill. If you have any questions
please feel free to give Tim at [phone], or Jon at (706) 355-$611 a call.
cc: Steve Hall
Bill Bokey
Archie lee
Craig Brown
/
OPTtOll:AI. FORM 99 (7--90)
FAX TRANSMITTAL
To /'-1}
NSN ~-01-311-l"368
7
INTRODUCTION
AIR STUDY
WARREN COUNTY LANDFILL
NORTH CAROLINA
AUGUST 1997
On August 5 and 6, 1997, Tim Slagle and Jon Vail of the United States
Environmental Protection Agency {EPA), Region 4, Science and Ecosystem
Support Division (SESD) conducted an air quality study at Warren County Landfill,
North Carolina. The study was requested by Waste Management Division, North
Remedial Branch, to determine if PCBs (polychlorinated bi-phenyls) were being
emitted into the ambient air from the landfill.
STUDY AREA
The six air monitoring sites utilized during the study were located within the
fenced boundaries of the landfill (Figure 1) for security purposes. Two sites,
designated A and B, were established adjacent to the vent pipe at the center of
the landfill. Meteorological data consisting of wind speed and direction was
recorded at this sampling location for the duration of the air study. Meteorological
data was recorded at the top of the land fill because the surrounding terrain was
relatively free of obstructions. Site C was located at the northwest corner of the
landfill. Site D was located on the west side between sites E and C. Site E was
located at the southwest corner of the landfill. Site F was located near the
southeast corner of the landfill. The upwind measurements at Site C were used to
determine if any of the pollutants being measured were transported into the area
from other sources.
SAMPLING PROCEDURES
The Air PCB samples were collected by the high volume PUF!XAD method. The
sampling methodology conformed to T0-4 of the Compendium of Methods for the
Determination of Toxic Organic Compounds in Ambient Air. The high volume
sampler utilizes a glass fiber prefilter with polyurethane foam (PUF) and XAD
absorbent cartridge for collection of the compounds in ambient air. Approximately
210 M3 of air was sampled during the 24-hour sampling period.
1
..
SEP-03-97 13 ,35 FROM,REGION 4 PESTICIDES IO ,404 582 8973 PAGE
SAMPLE CUSTODY
At the start of the sampling event, an initial flow rate and an initial elapsed time
reading was recorded from each high volume sampler internal clock. The samplers
were then sealed with custody seals. During the 24--hour sampling event a guard
was posted and the samplers were checked periodically. At the conclusion of the
sampling event, the integrity of the custody seals was verified, .and a final flow
rate and elapsed time were recorded. The sampling cartridges were then returned
to individual sampling jars and sealed with custody tape.
QUALITY ASSURANCE
Co-located duplicate sets of PUF/XAD samplers were operated at sites A and 8-
They were used to show the precision of the monitoring method.
A field blank PUF/XAD cartridge was carried to the field but not exposed. It was
analyzed to document lack of contamination from field transport. Initial and final
flowrates were recorded for the samplers to verify flowrate stability.
ANALYTICAL PROCEDURES
The samples were analyzed by the EPA, Region 4, SESD laboratory in Athens,
Georgia, in accordance with the Analytical Support Branch Laboratory Operations
and Quality Control Manual, September 1990.
The media designed to collect PCBs in air was analyzed by the T0-4 procedure. A
surrogate mixture was added to each PUF/XAD cartridge before extraction. The
particulate filter and PUF/XAD cartridge was Soxhlet extracted for approximately
24 hours using a 5% ether in hexane solution. The sample extract was analyzed
for the target analytes listed in Table 1 by using a Gas Chromatograph equipped
with an Electron Capture Detector.
AIR RESULTS
No PCBs in ambient air at the landfill were detected at sub-microgram per cubic
meter concentrations. The air sample analysis data is attached as Table 2. The
prevailing wind was from the north northwest with an average speed of 2. 7 miles
per hour. Meteorological data is attached as Appendix 1 •
2
-...,
N l
-® ,
f
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6iEPA
-·-----~---··----·---··-··~•·-ii
I
.
I
ec
9
ea
eA
I : I
I •
• _ •• -•• -•• -•• -•• -•• -•• .-•• .I.
0 50 100 175 200
SCALE
(feet)
FIGURE 1 LEGEND:
400
WARREN COUNlY LANDFILL
WARREN COUNlY, NORTH CAROLINA
AUGUST 6, 1997
Ae SAMPLER LOCATION = METSTATION
2 VENTPIPE
Site location Analyte PCB-1016 (AROCLOR 1016) PCB-1221 (AROCLOR 1221) PCB-1232 (AROCLOR 1232) PCB-1242 (AROCLOR 1242) PCB-1248 (AROCLOR 1248) PCB-1254 (AROCLOR 1254) PCB-1260 (AROCLOR 1260) AIR VOLUME (M3) A ug/M3 0.00341 U 0.01136 U 0.00341 U 0.00341 U 0.00341 U 0.00341 U 0.00341 U 220 TABLE 2 Air PCB Results Warren County PCB Landfltl Warren County, North Carolina 8 C ug/M3 ug/M3 0.00342 U 0.00350 U 0.01142 U 0.01168 U 0.00342 U 0.00350 U 0.00342 U 0.00350 U 0:00342 U 0.00350 U 0.00342 U 0.00350 U 0,00342 U 0.00350 U 219 214 D ug/M3 0.00346 U 0.01152 U 0.00346 U 0.00346 U 0,00346 U 0.00346 U 0.00346 U 217 U-malerial was analyzed for but not detected, the numl)er is the minimum quanlitation limit ug/M3 = micrograms per cubic meter of air E F ug/M3 ug/M3 0.00302 U 0.00302 U 0.01008 U 0,01008 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 248 248 en m, ,,1 I IS) w I ID. -.J ... w w m 'T1 ;u 0 J: ;u lT1 C'l ... 0 z l> ,, lT1 en >-! -n -0 lT1 en .... 0 ~ IS) l> 111 m II) (D ID -.J w ,, J:, C'l fT1 '11 ·J
Site Location A ug/M3 Analyte PCB-1016 (AROCLOR 1016) 0.00341 U PCB-1221 (AROCLOR 1221) 0.01136 U PCB-1232 (AROCLOR 1232) 0.00341 U PCB-1242 (AROCLOR 1242) 0.00341 U PCB-1248 (AROCLOR 1248) 0.00341 U PCB-1254 (AROCLOR 1254) 0.00341 U PCB-1260 (AROCLOR 1260) 0.00341 U AIR VOLUME (M3) 220 TABLE 2 Al r PCB Results Warren County PCB Landflll Warren County, North Carolina 8 C ug/K,3 ug/M3 0.00342 U 0.00350 U 0.01142 U 0.01168 U 0.00342 U 0.00350 U 0.003'12 U 0.00350 U 0.00342 U 0.00350 U 0.00342 U 0.00350 U 0.00342 U 0.00350 U 219 214 D ug/M3 0.00346 U 0.01152 U 0.00346 U 0.00346 U 0,00346 U 0.00346 U 0.00346 U 217 U-mnterial was analyzed for but not detected, the number is the minimum quc1ntitalion limit ug/M3 = micrograms per cubic meter of air E F ug/M3 ug/M3 0.00302 U 0.00302 U 0.01008 U 0.01008 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 0.00302 U 248 248
\
SEP-03-97 13 ,36 FROM,REGJON 4 PESTICIDES J0,404 562 8973
APPENDIX 1
WIND SPEED AND DIRECTION
RM YOUNG CO. TRAVERSE CITY, Ml
26700 SERIES TRANSLATOR
-------~-------------------------------~-----------------------------DATE DATE: Tn-:S TIME WS:AVG WS:MAX i<,1):.AVG WD:SDV T:AVG T :MIN T:MAX
MON D1".Y HR MIN MPH MPH DE:G DEG DEG F DEG F DEG F
---------------------------------------------------------------------
s 5 14 0 3.S 12 354 48********~************
8 5 15 0 2.5 10 21 64*********************
8 5 16 0 2.0 10 15 59******••~-~T**•******
8 s 17 0 S.6 24 293 85********************•
8 5 J.8 0 2 .5 10 62 90*********************
s 5 19 0 1.5 5 296 65*********************
8 5 20 0 2.6 7 332 41*********************
8 5 21 0 1.1 3 312 67********************* ,., 5 22 0 0.9 3 351 77********************* 0
6 5 23 0 2 .9 7 324 20****~•-····••********
0 6 0 0 3.l i 336 16********************* ....
3 5 l 0 LO 3 153 100*********************
s 6 2 0 2.7 5 318 17*********************
8 f. 3 0 2.S 5 335 12••···-··············· 8 6 ¾ 0 2.5 5 329 15*********************
8 6 5 0 l.9 5 328 19•·••*****************
£ 6 6 0 3.5 7 337 ll*********************
s 6 7 0 1. 8 6 315 27********•************ ,..
-=-6 8 0 2.0 6 313 29*********************
8 6 9 0 2.8 9 358 32*******••·~~-~-•-****
8 6 lO 0 2.8 8 355 30*****••-~•*•**•******
8 6 11 0 3.2 9 358 44••·-~·-·•************
" (;• 6 12 0 3.9 9 338 37****************W****
8 6 13 0 '.'3-9 12 349 55******~·····--*******
8 6 14 0 4.1 13 340 43****•****************
PAGE
r
Sep 4 '97 16 :43
lr.2.2 !Check condition of remote Fax. [phone]
T.2.2 Check condition of remote Fax. [phone]
jr.2.2 !Check condition of remote Fax. [phone]
DIVISION: OF WASTE MANAGEMENT
TO:
FAX:
FROM:
COMMENTS:
'
919-733-4996,Ext.201
Fax:[phone]
FAX TRANSMISSION COVER SHEET l
-----:
'
TO:
FAX:
FROM:
DIVISION OF WASTE MANAGEMENT
919-733-4996, Ext. 201
Fax: [phone]
FAX TRANSMISSION COVER SHEET
q£,_.J J/4.s ~i.---3 o I -~-/ 9-l;;;JJ
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COMMENTS: ---------------------
TOT AL NUMBER OF PAGES INCLUDING COVER SHEET: J
DATESENT: q/~/17 Tt
--
I :... I 9-I S:➔S:➔7 I I : 3DPt 1
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Augusr 21, 1997
&1<5
7~~14-
To: Mike Kelly, Pat Barnes, Technical Committee ........................................... by FAJ< (3 pages)
From: Joel Hirschhorn
Re: Evaluation ofETG Phase I report and recommendation of contractor.for Phase II
After I had submitted my comments on the Draft Eco Logic Phase I report I received the Phase I
report from ETG. I am wnting thls memo because I think it is possible to avoid a time consuming
comparative evaluation a1_1d discussion of the two reports. In my opinion the ETG work is
superior to the Eco Logic eff01t and I now folly support the selection ofETG for the Phase II
work. Considering all the time delays we have already faced, I hope that we may move forward
as speedHy as possible at this point.
l aro particularly disturbed by the submission of a Draft report by Eco Logic that lacked
considerable data. Their argument that the problem of inadequate dioxin test data was a result of
a bad decision by the laboratory is not satisfactory. ETG used the same lab for its dioxin and PCB
testing and it obtained fine dioxin test data, and at Jmv enough detection limits to demonstrate
compliance with the designated performance specification of lppt TEQ. The detection limits for
the PCB testing were also lower in the ETG work. The RFP did not specify submission of a Draft
Phase I report. ETG has submitted a final report and I see no reason why the state is obligated to
give Eco Logic still more time to respond to comments and submit a final Phase I repo11.
Mo~"t importantly, l have not found it necessary to raise the sam.e level of issues for the E TG
report that I found 11ecessa1y to raise for the Eco Logic report. To the contrary, I find the ETG
report considerably better, because they have given more complete and reasonable technical
information, analysis, an.d discussion. I am also impressed by the markedly greater e7'.-perience
ETG has in working on actual cleanup sites, which I think ex'Plains their better Phase I
performance. The ETG comment on how cost would be reduced substantially if c1eanup
performance goals were not as rigid as specified in the RFP was very important and appropriate,
and an indicator of the greater experience with cleanup projects.
In particular, I make the following comparisons between the two reports:
1. Unlike the Eco Logic report, the ETG repott is clear about what materials it tested in tem1s of
what was received and what was used for each run. Eco Logic used less than 60 pounds of site
soil for testing in three rune, while ETG used about 200 pounds in four runs.
2. The ETG effort was considerably better 'With respect to analyzing all waste streams and al so
about how they would be addressed in full scale treatment.
3. Toe ETG report presented all the dioxin data that was expected.
l
Ff?Ot-1 C -' -_ ._· .. -, \.
4. The ETG effort more convincingly demonstrated that their technology could meet the most
stringent cleanup goals. The problem of high detection limits confronted by Eco 1:.ogic can
probably best be understood on the basis of much smaller volumes of waste treated and, therefore,
less material available for analyses. ETG testing used 10 times as much soil for diox.-in testjug and
three times as much for PCB testing.
5. The ETG repo1t presented better information on full scale use of the technology.
6. The presentation of chemical anaiysis data was superior in the ETG report (e.g., presenting
detection limits for non detects; presenting results for soil blank). The repotting of non-detects
for PCBs in treated soil in the Eco Logic report was somewhat misleading, because the detection
fo.nits were relatively high; if one-half detection limits were used, then the levels would have been
comparable to the highest level reported for WC 1-4 in the ETG report (i.e., about 2 ppb).
7. I find it suspicious that the total PCB levels were so much lower for the Eco logic feeds for all
three runs as comp,u-ed to the levels for the four ETG tests (i.e., an average of 234 ppm versus
508 ppm). Note that the RFP cited an average PCB level of350 ppm. Tue difference is simply
too great to be ex.plained by normal variations witltin landfill materials. There may have been
some aspect of how Eco Logic processed the materials that e>..'J)lains such a major difference. In
any event, the higher levels for the ETG tests makes their results more impressive.
8. Unlike Eco Logic, ETG addressed pa1ticulate matter emissions.
9. Unlike Eco Logic, ETG presented data Oll VOCs in stack discharges and properly reponed
levels as less than the detection limits.
10. Unlike Eco Logic, ETG obtained some basic information on. physical characteristics of the
wastes.
Issues for ETG Phase J repQ!L
[If the state decides to wait for a final Eco Logjc report, then I propose that we give ETG an
opportunity to submit .responses to technical issues that can be raised about their Phase I report.]
1. They might have e:\..-plicitly addressed the poorer results for the WC 1-4 run. However, the
ex-planation is probably that the amount of BCD additives used were based on the overly low PCB
level obtained from less sophisticated chemical analysis that was used for the initial optimizatjon
test.
2. 111.e acmal discharges measured at the stack for PCBs and diox.ins were greater than the
specified performance standard: however, ETG correctly interpreted the levels as being at some
reasonable exposme points and their modeling was very conservative ( only 200 feet away from
2
the treatment unit). The Eco Logic test results for stack levels were considerably lower for PCBs.
This appears a result of the basic differences in the nature of the treatments (i.e., the efficiency of
PCB destruction). If it was solely a result of different gas flow rates ( about 50 dscfm for Eco
Logic versus about 160 dscfm for ETG) or mass throughputs of soil during the testing (i.e., less
than 7 lbs/hr for Eco Logic versus 5 lbs/hr for ETG), then higher levels would be e;\_-pected for
Eco Logic (i.e., more PCBs in less gas). There were higher levels ofPCBs in the ETG feeds, but
not enough to account for the substaotially higher PCB levels in the stack (i.e., an average of
about 8,000E-4 ug/dscm for ETG versus l.3E-4 ug/dscm for Eco Logic). All things considered,
it appears that the Eco Logic process is more effective at destroying PCBs. However, ETG
discussed using a more elaborate air emissions control system in their full scale application.
Nevertheless, ETG could be asked to provide more detail on the air modeling used to show how
dispersion reduced PCB levels by a factor of about 7000 for a distance of only 200 feet.
3. Like Eco Logic, ETG used the lab data for total PCBs but not PCBs plus El\1PCs; I believe
the latter should be used. However, in certain cases ETG did use EMPC levels, when only they
were reported for some isomers.
RECOMMEI'i"DATION
To summarize, I recommend that ETG be selected for the Phase II effort because:
■ ETG presented more complete Phase I test data.
■ ETG presented m.ore data demonstrating feasibility of meeting very stringent cleanup
goals.
• ETG presented higher quality information and discussion of how the technology would be
implemented at foll scale, including the potential for lowering costs by using less stringent
cleanup criteria.
■ ETG has more experience in actual contaminated site cleanups and the conduct of the
Phase I work hJVolved fewer human e1Tor and equipment problems than for Eco Logic.
■ In many respects, the ETG equipment is less complex than. the Eco Logic equipment and
poses fewer safety issues for the local comn:mJlity.
3
To: Mike Kelly, Technical Committee, Pat Barnes
From: Joel Hirschhorn
Re; Comroeuts on Draft Eco Logic Phase 1 report
Table 4: add diox..in TEQ levels in feed, similar to PCB data.
\
Table 6: data on PCB levels --a1.1.d perhaps other contaminants -appear to be rounded numbers,
compared to Table 4; only actual data should be used. The PCB data in Table 4 does not
correlate exactly with data in Appendix E; it appears that Total PCB + EMPC data were not used
and, if so, than the repo11 should defend excluding the EMPC data.
All tables: whenever ND is gjvelJ as a result place actual detection limit in parentheses next to
ND. If some data are suspect because of findings in blanks, then that should be noted. For ,
example, it is sn~picious that toluene was found at a higher level in Run 2 treated solid than in
otiginal feed.
In the calculation of dioxin TEQs it is not acceptable to assume NDs = 0 if the NDs are high; a
more proper and conservative approach is to use onehalf of the NDs.
Section 5: should include some infornrntion on leu.gtb of time for actual full-scale cleanup of the
site. Should ch.eek statements about estimated price of$350-400 per ton and what it includes or
excludes. ls it really a total, tum-key remediation cost, which statements now imply?
Section 4.2.3: would like to see some more detailed explanation ofhow TRM temperature \.vas
''inadvenently allowed to drop to 500°C, which. is below the mini.mum operating temperature of
s 50°C." How would this type of malfunction be prevented in actual full-scale eqwpment?
Section 4.2.3: statement about infeasibility of reaching a I ppt TEQ should be reexamined,
because it is not correct.
Table 9: wonld like some eXJJlanation for finding of dioxin in Run 3 treated scrubber water and
whether th.is would be found in full-scale equipment. The eA-planation on p.25 about "interference
in the analytical technique" is not satisfacto1y.
Would like to see a special sub-section in 4.2 about levels of PCBs and dioxins in all process
waste streams (solid, air, water) and discussion of meeting regulatory requirements and/or
providing treatment of process residuals in company's equipment, or whether offsite
treatment/disposal would be required. Should have some discussjon of PCB/dioxin air emissions.
, . ..J
Section 5. 5: statement that the process "requires minimal processing of untreated soil prior to
treatment" should be amplified, so that exact processing that may be necessary in full-scale
operation is fully detailed.
Was PM measured in exhaust gas?
TI1e dioxin data for Rw1 2, Sl and S5 need more discussion. In both cases the levels and
distribution of dioxin congeners is not typical for PCB impurities. But in the treated material,
there is even more dioxins than in the feed mate~ especially of the most toxic forms. Is it
possible that some reactions have occurred during desorption processing?
TI1ere should be more detailed information on exactly how the materials received by the company
were treated and handled prior to becoming designated as the feeds for the three runs. Was a
composite made from all incoming containers? Did each run correspond to one particular bucket?
How much oversize material was screened out as a percent of the original soil sample provided?
What did this mate.tial look like?
The report should present some discussion of its approach to give PCB data in tenns of total
PCBs rather than more typically used method of giving data in tenns of Aroclors. At least for the
SI data~ some cliscussion of lab data should be given to relate to more typical data on Aroclors
Should present some information on relative toxicities of different PCBs.
2
IJOd..::J H'7 L I : I LC,C I -8 I - 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
Wi lliam L. Meyer, Director
NA
DEHNR
August 5, 1997
MEMORANDUM
TO:
FROM:
Secretary Wayne McDevitt
Pat William~r Bill Meyer
SUBJECT: Briefing on recent events concerning the PCB Landfill
■ On July 29, Deputy Director Mike Kelly notified the PCB Working Group
and the two science advisors of EPA's plans to conduct some air
sampling at the PCB landfill on August 4.
■ On August 1, Ken Ferruccio faxed the news media and the Division of
\Vaste Management a 4-page statement basically indicating that there
would be a conflict at the landfill involving EPA officials and citizens. He
said that citizens would occupy the site and refuse to allow EPA to
conduct any testing until funds were provided (by the state) "to ensure
the scientific integrity of the sampling procedures and data."
■ Mike Kelly notified EPA of this potential conflict, and it was decided to
postpone the sampling event until August 5.
■ Mike arrived at the PCB landfill around 8 am Tuesday to unlock the
gates for EPA officials. Shortly after, Ken Ferruccio arrived and tried to
push past Mike, who was closing the gate. Mike urged Ken not to do
this, but Ken climbed over the chainlink fence and barbed wire to enter
the landfill. Mike called the Highway Patrol and an officer arrested Ken
for trespassing on state property. Ken refused bail and chose to remain
in jail.
■ EPA officials resumed their work.
■ A few hours later, Deborah Ferruccio arrived at the landfill. Despite
encouragement by Mike Kelly to leave the landfill and not take this
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
course of action, Deborah climbed over the gate to the landfill. She was
also arrested for trespassing on state property. Deborah was taken to
jail, and she also refused bail.
■ Henry Lancaster asked Pat Williamson to prepare a press release on
behalf of the Working Group and to include the goals of the group, a brief
description of the sam piing event in the spring of 199 7, the expected
selection of a technology late this fall to detoxify the landfill, and that the
Working Group does not support the action by an individual that is not
in line with the group's detoxification goal, nor any direct action that has
not been brought before the working group. Dollie Burwell, one of the
co-chairs of the Working Group, made a few changes and approved the
release. The release was sent to the Public Affairs office for distribution
to the Capital Press Corps and news media in Warren and Henderson
counties on Tuesday evening.
■ The Working Group had a conference call at 6 pm on August 5 and
reiterated their support for the goals of the group, as well as their lack of
support for those who take action not in keeping with the group's goals.
■ Bill Meyer and division staff are doing everything they can to deal with
the situation. Bill and staff member Larry Perry are spending Tuesday
night at the PCB landfill to ensure that the equipment is not vandalized
and testing is not disturbed. Bill or Mike will be at the landfill on
Wednesday until EPA finishes the air sampling.
NEWS RELEASE
Release Immediately
From: Joint Warren County/State PCB Working Group
Contact: Dollie Burwell, Chairperson, 919-981-0400 (w), 919-257-1353 (h)
WARREN COUNTY PCB WORKING GROUP ISSUES STATEMENT
The Joint Warren County/State PCB Working Group has been meeting
since early 1994 to look at ways to detoxify the PCB landfill in Warren County.
The group's goal has been to determine the current status of the landfill,
study the various technologies available to detoxify it, and then make a
recommendation to the secretary of the NC Department of Environment,
Health, and Natural Resources concerning the appropriate technology to use,
as well as seek funding for the detoxification effort.
Using $1 million appropriated by the General Assembly in 1995, the
group hired two science advisors; had air, water, soil, and landfill liner samples
taken from the landfill area in the spring of 1997 to determine the status of the
landfill; and are awaiting the results from two companies who tested their
technologies on soil samples from the landfill. The science advisors are
currently preparing a report on sampling results, and the Working Group
expects to select a technology in late fall.
The Working Group requested assistance from EPA early in 1997. Based
on advice from Joel Hirschhorn, science advisor to the Working Group, the
group concluded on August 1, 1997, that the presence of the science advisors
was not needed during EPA's air sampling event. EPA officials arrived at the
PCB landfill on August 5 to conduct air sampling.
Two Warren County citizens were arrested at the landfill on August 5.
The Working Group believes the two were arrested for trespassing.
The Working Group cannot in good faith support any unilateral action by
an individual that is not in line with the group's detoxification goals. Neither
can the Working Group support any direct action that has not been brought
before it.
#####
-'.l. _,..:,_._,I ..:.,.,_,,_,-,. .. _., ,,.,, ,._,._._ .. _ .. _, ' ' ,,._, .. , ,,._ ..... _., ' ' ·-· ' r,-._.,._ ·-· J..
df/ 1'¥
/C<--f /1.p_(t August 4, 1997 ..
· ,,?! · /{ To: The News Media and all Networks of Commurncat1on (.fo-c~
1-'t-From: Ken and Deborah Ferruccio 9f!j / :[J::/
Subject: An EPA NerShow at Warren PCB Landflll for Air Sampling
Citizens have requested that EPA cancel air sampling at the state's Warren
County PCB landfill until money can be appropriated for Independent scientists,
independent samples, and independent labs .
However, since EPA has not responded to the request, citizens went to the landfill
today prepared to stop the unjust testing planned for today and tomorrow, but EPA
did not show up.
If EPA attempts to test without the use of independent scientists, split samples,
and independent labs, citizens will continue to be at the landfill in an effort to stop the
testing.
Since EPA is a principal responsible party concerning the failed · and leaking PCB
landfill and has been criminally negligent since the landfill's construction, in order
to ensure Warren County citizens equal protection under the law, EPA must provide for
independent oversight for testing
i :, 1 ·
08/04/1997 22 :31 '31 ':125T::::l::,0 4 CHAPELSOUTHEPNLIGHTS
,,
1, August 4, 1997
From: Ken and Deborah Ferrucclo
Warren County, North Carolina
[phone] )J--
Reaaona why we wlll not accept EPA or state testing at the PCS landffll In
Warren County, North Carolina, without oversight -that Is, without
Independent scientists, spllt samples, and Independent labe,
and why we are requesting that EPA'e air samptlng tests scheduled for
today, August 4, be canceled and rescheduled when adequate funding
has been provided to ensure the scientific Integrity of the process
,20Jllctlng lntec11t1: The EPA and the state are the principal responsible parties.
The EPA Is gullty of crlmlnal neglect for approving an illegal landfill and for not
forcing the state to bring the landfill into compliance
The state has been In criminal noncompliance since the construction of the
landfill. The history of the state's Warren County PCB landfill is a history of EPA
criminal neglect and state criminal noncompliance.
(1) EPA is responsible for approving the PCB landfill without the crtticalty important
and indispensable bottom leachate collection system This system Is legally
required In the design of modern state-of•the-art landfllls and was In the
orlglnal landflll design. Neither state nor EPA officials can produce documents as
to who authorized the landfill to be built without a bottom leachate collection system
promised to the people of Warren County.
(2) The state and EPA have known about significant levels of PCB air emissions
since 1983 when the EPA sampled at the landfill and a half mile away Only after
this information was disclosed to the Working Group and made public by independent
scientists in November 1996 (15 years later) did the state bother to put a $180 filter on
the landflll's main vent. Recent data reveals the continuance of PCB air emissions tram
the landfltl, probabty from the ''hot spots" or holes in the top liner, which is seriously
breached For 15 years the state was able to save money through criminal
noncompllance by not monitoring the air quality and by not fllterlng PCB
air emlaalons because EPA did not force the state to comply with
regulatlona.
(3) This EPA-approved state-of~the-art dry-tomb landfill failed from the start, was
approved with hundreds of thousands of gallons of water In It and with
no bottom leachate eollectton system for pumping the water out. Because
at EPA's lack of enforcement. the state has been in criminal noncompllance
since 1982 and continues to be in criminal noncompliance. EPA has been criminally
negligent.
Paae 2
(4) This EPA-approved state-of-the-art landfill is leaking PCBs into the air and
dioxins into groundwater monitoring wells. Dioxins have been found in two of
...
the groundwater monitoring wells. The most toxic kind of dioxin {Tetra dioxin, which is
not the kind of dioxin generated as a by-product of the manufacturing of PCBs) has
been found in one of the groundwater monitoring wells. It is used in agent orange
Some citizens speculate that chemicals trucked from Fort Bragg to the PCB landfill
before it was capped may have included tetra dioxin and other chemicals in addition to
PCBs. The possible presence of "surprise" chemicals in the landfill would provide
another incentive (in addition to cost) for EPA and the state to resolve the landfill crisis
by providing data justifying ''repairing'' the landfill ( at an estimated $120,000) instead
of detoxifying it (at an estimated $24 million), requiring full excavation. and thus
exposing the truth about its contents.
(5) According to one of the Working Group's independent scientists, even if he
were to oversee testing procedures, it would be impossible to ensure the Joint Warren
County State PCB Landl'ill Working Group that EPA used an unbroken chain of
custody or that the agency did not bias laboratory testing There wil l be neither split
samples nor the use of independent labs
Envtronmental Ju1ttce
The Joint Warren County State PCB Landfill Working Group clearly stipulated
the conditions for EPA tests at the Warren County site: the use of independent
scientists, split samples, and independent labs
The way to turn communities into waste lands and to keep them wasts lands is
to permit EPA and the state to subordinate science to preconceived political and
economic vested interests by biasing laboratory results. The scientific integrity
of testing through the use of independent scientists, split samples, and, independent
labs must be a fundamental right of targeted and sacrificed communities struaolina
to achieve environmental justice. .,.._ "'
L5Jf
/1;t/4_
91 '32572E,D4 CHAF'ELSCIUTHEF:r lL I 13HT'.=,
t J August 1, 1997
(I ,· . ;:f ,,,_L l To : The news Media and all Networks of Communication
{ '·
1 l (v From : Ken Ferruccio )~
/
v"· Subject: Citizens Planning to Block EPA Air Sampling At PCB
/\t Landflll In Warren County, North Carolina
EPA will begin air sampling at the PCB landfill in Warren County on Monday. August 4
and will finish on Tuesday, according to a July 29 memo from state official Mike Kelly
to members of the PCB Working Group and Independent Science Advisors.
However, because the state has falled to provide adequate funding,
Independent scientists wlll not be avallabte to oversee the process, nor
wlll procedures be used to ensure scientific Integrity. EPA will do all
testing and run the samples through an EPA lab.
Since citizens wlll not tolerate EPA testing at the site without an
independent aclentlst and without procedures that would preclude
biasing the data, a conflict at the PCB site Involving EPA offlclals end
citizen, would seem lnevltabte.
Citizens have decided to respond to the EPA presence at the site by
occupying It and by refusing to permit any testing untll the necessary
funds are provided to ensure the scientific Integrity of the sampling
procedures and data.
This would seem to necessitate the Involvement of Independent
scientists and Independent labs. With a surplus of 334 mllllon dollars,
the state should be able to come up with money to enable Independent
scfentlsts to continue their work and to ensure the scientific Integrity of
tests regarding the PCB landflll.
The involvement of independent scientists and independent labs is of the utmost
concern to citizens because EPA along with the state are responsible for the leaking
landfill and want the most cost-effective solution. leaving open the possibility that
EPA's data on air sampling will be a -function of conflicting interests and bias to
support a recent report ( and an expected EPA Compliance Order) shifting the focus
from detoxifying the landfill to repairing it
In a telephone conversation yesterday afternoon with Working Group member Ken
Ferruccio, independent scientist tor the Working Group Joel Hirschhorn
said that even if he [or independent scientist Pat BarnesJ were to oversee testing
procedures, i-t-would be impossible to ensure the Working Group that EPA used
08/01 /1997 14:34 9192572504 CHAF'ELSOUTHEF'.t lL I r:iHT'.::,
Page 2
an unbroken chain of custody or that the agency did not bias laboratory testing. There
will be neither split samples nor the use of independent tabs .
He added that if money is spent to have him oversee EPA's air sampling at the tendfill,
there may not be enough money tor the work he needs to do concerning the site
investigation report, the Phase 1 detoxification report. and the Phase 2 detoxification
activities, so that to oversee the air sampling process could undermine detoxification
efforts.
However, concerning detoxification, Hirschhorn's view is that although the state must
continue to say it's committed to detoxification because of Governor Jim Hunt's 1982
promise, it is now clear that the state anticipates repairing the landfill for an estimated
cost of $120,000 instead of detoxifying it for approximately $25 million
Hirschhorn was referring to a July 20 report by Dr. Gregory N R,d'lardson. of G .N.
Richardson and Associates. Engineering and Geological Services, who, Hirschhorn
argues (in a July 28 memo evaluating the report), was hired by Bill Meyer. Director of
Solid and Hazardous Waste, to defeat detoxification:
The [Richardson] report is designed to support a decision
by the state to repair the landfill. rather than pursue
detoxification, regardless of its statements to the contrary
He [Richardson] has provided the state with a $120,000 alternative
to a $25 million detoxification. I also note that the report
was dated July 20 and was received by the Waste Division
the same day, and that the computer models were also
run on July 20. It seems odd to me that after having the
original set of documents a month or more for review
that so much happened on July 20. I wonder whether the
Richardson report may be linked to knowledge about the
timing of the noncompliance notice from EPA Region 4 to
the state ( An EPA Compliance Order.expected to "force"
the state to pump the water from the landfill and repair the landtlll,
circumventing Governor Jim Hunt's 1982 detoxification promise, is
expected soon.]
Hirschhorn argues that " the Richardson report was not merely some peer
review of documents, but rather an engineering analysis that constituted a
new work product designed to serve the interests of his client, namely the
state .... It Is as t1' the state went to a prOfessional engineer and asked for
an analysis of the best means to repair the landfill and Improve its performance
and a report providing the appropriate technical measures and providing a
9192572E,B4 CHAF'ELSOUTHERt ~LI (,HT'.=,
cost est1mate " Hirschhorn adds that " . . . Richardson informed me in a phone
call ... that he had invoiced the state tor his services, but that he also told
Meyer not to worry tf the state could not pay him."
Hirschhorn contends that Richardson " went way beyond what Bill Meyer asked
Page 3
tor in his letter of 12 June A normal peer review would not have involved computer
modeling and obtaining new data, nor would it have involved a new cost-estimste and
detailed recommendations for repairing the landfill."
According to Hirschhorn, " ... the conclusion by Richardson that the upgrading of the
landflll would otter 'less risk than the alternative of removal of the waste' is the clearest
sign that Richardson has responded to desires of Bill Meyer not officially expressed
in writingTI Hirschhorn contends that u Richardson has not performed or presented
any detalled analysis regarding relative risks of repairing the landfill versus
detoxification based on excavating the landfill, and his conclusion about this risk
issue is completely inappropriate professionally and unsupported technically."
It appears to citizens that state and EPA officials are working together on reports and
a compliance order to justify circumventing Governor Jim Hunt's 1982 detoxtfication
promise, based not on cost, not even on a leaking landfill, but on the tecl"tnical
feasibHlty of detoxification.
Resisting unjust environmental conditions and affirming the necessity of freedom
becomes indispensable for human survival when the government (1) formulates a
rationale for selective human sacrifice. (2) ratifies it into law, (3) targets its
"expendable" communities, (4) uses force to turn them into waste lands,
and {5) abuses democratic mechanisms such as worl<ing groups, committees, reports.
compliance orders, environmental justice concepts and criteria, etc., to permanently
subordinate the ''expendable" communities to a condition of involuntary servitude to
waste management facilities destructive to persons and properties, thus segregating
"expendableu people within dense pockets of deadly waste materials, and
gradualty but inevttably exterminating them --in other words. when the government
uses democracy itself as a mechanism for the systematic destruction of targeted and
sacrificed communities, when the instruments of freedom have failed, and when the
EPA's genocidal "containmenr principle begins goose stepping its way to Warren
County once again under the guise of law and order.
Citizens will never accept these conditions. They will continue to pose an absolute and
unyielding resistance to them . They will continue to make their history of
environmental injustice conscious of itsetf to the public through networks of
communication. They will continue to evolve from their oppressive conditions
the paradigm for their freedom.
08 /01 /1957 14 :34 9192572E,04 CHAF'ELSIJUTHERt~L I GHT~.
Page 4
The idea of an evolving community, transforming itsetf from a history of oppression to
a history of freedom through the networks of communication necessitates access to a
free press.
Therefore. a process obstructing the direct flow of information from local grass-roots
leaders to the news media is perhaps the most effective way to undermine their
quest for freedom. and perhaps the clearest indication of the power of repressive
forces keeping them in bondage .
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:
July31,1997
TO:
FROM:
Patrick Barnes"-.-~v
Mike Kelly f
SUBJECT: CONTRACT EXTENSIONS
.AVA
DEHNR
After paying your last invoice, we have determined that you have overspent your current
contract by $3,034.89. I have requested an adjustment be made on that contract which will allow
us to pay your last invoice in full. This will close out all funding for the previous contract and
any future invoices must be directly related to one of the specific tasks included on your contract
extension or it cannot be paid.
You will also be receiving a contract extension to cover your work on some of the tasks
we have discussed, specifically:
Final report on site assessment / investigation
Phase I detoxification review
Phase II detoxification report review / activities
Community Interaction
Legislative support
$15 ,000
$ 3,000
$ 8,000
$15 ,000
$10,000
As you are aware, there are not enough funds available to do all of the tasks which you
identified, however, this will cover those critical tasks we have identified as well as provide
funding for you to begin the next phase of detoxification through community interaction and
legislative support. Additional guidance will be developed by the working group and staff.
These are the only tasks being funded for you at this time.
Please call me should you have any questions.
CC: Bill Meyer
Henry Lancaster
Dollie Burwell
P.O. Box 27687,
Raleigh, North Carolina 27 61 1-7 687
Voice 919-733-4996 tem@•raMN
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/ 1 O"lo 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:
July31,1997
TO :
FROM:
SUBJECT:
Joel Hirschhorn "\{A
Mike Kelly ~\J'i'-
CONTRACT EXTENSION
AVA
DEHNR
After approving your last invoice, and subtracting out the one that had not been paid from
February, we have determined that you only have $3,204.76 remaining in your previous contract
instead of the estimated $15,000. As a result, we will have to add $14,795.24 to make the
$18,000 you quoted to complete the final site investigation report.
I have already submitted paper work to the department to insure that this happens and to
make certain that you have sufficient funding to complete this project.
We have, therefore, closed out all monies in your previous contract and cannot pay any
additional funds or expenses not related to completion of one of the specific tasks included in
your contract extension.
You will be receiving a contract amendment for the final site investigation report, as well
as amendments to provide funding for the additional work which we feel is of priority. As you
are aware, there are not sufficient funds available to pay the amount you requested for the other
tasks we discussed. The amendment will provide an additional $7,000 for Phase I detoxification
report review, and $15,000 for Phase II detoxification activities and analysis. No other tasks will
be funded for you at this time.
Please call me should you need additional information.
CC: Bill Meyer
Henry Lancaster
Dollie Burwell
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996 l@M2Jij§tfMii
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% 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:
AVA
DEHNR
July 29, 1997
TO:
FROM:
PCB WORKING G~,PUP, SCIENCE ADVISORS
MIKE KELLY~~
SUBJECT: EPA AIR SAMPLING AT PCB LANDFILL
We have been notified that the EPA will be coming to North Carolina on Monday,
August 4 to begin air sampling at the PCB landfill in Warren County. They should set up on
Monday, begin sampling, and finish sometime on Tuesday.
Although I have no other details at this time, I am letting you know for informational
purposes. They have requested access but no other assistance from the division, and I will let
you know more as we find out.
CC:~yer
Pat Williamson
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996 ff ffiA•~9M5
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
~e,,_l/CA
.rµs
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 l; 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:
I) 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
Page 2
Mr. Ferruccio 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 informed 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. Ferruccio 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 the Technical 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.
,,, .
draft July 23, 1997 Meeting Minutes
Page3
Pilot Studies
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 comp~nies 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
1.0 BACKGROUND
I. I 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
95-0/7
T<X.doc
3. I Off-site Activities
3.1.1 Monitoring Well Placement
3.1.2 Monitoring Well Design and Construction
3.1.3 Sutfnce Water 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 Water Extraction Wells
3.5 Quality Assurance/Control Procedures
3.6 Analytes and Analytical Methods
-1-
....
PCB LANDFILL
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. 1 Groundwater
4.2.2 Surface Water
4.3 • Surface Soil and Stream Sediment Characteristics
4.3.1 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 .1 Discharge Potential
5.2 Off-Site Environmental Impacts
5.3 Waste Characteristics and Site Setting
6.0 RECOMMENDATIONS
95-017
TOC.doc
6.1
6.2
Immediate Measures (60 -90 Days)
Long Term ( 1 to 2 Years)
-II-
PCB LANDFILL
SITE INVESTIGATION REPORT
(Continued)
TABLES
2. I 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
FIGURES
I. I Location Map
1.2 Site Map
1.3 Master Plan Flow Chart
2.1 Facility Map (Prior to Field Work)
2.2 Facility Design
2.3 Hydrograph
3. I Major Flow Paths
3.2 New Sample Network
3.3 Air Monitoring Network
(' ~.4 Off-Site (Background) Wells~
~.5 Generic Monitoring Well Design
3. 6 Extraction Wells
4.1 Lithologic Cross Sections A-A',~
4.2 Lithologic Cross Sections~•, B-B'
4.3 Water Table Contour Map ~
4.4 Depth to Rock Contour Map
APPENDICES
l. 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
..
,. ....
~ .. i~k
07/19/1997 18:48 '31 '325721:,04 CHAF"ELSCIUTHEF:t-1L I C,HT•::::;
Dear Mr. McDavitt,
Congratulations on being selected as North Carolina's Secretar~ of the DeJ?Srtment
of Environment, Health, and Natural Resources You are assuming a most important
but difficult position. and our best wishes are with you in the days to come. As you
know, one of the difficulties you face involves the states's responsibility to detoxify the
failed PCB/dioxin landfill in Warren County.
Recentty, Joan Wald's office called to assure my husband Ken and me that you have
been receiving and personally reading ours and others' communications concerning
the PCB/dioxin landfill.
Some time ago I discussed with Joan in her position as Deputy Chief of Staff the
problem of Secretary Howes' seven-month delay in formally and legally reconstituting
the Joint Warrren County/State PCB Landfill Working Group. Reconstitution was to be
a mere formality that was to have taken a few weeks .
Instead of decreasing citizen membership to four citlzen seats from seven, which was
the proposal of acting Co-Chairs Henry Lancaster and Dollie Burwell, the PCB
Working Group voted to increase citizen membership to nine seats_ The PCB Working
Group then decided to offer renewed membership to all members who wanted to
continue serving and to place an ad in the local newspaper inviting new members to
serve on the PCB Working Group as well.
In all, including past members, nine citizens responded, and their names were
to be submitted to Secretary Howes by a letter sent from the PCB Working Group's
secretary. However, the PCB Working Group's secretary has been unable to share a
copy of this letter with the PCB Working Group, nor has past Secretary Howes· or
Deputy Secretary Lancaster's office been able to produce a copy either. We are
wondering just how much communication has been actuatly made available to you .
After listening to us concerning the seven (now eight) months of reconstitution delay,
Joan said that she would look into the situation and get back with me. Later she said
that she Ncouldn't get anywhere with DEHNR," neither with Secretary Howes nor with
Deputy Secretary Henry Lancaster.
Joan suggested that we arrange to meet with you as Senior Counselor to Governor
Hunt and Director of Intergovernmental Affairs. She said that you were the person to
meet with because you were outside of DEHNR. She asked us to choose a few ;I:
f(,:. _____ D_e_bo-reh and Ken Ferruccio
~· · Co-Directors
P.O. Box 9i3
Warrenton. NC 27589 [phone] & Fax
07/1 9/1997 18:48 ':il '32572t.04 CHAF'ELi::;l]I_ITHERt•Jl I t::iHr::;
.. '
citizens representative of a diversity of interests to attend the meeting as welt as the
PCB Working Group's Independent Scientists.
This meeting obviously never materialized, but a similar one with you now as
DEHNA's new Secretary would be just as valuable and probably more so.
Secretary Howes and Deputy Secretary Lancaster's handling of the formal and legal
reconstitution of the PCB Working Group has been inappropriate and has disregarded
Warren County citizens' basic civil right to be represented concerning the interests of
their environment, health, and natural resources concerning the PCB/dioxin •ancttill .
It is our hope that Governor Hunt and Secretary Howes both know that it is time tor a
new kind of leadership at DEHNR--.a leadership based on tnctusion of citizens and
Independent scientists through an open and honest democratic process. It would be
espooiatty valuable if you could be scientifically and technically briefed in a meeting
with state officials Bill Meyer, Director of the Division of Waste Management, his
Deputy Dtrector Mike Kelly, and Independent Science Advisors Patrick Sames and Dr.
Joel Hirschhorn. Having been scientifically and technically informed on the Issues, it
would then be most valuable for you to meet with the PCB Working Group.
Mr. McOevitt, you can best begin your new position as Secretary of DEHNR by
promoting an atmosphere of trust and good witl .. This would be to (1) affirm the vatidity
of the democratic process by seeing to it that the PCB Working Group is formally and
tegany reconstituted according to the nine-member citizen model that was voted on by
the PCB Working Group, (2) to affirm through state and citizen cooperation the goal we
all have and that Governor Hunt pledged~~to detoxify the PCB/dioxin landfill when
technieally feasible without further delay, and (3) to affirm the Governor's commitment
to his detoxification pledge by committing funds to phase one of a several phase full-
scale detoxification process.
Thank you for your consideration in these important matters. We look forward to
meeting with you in the near future.
Sincerely,
Deborah Ferruccio
cc: Bill Meyer, Director Division of Waste Management
Mike Kelly, Deputy Director Division of Waste Management
Patrick Barnes, Independent Science Advisor to the PCB Working Group
Or Joel Hirschhorn, Independent Science Advisor to the PCB Working Group
Joan Weld, Deputy Chief of Staff to the Governor
~ti
4~
~'t ,/7~c.f June )9, 1.997 ................................................................................. by FA..X
ffe,, &'-I Ir.-;
/f /4 J To: l\i1ike Kelly
From: Joel Hirschhorn
Re: Estimated costs for foture work
The follovv:ing estimates are given in terms of total dollars, representing labor associated with
specific activities, including time dealing with Working Group members/state and EPA officials,
other Science Advisor, projec.t management, mee6ngs, aud travel expenses.
Final report/assessment and site investigation repon: $18,000
Phase I technology activities and evaluation of Phase I repo1ts, selection of Phase II vendor:
S7,000
Participation in Phase IJ activities with vendor and evaluation of Phase II repo1t: $40,000
Activities related to dissemination of information to the public, ,,;hich may include producing new
documents and 1JJaterials. and attending meetings: $10,000
Activities related to use of all reports and work for securing funding for detox from state
legislature, which may include prepai-ation of new repo1ts by Science Advisors: $10,000
In round numbers, after the last invoices submitted I estimate about £15,000 remaining in the
currently available funds.
11ms, subtracting the $15,000 from the total of$85,000 (but actually from $25,000 for :first two
activities above\ leaves an estimate of $70,000 for new funds required.
i--. 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
MEMORANDUM:
TO: Patrick Barnes
Joel Hirschhorn
FROM: Mike Kelly
NA
DEHNR
June 17, 1997
SUBJECT: SCIENCE ADVISOR'S CONTRACTS I REMAINING CRITICAL TASKS
TO BE COMPLETED
1. As you are aware, your current contract as Science Advisor(s) fot the Warren County
PCB Working Group expires on)une 30, 1997. I met briefly last week with Henry Lancaster
and Dollie Burwell to explain where we are on the contracts and to go over the current financials
from the funds available to pursue detoxification. I agreed to look at the remaining critical tasks
and put together some information for them as to those items remaining to be completed, in order
that we may begin to re-allocate funds left in the current budget to insure that these tasks get
finished.
2. On Monday, I discussed with both of you some of the items that I see are remaining
"critical tasks":
**** Final report on the assessment and site investigation phase
****
****
Evaluation of the Phase I reports to include selection of Phase II vendor
Evaluation of the Phase II report and recommendation on detoxification
3. Please provide me with an estimated cost (ie your billing) for completion of these tasks.
Also, if there are additional tasks you feel are necessary, itemize those with the cost as well. I
plan to look at either extending your contracts or putting the critical tasks on new contracts for
completion and payment according to the task. Once I have a grasp for the money needed to
complete the current projects underway, we will know what other funds are available to be used
for additional items the Working Group feels are important over the next 6 - 8 months. This will
also give the Working Group and State time to plan for future needs and additional funds.
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
MEMORANDUM TO Joel Hirschhorn and Patrick Barnes
June 17, 1997
4. Please let me know when the Working Group and State can expect the final report on the
site assessment and investigation phase. The report should clearly state your conclusions and
basis for such, as well as the recommendations you have on those actions which should be taken
during the interim as we prepare for detoxification. There has been a lot of interest lately from a
number of people in regards to this report, particularly in light of the recent memorandums and
letters which have made statements attributed to the science advisors and the condition of the
landfill. The report should be a joint signed report. Other reports, lab analysis, etc., from
contracts associated with the project, may either be attached or referenced. The State is not
working on a final report.
5. Each of you have some funds remaining on your current contract. Please review your
estimated billings for the month of June, and take into account any portion of those remaining
dollars which will be applied to the final report on site assessment and investigation. I received
invoices from each of you today which show your status through June 1.
6. For planning purposes, I envision the following time-table:
August 1: Receipt of Phase I reports
September 1 : Selection of vendor for Phase II
November 1: Receipt of Phase II reports*
December 1: Evaluation of Phase II reports and recommendation for detoxification
Dec-April 98: Develop and implement detoxification funding plan
May, 1998: General Assembly, aquire funding
Jul-Dec: Contract for detoxification
January 1999: Begin detoxification
*although not anticipated, by the RFP, the Phase II vendor may take an additional 30-45 days
7. I am scheduled to be at Ft. Jackson, SC on Monday and Tuesday of next week, so please
provide the information to me by noon on Friday, June 20. This will allow me time to get the
information to the Department before Monday.
Thanks! Please call me with any questions you may have.
CC: Henry Lancaster
Bill Meyer
Laird Davison
Y'at Williamson
Brenda Rivers
PCB Working Group
PCB LANDFILL DETOXIFICATION
PROPOSED BUDGET FOR THE $2 MILLION
COMPLETION OF FINAL DESIGN DRAWINGS FOR FULL
SCALE OPERATION
DIRECTIONAL DRILLING, TESTING UNDER LANDFILL
LINING OF POND FOR USE DURING DETOXIFICATION
SITE PREPARATION WORK
WATER AND POWER
OTHER AREAS THAT CAN BE COMPLETED
USING THESE FUNDS ARE BEING IDENTIFIED
$529,000
$200,000
$50,000
$600,000
$300,000
$321,000
TOTAL: $2,000,000
The next phase of the project (actual detoxification) will require approximately $16 million based
on the original cost projections in the Phase II document. It is hoped that this cost will actually
decrease as a result of the bidding process.
OTHER AREAS BEING EXPLORED FOR FUNDING/RESOURCE SUPPORT:
National Institute of Environmental Health Services: funding for job training; have
sponsored a scholarship for a Warren County representative to attend the job training seminar in
April 1999 on how to set up a program for the county (a state representative will also attend).
EPA, REGION 4: has set aside $75,000 per year for three years from their Environmental
Justice program to provide a community liaison staff person and fund community outreach efforts.
The detoxification project does not qualify for "Superfund" monies, as the landfill was the
"solution" to a Superfund site, ie 200+ miles of roadside. Region 4 is very supportive of the
project and will continue to look for funding sources.
BROWNFIELDS GRANT: Warren County has applied for a Brownfields grant to assist in
community involvement, final assessment work at the landfill, and re-development planning; will
know in mid-May if they are successful (applied for $200,000).
DEPARTMENT OF DEFENSE: met with representatives at the Pentagon to discuss available
funds for detoxification (IO percent of the landfill contents came from Ft. Bragg); initial reaction
from the Pentagon is that they have no funds available for detoxification.
PCB LANDFILL, WARREN COUNTY, NC
PROPOSED DETOXIFICATION
l) PCB landfill sited in Warren County against the wishes of the people. The Environmental
Justice movement got its start here.
2) Governor Jim Hunt made a promise in 1982 to look at detoxification if and when the
technology was available. In 1994, Secretary Howes, DENR, set up a Working Group in Warren
County to study the feasibility of detoxification and to provide an in-depth assessment of the
landfill.
3) Over $1 million was spent studying detoxification technologies and assessing the landfill. A
technology was chosen, and in 1998, $2 million was appropriated to begin actual detoxification.
4) Detoxification is feasible, and it is the right thing to do.
5) The recent court decisions regarding pay back of taxes to retirees may have a dramatic effect
on the available state funds for the project. The next portion of the project is the actual
detoxification process that will require $16 million to select and contract with a vendor. The state
will need this amount to enter into a contract for this phase of the detoxification.
6) The Phase II report for detoxification set the total estimated cost at approximately $24 million,
and took into account worst case scenarios. It also included a $2 million contingency. The site
would be detoxified to levels less than 10 times drinking water standards and be available to
Warren County for use with its surrounding property as either an industrial park or recreational
park.
7) The EPA, congressional staff and the DOD have been contacted to see what funds may be
available to suppo11 the project. The site does not qualify for "Superfund" cleanup funds as the
site was the remedy to the cleanup of a National Priority Listed (NPL) site (spill along the road
side) It is anticipated that any funds received from EPA will be less than $500,000. The DOD
will notify us within the next two weeks if they have any funds available.
8) The cleanup standards are very strict and will allow the state to walk away from the landfill
without any future liability, maintenance or monitoring. Failure to detoxifiy the landfill may
require a more extensive and expensive cleanup in the future.
9) Although the landfill is currently not leaking, it does contain nearly 2 million gallons of water.
During assessment of the landfill, there were indications that the top liner is beginning to fail. The
state is currently under a Notice of Non-compliance from the EPA that may require expenditure
of substantial funds in the future for upgrading the landfill if we do not pursue detoxification.
I 0) Federal participation in the project will decrease the amount necessary for contribution by the
state.
****
****
****
****
PCB LANDFILL, WARREN COUNTY, NC
TALKING POINTS ON PROPOSED DETOXIFICATION
Detoxification efforts are underway using $2 million allocated in 1998, following
the expenditure of $1 million in the last three years assessing the landfill and choosing
a detoxification technology
Next phase of project will require $16 million for on site work; federal dollars
are crucial to the state's ability to contract for this work
Representative Clayton's support is also crucial to obtaining this money to help
fulfill a promise to detoxify the landfill in Warren County, the birthplace of the
Environmental Justice movement
Failure to proceed with detoxification will cause significant loss of faith and trust
in state government, breaking a promise, and potentially causing civil disturbance in the
county
PCB LANDFILL, WARREN COUNTY, NC
PROPOSED DETOXIFICATION
I) PCB landfill sited in Warren County against the wishes of the people. The Environmental
Justice movement got its start here .
2) Governor Jim Hunt made a promise in 1982 to look at detoxification if and when the
technology was available. In 1994, Secretary Howes, DENR, set up a Working Group in Warren
County to study the feasibility of detoxification and to provide an in-depth assessment of the
landfill.
3) Over $ I million was spent studying detoxification technologies and assessing the landfill . A
technology was chosen, and in 1998, $2 million was appropriated to begin actual detoxification.
4) Detoxification is feasible, and it is the right thing to do .
5) The recent court decisions regarding pay back of taxes to retirees may have a dramatic effect
on the available state funds for the project The next portion of the project is the actual
detoxification process that will require $16 million to select and contract with a vendor. The state
will need this amount to enter into a contract for this phase of the detoxification.
6) The Phase 11 report for detoxification set the total estimated cost at approximately $24 million,
and took into account worst case scenarios. It also included a $2 million contingency. The site
would be detoxified to levels less than IO times drinking water standards and be available to
Warren County for use with its surrounding property as either an industrial park or recreational
park .
7) The EPA, congressional staff and the DOD have been contacted to see what funds may be
available to support the project The site does not qualify for "Superfund" cleanup funds as the
site was the remedy to the cleanup of a National Priority Listed (NPL) site (spill along the road
side) It is anticipated that any funds received from EPA will be less than $500,000. The DOD
will noti(y us within the next two weeks if they have any funds available.
8) The cleanup standards are very strict and will allow the state to walk away from the landfill
without any future liability, maintenance or monitoring. Failure to detoxifiy the landfill may
require a more extensive and expensive cleanup in the future .
9) Although the landfill is currently not leaking, it does contain nearly 2 million gallons of water.
During assessment of the landfill, there were indications that the top liner is beginning to fail. The
state is currently under a Notice of Non-compliance from the EPA that may require expenditure
of substantial funds in the future for upgrading the landfill if we do not pursue detoxification .
I 0) Federal participation in the project will decrease the amount necessary for contribution by the
state.
Benefits of the Joint Warren County/State PCB Landfill Working
Group Detoxification Treatment Proposal
■ The commitment is to detoxification treatment, which can be achieved through Base
Catalyzed Decomposition (BCD). BCD is a treatment technology that involves heating
the contaminated soil to a temperature of less that l000°F and combining it with sodium
bicarbonate (household baking soda) to break down the PCBs into harmless materials.
The US EPA developed this treatment technology with federal dollars. The North
Carolina General Assembly appropriated $1 million to assess the PCB Landfill and
identify the detoxification treatment technology --BCD was chosen.
■ The commitment is to a solution that poses the least health risk to the community. BCD
presents less risk to public health. It can be done on-site and does not involve
transportation to another location. BCD presents no unsafe air emissions.
■ This $24 million proposal represents a conservatively structured budget under a worse-
case scenario to achieve complete and permanent detoxification treatment. It eliminates
future liability for the State of North Carolina.
■ This entire process is based upon community acceptance. The technology selection
process was conducted with the full participation of Warren County citizens.
■ 1982 -Governor Hunt's commitment, in a letter to the citizens of Warren County,
to detoxification treatment
■ 1983 -North Carolina General Assembly passed a bill supporting detoxification
treatment
■ 1993 -Former DENR Secretary Jonathan Howes wrote a letter supporting
detoxification treatment on-site
■ 1996 -North Carolina General Assembly appropriated $1 million to identify
detoxification treatment technology for the PCB Landfill
■ 1998 -Governor Hunt included $15 million in his 1998-99 budget for the BCD
treatment technology for the PCB Landfill
■ 1998 -Senator Frank Balance introduced a bill appropriating $24 million for
detoxification of the PCB Landfill using the BCD treatment technology.
F': 01
JUL -15-97 15: 23 t lC l·lAFN
Waste Awareness an/:/(/ WJtliN •>◄)
M:EMO
July l 6, 1997
To: Bill Meyer, Director, NC Division of Waste Management _ \ _ AfJ)/f--
From: Jim Warren . _ {\} I'"'-l,--JW v
CC: PCB Working Group ( : ·
Subject: S&ME Engineering Report on the Landfill
As discussed in previous memoranda from science advisors Pat Barnes and Joel Hirschhorn
and from myself, I am formally requesting as a member of the PCB Working Group technical
<.::ummittcc, Lhat you provide the science advisors with copies of all preliminary drafts of the
S&:ME engineering report, as well as copies of all comments and communications to S&.ME from
the state.
As you know, there is consioorable concern about the validity of the final S&M.E report due to
what appears to be undue influence from your divisio,n pl:ior to the report's completion.
Please notify me if there is any reason for not complying with this request promptly.
AdvtlOrf BOlrd: Or. Paul Connett• Ellen Connett• Pat Costner• Or. Gerald Drake• Billie Elmore• Rev. Isaiah Madison• William Sa~r
b:·u I 1,l .. -k<.
/l-1-~ "t;.:.:.::b.F A Environmental Consultants
/J 1~-= :Cz=:g = = = ==== ;;-1,,,'.._ /i Barnes, Ferland and Associates, Inc.
r --1 _fc_ June 16, 1997
Mr. Mike Kelly
Deputy Director
Division of Solid Waste Management
State of North Carolina
Department of Environment,
Health and Natural Resources
PO Box 27687
Raleigh, N.C. 27611-7687
SUBJECT: Proposed Remaining PCB Landfill Detoxification Activities
and Opinion of Cost
Dear Mike:
BFA #95-017
As you requested, this letter proposal outlines the remaining project activities, an estimate of their
associated cost and an implementation schedule Some of the items were identified in my original
scope of work, but become displaced by the enonnity of the field investigation. This was
discussed in my memo to the Working Group dated May 22, 1997.
The attached scope of work and fee schedule (Attachments A & B, respectively) are arranged by
Task. which enables incremental authorization, if desired, by the State and Working Group.
With respect to the Final Assessment Phase Investigation Report, l will require 30 to 45 days to
properly analyze all of the results and present it in a comprehensive project report fonnat
If you have any questions please don't hesitate to call me.
PADpsg. 6-.l 6MK J .doc
Sincerely,
Barn d and Associ , c.
~/20! . (
Patrick A Barnes ---
President
3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803
Office [phone] • Fax [phone]
ATTACHMENT A
SCOPE OF WORK
JUNE 16, 1997
Task 1 Assessment and Investigation Phase Report
BF A will develop a comprehensive Facility Impact Assessment Report. The report will pull
together the results of the assessment activities which took place over the duration of the
contract It will draw independent conclusions and make all appropriate recommendations for
further actions. It is assumed that report activities dealing with technology selection will await
completion of the current pilot scale testing and subsequent preliminary design.
Task 2 Phase I Report Evaluation and Phase IT Vendor Selection
BF A will perform a detailed review of the pilot scale testing and provide an independent analysis
to the Working Group. The analysis will focus on the issues related to scaling up the technology
to full scale treatment.
Task 3 Finalize Community Interaction Plan
BF A will work closely with Working Group sub-committee members to develop a comprehensive
community interaction plan which maximizes understanding of. and the participation by all sectors
of the Warren County community in the development and implementation of site detoxification
The major components of the Plan include:
3. l Plan finalization
3 .2 Community research and surveys
3 .3 Develop information packets
3. 4 Implementation of Plan
This task assumes four large communhy meetings over the next year. This task also assumes the
development of a regular newsletter on the status of the landfill project.
It is believed that obtaining regulatory approval for detoxification will require broad-based
community support. In addition to the community meetings, this task includes l month of door to
door canvassing to generate comprehensive project support .
Task 4 Legislative Support
Develop proposals and plans which maximize legislative understanding and support of
detoxification efforts.
95-0] C
AtL~.d,:,,:
-1-
4.1 Briefing Document -Develop a summary document highlighting key project activities for
distribution to the General Assembly.
4.2 Lobbying -As directed by the Working Group, BFA wi11 participate in lobbying necessary
General Assembly Members to seek support for the comprehensive landfill detoxification
program.
Task 5 Phase D Detoxification Design Review
Bf A will review all detoxification design documents on behalf of the Working Group and work
with the selected design team to ensure all community concerns are adequately addressed by the
proposed design activities; where necessary, suggested modifications to the design will be
recommended.
Task 6 Minority Business Participation
BF A will work closely with the community involvement sub-committee of the Working Group to
develop a comprehensive Minority Business Utilization Program. This program will identify the
various means which will be used by t.he State to ensure maximum economic benefit for the
Warren County area and the black community as it relates to contracting opportunities as sociated
with the detoxification of the PCB landfill.
This task does not include implementation of the program; however, it does include general
surveys of the community and business sector to identify the optimum program elements.
9.i-01 -
Ar¼..dac
-2-
Task 1:
Task 2
Task 3:
Task 4·
Task 5:
Task 6:
9.).()J ~
Au8 doc
ATTACHMENT B
FEE SCHEDULE
Final Repon of Assessment and Investigation Phase
Phase I (Pilot Scale) Evaluation
Community Interaction Plan
Development and Implementation
Legislative Support
Independent Phase II Design Review and Analysis
Minority Business Participation Program
Total
$15,000
$3,000
$15,000
$10,000
$ 8,000
$12,000
$63,000
Post-~ Fax Note 7671 Date .'; /·'
To Fn,m
Co.
Phone• Phone#
--~~ Fax#
TO : Mike Kelly and The Working Group
FROM: Pat Barnes, Science Advisor
DATE June 13, 1997
SUBJECT: Review of Landfill CAP Evaluation
I have reviewed the June 5, 1997 report from S&ME evaluating the Landfill Cap System and
disagree with the statement that the PVC liner "appears to be in fair condition". My points of
concern and questions for S&ME are summarized below:
1. S&ME states that the specifications of original PVC liner was not available for comparison. I
am concerned that by comparing the test results given in Table 2 to a "typical 10-mil PVC''
liner, we may not be comparing apples to apples. Can a range of values be provided for
various types of IO-mil PVC liners available so that a more detailed comparison oftest results
can be made?
2 I am uncertain how the PVC liner condition could be considered fair if the seams showed root
penetration along "several seam sections''. Root penetration means the PVC liner has failed
and if it has failed I'm not sure its condition should be considered fair.
3. As mentioned, pinholes were present in PVC Sample B-J . This was obvious to everyone
present during the field activities as well. Was an effort made by S&ME to quantify the
density of the pinholes using a light table? This method is much more accurate than the use of
sunlight in the field. A light table may have yield pinholes in Sample B-2 as well.
4. In the field I observed at least one hole in the PVC liner which was approximately 1 /2 inch in
diameter. This hole was not mentioned in the S&ME report. The hole was obviously not
caused by the excavation process because it had roots growing through it. It was either
missed by S&ME or considered a pinhole. Both of which I find hard to believe.
5. I recall that the condition of the liner was documented in the field with photographs. Were
more detailed pictures taken in the laboratory as a part of the analysis? If so, can copies with
descriptive text be provided. I feel that this could be of tremendous value to Working Group
members who were not present for the excavation activities
3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803
Office [phone] • Fax [phone]
MEMORANDUM
June 13, 1997
Page 2
6. Portions of the PVC liner in the north excavation were severely wrinkled and significant
depressions in the surface of the PVC liner were present in the south excavation. The
depressions appeared to be made by a track hoe prior to placement of the PVC liner The
S&ME report does not address whether or not this condition of the top liner may result in
increase potential loss of integrity.
7. As I mentioned in a previous memorandum to the Working Group, a portion of the PVC liner
seam at the south excavation (B-2) appeared to contain no adhesive. This matter was not
discussed by S&:ME
8 With respect to the integrity of the liner system, the conclusions of the report are not as
definitive as they should be. Especially, given the obvious poor condition of the PVC liner as
observed by several in the field .
If as suggested by Joel, there is an earlier draft to trus report submitted to the State, I too would
like to review it. Changes to the report in moving from draft to final could possibly explain the
contradiction between the first and the second sentences of the final paragraph of page 8. I fail to
understand how the PVC liner condition could be considered fair if it is breached "along several
seam sections".
PA.8. p5g·6-I JWtl I.doc
cc : Joel Hirschhorn
CO-CHAIRS:
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
DOLJJE B. BURWEU
HENRY LANCASTER
MEMORANDUM
TO:
FROM:
PCB Working Group Members
Dollie B. Burwell, CO-CHAIR
July 11, 1997 DATE:
RE: Confirmation of July 23, 1997 meeting and its purpose
Please be informed that the purpose of this meeting is as follows :
1) to discuss the implications of the resignation of Secretary Howes,
2) to hear reports and recommendations regarding the sampling and testing from Pat Barnes,
Joel Hirschhorn, Mike Kelly, and the Technical committee and
3) to assess where we are regarding the pilot studies.
We are currently working on the agenda and since Doris will be on vacation next week, we will
try to make it available by fax Tuesday, July 22. Those of you without a fax machine may stop
by the office to pick up an agenda.
720 Ridgeway Street -Warrenton, N. C. 27589
Phone [phone] -Fax [phone]
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 July 10, 1997
AVA
DEHNR
MEMORANDUM: Q, ,
TO: JOEL lllRSCHHO/tlll_ \\ \ .· // -~~
FROM: MIKE KELLY\ ·~. \ \__;
SUBJECT: FUNDING FOR COMP~ETIQN-0-SITE INVESTIGATION I ASSESSMENT
REPORT ON THE PCB 'tA:fJDFILL
As you are aware, your contract expired on June 30, 1997. Yesterday, I met with
department Purchase & Contract's Personnel to discuss the future projects and tasks still
remaining to be completed. We will be sending a contract amendment to you soon detailing the
remaining tasks.
This letter serves as authorization for you to complete work on the Site Investigation /
Assessment Final Report. I am authorizing you an additional three thousand dollars ($3 ,000) to
the current $15,000 remaining in your previous contract to complete this report, based on your
letter of June 19 in which you stated that it would take $18,000 to complete. For a sum not to
exceed the $18,000, we will require a completed final report which details the findings, your
conclusions and basis for your conclusions. The report should be a joint report signed by you
and Patrick Barnes. Patrick, in his letter of June 16, 1997, indicated that it would take
approximately 30-45 days to complete (you did not provide a time frame as I had requested in
my letter of June 17). Although we want the report as quickly as possible, I would hope that it
can be completed no later than August 1 ( assuming you and Patrick started work on it last
month).
Please be advised that we will not pay the above amount until the report is satisfactorily
delivered to us. Your invoice should indicate the number of hours and charges associated with
its preparation.
We are reviewing the current available funds and will soon be allocating the balance of
money for specific projects as detailed in my June 17th letter.
Copy: ..-Bill Meyer
Henry Lancaster
Dolly Burwell
Laird Davison
Doris Strickland
Brenda Rivers
P.O . Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996 If ffiJJiiiJl:&ti
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/ 10% post-consumer paper
07/03/1997 00:58 '3192572504
July 2, 1997
To: BHt Meyer/Mtke Ketty
From : Ken Ferruceio
CHAPELSOUTHERNLIGHTS
9 pages (this cover page, a statement of 3 pages, and 5 pages of supporting
matertals)
F'AGE D1
07/03/1997 00:58 91 92572604 CHAF'ELSCIUTHEFNL I GHT~;
NIOllttnum
July 2, 167
To: PCB Working Group Acting Co-Chair• Dome Burwell,
Henry Lanca•ter
cc: Working Grol.lJ) Members, Science AdVtsors
Jam• e. Hunt; Jr., Governor of North Caronna
Joan Weld, Envtronmental Advisor to Governor Hunt
Jonathan B. HOwts. Secretary, DEHNR
John Hankinson, ReglOn IV EPA Administrator. Atlanta, Georgia
Btshop Robert Johnson, Episcopal Diocese of North Caroltna
Bishop Gary Gloster, Episcopal Diocese of North Carolina
News Mecfi«
From: Men fe,rucclo /~
F'ACiE 02
SUBJECT: THE URGENT NEED FOR A PCB WORKING GROUP MEETING
TO RECONSTITUTE THE WORKING GROUP AND FOCUS ON CAmCAL
Iss,u11
tarn stating to you, Henry and Dome, and for the pubtlc record the following points:
Througll your concerted effort• a, acting co~chalrs, the state h11 been
able to proJect the publlc perception that It Is committed to a cltlzen-
empo•••ld democratic proce1• for detoxification of ffle PCB landf111
througt. the wo'1< of the Joint warren County/State PCB Landflll Working
Group, t>ut, In fact, It Is not. The mautve public deception that a
functtontng Wotktng Group exists has not gone unnoticed by all who are
wH.,...-to ttMt ,rocna.
(1). The fact that you •• co-chairs have not called a Working Group
melttna · ( e1pect1ny after It wa• requested by membere and lnd•pendent
aclM1tfffl) reftecta • d1anagard for the needs and right• of Warren County
clttn•~
(2) · ·Ttfe ' membership Of the Working Group that was tb have reeolved the
PCllfdtalfln crtala through the democratic proceas expired seven months
ago and h,t yet to be reconstHuted.
07/03/1997 00:58 9192572504 CHAPELSOUTHEFNLIGHTS PA(3E 0::
(2)
(3) Extremely •erloue laaues concerning the PCB/dioxin tandtllt crisis
need to be addressed lmmedtately by the Working Group, as clearly
Indicated by the encto•ed memos from Working Group Member• and
Independent sctenrtats, some memos strongly suggesting or urgently
requesting a Working Group meeting to be followed by pubtlc Information m•••n ...
( 4) . 9ut theae memos have falled to effect a meeting through you aa
aC,tng co-chairs at a ttme when putting off meetings obviously
undermines detoxification objectives. By not achedullng a meettngt you
are facmtattng state/EPA strategies and propaganda. undermining the
po•ltlon of Independent eclentlats concerning the failed status of the
landffll, and farnng to provide representative, stable leaderahtp and Input
for the people Of Warren County.
Hanry, I would expect nothing less from you as co-chair because you take your
marching orders frbm the Hunt administration, one of which was to instiMlonartze the
Wortdng ~roup, wait for the membership to expire. then delay reconstituting the
Working Group wtine simultaneously creating the publlc perception that a functioning
Working Group informed by the democratic process actually exists when, in fact. it
does not. Thia I• a atrategy of massive public deception and ta a clear
Indication of how the Hunt administration's pollctes are discriminatory
and ate based on I wllllns,nee• to enslave and sacrifice people,
e1pect11ty . people of color, by keeping them tn Ignorance ot the tacts,
oftM'I · through the help of people of color.
But l'artt the prNmptlon of the democratic proceee foltowed by the UN of
force the very Naenee of the waste expansion pol let•• that have
domln•ted North Carollna under four Hunt admtnlatratlone, beglnntng
with Hunt•'s 1981 Yf.11!1 Management Act,. preempting the democratic
proce11 concemlng elftngsf and followed by the use of force hen, In
1982/itl'?
Now, once again the Hunt administration ta disregarding the democratic
proce•• regerd1ng the PC&'dloxln crtate and la about to use force. Thi a
tlrwe tht u•e of force woufd be backed by an EPA Compliance Order to
attempt· to rNotve the crtal1 at the landfill with a · band-aid solutlon • that
ha~, been ctearly rejected by the Working Group and by Warren county
cltll ... :N •H.
Let me at•te my poettfon very clearfy concerning ·the at,te's uae of force
10 that there can be no doubt as to where I stand. I am not aayfng that
:I ..
07/03/1997 00 :58 91 92572604 CHAPELSOUTHERNLIGHTS
(3)
the state cannot prevall through the use of force. I am saying that the use
of force fa the only way the state can prevail
(1) tf It contlnuH to lie to the publle about the status df the landfltl by
talsltytng docurnenta, teat results; etc., and by getting contractors to do
llkewtae,
(2) rt · 1t continue• to circumvent the democratic proce•• by not offlclally
recondtutlng the Working Group,
(3) ff It· continues to block Working Group meetings and the flow
of tnfCJntmtton to the pubUc,
(4) ff It circumvents Hunt's detoxlttcatfon promise of 1982, gtven
techntcat f•••I nmty. and
(5) tf I·t uaea an ·EPA Compliance Order to Justify the uae of force
and thu. thlfta the focus ot moral reaponslblllty for uetng force
from ltNlf to EPA, and Juattflea the use of force on legal grounds.
Oolfte, given the urgency of the issues and the obvious need for a meeting
as expr8$Sed ln the foHowlng memos, a co~chalr who actually represents local
warren County citizens would be screaming tor a meeting.
I hwe therefore taken the time to provide you with outltnes and abatracts
regarding the tonowlng memos because I am convinced that after you
have rad this Information, you must either provide local representation
tor the people of Warren · County by lmmedtately echedultng a Working
Group meeting. or submtt your resignation as acting co-chair so that
tocllf n,preeentatton can be provided on the executive committee.
07/03/1997 00:58 91 '32572504
May 27, 1997
(4)
To: PCB Working Group, Science Advisors
From: Jim warren
CHAPEL~;OUTHERHL I (iHT~;
Subject: Concerns about the state's intentions
I. Evidence for falled ••ndf 111
A. Dioxin in groundWater
B. PCBs in air amiSSiOns
C. L&achata system failure
D. Sertous damage to top liner
II. Conoema at,c,ut atatelEPA
A. Stowness Of state
1. State delayed making test results on PCB air emissions available
to Science Advisors. High PCB levels were shown in some samples.
2. etn Meyer has not followed through on March offer to
contact EPA and request an EPA/state agreement "that compliance
probtems be remedied through detoxification."
3. State has had six months to revalidate the Working Group but has
not done so.
8. State/EPA Strategtes
1. State Is planning to pump water from landfill before full-scate
detoxifleation.
2. EPA may --forcen state to pump.
3. State planning a risk assessment to "prove" site poses no danger.
4. "Short-term fixesn would enable EPA to make token commitment to
detoxification then 11stall for infinlty.n
5. Mike Ketty and possibly others promoting Idea that this site doesn't
warrant detoxification. This contradicts Meyer JKeHy datoxtftcatlon
commitment stated to Working Group.
PAGE 05
6. The state may be stalling, gambling Governor Hunt can weather the storm.
ff stall ts on, Is the Governor's office in on rt? Are the Governor's people
informed on present status of work_ by the Working Group?
7. Lancaster is planning to propose changes in Working Group's structure
fsee my June 1 S press release on the restructuring issue)
Warren expresses concern that funding for the Working Group process and for
independent scfenttsts will be exhausted within a few months and proposes that
''we: tmmldfately begin planning for a community meeting and to prepare for a
coniprehttrniivl!t news release concurrent with a formal report from the science
advtsors regarding the complete results of the recent site tests," and asks acting
co-chair DoHie Burwell to can a meeting within two weeks. [No response to memo]
07/03/1997 00:58 9192572504 CHAPEL~U_ITHERflL I GHTS F'AGE Of:.
June 10, 1997
(5)
Press Statement with copies to Science Advisors and PCB Working Group
From: Ken and Deborah Ferruccio
SubJect: North Carollna's PCB/Dioxin Landfill Crisis t·n Warren County
Presents tnformation on the present status of the landfill, on the latest state and
EPA strategies {pumping before detoxifying, etc.), on the Implications of lmptementtng
the strategies, provides context and perspective on the Hunt administration's waste
management policies (waste expansionist policies and strategies}, and warns the
Governor and hts administration concerning an EPA/state attempt to pump prior
to detoxtfteation.
June 13. 1997
To : Mike Ketty and The Working Group
From : Pat Barnes. Science Advisor
Subject: Review of Landfill Cap Eval uatton
Barnes challenges the position of the engineering firm S&ME that the PVC liner is in
fair condttton and presents a summary of points. He concludes by stating his desire to
review an eartter draft to the report on the PVC liner if such a report exists and can't
understand how ttie liner can be in fair condition since It's breached.
June 13, 1997
To: Workwtg Group
From: .x. Hirschhorn
Subject: Recent development• and some concerns
Hirsehhom states that there were two drafts regarding S&ME's report on the condition
of the PVC liner and is concerned that " the contractor went out of his way to downplay
the negative ftndings about the liner. n Hirschhorn writes:
I think the Working Group should feel quite disturbed about the fact that
the state had received a draft report that it did not share with the science
advisors and that it never Informed us that such a draft report had been
issued even after repeated expressed concerns about the long delay in
receiving the report from the contractor. If the Working Group feats as I do
about the behavior of the state, then I recommend that it formally ask Mike
Kelty in writing for a copy of the original draft contractor report and the
written state comments given the contractor.
Concerning an EPA Compliance Order, Hirschhorn states his concern
tnat EPA may l■aue a Compllance Order to the state
and that the Working Group would not neceaaarlly be
Informed about the transmittal of an offlclal document
07/03/1 997 00:58 91 '3 2572504 CHAPEL~;l]IJTHERt,ll I GHT~;
(b)
to the state. Thia opens the posslblllty for the state to
secretly take actions at the landfill that It Interprets ••
necessary to reapond poalttvely to the EPA order.
PAGE 07
Taking what I call bandwafd actions, such as dewaterlng the
landtlll and fixing the leachate collection pumping ayatem,
would In my opinion constitute an action making eventual full
scale landfltl detoxification highly unllkely. I am recommending
to the Working Group that they formally In writing ask both EPA
Region 4 and the state to Immediately provide the Working
Group with a copy of any type of Compliance Order t hat EPA
lsauee, or haa already Issued to the state.
Hirschhorn concludes his memo by stating that "there are good reasons,
1nc1·udlng those preaented recently by Jim warren In his May 15 memo,
for a meeting of the Working Group, lneludlng reviewing the results of all
the site tnveatlg,ttlon work conducted at the landfltl." (The acting co--
chair• did not call a meeting.]
June 16, 1997
Press Statement With copies to PCB Working Group and Science AdVlsors
From : Ken Ferruccio
Sub)ttct: Responaea to Enclosed Memo From PCB Working Group Acting
Co-Chair. Dome Burwell and Henry Lancaster to PCB Working Group
Members Concerning May 29 Meeting With Secretary Jonathan B. Howes
Focuses on procedural and substantive issues concerning the restructuring of the
Working Group, the six-month delay concerning restructuring , and challenges the
position that 1'stabte leadership and input" has been provided,
June 20» 1997
To : PCB Working Group, Science Advisors, Senator Frank Ballance
From : Jim warren
Subject: Sertoue Problem•
Warren urges" Dotlie [Burwetl], as acting Co-Chair. [to] promptty follow Joel's
June 13 a<Mce and formany ask EPA Region 4 and the state to Immediately provide
the Working Group with a copy of any type of Compliance Order that EPA issues, or
has already issued. to the state. And to notify the WG [Working Group] of this."
Warren states his concern that the Working Group does not yet have a completed
report "regarding the March site testing.'' but that Pat Barnes could complete his report
within a few days once funding became available, Warren therefore asks Dollie and
Henry to do what's necessary to provide the amount needed from the "roughly
$100 thooeand apparentty remaining from the WG [ Working Group's J original
allocation."
07/03/1997 00 :58 '3192572504 CHAPEL'.:UJTHERt--lL I GHr::;
(7)
warren argues that" with all the problems we already know about ---Joel states ..
that dioxin is out of the landfill---and with a potentially serious threat to the community
from air emissions, why should we wait for such important information? Who will justify
this?"
Warren reminds the Working Group that they along with the science advisors agreed
in December" to begin to inform the community this past spring, yet no move to do so
has occurred. We have a responsibility."
warren states also his belief that the state has acted in bad faith "regarding the release
of SM&E's engineering analysis of the landfill liner/ arguing that" the state provided
substantial input and apparent 'editing' of S&ME's original draft prior to a June 5 final
report. Warren wants the Working Group to be" provided with all information from
SM&E (including both earlier drafts) as well as the state's extensive comments which
were apparentty incorporated, at least in part, in the final report."
warren asks Henry and Dollie to "formalize this request," and adds that " This situation
has the look and feet of a classic manipulation of information ---a sanitizing of
negative data regarding the landfill. I hope I am wrong." Concerning
restructuring of the Working Group, Warren writes:
I strongly oppose Henry's idea of restructuring the Working Group.
I ask that both acting Co-Chairs { Burwell and Lancaster]
reaffirm support for the democratic process which the WG
painstakingly pursued in December and January to reconstitute
and, I believe, strengthen the WG . After we followed a fair and agreed-upon
process. and have waited in good faith for six months for our process to be
endorsed by the Secretary, it is wholly unjustifiable and somewhat lnsutting
that addittonal changes are being considered at this time, What is going
on?
Warren appreciates Secretary Howes' reiterating "the Administration's commitment
to detoxification of the landfill, support for the Working Group and science advisor
support," a commitment stated in a June 12 memo by Burwell and Lancaster to
the Worktng Group regarding their May 29 meeting with the Secretary,
Warren adds that the Secretary "can fortify his words ... by diligently pursuing the
rectification of the above problems." Warren concludes by restating his request of May
15 {Which he parenthetically notes u was not responded to)·· that the Working Group
needS to meet very soon to discuss the above issues and more." He asks
that Dollie and Doris Fleetwood [PCB Office Secretary]" conduct a poll of alt
members [of the Working Group] to determine the best of the three following dates
to meet: July 9, 10, 11 ," Warren asks" Dollie and Henry to make all efforts to
ensure we will have a completed report from the science advisors by that time."
[As of yet. no such poll has been conducted, nor have we been notified that a Working
07/03/1997 00 :58 9192572E,04 CHAPELSCIUTHER~~L I GHT~;
Group meeting has been scheduled.]
(I)
July 1, 1997
To : Co+Chairs DolHe Burwell/ Henry Lancaster
Working Group Members
From: Bobbie Riley
PAGE 0'3
Ms. Riley, who lives two mites from the landfill, cannot understand why co-chairs have
not responded to recent requests for a Working Group meeting to discuss
critical tssues mentioned in memos, issues demanding immediate attention and which
will require several meetings to address. She requests that a co-chair call a meeting
as soon as possible and, abstracting from memos she's read, she lists eight
agenda Items for the meeting.
Ms. Ritey concludes as follows:
It all appears very questionable to me. As a private citizen serving
on this committee and living in this community I am worried. We
are accountable and need to act responsibly to make sure these
processes are not flawed.
I was surprised to read that Jim's memo and request [for a meeting]
of May 15 was not responded to. As a member of the WG I will expect a
prompt response to this request.
~,,
~-?atu~ July 2, 1997 ...................................................................................... by FAX
/J-;,_;f(, To: Working Group through Doris Fleetwood
~µ.s
Froru: Joel Hirschhorn
I hope that you have previously received the communication from me \\.1th questions concerning
the background of Dr. Richardson, whom Bill Meyer has asked to review various documents
about the landfill condition and the views of the Science Advjsors.
Those questions have been answered by Dr. Richardson and he has also provided me a copy of his
detailed resume. Clearly, Dr. Richardson is a senior, distinguished professional.
However, in my opinion, .he is very likely to give Bill Meyer the kind of comments the: state
wants, namely comments that downplay the unacceptable condition of the landfill and the
evidence that it is leaking.
The main points that I find troubling is that Dr. Richardson is a former, long term employee of
S&ME, the contractor whose report I have questioned, bec:tuse of questionable interpretations
made about the condition of the top plastic liner resulting from likely comments on a draft giv eu
to the state. His resume lists l O projects involving landfills in North Carolina where his clients
have been counties, cities, or waste companies; such projects in some way must involve· approvals
by the state. Therefore, although he has not worked directly for the state, some of his
professional work certainly involves the state and, therefore, he would be reluctant to take public
posjtions contrary to the desires of the .state.
Dr . .Richardson also has strong ties with the U.S. EP~ and clearly EPA has some responsibility
for the Warren County PCB landfill. I also thiuk it is fair to say that much of his career has been
associated \.vith being an advocate of landfills.
Although we have a copy of the letter sent by Bill Meyer to Dr. Richardson, it is difficult for me
to believe that the letter represents the first and only communicatio.n betwee!l the two. We do not
know what may have been said to Dr. Richardson m informal phone or personal conversations.
My view is that we can expect Bill Meyer to receive what he wants, namely statements from a
highly credentialed professional that downplays the problems with the landfill and disagree!'; with
the view that the data indicate a .leaking landfill I find it difficult to believe that Dr. Richardson
would openly criticize what both EPA and the state did in terms of the design, construction, and
operation of the landfill.
It seems to me that what we have here is yet another piece of evidence indicating that tb~ state is
seeking ways to thwart attempts to obtain detoxification of the landfill, regardless of public
statements that supposedly support detoxification.
cc: Pat Barnes