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HomeMy WebLinkAboutNCD980602163_19990308_Warren County PCB Landfill_SERB C_Detoxification, Nov 1997 - Mar 1999-OCR-1,;•.:·_.•\:· . •.'•', JAMES B. HUNT JR;, :}'iiG<;>~TTtR ··.-... :,:· .. : . ~~-!} > NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT March 8, 1999 MEMORANDUM TO: Daria Holcomb Kathy Lawrence Nan Freelan Pat Backus ike Kelly FROM: Pat Williamson SUBJECT: Job Description for Community Involvement Coordinator In our phone conference call on Friday, March 5, we agreed that the following should be included in the job description for the Community Involvement Coordinator: Help obtain funding for detoxification of the PCB landfill and community activities; Serve as a liaison to the state, the community, and the PCB Working Group, including assisting with local contracting/sub-contracting needs, working with technical advisory group/science advisors as necessary, and facilitating job training activities; Lead community involvement; Provide education and updates about the PCB Landfill; and Have strong writing and verbal skills. 401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605 PHONE 919-733-4996 FAX 919-71 5-3605 AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER STATUS OF PCB LANDFILL DETOXIFICATION WARREN COUNTY, NC February 25, 1999 BACKGROUND: In the late l 970's several thousand gallons of polychlorinated bi-phenyls (PCBs) were illegally disposed by spraying along approximately 210 miles of state roadways. PCBs were used extensively as transformer fluids in the early l 970's. However, because they were suspected carcinogens, they were outlawed from manufacture in 1976 and strictly controlled in disposal as transformers came out of service. Listed as a Superfund site under the US EPA program, the roadways were dug up and the contaminated soils disposed in an approved PCB landfill located in Warren County. There was much opposition to the landfill and the Environmental Justice movement supposedly started at this site. In 1982, Governor James B. Hunt, Jr., made a commitment to the people of Warren County that if appropriate and feasible technology became available, the state would explore detoxification of the landfill. In I 995, $1 million was appropriated to study detoxification. The General Assembly provided this money for the sole purpose of studying various detoxification technologies, including bench scale work; confirming that detoxification is possible; and identifying the best technology available to do the work. The Warren County PCB Working Group (WG) was established and consists of local citizens, state employees and members of various environmental organizations. This group has been working together in a joint partnership to explore detoxification. CURRENT ST A TUS: The WG, through the Division of Waste Management (DWM), contracted with two independent science advisors to provide technical expertise to the WG and to help outline the steps necessary to explore detoxification. With staff from the DWM, the WG and science advisors outlined activities that needed to take place during the detoxification studies. These activities included an extensive site inve'?tf~~igri, IT\6nitoring wells installation, boring into the landfill to extract soils for testing, and the actual detoxification studies. Mobilization/site work: On February 12, 1997, DWM personnel and science advisors began work at the PCB landfill to install additional monitoring wells and begin the site investigation. Fifteen new monitoring wells were installed around the perimeter of the landfill and in the immediate area within .25 miles of the landfill. Three were placed off site as background wells, approximately 1.5 miles away. Two bore holes were placed in the landfill from which soils were extracted and containerized for the detoxification studies. Extraction wells were installed in the bore holes. Two eight foot square areas were dug out in order to examine the top liner of the landfill cap system. "Split spoon" samples were taken of the clay cap and the landfill contents. These samples were analyzed for a variety of things including moisture, compaction, permeability and PCB content. The clay cap is covered by a 10 mil plastic liner. Sections of this liner were cut out and sent to a testing laboratory for examination. The cut out portions were replaced and the holes refilled. Sampling: Extensive sampling was done in the monitoring wells and streams around the landfill. Soil and sediment samples from selected locations around the area were taken. These samples were analyzed for a variety of chemicals including PCBs, dioxin, heavy metals, pesticides and volatile organic chemicals. Detoxification studies: Beginning in I 996, the science advisors for the Working Group, along with DWM staff, conducted a detailed technology screening, evaluation, assessment and comparative analysis on potentially feasible technologies. Potential feasibility had to have been demonstrated through prior successful full scale use of a technology for PCB detoxification work. Any technology that existed only as a research or developmental technology was deemed inappropriate. Twelve different technologies were considered. All but two were screened out. Only Base Catalyzed Decomposition (BCD) and Gas Phase Chemical Reduction technology were found to be appropriate and potentially feasible for the Warren County landfill. Two companies were subsequently picked to conduct bench scale demonstrations. ETG Environmental, using BCD, and ECOLOGIC, using the Gas Phase Chemical Reduction technology, were provided samples of the contaminated soils from the landfill, along with very stringent guidelines and treatment goals for both PCBs and dioxin. Following their bench scale studi?t~~.P co/npany submitted phase I reports that were analyzed by the WG, state staff and science advisors. - 2 .. As a result of these phase I studies, the Working Group concluded that feasible and effective detoxification technology is now available and selected BCD as the preferred technology for detoxification of the PCB Landfill. ETG Environmental, Inc. (ETG) was subsequently awarded a contract to perform this Phase II preliminary design of a full-scale BCD detoxification system to remediate the PCB Landfill (ETG performed the successful Phase I bench scale BCD study). The primary purpose of this report is to develop sufficient conceptual design information to allow for preparation of a cost estimate to form the basis to request funding from the State legislature for final design and detoxification of the PCB Landfill utilizing the BCD process. The BCD process utilizes non-incineration chemical reactions to detoxify the PCBs and dioxins/furans in the contaminated materials. Chlorine atoms are chemically removed from the PCB and dioxin/furan molecules, and replaced with hydrogen, rendering them non-hazardous. The resulting non-hazardous oil can be recycled off-site. Detoxified soils will be replaced on-site, covered and revegetated. The process has been proven at several full-scale project applications. The preliminary conceptual design of the full scale detoxification project is divided into two components. The first component provides written conceptual designs for site preparation, excavation, treatment, confirmation/verification sampling, stormwater management, security, site reclamation, decontamination, and demobilization. These aspects of the project have been conceptually designed to provide the basis for a detailed cost estimate for detoxification. The second component presents those aspects of the project which will be completed during the final design portion of the Phase III Design/Build detoxification. Outlines have been provided to introduce these final design items, as follows : emergency response plan, permitting plan, performance demonstration plan, air monitoring plan, quality assurance plan, health and safety plan, construction quality assurance plan, and technical specifications. To assist in the overall project oversight, a Citizens Advisory Board (CAB) would be established as a committee to the Working Group and would include an independent science advisor(s). The Design/Build detoxification contractor would include Program Management, working in conjunction with the state, to ensure that the local community has a strong role in the detoxification project's implementation. The Design/Build detoxification contractor would also include a coordinator to ensure maximum economic benefit to local/minority businesses and the local economy. Direct local economic impact is estimated in the range of $3 million to $5 million, which includes the hiring of local individuals and utilization of local businesses for supplies, materials, and services to support the detoxification project. A detailed cost estimate has been prepared to perform the detoxification project utilizing the BCD process. A cost of $23,975,000 is presented, which includes a $2,079,000 contingency. ' ·'i\:.Q.nce funding is obtained, we would send out requests for a statement of interest from , WI ' ••• ,_ '\ various vendors who have the ability to use BCD technology on a full scale operation. We would also be preparing a RFP for the final design report on the detoxification effort. A RFP would be sent out and a vendor selected for the detoxification through competative bids. 3 CURRENT ST A TVS: The North Carolina General Assembly appropriated $2 million in 1998 to begin detoxification of the landfill. This appropriation bill also specified the BCD technology and cleanup levels of 200 ppb PCBs and 200 parts per trillion toxicity equivalent concentration (TEQ) for dioxins/furans. In January 1999, the state hired Ms. Pat Backus, chemical and environmental engineer, to be the project manager for detoxification. The state is currently completing the scope of work and contract negotiations with ETG Environmental for completion of the Phase III final design plan, for full-scale detoxification. It is anticipated that this final plan will be completed in August 1999. During the next few months, the state will be pre-qualifying prospective bidders for the detoxification. Assuming adequate funding is received, a request for proposals (RFP) for the detoxification will be sent out this fall, and a contract awarded in the first quarter of 2000. Depending on a variety of factors, including capabilities of the company receiving the contract, our plans would include an on-site full-scale demonstration in the second half of 2000, and actual detoxification taking place by the end of the year 2000. At the current time, it is estimated that detoxification will take 18 to 24 months of actual on-site work to complete. During the balance of 1999, the state will undertake as much work as possible using the $2 million currently allocated. We anticipate the final phase III work to cost approximately $530,000. Other pieces of the project, such as site preparation, lining of the leachate pond, confirmation sampling under the landfill and utility needs, are being identified in order that they may be completed during the interim time. On February 16, 1999, Henry Lancaster, Mike Kelly and Pat Backus met with representatives of the EPA Region 4 in Atlanta to discuss potential funding support for detoxification and the permitting required from EPA to do the work. CONTACT: Michael A Kelly, Deputy Director Pat Backus, Project Manager Pat Williamson, Public Information Officer, 919-733-4996, ext. 203 919-733-4996, ext. 308 919-733-4996, ext. 337 C:Q.{;1IJIJIU: PCB GJORK rnG GROUP Fax:252-257-1000 Fe b 1 '99 15 :03 F·. 01 JOINT WARREN COUNTY/STATE PCB LANDFILL WORKING GROUP 7 20 RIDCF;WAY STREET WAARENTON, N.C. 2758Q PHONE 252-257-1948 -FAX 252-257• 1000 DQLLJE & .IUJtnLl HCNRY .LANCAIT'Elt FAX COVER SHEET TO: DATE: #PAGES: Henry Lancaster Tommy Cline Dennis Retzlaff Nan Freeland Jim Warren Dollie Burwell Ken/Deborah F erruccio Daria Holcomb Bobbie Riley _ Mike Kelly January 29, 1999 4 (including cover sheet) Working Group Members, 919-733•9519 919-733-1431 252-257-2897 828-255-7953 919-493-6614 252-257-2088 252-257-2604 252-257-5399 252-431-1453 919-715-3605 Please find a meeting announcement and a copy of a letter to Secretary McDevitt that was discussed at the December and January meetings. PCB WORKING GROUP Fax :252-257-1000 Feb 1 '99 15 :09 F·. 02 ~Meetini: Announcement The Joint Warren County/State PCB Landfill Working Group will meet Tuesday, February 23, 1999 at 6:00 p.n1. in the conference room of the Warren County Office. Agenda Items: A) Contract with ETG B) Federal Contact C) Legislative Outreach D) Secretary McDevitt Update PCB WORK I t~G GROUP Fax :252-257-1000 Feb 1 '99 15 :10 I ' Jolnt Warren CcauttylSt1te PCB Landfill W~rkJa1 Group 720 R,jdsew11y Street : We.rfflnlon, North Carolina 27589 ' ' ; -l Depwnent or Bn\;nmont and Natural Re.sources Box 27617 r . I • P. OZ, I I I \ I I 1 __ _ l 3,. Wa;110 MtOevltt, J~ ti&h, NC 276l 1-768f ! I ; I Df Secretary M~Devitt: . . i . t. , ·For the put fo11r i.,.,,, the Warren Counl)'/State l>C13 J,an~fi!l Worklna Oroup as w~ked toward determinbis the CU!rent stmtus of the landfill and o taining full funding or d~tb,cification of the PCB•contaminate-1 soiJ in the landfl.11. We~~ e had 1he liSSistencc of ou~lde science advisors, ls well u St mi11ion provided by \he Oe~eral Ass~mbly to he~ with lh~e tasks I I : Whit~ n1etnbers ofthe Workina Group reel we have tr.svcl~ far alona \he r\)ad I wurd detb,dfication, cur joum~' ;, not >·et flni1hed . Fult fundina for de ,dfication is ,ti !l n . dtd, the phue) fuU•scale plat1 fut detoxlfic,tion must still be prepared, an . a contrector selecte fo: actual cetoxmcaticin, i l . I On January 7, 19~9, Workina Group member, rnet to di~c~s and determine wh t we felt our.tutu.re role should t>e,1memberih!p of the Wcrkins Oroup, and pur aupport and stafff& ueed~. The foHowSna is our propbsal for )'t)ur considerat10n. ! \ Mii•ion: Work toa•ll>•r to dotox!I) the PCB Landlill. i \ Rol~: We would like to continue our efforts to help obwn: fwldin.a for detoxifiqation, t6 serve u I l,iai10n to the state on behalf of the Wurett County oonunW1.ityJ to serve 11 a liaison to the community; to provide edu~tion and updates ab~~t PCB LandfiU isiues; to lead • c~mmunity involvcmtnt CWf'aign; to help dev IC1p spedflcati1ns for detoxiflc:ation of the landfill and f~f the 1ole¢lion of a contractor~ and to oetennine the 1upport ,md budae n~eds for the cm n~ Adviaory ~oard. We sugJcsi havina rcpresentadvca from the foUc\\i a local interests to s rve on t~ Citiitnf Advisory Board: education, eco:1omic eveJopment, health spe;tllist, •mer&ency m11n.a1ement 1 envlronm~ntal 1wzation, ~lected ou.nty cffic.lal or his/her representath·e, civfo 1ro1Jp, con~e ed county citiz.ens, nd citizen• ne4r U-,e PCB LandfiU. PCB WORKrnG GROUP Fax:252-257-1000 Feb 1 '99 15 :10 F·. 04 c, •.,:,. , ;. 7? I O ·~,~ ' ! j i Mr.I Wayne McDevitt. Se4rewy Paaie :z '. 1an~ 2S, 1999 Needs: In order to ;aocompU1h the role of the Cttlr..ens Advi ry Board, we need secretarial ~upport; offic.e apace, supptlc1, and equt t; a community l aison bjred; and technical support from science advisor, o othen on an as me e.d basis. · We would like to thank you for the opportunity to have inp t and be a pert of the process to ~toxify the PCB Landfill. Thi, i11ue hu been an 11rea d cone for the citirAN in rmen County for neerly 20 )'~, and we very much want to continue o efforts with t:1e stat to dct~xif)· the PCB landfill .'. l In llsht of the con~ninl of the Oeneral Assembly. we wou d like to mett with Yfu in the verj near future to discus~ QW' continued workin1 relationship witl\the atate and Werre~ County. Heriry Lancuter will be i~ contact with )'OU to aet a meeting date. i Sincerely, Joint Warren County/State PCB Landfill Working Group 720 Ridgeway Street Warrenton, North Carolina 27589 January 25, 1999 Mr. Wayne McDevitt, Secretary NC Department of Environment and Natural Resources PO Box 27687 Raleigh, NC 27611-7687 Dear Secretary McDevitt: For the past four years, the Warren County/State PCB Landfill Working Group has worked toward determining the current status of the landfill and obtaining full funding for detoxification of the PCB-contaminated soil in the landfill. We have had the assistance of outside science advisors, as well as $1 million provided by the General Assembly to help with these tasks. While members of the Working Group feel we have traveled far along the road toward detoxification, our journey is not yet finished. Full funding for detoxification is still needed, the phase 3 full-scale plan for detoxification must still be prepared, and a contractor selected for actual detoxification. On January 7, 1999, Working Group members met to discuss and determine what we felt our future role should be, membership of the Working Group, and our support and staffing needs. The following is our proposal for your consideration. Mission: Role: Work together to detoxify the PCB Landfill. We would like to continue our efforts to help obtain funding for detoxification; to serve as a liaison to the state on behalf of the Warren County community; to serve as a liaison to the community; to provide education and updates about PCB Landfill issues; to lead a community involvement campaign; to help develop specifications for detoxification of the landfill and for the selection of a contractor; and to determine the support and budgetary needs for the Citizens Advisory Board. Membership: We suggest having representatives from the following local interests to serve on the Citizens Advisory Board: education, economic development, health specialist, emergency management, environmental organization, elected county official or his/her representative, civic group, concerned county citizens, and citizens near the PCB Landfill. . '\ . Mr. Wayne McDevitt, Secretary Page 2 January 25, 1999 Needs: In order to accomplish the role of the Citizens Advisory Board, we need secretarial support; office space, supplies, and equipment; a community liaison hired; and technical support from science advisors or others on an as needed basis. We would like to thank you for the opportunity to have input and be a part of the process to detoxify the PCB Landfill. This issue has been an area of concern for the citizens in Warren County for nearly 20 years, and we very much want to continue our efforts with the state to detoxify the PCB landfill. In light of the convening of the General Assembly, we would like to meet with you in the very near future to discuss our continued working relationship with the state and Warren County. Henry Lancaster will be in contact with you to set a meeting date. Dollie Burwell Co-Chair Sincerely, Henry Lancaster Co-Chair PCB LANDFILL, WARREN COUNTY, NC PROPOSED DETOXIFICATION 1) 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 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 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-~,.p_uring assessment of the landfill, there were indications that the top liner is beginning to fail. flif•itate 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. 10) 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 F F M 9 19 7153 6a5 SOLI D WASTE DIV 11.1 6 .1 998 17:45 i, f!J~ (()-ctJ . . . . I ~ \ ~ l'1ovember 16. 1998 .............. · .............................................................................. by F (,_ I . -. /fl i . .·~ .1-_}-. To: Milce Kelly : }, J i '•Jo\.. Front Joel Hitschhom : • " ...... . ,, Re: Detoxification of the W~eo County PCB Landfill i I . I I have had an opportunity to .txamine tho recently-r.ubmitted propoul by ETG on how t spend the $2 million appropriated b~ the stato legislaturo. 1: J am writing to you because I feel an ethical and professional rosponaibility to protect th interests of the residents of Warren C 1unty and to help ensure wise spend.mg of North Carolina owes. . I • . Let me state immediately tha . I found the ETG proposal without mt6grlty and technfoal uallty and competence. I strongly commend that DENR NOT solo souroe tho project to ET . J strongly reoommend that the ~ate pw-suc an orderly R.FP process. I Moroover, despite any lanp 1 ke in: the appropriations bill specifying the use of BCD, I n~w support DENR finding son,e egal way to keep the door open to other detoxification tecir.ofogie& that can meet the stringent p ormance standards previously cstabliSihed. My reason fofthis ls twofold. Firm, I am dimlaye at the ETG proposal which in my professional opinion in oates a lack of quality and competen ~. For ex:ampie, I found the amount of money wanted for al deiign outrageous and the c : cept that equipment would be pw-oh.ased by the state totiuw unacceptable. For $2 millio~ :I would have expected a very different proposal that woul1 have focused on an onlite pilot det#,onstration of the teclmology. 1 I I Secou~ sin.cc we completed ~e various activities that reiulted in the selection ofETG fdr the Phase 11 work, 1 have become !aware of a different treatment technology that off ors incr ible teob.nioal and econon:,ic advan~ages over ETQ• s BCD process. As l know you appreciat as an experienoed environmental p~'fessionaL the field of remediation technology is in oonstan flux and improvement in response to· o '.mpetitive developments and market needs. Another comp y has mov~d forward veiy rapidly d at this thne probably has more e>rten&ive, highly sucoe field exp~rlenc~ vvith its simple, lo't: cost teohnology 'Which is highly effective for PCBs and di xins. I bollovc its technology could b~ used _at a fraction of the $24 million originally estimated r BCD. ii I 1 hope, th~roforc, that DENR ~ find some logal means of using a RFP that allows other technologies to oompoto. I w~uld also urge O.ENR to oonsidor usms a rapidly expanding\ concept In remedial teolmology oontra~g, namely a Jinn guarantee of mootiag perfomw>ce s••r- Althoush 1 am no longer on Jt payroll as a Soionco Advisor, 1 want to o.tr.r my udstan°I' in any practi.oal way to best ensure ~, use of the most c~otive, safe, and cost-e.ffeodve means or dctoxifytng the Warren Countr PCB Landfill. cc: PCB Worklng Oroup ' i I ; I t I I "' , p. 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. Area required for project implementation including site layout and work zones Site operations and logistics - --3 1, c / {, Q v I Pn. c f\J T S CC u ri I f)' / Construction of contamination reduction facilities if necessary Temporary storage facilities Other potential temporary and permanent horizontal and vertical construction Stonnwater management / • Ponds • Need for infrastructure '~61L~%~· Phasing of fill removal and clean fill placement ·.:..,.:-_ .. 8 .. --'Detailed estimates of quantities to be removed in each phase 9. Site plan showing anticipated final topography of each cell as it is closed l=, /111 J ~ f i 11.,,e,~e!Ji d ,_R-1<-) . 10. Permits necessary -local, state and federal S\--c:-(~ J',l\.c""'L.\ \--c:,v-',~ 3655 Maguire Boulevard • Suite 150 • Orl ando Florida 32803 Office (407J 896-8608 • Fa x (407) 896-1822 I I -I.,;:-I :::_1:::_1; I : I L!Yl·I November 12, 1997 ................................................................................. by fax (2 pages) To: Steve Detwiler Mike Kelly Pat Barnes From: Joel Hirschhorn Re: SUGGESTED TOPICS FOR NOVEMBER 14 KICK-OFF MEETING ON PHASE II DETOXIFICATION PROJECT General goal for meeting: to develop a ~1Jecific work plan that details all the activities and the specific outputs for the fornl Phase Il repo1t. At this meeting all major assumptions, tradeoffs, and paxticulars should be thoroughly discussed and consensus decisions reached on how to proceed. Any issues vvi.th RFP !iliould be thoroughly addressed. A detailed table of coutents 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 procedme for handling changes in the work plan should be agreed to. As to the Phase II repmt being pr~pared, the follo,:ving are imp01tant priorities: TI:te rep01t should communicate in words, figures, and data a technically complete but easily understood picture of vvhat a foll-scale detox project for the landfill would consist of and .look like. All impacts on the local community should be dearly identified. An Executive Summary should be conceived as serving as the basis for presentations to lawmakers and others o.u the Phase II project/repo1t. 171e rep01t should have sufficient details to supp01t 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.~iages, beginning 'With a final design phase, Vvith a reliable cost estimate for each phase . ...., '",. .. ·- Supplemental site investigation "vork to be conducted during the final design phase should be scoped out iu order to resolve uncertainties about contamination outside the landfill that might require detox. Several levels of potential cleanup performance objectives for PCBs and dioxins/forans should be selected to assess different levels of detox and their associated costs. For example, one scenario could nse the st1iugent 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 performance levels on volumes of material to be detoxified and costs must be specified. A site. perimeter air monitoring system should be designed and apprnp1iate action levels defined. Special attention shon.ld be given to landfill excavation and material hand.ling processes and procedm:es aud hovv particuJates ·will be effectively controlled. 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\vater removal by the state. An early phase should be performance verification or demonstration for full-scale equipment. at the site dming a trial production nm. llle maximum amount of excavated materials to be used should be identified, as well as the general protocol, \\1.th special emphasis giv en to air pollution control equipment and effective functioning of a perimeter air monitoring system r--. ..::.:. An emergency response plan should be developed and any special costs identified, such as necessary training for local hospital persouuel. Special attention should be given to local residents w:ithi.n about five miles of the site. A plan to use locally available labor should be developed, v--ith special costs identified, such as technical training for skilled and semi-skilled positions. Use C>flocal finns for supplies should also be examined. A reasonable estimate for the economic contribution to Wanen County from the project should be given. The use of a Citizen Advisory Board with its own · ndent technical consultants should be included in project design and cost estimates. e CAB , 1 ould provide oYersight throughout project duration. A plan to use the project to serve local educatio:oal ust:itutions should be developed based on cooperation with the CAB. For example, site tour , presentations by site managers, and possibly ex-polt of data from monitoring stations to schools r libraries should be considered. l) L l s. ~ '--'---'--~ 2