NCD980602163_20000323_Warren County PCB Landfill_SERB C_History of Landfill-OCR

A.TA
NCDENR
JAMES 8 . HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L . MEYER
DIRECTOR
BACKGROUND:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
March 23, 2000
STATUS OF THE PCB LANDFILL
DETOXIFICATION EFFORT
WARREN COUNTY, NC
In the late 1970's several thousand gallons of polychlorinated biphenyls (PCBs) were
illegally disposed by the spraying of contaminated oil along approximately 210 miles of state
roadways. Listed as a Superfund site under the US EPA program, the roadways were dug up and
the contaminated soils disposed in a Toxic Substances Control Act (TSCA) approved PCB landftll
located in Warren County. Residents and civil rights leaders vehemently protested the location of
the landfill in Warren County. These protests are considered the "watershed event" which brought
the issue of environmental justice to the national level
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 1995, $1 million was appropriated to study detoxification
technologies.
The Warren County PCB Working Group (WG) was established and consisted of local
citizens, state employees, and members of various environmental organizations. This group
worked together in a joint partnership to explore detoxification.
DETOXIFICATION STUDIES:
With staff of the Division of Waste Management (DWM), independent science advisors,
and the WG, an extensive site investigation was performed. This included the installation of
additional monitoring wells, boring into the landfill to extract soils for testing, and bench scale
detoxification studies.
Twelve different technologies were considered. Two technologies, Base Catalyzed
Decomposition (BCD) and Gas Phase Chemical Reduction, were found to be appropriate and
potentially feasible for the Warren County landfill. Following very rigorous testing using
stringent guidelines and treatment goals for both PCBs and dioxin, it was determined that BCD
was the best technology for detoxification.
The BCD process utilizes non-incineration chemical reactions to detoxify the PCBs and
dioxins/furans in the contaminated soils. Chlorine atoms are chemically removed from the PCB
and dioxin/furan molecules, and replaced with hydrogen, rendering them non-hazardous.
Detoxified soils will be replaced on-site as part of a redevelopment plan for the area.
DESIGN ACTIVITIES:
A Phase II, Preliminary Draft Design Plan based on the BCD detoxification studies
estimated the maximum cost for the entire project to be under $24 million. In 1998, an additional
$2 million was appropriated to begin the detoxification process using BCD. In 1999, a maa WWl•MN•M
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/1 0o/o POST-CONSUMER PAPER
chemical/environmental engineer was hired by the DWM to be the project manager and a contract for a Phase III
Final Design was issued.
Several meeting were held with EPA TSCA personnel in Atlanta (Region IV) and Washington, DC
(Headquarters) to solicit input on the final design and to outline permitting requirements for the detoxification.
The final design package was completed in March of 2000. In addition to design drawings and technical
specifications, the package included a Community Outreach and Involvement Plan to help ensure that residents and
local business receive some financial benefit from the detoxification efforts and are kept informed of activities at the
site.
OTHER RECENT ACTIVITIES:
With the selection of a detoxification technology the mission of the WG was fulfilled. In August of 1999
the group was reestablished as the Citizens Advisory Board (CAB) with a new mission to continue to participate in
the efforts to detoxify the landfill and to serve as a liaison between the state and the community at-large.
Additionally funding for the actual detoxification was sought through the EPA Superfund Program, the
EPA Brownfields Program, and the Department of Defense (approximately 10 percent of the landfill material came
from Ft. Bragg). EPA Region IV is providing a grant of $225,000 to fund a Community Involvement Coordinator
and job developer for the project. However, no funding was available from these sources for the actual
detoxification.
In 1999, an additional $1 million was appropriated and $7 million made available to match federal funds
for the detoxification effort. However, approximately $1. 4 million of previously appropriated funds were reverted
back to the state budget office for Hurricane Floyd relief Efforts to obtain federal matching funds were also
suspended in deference to the Hurricane Floyd needs.
CURRENT STATUS:
Based on the outlook of limited additional funds in the near future, a phased funded approach has been
investigated. With the funds available and reserved, site preparation, equipment mobilization, performance testing,
and the treatment of a limited amount of material could be completed. This approach was received favorably by the
EPA and the state budget office. During the time required to complete the initial phases, there will be additional
opportunities to obtain funds from state and federal sources to continue to the project to completion while these
efforts are underway.
A Request for Proposals for the initial phase of work is being prepared for issue in May. Following
selection of a remediation contraction, a contract should be signed by the fall of 2000.
CONTACT: Michael A. Kelly, Deputy Director
Pat Backus, Project Manager
919-715-3644
919-733-4996 ext 308
..
STATUS OF PCB LANDFILL DETOXIFICATION
WARREN COUNTY, NC
24 March 2000
BACKGROUND:
In the late 1970s 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 1970s. 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 BP A program, the roadways were dug up and the
contaminated soils disposed in an approved PCB landfill built in Warren County. There was
much opposition to the landfill and the Environmental Justice movement supposedly got its start
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 1995, $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 PCBWorking Group (WG) was established and consisted oflocal
citizens, state employees and members of various environmental organizations. This group
worked together in a joint partnership with the state to explore detoxification.
ASSESSMENT STATUS:
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
investigation, installation of monitoring wells, boring into the landfill to extract soils for testing,
and the actual detoxification studies.
1
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 boreholes were placed in the landfill from which soils were extracted and
containerized for the detoxification studies. Extraction wells were installed in the boreholes.
Two eight-foot square areas were dug out to a depth of approximately two feet 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. A 10-mil plastic liner covers the clay cap.
Sections of this liner were cut out and sent to a testing laboratory for examination. The cut out
portions was replaced and the holes refilled.
Samplin~:
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 1996, 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
studies, each company submitted phase I reports that were analyzed by the WG, state staff and
science advisors .
2
The N01ih 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 parts per billion PCBs and 200 parts per trillion toxicity equivalent
concentration (TEQ) for dioxins/furans .
In January 1999, the state hired Ms. Pat Backus, PE, and a chemical and environmental
engineer, to be the project manager for detoxification.
On February 16, 1999, Henry Lancaster, then the Deputy Secretary for DENR, 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 requirements from EPA to do the
work. Henry Lancaster and Mike Kelly also traveled to Washington in February 1999, and with
Jim McCleskey, of the Governor's Washington office, met with various members of the North
Carolina Congressional staff The purpose of this visit was to update them on the project and to
visit the Pentagon to discuss the possibility of securing funds from the Department of Defense to
help in the detoxification effort. Approximately 10 percent of the contaminated soil in the PCB
landfill came from Ft. Bragg.
A contract for Phase III, Final Design, was awarded to ETG Environmental in May of
1999. The DWM then sent out requests for a statement of interest to various vendors with the
ability to use BCD technology on a full-scale operation. The DWM wanted to begin looking at
the number of qualified firms available to bid on the full-scale detoxification. Ten companies
submitted letters of interest and qualification packages.
The general assembly passed an additional appropriations bill during the 1999 session to
set aside $7 million out of reverting funds, and to also transfer $1 million from the solid waste
white goods fund for the PCB landfill detoxification project. The appropriations bill for the $7
million will require some federal matching funds .
In August 1999 the WG was reorganized as a Citizens Advisory Group (CAB) with a
mission to pursue detoxification and the necessary funding to complete the project. Their
responsibilities also were to continue working with the state staff and contractors to complete the
final design plans for detoxification and to help finalize plans for the redevelopment of the land
once detoxification was completed.
In December 1999, as a result of state needs for hurricane relief, approximately $1.42
million of non-obligated money was transferred from the detoxification fund back to the state
budget office.
As a result of these phase I studies, the Working Group concluded that feasible and
effective detoxification technology was 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 a 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.) This Phase II design was used as the basis for requesting funds from the General
Assembly 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 re-vegetated. 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.
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 was established, which included a $2,079,000 contingency and approximately
$1,000,000 for air monitoring and testing.
3
4
CURRENT STATUS:
The Environmental Protection Agency (EPA) has agreed to provide $225,000 ($75,000
each year for three years) out of their Environmental Justice Program for the hiring of a
Community Involvement Coordinator to work in W atTen County as a liaison between the local
community, CAB, state staff and the contractor for detoxification. The individual hired will
work through the WaiTen Family Institute and will be located at the Warren County PCB office.
Applications are currently being accepted for this position.
On February 3, 2000, Pat Backus and Mike Kelly, along with representatives from ETG
Environmental, met with the permitting staff at EPA headquarters in Washington, DC. The
purpose of this meeting was to bring the EPA staff up to date on the current detoxification
efforts and to discuss a phase-funded approach to the detoxification project. The detoxification
project will require a permit from EPA. The Final Design Phase III document was completed
and turned over to the state on March 9.
DENR staff met March 21 with state contracting personnel to discuss the RFP for a
phase-funded approach to the detoxification. Work is progressing on this RFP. Under the
current schedule, it is anticipated that a contract for the actual detoxification will be signed this
fall.
Efforts are currently being undertaken to find additional funding to complete the project
as well as the matching federal dollars required under the appropriations bill from 1999.
CONTACT: Michael A. Kelly, Deputy Director
Pat Backus, Project Manager
919-715-3644
919-733-4996, ext. 308
•
PCB LANDFILL
BRIEF HISTORY
In July 1978, the state received the first report of a chemical spill. The spill
material was identified as PCBs on NC 58 in Warren County. PCBs are polychlorinated
biphenyls, a chemical that was widely used as a liquid insulation material in electrical
transformers. The chemicals were banned in 1978.
Eventually, 241 miles of PCB-contaminated roadside were identified in 14
counties. An activated charcoal solution and liquid asphalt were applied along the 241
miles of North Carolina highways where the shoulders had been contaminated with
PCB. This action was taken to temporarily deactivate the PCB to prevent migration
and reduce any hazard to the public.
In December 1978, the state obtained an option on 142 acres of land in Warren
County to use as a disposal site for the PCB-contaminated soil. North Carolina
petitioned EPA to modify its regulations to permit alternative methods of disposal of the
contaminated soil and debris, but EPA denied the petition.
North Carolina and EPA officials signed a cooperative agreement in May 1982
that provided $2.5 million in federal Superfund cleanup money to construct a PCB
landfill in Warren County and clean up the contaminated roadsides. That same
month, the state deeded 120 acres surrounding the landfill site to Warren County as a
buff er zone.
Construction of the landfill began in June 1982. By the end of October, 7,223
truckloads of PCB-contaminated soil had been taken to the landfill. Capping of the
landfill began in November, but bad weather prevented the final soil layer and seeding
of the cap to be completed. Heavy rains in December caused soil erosion on the cap
and bubbles developed in the exposed liner from gas in the landfill (caused by
decomposition of vegetation mixed in soil). The problems were corrected and landfill
completion was scheduled for spring.
Landfill construction resumed in May 1983 and was completed in July.
UPDATE
Staff from the N.C. Division of Solid Waste Management inspect the PCB landfill
monthly to be sure that it remains in good repair.
The four monitoring wells at the site and the four surface water monitoring sites
(upstream and downstream on Richneck Creek and an unnamed tributary) are
sampled twice yearly. No PCBs have ever been found in the samples.
In May 1990, the grass and soil on the landfill cap were sampled. No PCBs were
detected in the cap samples. Only one sediment sample from the leachate pond
showed a detectable concentration of PCBs. PCBs were detected at a level of 0.27 ppm
in this sample, which is below the 1.00 ppm cleanup level for PCBs in soil. State
✓
officials think this residue occurred when the pumps in the leachate collection system
were primed after the landfill was closed.
CURRENT STATUS
In 1993, soon after his return to office, Governor Hunt was briefed by state
officials on the status of the landfill. He was told that the contents of the landfill had
not been sampled since it was constructed and that there was water in the landfill that
needed to be checked to find the source and remove it. In March 1993, at the direction
of the governor, state officials met with Warren County officials in a public meeting to
determine what to do about the water. The intent of that meeting was to get
concurrence on extraction of the water, but several citizens expressed an interest in
detoxifying the landfill. Local legislators also said they wanted to ensure the safety of
the landfill. As a result, the NC Department of Environment, Health, and Natural
Resources set up a 16-member working group composed of Warren County citizens
and state officials to make recommendations to the governor about the future
management of the PCB landfill.
The Joint Warren County and State PCB Working Group, which met for the first
time in March 1994, hired Pauline Ewald as a science advisor to work with the group.
The group later approved a plan to sample the PCB landfill.
In late July 1994, surface soil, air, groundwater, surface water, sediment, and
landfill samples were taken by both the state and Ms. Ewald's company, ECO. No
PCBs were found outside of the landfill. However, the laboratory that analyzed the
state's samples detected some dioxins at the ppq (parts per quadrillion) level in three of
the monitoring wells. Opinions varied as to where the dioxins originated.
In September 1994, the working group's membership was increased to 22.
At the request of the working group and with its strong backing, Senator Frank
Balance introduced legislation during the 1995 session of the General Assembly to
appropriate $10 million for cleanup of the PCB landfill. Though this bill was not
enacted, Senator Balance did get the General Assembly to appropriate $1 million from
the Highway Fund for pilot projects to determine the most appropriate technology for
cleanup of the landfill.
The science advisor to the working group recommended base catalyzed
dechlorination (BCD) as a detoxification method. The working group studied the BCD
process and several other possible technologies. The members felt that the BCD
process was a suitable technology and would be acceptable to the community because
it could be done on site. The working group is currently working with the state to
select vendors and get the pilot projects started.
The working group is also seeking the services of a science advisor since the
contract with Ms. Ewald expired in June 1995.
. '. JAMES B. HUNT JR.
:· .-GoVERNOR
lk .:\_.
,J<:t i'
i, WAYNIE MCOEVI'." t. SECRETARY )' r .
t .:,-'fNILLIAM L. MIEYER 11,. · ..
~'DIRIECTOR
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17 <
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
STATUS REPORT
PCB LANDFILL
WARREN COUNTY, NC
DETOXIFICATION STUDY
REPORT TO THE
ENVIRONMENTAL REVIEW
COMMISSION
APRIL 27, 1998
401 OBERLIN ROAD, SUITE 1150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -150% RECYCLED/I 0% POST-CONSUMER PAPER
Mrs. Dollie Burwell
Citizen of Warren County
Co-chair, PCB Working Group
Michael Kelly, CPM
Deputy Director
Division of Waste Management
Mr. Patrick Barnes, PG
Science Advisor
Barnes, Ferland & Associates
Dr. Joel Hirschhorn
Science Advisor
Hirschhorn & Associates
Mr. Henry Lancaster
Deputy Secretary
DENR
SPEAKERS:
Phase Il -PRELrnINARY DESIGN REPORT
PCB LANDFILL DETOXIFICATION
Warren County, North Carolina
Prepared for
THE JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP AND
THE NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
ICF KAISER ENGINEERS, INC.
Gateway View Plaza
1600 W. Canon Street
Pittsburgh, Pennsylvania 15219
March,1998
Prepared by
In Association with:
BFA Environmental, Inc.
3655 Maguire Blvd. Suite 150
Orlando, FL 32803
ETG ENVIRONMENTAL, INC.
16 Hagerty Boulevard
West Chester, Pennsylvania 19382
Hincbborn & Associates, Inc.
2401 Blueridge Ave. Suite 411
Wheaton, MD 20902
Preliminary Design Report -BCD Detoxification Warren County Landfill
EXCUTIVE SUMMARY
The State of North Carolina owns and maintains a closed landfill containing
Polychlorinated Biphenyls (PCBs) and dioxin/furan contaminated materials in Warren
County, NC. The materials in the landfill were generated from cleanup of areas along
state roads where PCB materials were illegally disposed. Due to considerable local
opposition to the construction of the landfill, the residents of Warren County were
assured by the Governor and the state legislature in the early 1980s that the landfill would
be eliminated through detoxification when feasible and effective detoxification
technology became available.
In 1995 the North Carolina General Assembly appropriated one million dollars to
study detoxification feasibility and to investigate the site. After an extensive review of
potential detoxification technologies, the Joint Warren County/State PCB Landfill
Working Group (Working Group) selected Base Catalyzed Decomposition (BCD) and
Gas Phase Chemical Reduction as the technologies for consideration for detoxification of
the PCB Landfill. Actual landfill materials were tested in a Phase I bench scale study
utilizing each of these two technologies.
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
ETG Environmental, lnc./lCF Kaiser March 1998
--"""'11t-
Preliminary Design Report -BCD Detoxification Warren County Landfill
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.
Toe BCD process utiliz.es 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-haz.ardous. Toe resulting non-haz.ardous oil can be recycled off-site.
Detoxified soils will be replaced on-site, covered and revegetated. Toe 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,
storm water 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. Drawings have been provided to supplement
these conceptual design items.
Toe 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.
ETG Environmental, lnc./lCF Kaiser ii March 1998
Preliminary Design Report -BCD Detoxification Warren County Landfill
To assist in the overall project oversight, a Citiz.ens 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 eontractor 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 $3-5 million, which includes the hiring of local
individuals and utilization of local businesses for supplies, material, 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 contingencf account for the following asswnptions, which could change as
the detoxification project progresses:
1. Quantity and characteristics of the material to be treated. 60,000 tons
of material at 10-12% moisture content and average concentration of
500 parts per million (ppm) for PCBs has been assumed.
2. Regulatory uncertainties associated with permit acquisition and final
design activities.
3. Modifications required to the detoxification project as a result of final
design changes that may result from the permit/final design process.
ETG Environmemal, lnc./lCF Kaiser iii March 1998
SUMMARY -THE BASE CATALYZED
DECOMPOSITION (BCD) TECHNOLOGY
• Non-Incineration Chemical Destruction of Poly chlorinated Biphenyls
(PCBs) and Dioxins/Furans Through Chemical Dechlorination Reactions.
(After Removing Chlorine, PCBs and Dioxins/Furans are Non-
Hazardous ).
• BCD is Conducted in Solid and Liquid Phase. Solid Phase BCD
Removes/Destroys PCBs and Dioxins/Furans From Soil. Liquid Phase
BCD Chemically Destroys PCBs and Dioxins/Furans Removed From
Soil.
• Solid Phase BCD Utilizes Reagent Assisted Indirect Heat Thermal
Desorption. Reagent is Sodium Bicarbonate or Baking Soda. Safe
Process -Operating Temperatures Less Than 1000°F and an Inert (Low
Oxygen) Atmosphere. Reaction Products are Non-Hazardous Oil and
Table Salt (Sodium Chloride). Clean Soil is Left On-Site. Oils, PCBs
and Dioxins are Vaporized and Removed in the Gas Phase.
• Primary Vapor Treatment of Contaminants is Condensing to Recover
Contaminants for Further Chemical Destruction by Liquid Phase BCD.
Low Volume Vapor Flow and Discharge.
• Liquid Phase BCD to Destroy PCBs and Dioxins/Furans. Small Quantity
to be Treated in Liquid Phase -Less than 50 tons for Entire Project.
Produces Non-Hazardous Oil and Sodium/ Potassium Chloride Suitable
for Off-Site Recycling. Safe Process -Operating Temperatures Less than
650°F.
• Technology Proven for Full Scale Applications. Successful
Demonstration on Warren County Soils. Soil and Air Discharge
Standards Met/Exceeded.
Environmental. Inc,
Thermal Desorption I BCD (Chemical Dehalogenation) Contaminated Media Dechlorination Reagent "Clean" Media Dechlorination Reagents ► Off-gas Treatment/ Recycling t Contaminant Recovery/Recycling Water Treatment/ Recycling --~ s=au Envlronmental, Inc.
Continuous Indirect Heat Thermal Desorption System .--...-.. -=-u Environmental, Inc .
Therm-0-Detox Batch Vacuum System --~ s=au Environmental, Inc.
BCD -Chemical Dehalogenation • Destroys Recalcitrant Contaminants: -PCBs -Dioxins I Furans -Pesticides • Licensed from EPA-RREL • Coupled to ETG's Therm-O-Detox,,r System ---------------------------~ -=-u Environmental, Inc.
Dr. Joel Hirschhorn
Doctor Hirschhorn received an engineering Ph.D. from Reusselaer Polytechnic Institute and was a
full Professor of engineering at the University of Wisconsin, Madison for many years. He was
also a senior official at the U.S. Congressional Office of Technology Assessment where he helped
shape several federal environmental laws . He is a nationally recognized expert on toxic waste site
cleanups and technologies. He has published hundreds of papers and several technical books, and
is the Editor of the Journal Remediation. As an environmental consultant he has worked for many
leadi~g industrial companies, state and federal agencies, and grassroots community groups
needing independent technical advice.
Biographical Summary
Patrick A. Barnes, P.G .
Mr. Barnes is a North Carolina Registered Professional Geologists with extensive experience in
hazardous waste site remediation . He is president and founder of Barnes Ferland and Associates,
a full sen·ice Environmental engineering firm. He has more than 13 years of landfill site
assessment and remediation experience including final closure activities at the Love Canal
Emergency Declaration area , and implementation of remedial design at the BROS, IFF and
GEMS Superfund sites. He is the current Technical Advisor to the North Fort Lauderdale
community for the Wingate Superfund site remediation, which like Warren County PCB Landfill
is a nationall y known environmental justice site. Mr. Barnes also has extensive remedial site
construction and project management experience. His primary area of expertise is subsurface
migration of contaminants. For the past 2 years he has worked closely with the Joint Warren
County Working Group as they move closer to detoxification of the PCB Landfill. He has
specifically been responsible for leading the site assessment and community out reaching project
components
PCB LANDFILL
BRIEF HISTORY
In July 1978, the state received the first report of a chemical spill. The spill
material was identified as PCBs on NC 58 in Warren County. PCBs are polychlorinated
biphenyls, a chemical that was widely used as a liquid insulation material in electrical
transformers. The chemicals were banned in 1978.
Eventually, 241 miles of PCB-contaminated roadside were identified in 14
counties. An activated charcoal solution and liquid asphalt were applied along the 241
miles of North Carolina highways where the shoulders had been contaminated with
PCB. This action was taken to temporarily deactivate the PCB to prevent migration
and reduce any hazard to the public.
In December 1978, the state obtained an option on 142 acres of land in Warren
County to use as a disposal site for the PCB-contaminated soil. North Carolina
petitioned EPA to modify its regulations to permit alternative methods of disposal of the
contaminated soil and debris, but EPA denied the petition.
North Carolina and EPA officials signed a cooperative agreement in May 1982
that provided $2.5 million in federal Superfund cleanup money to construct a PCB
landfill in Warren County and clean up the contaminated roadsides. That same
month, the state deeded 120 acres surrounding the landfill site to Warren County as a
buff er zone. ·•
Construction of the landfill began in June 1982. By the end of October, 7,223
truckloads of PCB-contaminated soil had been taken to the landfill. Capping of the
landfill began in November, but bad weather prevented the final soil layer and seeding
of the cap to be completed. Heavy rains in December caused soil erosion on the cap
and bubbles developed in the exposed liner from gas in the landfill ( caused by
decomposition of vegetation mixed in soil). The problems were corrected and landfill
completion was scheduled for spring.
Landfill construction resumed in May 1983 and was completed in July.
UPDATE
Staff from the N.C. Division of Solid Waste Management inspect the PCB landfill
monthly to be sure that it remains in good repair (see attached monthly report sheet
for details of what is inspected).
The four monitoring wells at the site and the four surface water monitoring sites
(upstream and downstream on Richneck Creek and an unnamed tributary) are
sampled twice yearly. No PCBs have ever been found in the samples.
In May 1990, the grass and soil on the landfill cap were sampled. No PCBs were
detected in the cap samples. Only one sediment sample from the leachate pond
showed a detectable concentration of PCBs. PCBs were detected at a level of 0.27 ppm
in this sample, which is below the 1.00 ppm cleanup level for PCBs in soil. State
officials think this residue occurred when the pumps in the leachate collection system
were primed after the landfill was closed.
CURRENT STATUS
In 1993, soon after his return to office, Governor Hunt was briefed by state
officials on the status of the landfill. He was told that the contents of the landfill had
not been sampled since it was constructed and that there was water in the landfill that
needed to be checked to find the source and remove it. In March 1993, at the direction
of the governor, state officials met with Warren County officials in a public meeting to
determine what to do about the water. The intent of that meeting was to get
concurrence on extraction of the water, but several citizens expressed an interest in
detoxifying the landfill. Local legislators also said they wanted to ensure the safety of
the landfill. As a result, the NC Department of Environment, Health, and Natural
Resources set up a 16-member working group composed of Warren County citizens
and state officials to make recommendations to the governor about the future
management of the PCB landfill.
The Joint Warren County and State PCB Working Group, which met for the first
time in March 1994, hired Pauline Ewald as a science advisor to work with the group.
The group later approved a plan to sample the PCB landfill.
In late July 1994, surface soil, air, groundwater, surface water, sediment, and
landfill samples were taken by both the state and Ms. Ewald's company, ECO. No
PCBs were found outside of the landfill. However, the laboratory that analyzed the·
state's samples detected some dioxins at the ppq (parts per quadrillion) level in three of
the monitoring wells. Opinions varied as to where the dioxins originated.
In September 1994, the working group's membership was increased to 22.
At the request of the working group and with its strong backing, Senator Frank
Balance introduced legislation during the 1995 session of the General Assembly to
appropriate $10 million for cleanup of the PCB landfill. Though this bill was not
enacted, Senator Balance did get the General Assembly to appropriate $1 million from
the Highway Fund for pilot projects to determine the most appropriate technology for
cleanup of the landfill.
The science advisor to the working group recommended base catalyzed
dechlorination (BCD) as a detoxification method. The working group studied the BCD
process and several other possible technologies. The members felt that the BCD
process was a suitable technology and would be acceptable to the community because
it could be done on site. The working group is currently working with the state to
select vendors and get the pilot projects started.
The working group is also seeking the services of a science advisor since the
contract with Ms. Ewald expired in June 1995.
.,,
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'
JULY 1978
July 30
AUGUST 1978
August 3
5
10
15
17
17
18
18
28
EVENTS SURROUNDING PCB PROBLEM
First report of chemical spill which was later identified as PCB in Warren
County on N. C. 58
First NRCD laboratory confirmation of PCB's (Johnston County).
Meeting of concerned citizens in Johnston County with state officials.
Memo to local health directors (OHR).
Governor requested the President to declare 14 counties as disaster areas.
Request for emergency relief funds made to the Federal Highway Administration,
U.S. Department of Transportation.
Flyers concerning health effects delivered to residents along spills (OHR).
Governor requested federal assistance through the Federal Disaster Assistance
Administration, Department of Housing and Urban Development.
Blood samples taken from 20 people along spill sites (DHR).
N. C. Department of Transportation begins applying a solution of activated
carbon at the rate of one gallon per square yard and an application of
liquid asphalt at the rate of 1/10 gallon per square yard to the 210 miles
of contaminated highway shoulder.
29 Flyers concerning health effects to crops and livestock delivered to
residents along spill (AGRIC.).
SEPTEMBER 1978 --Search Begins for Solid Waste Landfill Sites
Sept. 1 Memo to physicians in affected counties (OHR).
6 First test of pick up equipment along uncontaminated road shoulder material.
13 Second test of pick up equipment along uncontaminated road shoulder material.
19 Third test of pick up equipment along uncontaminated road shoulder material.
29 Governor's request for assistance from the Federal Disaster Assistance
Administration, Department of Housing and Urban Development1is denied.
OCTOBER 1978
Oct. 4
5
NOVEMBrn 1978
Nov. 6
20
Notified by Federal Highway Administration, U. S. Department of Transportation,
that our request for emergency relief funds denied.
Test of pick up equipment on contaminated road shoulder material on Highway 58
in Warren County.
Test results of pick up of contaminated shoulder material available and
indicates that the contaminated soil can be picked up and treated without
harming the ~nvironment or personnel involved.
Chatham County Commissioners passed a resolution "agreeing to sell the State
of N. C. 6 acres of land at the county landfill site to be used for the
storage and disposal of PCB contaminated soil to include all PCB contaminated soil now known to be in Chatham County."
✓
,,
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.DECEM.6--ER 1978
Dec. 1
4
6
12
15
21
28
JANUARY 1979
Jan. 4
Obtained option on Warren County site (Carter & Paul Pope).
Public Hearing in Chatham County Courthouse on Chatham Landfill site held
by County Co11111issioners and attended by state officials.
Application filed with EPA for Chatham County site.
Application filed with EPA for Warren County site.
Withdrawal of state's offer to purchase site in Chatham County Landfill.
Published Negative Declaration on Warren County site.
Withdrawal of application to EPA for approval of the Chatham County Landfill
site.
Public Hearing on Warren County site held in Warrenton at the National
Guard Armory.
6 Test of in-place treatment on uncontaminated highway shoulder material
in Wake County
29 Secretary Hyde and other N. C. officials met in Washington, D. C., with
Deputy EPA Administrator Barbara Blum and other federal officials to
discuss in-place treatment.
FEBRUARY 1979
Filed petition with EPA to amend rules under the Toxic Substances Control
Act.
15 Test of in-place treatment on contaminated highway shoulder material in
Johnston County (N. C. 210).
MARCH 1979
March 22
31
MAY 1979
May 7
JUNE 1979
June 4
Test of in-place treatment on contaminated highway shoulder in Alamance
County (SR 1010).
Opt1on on Warren County site (Pope) expires--unable to renew.
State agrees to EPA request for an additional 10 days to announce decision
on petition to amend rules.
Douglas Castle, EPA Administrator, rules against petition to change rules
to allow consideration of alternate methods of treatment.
John White, Region _ __IV EPA Administrator, approves Warren County application.
PCB LANDFILL
BRIEF HISTORY
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In July 1978, the state received the first report of a chemical spill. This
was later identified as PCB on NC 58 in Warren County. Eventually, 241 miles
of PCB contaminated roadside were identified in 14 counties. An activated
charcoal solution and liquid asphalt were applied along the 241 miles of North
Carolina highways where the shoulders had been contaminated with PCB.
This action was taken to temporarily deactivate the PCB to prevent migration
and reduce any hazard to the public.
In December 1978, the state obtained an option on 142 acres of land in
Warren County to use as a disposal site for the PCB contaminated soil. North
Carolina petitioned EPA to modify its regulations to permit alternative methods
of disposal of the contaminated soil and debris, but EPA denied the petition.
North Carolina and EPA officials signed a cooperative agreement in May
1982 that provided $2.5 million in federal Superfund cleanup money to
construct a PCB landfill in Warren County and cleanup the contaminated
roadsides. That same month, the state deeded 120 acres surrounding the
landfill site to Warren County as a buffer zone.
Construction of the landfill began in June 1982. By the end of October,
7,223 truckloads of PCB contaminated soil had been taken to the landfill.
Capping of the landfill began in November, but bad weather prevented the final
soil layer and seeding of the cap to be completed. Heavy rains in December
caused soil erosion on the cap and bubbles developed in the exposed liner from
gas in the landfill (caused by decomposition of vegetation mixed in soil). The
problems were corrected and landfill completion was scheduled for spring.
Landfill construction resumed in May 1983 and was completed in July.
UPDATE
Staff from the N.C. Division of Solid Waste Management inspect the PCB
landfill monthly to be sure that it remains in good repair (see attached monthly
report sheet for details of what is inspected).
The four monitoring wells at the site and the four surface water
monitoring sites (upstream and downstream on Richneck Creek and an
unnamed tributary) are sampled twice yearly. No PCBs have ever been found
in the s.amples.
In May 1990, the grass and soil on the landfill cap were sampled. No
PCBs were detected in the cap samples. Only one sediment sample from the
leachate pond showed a detectable concentration of PCBs. PCBs were detected
at a level of 0.27 ppm in this sample, which is below the 1.00 ppm cleanup
level for PCBs in soil. State officials think this residue occurred when the
pumps in the leachate collection system were primed after the landfill was
closed.
CURRENT STATUS
In 1993, soon after his return to office, Governor Hunt was briefed by
state officials on the status of the landfill. He was told that the contents of the
landfill had not been sampled since it was constructed and that there was
water in the landfill that needed to be checked to find the source and remove
it. In March 1993, at the direction of the governor, state officials met with
Warren County officials in a public meeting to determine what to do about the
water. The intent of that meeting was to get concurrence on extraction of the
water, but several citizens expressed an interest in detoxifying the landfill.
Local legislators also said they wanted to ensure the safety of the landfill. As a
result, the NC Department of Environment, Health, and Natural Resources set
up a 16-member working group composed of Warren County citizens and state
officials to make recommendations to the governor about the future
management of the PCB landfill.
The Joint Warren County and State PCB Working Group, which met for
the first time in March 1994, hired Pauline Ewald as a science advisor to work
with the group. The group later approved a plan to sample the PCB landfill.
The sampling is being conducted by state officials with oversite by Ms.
Ewald and her company ECO. Surface soil, air, groundwater, surface water,
and sediment samples are being taken. Wet and dry samples of the landfill
contents are also being taken. Sample results will not be available for at least
30 days.
PCB LANDFILL MONTHLY REPORT
NAME DATE ______ _ -----------------------
1. Entrance Road
2. Monitoring Wells
Casings, locks
Fences, gates, locks
3. Landfill Fence, Gate, Locks
4. Air Vent
5. Landfill Cover
Erosion, vegetation
Subsidence
6. Leachate Detection System
Water in sump
7. Leachate Collection System
Access pipe
Pump
Piping
8. Treatment Works
Influent piping
Sand filter
Carbon filter
Effluent piping
9. Surface Impoundment
Erosion, vegetation
10. Irrigation System
Influent piping
Pump
Sprinkler units
NO POTENTIAL
PROBLEM PROBLEM OBSERVATIONS
DATE ______ _
Pumping Data
Pumping Times
Pumping Volume
Irrigation Data
Irrigation Times
NAME
Irrigating Volume
--------------------------
' ..
STATUS REPORT
PCB LANDFILL
WARREN COUNTY, NC
REPORT TO THE
ENVIRONMENTAL REVIEW COMMISSION
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DECEMBER 22, 1997
BACKGROln'-D:
In the late seventies several thousand gallons of polychlorinated bi-phenyls (PCBs) \Vere
illegally di sposed by spraying along approximately 210 miles of state roadv-.-ays . PCBs were
used extensively as transformer fluids in the early seventies. 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, the state made a commitment to the people of Warren County that if appropriate
and feasible technology became a\'ailable, the state would explore detoxification of the landfill.
In 1995, one million dollars was appropriated to study detoxification.
The Warren County Working Group (WG) was established and consists of local citizens,
state employees and members of various environmental organizations. This group has been
\\Orking together in a joint partnership to explore detoxification.
Ct:RRE:\T STATt:S:
The WG, through the Division of Waste Management (DWM) contracted with tv,·o
independent science ad\ isors 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
in\'estigation, monitoring well s installation, boring into the landfill to extract soils for testing,
and the actual detoxification studies.
Mobilization/site work:
On February 12 , DWM personnel and science advisors began work at the PCB landfill to
install additional monitoring \veils and begin the site investigation. Fifteen new monitoring
wells were installed around the perimeter of the landfill, in the immediate area surrounding the
landfill, and three were placed off site as background wells. 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 areas, 8 X 8 feet in size, 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 of 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.
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:
Two technologies were chosen as the most appropriate for the detoxification study, and
through a Request for Proposal, two companies were subsequently picked as the firms to do the
demonstration with a pilot study. ETG Environmental, using a process called Base Catalyzed
Decomposition (BCD), and ECOLOGIC, using a process called chemical dechlorination, 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 studies,
each company submitted phase I reports which were analyzed by the WG, state staff and science
advisors. After careful study, it was determined that ETG and their BCD process was the best
technology for detoxification of the PCB landfill. ETG was awarded a contract earlier this
month to complete a phase II report, which is a preliminary remedial design for the full scale
detoxification of the landfill.
The final phase II report is expected to be completed in February. It will outline the
process, time frame and costs associated with the detoxification of the landfill.
OTHER ISSUES;
Air sampling/ weather station:
The state and EPA have conducted three sets of air monitoring at the landfill for PCBs.
This testing was done in response to concern for potential release of PCBs into the air following
a report and recommendation by the science advisors. The state has also installed a mini-
weather station with continuous monitoring for temperature, rainfall, barometric pressure and
water level in the landfill.
Compliance:
The state was issued a Notice of Non-compliance (NON) by the EPA in August of this
year. The NON cited the state for failure to complete all necessary annual testing at the landfill
and for not continuously removing water from the leachate collection system. The state
responded with a plan in November, and was notified last week by EPA that the plan had been
approved. As part of this plan, the state will be required to re-cap the landfill if detoxification is
not pursued. The schedule for compliance includes installation of a continuous pumping system
to remove the water in the landfill and expansion of the monitoring requirements for monthly
and semi-annual testing. EPA has given the state until next August to pursue funding for
detoxification before a full scale plan to re-cap the landfill would be required.
Fundin2:
Currently all funds have been committed. These funds will insure completion of the
phase II detoxification study and review by the science advisors. One of the science advisor's
contract will expire in March of next year following completion of the phase II. The other
advisor's contract goes through June 30, and includes additional work for community
involvement and to develop a plan to seek funding for detoxification.
There is approximately $14,000 remaining in the original one million dollars. This
money will be committed to Warren County to continue operation of the WG office which
includes a part time secretary and office space. This office has proven invaluable in
coordinating activities and fielding a variety of inquiries from various members of the state and
local communities. The contract with Warren County has been $25,000 per year for the last two
years, and it is hoped that additional funding will be found to continue this work beyond June of
next year.
Schedule:
As previously mentioned, the phase II report should be finalized in February. It is
anticipated that a report on the detoxification efforts, including cost estimates for full scale
detoxification, will be made to the Commission in the early spring.
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STATUS REPORT
PCB LANDFILL
WARREN COUNTY, NC
JUNE 24, 1997
PART I: BACKGROUND.INFORMATION THROUGH NOVEMBER 1996
PART II: RECENT EVENTS. SAMPLING. DETOXIFICATION STUDY
✓
I f' _.
PCB LANDFILL STATUS
BRIEF BACKGROUND
In 1993, Governor Hunt was briefed by state officials on the status of the PCB
landfill in Warren County. He was told that the contents of the landfill had not been
sampled since construction, and that there was water in the landfill that needed to be
tested and removed. The PCB landfill was constructed to be a dry facility. At the
direction of the Governor, state officials met with Warren County officials in a public
meeting to determine what to do about the water. The intent of that meeting was to
get concurrence on extraction of the water. Several citizens demanded that
detoxification be considered as a prerequisite to dewatering or done simultaneously
with dewatering of the landfill. They also cited the commitment that Governor Hunt
made in a 1982 letter to the citizens of Warren County to detoxify the landfill when
feasible. As a result, DEHNR set up a 16-member working group composed of Warren
County citizens, environmentalists, and state officials to make recommendations to the
Governor about the future management of the PCB landfill.
The working group met for the first time in January 1994. Upon the group's
recommendation, a contract was entered into with Pauline Ewald, head of
Environmental Compliance Organization, on May 1, 1994 for $82,950 (money came
from DEHNR) to serve as the group's science advisor for one year. Her duties were to
recommend site evaluation procedures, a methodology for water removal, a
detoxification technology, and long-term controls for the PCB landfill.
In July 1994, a sampling event was conducted at the landfill by Ms. Ewald's
company and the state. No PCBs were found outside of the landfill. However, the
laboratory that analyzed the state's samples detected some dioxin at the ppq (parts per
quadrillion) level in three of the monitoring wells around the landfill. Opinions varied
as to where the dioxin originated. Despite the fact that Ms. Ewald tried to discredit the
state's findings, she used those findings to conclude in her report that "In the absence
of other likely sources of chlorinated contamination, it is likely that the PCB landfill is
the source for the dioxin and furan contamination noted at the site." The report
prepared by Ms. Ewald was not acceptable to the state. It was peer-reviewed by several
outside sources who were also critical of her report.
The state recommended that the landfill be resampled. The working group
opposed both resampling and removal of the water from the landfill. Ms. Ewald's
report convinced several members of the working group that the landfill was leaking.
Even though several members of the working group aclmowledged that the presence of
water in the landfill presented a potential risk, they did not want the water removed.
They have repeatedly expressed concern that if the landfill were made safe by removing
the threat of the water that the state would not proceed with any detoxification effort.
Ms. Ewald recommended that a technology lmown as base catalyzed
dechlorination (BCD) be used to detoxify the landfill. The state advised the working
group that at least three methods should be considered and that the General Assembly
would want information about various technologies available for detoxification, why
1
certain technologies were approved/rejected, and costs. The working group felt that
the BCD process was a suitable technology and would be acceptable to the community
because it could be done on site. The state and the working group went through the
process of selecting vendors to conduct pilot projects at the landfill using BCD
methods. Two vendors even went through the EPA process for approval. Both
eventually received approval by EPA. Pilot-scale proposals by the vendors included a
cost ranging from approximately $700,000 to $800,000 for on-site testing of
technologies.
Ms. Ewald's contract expired in May 1995.
CURRENT STATUS (July 1, 1995-present)
Membership
The original working group was composed of 16 members. At the working
group's request, the membership was raised to 24 in September 1994. Presently,
there are 21 people on the working group, with Senator Frank Balance serving as an
ex-officio member and Mr. Bill Meyer, director of the Division of Waste Management,
serving as staff. Three positions are vacant (one public safety and two youth).
Approximately 10-12 members show up for meetings on a regular basis, and·they are
the decision-makers. The others attend meetings sporadically or never attend. There
are only two elected officials on the working group. County Commissioner Lucius
Hawkins' attendance is sporadic. He was defeated in the spring primary. Ms. Dollie
Burwell, the Register of Deeds for Warren County, is one of the co-chairs and a regular
attendee. She also was defeated in the spring primary.
The credentials of the working groups members, other than the three state
representatives, are basically unknown. The working group very heavily relies on the
state for staff, technical expertise, and support. Yet members have repeatedly said
they do not trust the state.
Expenditures
In March 1994, Warren County was awarded $100,000 from the Solid Waste
Grants Program to be used for capital improvements on the PCB Landfill.
During the 1995 session of the General Assembly, the legislature appropriated
$1 million from the Highway Fund for pilot projects to determine the most appropriate
technology for cleanup of the landfill.
The working group members decided they needed the services of another science
advisor as well as support staff. On March 7, 1996, Mr. Joel Hirschhorn (Maryland)
and Mr. Patrick Barnes (Florida) were hired as science advisors for the working group.
On March 18, 1996, Ms. Doris Fleetwood was hired as a part-time secretary for the
working group. A joint agreement was made between the DEHNR and the Warren
County Board of Commissioners to provide office space, furniture, equipment,
supplies, conference room, kitchen, restroom facilities and parking for the secretary
2
and the two science advisors. The working group's office opened on March 25, 1996, in
the CP&L Building in Warrenton, NC. The $1 million appropriated by the General
Assembly is being used to pay the science advisors, the secretary, and office rent. The
science advisors are each paid at the rate of $100 per hour of work. The cost for the
half-time secretary and office space is $25,000 for one year. As of September 1996,
$60,252 has been expended from that fund, of which $31,809 has gone to the science
advisors.
In the fall of 1995, the Division of Waste Management began working with CP&L
to provide electrical service to the landfill for pilot projects or any full-scale
detoxification effort. CP&L was paid $64,384 for this service from the capital
improvements account. Poles and lines for electrical service are in place, and
transformers }Vill be added when the specific electrical demands are known. This
provides a permanent source of power for detoxification efforts or dewatering the
landfill, as well as other activities that may require electricity.
Master Plan
After talking with the working group and reviewing files and documents related
to working group activities and the PCB Landfill, the science advisors developed a
master plan. This master plan stated why the working group should change its
current strategy and offered an alternative strategy. The working group approved the
master plan at their April 25, 1996 meeting.
The science advisors offered several reasons for changing the current strategy of
the working group. Briefly, the science advisors stated that it would be just as
effective, and less expensive, to invite a few companies to conduct off-site, bench-scale
tests on the landfill's contents rather than pilot-scale projects. This would also mean
that less material would have to be removed from the landfill for the studies. The
science advisors stated that other detoxification technologies must be thoroughly
examined. They also said that a much stronger case for funding from the General
Assembly could be made by spending money on a more thorough site investigation and
remedy design.
The science advisors recommended several key steps in the alternative strategy.
They felt that a more detailed evaluation of detoxification technologies and vendors
should be conducted by the science advisors. They also suggested that a site
investigation be conducted to determine the current status of the PCB Landfill and the
surrounding area. This investigation, if approved, will include the placement of
additional monitoring wells and a resampling of the landfill and surrounding area. The
site investigation will cost roughly $50,000 (excluding state staff costs), and it will be
funded from the $1 million approved by the General Assembly.
The alternative strategy also calls for several other items:
Designing a soil and waste removal plan and selecting a vendor to do
this;
Issuing a feasibility study report;
3
'f
Inviting vendors to conduct bench-scale treatability tests;
Evaluating test results and selecting/ ranking vendors (to be done by
science advisors);
Finalizing the site investigation report;
Meeting with working group/highest ranked vendors;
Selecting best technology vendor (pre-qualified for actual cleanup);
Hiring best technology vendor as design contractor (under current
funding);
Selecting a remedy and issuing a remedial design report.
The remedial design report would be used as the basis for the working group and
DEHNR to formally propose the landfill detoxification project to the General Assembly
to obtain funding.
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
September and four responses were received in October. These responses were
reviewed by the science advisors. Pending some additional clarification, the science
advisors recommended CDM (Camp Dresser & McKee).
The working group, including the two science advisors, held a meeting on
October 23, 1996. At that meeting, Mr. Hirschhorn presented the members with a
draft letter to EPA Region 4 Administrator John H. Hankinson, Jr., accusing the state
of a "serious and prolonged lack of compliance." The letter stated that the state: "(1)
did not carry out all required groundwater monitoring; (2) failed to analyze early data
that we believe show that the landfill has had water entering and escaping it; (3) failed
to act or plan to remove large amounts of water inside the landfill; and (4) failed to
repair a dysfunctional leachate collection system." The letter also stated that "the
serious and prolonged lack of compliance by the state, as owner and operator of the
landfill, also reveals a lack of oversight and enforcement by EPA Region 4 that
demands attention, explanation, and correction." With a few corrections, the working
group agreed that the co-chairs were to sign the letter, and it would then be sent to Mr.
Hankinson.
Mr. Hirschhorn presented the working group with another draft letter to Mr.
Elliott P. Laws, EPA assistant administrator for Solid Waste and Emergency Response.
The working group requested a clear, definitive policy position concerning the extent to
which CERCLA and National Contingency Plan requirements apply to the PCB landfill.
This letter was approved as written.
Mr. Hirschhorn presented the group with a signed declaration stating that in his
professional opinion, detoxification technology appropriate for use at the PCB landfill is
now commercially available. The two technologies he named are gas phase chemical
reduction and base catalyzed decomposition. In addition, Mr. Hirschhorn presented a
written statement that accused the state of "delaying the efforts by the Working Group
4
to complete the current project to assess, test, and select detoxification technology."
He also stated that the issue is not whether detoxification can be done, but whether
the state will honor the commitment made by Governor Hunt in an October 20, 1982
letter.
After considerable discussion about whether to release the letters and the
statements to the news media before or after the November 5 election, the working
groups decided to issue a media advisory on November 11 informing the news media
that there would be a press conference on November 12 at 11 am. It was later
announced that the press conference would be held at the Capitol Building.
At the October 23 meeting of the working group, Mr. Barnes noted that he had
met with Senator Frank Balance and US Representative Eva Clayton, at the request of
working group co-chair Dollie Burwell. Mr. Hirschhorn was not invited to this meeting,
and he subsequently wrote a letter to the working group seeking clarification as to who
had the authority to initiate such an action (i.e., could a co-chair or working group
member authorize such an action without the consent of the others).
Mr. Hirschhorn wrote another letter complaining that co-chair Henry Lancaster
had never explained to him that he had the option of being the sole science advisor or
working with Mr. Barnes. Mr. Hirschhorn said that he was given only the option of
working with Mr. Barnes. In his letter, Mr. Hirschhorn stated that he would have
chosen to be the sole science advisor had that option been given to him.
In response to the accusations made against the state in the letter to John
Hankinson and the two statements drafted by Mr. Hirschhorn, the Division of Waste
Management had a temporary engineering consultant review inspection/monitoring
files to determine if the state was in compliance with permit conditions. The following
are the findings:
• Monthly inspection and landfill leachate monitoring reports are complete for
1984-1986 and from 1990 to the present. Reporting was spotty for 1987-
1989. The PCB landfill was closed in 1983, and 1984 was the first full year
of required reporting;
• From 1983-1993, an estimated (based on pumping rates and pumping time)
12,400 gallons of leachate was removed from the landfill. No documentation
was found for 1987-1989. Amounts ranged from a low of 100 gallons in
1986 to a high of 5 ,297 gallons in 1983. Pumping was not conducted in
some winter months when the temperature was below freezing and the
leachate in the pipe was frozen. In 1994, an estimated 100 gallons was
pumped each month (pumping time available, but calculations incomplete at
this time). In August 1995, pumping ofleachate at the landfill was ceased at
the request of the working group. As of November 1996, pumping has not
been resumed;
• Semi-annual sampling has been conducted each year (beginning in
November 1982) except for 1987 when there was only one sampling done. At
5
, ' '
the request of the working group, semi-annual sampling ceased after May
1995. Semi-annual sampling resumed in early October 1996;
• The Final Technical Report for the PCB landfill project was sent to EPA
Region IV Environmental Scientist Al Hanke in September 1983;
• Background sampling of groundwater, surface water, and surface water
sediments was conducted July-September 1982 (documented in June 30,
1983 letter from Tom Karnoski to O.W. Strickland and is part of the Final
Technical Report to Al Hanke;.
• In the spring of 1990, the Division of Waste Management notified officials in
the Secretary's Office that there was water in the landfill that needed to be
removed, but that funds were not available. A request for funds to dewater
the landfill was not a high priority in the department's legislative budget
package in 1991, and did not make it to the General Assembly. As
mentioned earlier in this report, state officials met with Warren County
officials in a public meeting in May 1993 to determine what to do about the
water. One of the goals of the working group, established as a result of this
meeting, was to assess the need to remove rainwater from the landfill and
recommend to DEHNR the basis and technology for removal or allowing
rainwater to remain in the landfill. The working group did not address this
issue (until the October 23, 1996 meeting) other than to say that it did not
want to dewater the landfill unless done in conjunction with detoxification;
• The RFP (February to October 1996) for the excavation of soils from the
landfill requires the construction of two to four extraction wells into the
landfill. These extraction wells can also be used to dewater the landfill. This
activity will also provide data on the status of the top liner with respect to
liner integrity or leakage.
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. To the division's knowledge, the sampling plan is the
only document that has been significantly delayed. We had envisioned that the
sampling plan would be ready for the working group's approval in the summer. The
initial draft plan supplied by Mr. Barnes was inadequate and lacking in detail. Division
staff worked with Mr. Barnes to draft a plan that could be implemented. The sampling
plan cannot be implemented, however, until the monitoring wells have been
constructed.
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
6
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2, 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background wells will be
included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
11/7 /96
7
RFP for Excavation, Handlin&, and Storaee of PCB Soils from Landfill
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
September and four responses were received in October. However, the RFP did not
clearly indicate that the respondents were to consider the presence of landfill gases,
particularly methane, in design and operation of tasks in the proposal. We have asked
the respondents to indicate their consideration or lack of consideration of methane in
their proposals to the Division of Waste Management. We have also requested all of
the respondents to include an itemized list and cost of all separate elements in their
proposal response to the RFP. The responses are due at noon, Friday, November 15.
The RFP for the excavation of soils from the landfill requires the construction of
two to four extraction wells into the landfill. These extraction wells can also be used to
dewater the landfill. In addition, this activity will provide data on the status of the top
liner with respect to liner integrity or leakage.
PCB Landfill Samplin& Plan
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. We had envisioned that the sampling plan would be
ready for the working group's approval in the summer. However, the sampling plan
cannot be implemented unW the monitoring wells have been constructed, and the
state has focused its attention in this direction.
RFP to Conduct Dioxin/Furan Testin& on Water, Soil and Sediment Samples
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
RFP to Construct Monitorin& Wells
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2, 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background wells will be
8
included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
9
. .
PCB LANDFILL, WARREN COUNTY
ACTIVITY UPDATE
June 20, 1997
I. RECENT ACTIVITIES
On February 12, 1997, the Division of Waste Management mobilized on site at the PCB
landfill in Warren County to begin site investigation and assessment. This phase of work was
designed to do three things:
1) Put in additional groundwater monitoring wells around the landfill, and 3 "off-site"
wells,
2) Put two bore holes in the landfill to extract soil for a detoxification study, and replace
the bore holes with extraction wells, and
3) Collect a series of samples for analysis.
Contracts were issued to various companies to do the work. Two companies, S&ME and
Environmental Investigations, are both local companies and were chosen for items #2 & # 1
(respectively) above. One laboratory in Wilson provided air analysis on samples collected by the
division, and a laboratory in Oklahoma was chosen to do dioxin analysis. The state health lab
provided most of the analysis for the division.
Two vendors were chosen by the Science Advisors and Working Group to provide the
bench scale detoxification study. A contract was issued to ETG, Inc., West Chester, PA, for a
process called base catalyzed dechlorination, and to Eco-Logic, a Canadian firm, to demonstrate
a process called gas-phase chemical reduction.
The landfill activities were completed in mid-April. The Division of Waste
Management's personnel worked more than 2,000 man-hours on the project.
II. MONITORING WELLS
Eighteen new monitoring wells were installed. Seven of these wells were around the
outside perimeter of the fenced-in area, seven were placed in a perimeter from 100 yards to 1/2
mile from the fenced in area, and three were placed on private property approximately 1-2 miles
(air miles) from the landfill (east, south and west) to serve as "background" wells.
The wells, in some cases, are "nested" in the same location, ie one deep and one shallow.
Four monitoring wells already existed at the landfill.
These additional wells will help to identify the geologic and hydrologic features around
the area of the landfill and additionally provide more locations from which monitoring samples
can be taken. The off-site wells provide a broader scope of the groundwater conditions in
Warren County at three different areas located sufficiently far enough from the landfill to insure
that they would not be impacted by it.
III. BORE HOLES
Two bore holes were placed in the landfill, one along the south ridge line and one north
of the vent pipe. These holes were used to extract contaminated soil from the landfill to be used
in the detoxification study. Extraction wells were installed in these holes and could easily be
utilized for the removal of water in the landfill.
An area around the bore holes approximately 8 feet by 8 feet, was opened to the top of the
plastic liner which covers the top of the landfill cap. Samples of the liner and borings from the
landfill cover, cap and materials in the landfill were taken and analyzed for a variety of strength
and permeability parameters.
The plastic liner was in "fair" shape. Some pin holes were noted and of particular
interest, the seam of the plastic liner was not glued in one spot and had been penetrated by grass
roots from the surface cover. The clay cap and cover over the liner were tested and both exceed
the current landfill cover standards for permeability.
IV. SAMPLING & ANALYSIS
More than 200 samples were taken from the landfill, monitoring wells, streams, sediment
and surrounding surface areas during March and April. Samples were analyzed for many
different parameters to include PCB, dioxin, herbicides, pesticides, volatile organic chemicals
and metals.
The initial review shows nothing unusual in the area. No PCBs were detected in the
groundwater or surface samples; trace amounts were found in the landfill leachate inside the
landfill, and of course, in the soils contained in the landfill. All other tests essentially show "non
detects" or negligible amounts, and only the dioxin analysis appears to be in question.
An outside firm from Broken Arrow, OK, was contracted from a list of approximately
eight companies across the country capable of doing dioxin analysis. The samples were
analyzed for 17 different dioxin compounds. It is normally accepted that two compounds
(2,3,7,8 TCDD-tetrachlorodibenzodioxin, and 2,3,7,8 TCDF-tetrachlorodibenzofuran) are
considered "toxic" and of concern. One monitoring well north of and adjacent to the landfill
showed some TCDD, 24 pg/1. This is the only "hit" for a 2,3,7,8 dioxin compound in a
monitoring well, although other dioxin compounds were found in numerous samples, including
the background and "blanks." We have neither received nor produced a report as to the
conclusions from the dioxin data, however, the Science Advisors hired by the Working Group
are using this information to say that the landfill is leaking dioxin into the groundwater. As
mentioned, we found no PCBs in the groundwater, and the Science Advisors have said that our
detection limits were not low enough to adequately determine if, in fact, PCBs are present (the
detection limit was .1 ppb, the drinking water standard is .5 ppb ).
The Environmental Protection Agency "split" some samples with the state, and we have
been told that their data is similar to ours. The Science Advisors have been asked to give us a
date as to when they will have a final report.
V. DETOXIFICATION STUDY
As previously mentioned, two companies were selected by the Science Advisors and
Working Group to perform bench-scale detoxification on samples supplied to them by the state.
These technologies, base catalyzed dechlorination and a gas phase chemical reduction method,
are currently being evaluated. Phase I reports on the studies are due in August, and will be
evaluated by the state and Science Advisors and a contract for a Phase II, preliminary draft
design, will be given to one of the two vendors and technologies.
A Phase II report should be available in November, which will outline the process for full
scale detoxification of the landfill and the estimated cost. We currently project the costs to be in
the $20 million to $30 million range and would estimate it to take from 1 1/2 to 2 years to
complete.
There are a number of technologies available for this type of work. We continue to
receive a number of calls from companies that would like to have their technology considered,
but we have so far focused only on the two selected by the Science Advisors.
VI. AIR SAMPLING
Prior to starting the work in and around the landfill, the state took ambient air samples
from the vent pipe (air inside the landfill) and around the landfill, to check for PCB air
emissions. One of the Science Advisors made a report in November that referenced an air
emission study conducted by the EPA in 1983. His conclusions were somewhat different than
the EPA made, and he was successful in convincing the Working Group that PCB air emissions
were continuing to emanate from the landfill.
In response to this, the state placed a carbon filter on the vent pipe that allows methane
gas generated in the landfill to escape.
In the initial air testing done by the state, air from inside the landfill and at four other
locations did not detect the presence of any PCBs in the air. One sample, however, situated on
the landfill near the vent pipe did show high levels of PCB. Another sampler 2 meters away, and
one pulling air from inside the landfill, did not detect any PCBs. The laboratory rechecked the
sample near the vent pipe, and confirmed the presence of PCB. We have no explanation for the
presence of PCB, particularly in the quantities found, except for lab contamination. The Science
Advisors, however, firmly believe that this is a result of cracks in the cap and the PCBs are
escaping at that point. No other evidence indicates that this is occurring.
The state set up and performed air monitoring at the landfill once work began using high
volume air flow pumps, and workers digging in the landfill wore ambient air monitors. The
results of this testing detected no PCB's.
In January, the state put in a series of plug holes over an extensive grid around the
perimeter of the landfill and later tested each of these holes for the presence of methane.
Methane is being generated and escaping the landfill through the vent pipe, and therefore should
be detectable in a plug hole if cracks exist in the cap, which would provide an escape route for
the gas. None was detected in any of the 25 plug holes sampled.
VII. COMPLIANCE ISSUES, EPA
As a result of investigations and inquiries conducted by the Division of Waste
Management and the Working Group, we have determined that there are areas in which we have
not been in compliance with the EPA permit issued for this landfill. For instance, some monthly
inspection reports are missing for some years prior to 1990, and it can be assumed that the
required monthly inspections were not done.
A permit condition requires that water be removed from the landfill. We know water
exists in the landfill, and we attempt to pump water out on a monthly basis, but are unable to
actually remove much water with the current system. The Working Group, since its inception,
has apparently opposed the removal of water from the landfill because members feel that it the
water is removed, there will be much less incentive to detoxify the landfill. We tried to work
with the group on this matter, but it later used that against the state on the issue of non-
compliance.
We are required to perform extensive semi-annual monitoring at the landfill. We have no
records for two years since the closing of the landfill, and know that in the second half of 1995
and in 1996, no sampling was conducted at the request of the Working Group due to plans for an
extensive sampling plan as part of the site investigation and assessment.
There has also been a lot of discussion by the Science Advisors in regards to the "missing
pipe system" which was in the original set of drawings for the leachate collection system, but not
in the "as built" drawings. Until recently, we were not able to document that the change had
been approved by the EPA. Accusations of "short cutting" the construction of the landfill were
made.
The Working Group sent a letter to EPA in November of 1996 detailing how the state
was out of compliance with its permit. The EPA is investigating and we fully expect them to
issue us a compliance order to come .into compliance, maybe as early as next month.
' .'\
We further expect this order to require us to begin removal of water from the landfill,
which is still adamantly opposed by the Working Group. There are also no funds currently
available to utilize for coming into compliance.
VIII. AREAS OF FOCUS BY THE WORKING GROUP I SCIENCE ADVISORS
The Working Group clearly would like to see the state make a public statement declaring
its intent to detoxify the landfill.
Much of the efforts of the Science Advisors has been to demonstrate that the landfill is
leaking and posing a threat to the citizens of Warren County. As previously mentioned, a lot of
attention has been given to potential "hot spots" without regard to additional results and technical
reasomng.
For instance, focus is being placed on dioxin, when certain conegers of dioxin are found
in almost every sample tested, yet they are "proof positive" that the landfill is leaking, even
though we have very low levels of PCB in the leachate inside the landfill, and no dioxin. There
are also no PCBs in any of the monitoring wells.
The air sampling results for one sample "shows ambient exposure to PCBs," yet the level
is so high that if it was a real "hit," PCBs should have been detected in other samples as well,
especially either in the vent or on one of the high volume samplers.
The Science Advisors are using fluctuating water levels in the monitoring wells and in a
vent pipe to show the landfill has water coming in and going out, as evidenced by the pin holes
and bad place in the seam of the plastic liner. Yet the moisture content and permeability of the
cap is almost the same as it was originally, which would not support the theory of "large cracks"
in the cap. Lack of these cracks is further supported by the methane sampling.
The Working Group wants to show that the state cannot be trusted to keep the landfill
safe, as evidenced by its non-compliance and its failure to properly construct the leachate
collection system, and therefore, it must be detoxified.
IX. ANTICIPATED SCHEDULE
Under the current contracts, we anticipate having a report on the site investigation from
the Science Advisors this summer. The Phase I detoxification studies are expected in August,
and we should issue the contract for Phase II around September 1. The Phase II report, which is
the preliminary draft design, should be received in November. This report would be reviewed
and the Working Group would put together a strategy for the 1998 General Assembly to receive
funding.
Should funding be received, we could issue a contract in the fall of 1998 and begin
detoxification in early 1999, if the technology from the current study is chosen. The process
would be lengthened possibly by one to two years if other technologies are considered.
....
FACT SHEET ON PCB CHEMICALS
What are PCBs?
•
•
•
Abbreviation for Polychlorinated biphenyls .
~ (means many); Chlorinated (contains chloride atoms, such as the chloride .
in table salt which is sodium chloride); hi (means two); Phenyls (is an organic.
compound with a six sided closed ring structure).
Many chlorides on two or~anic compound rin~s
H ~ ~Many Chlorides
CL "V.., CL
2 Ring Structure
What are the characteristics of PCB?
Clear viscous liquid.
Very low water solubility (25 parts per billion).
Strongly sorbed to mineral and organic surfaces.
Approximately 1.5 times heavier than water.
Evaporation at 100 degrees celsius for 6 hours is less than 0.1 %.
Stable at high temperature-requires 2000 degrees celsius for destruction.
What are PCB 's used for in industry?
Primarily used as an electrical insulator to prevent electric arcing in transformers,
also used as heat transfer and hydraulic fluid, vacuum pump fluids, lubricants,
and carbon paper. • PCB 's have not been manufactured or used since 1978.
What is the toxicity of PCBs?
PCBs are very stable and remain unchanged in the environment which results in
biological magnification or accumulation in both plants and animals. Small organisms
consume PCBs and higher life forms consume the smaller organisms thus increasing the
PCB concentration. Higher life forms develop organ disfunction, especially liver disfunction
at high PCB concentration. The primary human health concern is cancer. PCBs have
induced liver cancer in animals, and liver and skin cancers is suggested in humans, however,
there is inadequate evidence of carcinogenicity of PCBs in humans. PCBs are regulated
primarily for environmental impact rather than health impacts.
FACT SHEET ON PCB LANDFILL
What is the source of PCBs in the landfills?
In 1978 approximately 30,000 gallons of PCB was dumped on 241 miles of roads in
14 counties in North Carolina. The source of the PCB's was Ward Transformer Company
located in Wake County. (Alamance, Chatham, Edgecombe, Franklin, Granville, Halifax,
Harnett, Johnson, Lee, Nash, Person, Wake, Warren, Wilson Fort Bragg, are the 14
counties)
What is the concentration of PCBs in the Landfill?
The maximum concentration of PCBs on the road shoulders was 4,900ppm. The
average concentration of the soil-grass-PCB materials placed in the landfill was 135ppm.
How did water get into the PCB landfill?
The landfill received PCB contaminated soils from September 15 through October
27, 1982. During this time several rainfall events, including 2 strong thunder storms,
occurred. Some of the rainwater was diverted to a corner of the landfill and solidified with
cement kiln dust. A major part of the rainfall soaked into the PCB contaminated soil like
a sponge. The final plastic and clay cap was contructed and prevented any further
infiltration of rain water. The trapped rain water over the years has moved by gravity to the
bottom of the landfill. It is estimated that between 500,000 to 1 million gallons of water are
trapped in the landfill.
When did we find the water in the landfill?
The state was aware of the potential for trapped rain to move from the soil mass to
the leachate collection system at the bottom of the landfill. From 1983 to 1990 small
amounts of water was removed, however, the rate of removal was very slow. Less than 50
gallons could be removed before the removal system would become dry. It took several
hours for the water to refill the leachate pipe. It was assumed that the trapped water was
still largely retained in the soil mass and not moving to the leachate or water removal
system. In March 1990 the combination of past pump malfunctions and slow recharge to
the water removal system led to the dismantling of the pumping system and examination of
the internal leacheate or water collection system. At that time a 10 to 20 foot saturated
zone in the bottom of the landfill was identified.
What was done about the water in the landfill?
The detection systems under the landfill and the monitoring wells were checked to
ensure that no leakage was occurring from the landfill. There was no leakage. The
DEHNR was notified. The water needs to be removed to ensure the long term integrity of
the landfill. The proposal is to provide resources to remove the water.
How will the water be treated and disposed?
The PCB landfill site contains an above ground sand and carbon filter to remove
PCBs. Once the PCBs are removed and treated the water will be applied through an
existing irrigation system to the surface of the landfill. The landfill surface is covered with
fescue grass which will utilize the water for growth.
How will we keep PCBs from being applied in the water to the surface of the landfill?
119 samples of water in the leachate collection systems have been analyzed. When
the samples are filtered throurgh the sand and carbon systems no PCBs were detected in
the filtered water. The maximum concentration of PCB in the rainwater has been 0.3ppb.
The reason for this low concentration is the very low solubility of PCB in water and the high
affinity of PCB for soil particles removed by pumping. Filtering removes the soil particles
which are retained in the sand and carbon filters. The sand and carbon will be disposed of
in an off site PCB landfill of the water in the landfill. Monitoring of the detection system
below the landfill and groundwater monitoring was continued and no leakage was detected.
No additional resources were provided to remove the water. In 1992 a budget request was
submitted to address removal of the water from the landfill. The Budget request was not
included in the budget for this budget cycle.
Why do we need to remove the water?
The water does not pose an immediate threat to the landfill through leakage to
groundwater, however, it does increase the pressure or driving forces on the bottom liner,
In order to reduce the potential for failure of the liner and prevent leakage the water needs
to be removed.
How is the water proposed to be removed?
New submergible pumps need to be installed into the bottom of the landfill through
the existing collection and removal systems. Pumping tests need to be implemented to
determine the maximum rate of removal. Once this is done the water will be pumped on
a routine and continuing basis until all the water is removed. The new proposal is to add
storage tanks for filtered water so the water can be tested prior to application as irrigation
to the landfill surface. If any PCBs are detected the water will be refiltered until no PCBs
are detected before irrigation.
How long will it take to remove the water from the landfill?
The current proposal is two years. The removal actions during this time will identify
the rate of removal and if more time is required for removal it will be accomplished by
pumping for more than two years. The actual time of removal is not yet known.
What monitoring will be implemented to ensure the effectiveness of the new effort?
Background sampling of ground water, surface water, grass and soil on the landfill
surface has been accomplished. Additional samples will be taken to ensure a high
confidence level in existing conditions before irrigation is initiated. The proposal also is to
add new storage systems for treated water to ensure proper treatment before irrigation.
This will prevent any PCB application to the landfill surface.
How will the public be kept informed?
It is the intent of the Department of established a mechanism to identify community
leaders of Warren County and establish communication and information transfer systems
to interact with the Department in all phases of this effort. Our intent is to have maximum
participation by Warren County citizens in this effort.
Feb. 13, 1991 The Dept. of Administration made repairs to the
irrigation system.
Mar. 20, 1991 A leachate measurement system was installed to measure
the level of leachate in the PCB landfill cell.
Apr. 25, 1991 Pump-down and recharge measurements were made for the
leachate collection system.
Sept., 1991 Division Task Force established to study further
action needed to pump and treat leachate in the PCB
landfill cell.
Calculations made to estimate time required to remove
leachate from cell.
Estimations of cost of installing a recovery well
in the landfill cell were made.
Calculations made of the possible volume of leachate
in the landfill cell based on varying vertical head
levels and varying porosities.
Oct. 10, 1991 SPATCO submits report on "Landfill Water Recovery/
Treatment Cost Estimate".
Oct. 7, 1991 Carolina Power & Light Company made cost estimate of
providing electric power to the PCB landfill site.
Oct. 17, 1991 A survey of the landfill cell and monitoring wells was
done in order to be able to estimate subsidence levels
during landfill dewatering operations and in order to
estimate relative water table elevations for the
monitoring wells.
----1991 Discussion regarding Memorandum of Agreement to
outline responsibilities of the various departments
(DOA, DOT, DEHNR) for the PCB landfill.
May 29, 1992 PCB landfill resurveyed to verify elevations of
October 1991 survey.
July 6, 1992 Report submitted by Randy McElveen regarding
"Alternatives and Procedures for Evacuating Rainfall
From The Warren County PCB Waste Disposal Facility
Located In Warren County, North Carolina".
. ..
May 30, 1985
Jan. 4, 1990
Div. Env. Mngt. Permit re-issued for nondischarge type
wastewater treatment and disposal facility.
Memorandum from Solid Waste Section to Division
discussing maintenance and operation needs at the PCB
Landfill and the need for appropriations for an
operations and maintenance budget.
March, 1990 Study of landfill leachate system results in an
estimate of approximately 13.3 feet of head in the PCB
Landfill cell.
It was discovered that the foot valve in the leachate
collection system had failed and needed to be
replaced. This explains why no leachate had been
pumped in recent years, since the system would not
hold the prime water.
Other maintenance needs also identified at the PCB
Landfill site.
Plans were initiated for additional investigation of
the leachate head and the leachate pumping system.
Mar 28, 1990 Letter from Dept. of Crime Control and Public Safety
to the Division of Environmental Management requesting
the transfer of the wastewater treatment and disposal
facility permit to the Dept. of Administration.
April, 1990 Additional investigation and sampling at the PCB
Landfill facility including sampling of cover soils,
cover vegetation, sand and carbon from the treatment
system, and soils from the sediment basin, in addition
to the regular sampling of the monitoring wells,
streams, stream sediments, leachate influent and
leachate effluent.
May 3, 1990 The leachate detection probe was repaired and tested.
May 16, 1990 Memorandum from Secretary Bill Cobey, DEHNR, to
Secretary James Lofton, DOA, summarizing
responsibilities of the various departments to provide
support and assistance to the Department of
Administration as the permit holder for the state PCB
landfill in Warren County.
June 26, 1990 Memorandum from Solid Waste Section to the Division
regarding additional equipment and measures necessary
to study the collection and disposal of leachate at
the PCB landfill.
Aug. 28, 1990 The irrigation system at the PCB landfill was tested
and found to be broken.
Sept. 25, 1990 Memorandum from Division, to Solid Waste Section
authorizing purchase of a water level indicator and
other equipment necessary to measure leachate levels,
leachate pumping rates, volumes, etc.
Sept. 25, 1990 Memorandum from Division, to Solid Waste Section
authorizing purchase of a water level indicator and
other equipment necessary to measure leachate levels,
leachate pumping rates, volumes, etc.
1991 The monitoring wells, streams, and stream sediments
were sampled in April and October. The PCB landfill
was inspected on a monthly basis and minor maintenance
and repairs were performed.
Feb. 13, 1991 The Dept. of Administration made repairs to the
irrigation system.
Mar. 20, 1991 A leachate measurement system was installed to measure
the level of leachate in the PCB landfill cell.
Apr. 25, 1991 Pump-down and recharge measurements were made for the
leachate collection system.
Sept., 1991 Division Task Force established to study further
action needed to pump and treat leachate in the PCB
landfill cell.
Calculations made to estimate time required to remove
leachate from cell.
Estimations of cost of installing a recovery well
in the landfill cell were made.
Calculations made of the possible volume of leachate
in the landfill cell based on varying vertical head
levels and varying porosities.
The Division notified the Department of fluctuations
in the leachate levels measured at the PCB landfill.
Oct. 10, 1991 SPATCO submits report on "Landfill Water Recovery/
Treatment Cost Estimate".
Oct. 7, 1991 Carolina Power & Light Company made cost estimate of
providing electric power to the PCB landfill site.
Oct. 17, 1991 A survey of the landfill cell and monitoring wells was
done in order to be able to estimate subsidence levels
during landfill dewatering operations and in order to
estimate relative water table elevations for the
monitoring wells.
----1991 Discussion regarding Memorandum of Agreement to
outline responsibilities of the various departments
(DOA,· DOT, DEHNR) for the PCB landfill.
1992 The monitoring wells, streams, and stream sediments
were sampled in May and November. The PCB landfill
was inspected on a monthly basis and minor maintenance
and repairs were performed.
May 29, 1992 PCB landfill resurveyed to verify elevations of
October 1991 survey.
•.
July 6, 1992 Report submitted by Randy McElveen regarding
"Alternatives and Procedures for Evacuating Rainfall
From The Warren County PCB Waste Disposal Facility
Located In Warren County, North Carolina".
Aug. 28, 1992 The Division submitted to the Department a Budget
Request to perform operations and maintenance at the
PCB landfill.
Nov. 20, 1992 S&ME submitted a report to the Division assessing the
current conditions at the PCB landfill and proposing
methods for the recovery, treatment, and disposal of
leachate from the facility.
..
October, 1982 Governor Hunt meets with residents of Warren County.
Oct. 20, 1982 Governor Hunt's open letter to the citizens of Warren
County.
January, 1983 Sampling of 55 private wells within a three mile
radius of the PCB landfill.
June, 1983 The Intergovernmental Working Group On PCB
Detoxification began meeting. This group met nine
times beginning in June, 1983.
1984 The monitoring wells, streams, and stream sediments
were sampled in June and December. The PCB landfill
was inspected on a monthly basis and minor
maintenance and repairs were performed.
December, 1984 The Final Report And Recommendations of the
Intergovernmental Working Group On PCB Toxification
was submitted to Governor Hunt.
1985
May 30, 1985
1986
1987
1988
1989
1990
The monitoring wells, streams, and stream sediments
were sampled in May and November. The PCB landfill
was inspected on a monthly basis and minor
maintP.nance and repairs were performed.
Div. Env. Mngt. Permit re-issued for nondischarge type
wastewater treatment and disposal facility.
The monitoring wells, streams, and stream sediments
were sampled in May and November. The PCB landfill
was inspected on a monthly basis and minor
maintenance and repairs were performed.
The mo i toring wells, streams, and stream sediments
were sampled in June. The PCB landfill was inspected
on a monthly basis and minor maintenance and repairs
were performed.
The monitoring wells, streams, and stream sediments
were sampled in February and July. The PCB landfill
was inspected on a monthly basis and minor maintenance
and repairs were performed.
The monitoring wells, streams, and stream sediments
were sampled in March and October. The PCB landfill
was inspected on a monthly basis and minor maintenance
and repairs were performed.
The monitoring wells, streams, and stream sediments
were sampled in April and October. The PCB landfill
was inspected on a monthly basis and minor maintenance
and repairs were performed.
✓
,,.
Harch 6, 1990 The Division of Solid Waste Management notified the
Department of the status of the PCB landfill and some
operations and maintenance needs at the facility, and
made recommendations on actions to be taken.
Jan. 4, 1990 Memorandum from Solid Waste Section to Division
discussing maintenance and operation needs at the PCB
Landfill and the need for appropriations for an
operations and maintenance budget.
March, 1990 Study of landfill leachate system results in an
estimate of approximately 13.3 feet of head in the PCB
Landfill cell.
It was discovered that the foot valve in the leachate
collection system had failed and needed to be
replaced. This explains why no leachate had been
pumped in recent years, since the system would not
hold the prime water.
Other maintenance needs also identified at the PCB
Landfill site.
Plans were initiated for additional investigation of
the leachate head and the leachate pumping system.
Mar 28, 1990 Letter from Dept. of Crime Control and Public Safety
to the Division of Environmental Management requesting
the transfer of the wastewater treatment and disposal
facility permit to the Dept. of Administration.
April, 1990 Additional investigation and sampling at the PCB
Landfill facility including sampling of cover soils,
cover vegetation, sand and carbon from the treatment
system, and soils from the sediment basin, in addition
to the regular sampling of the monitoring wells,
streams, stream sediments, leachate influent and
leachate effluent.
May 3, 1990 The leachate detection probe was repaired and tested.
May 16, 1990 Memorandum from Secretary Bill Cobey, DEHNR, to
Secretary James Lofton, DOA, summarizing
responsibilities of the various departments to provide
support and assistance to the Department of
Administration as the permit holder for the state PCB
landfill in Warren County.
June 26, 1990 Memorandum from Solid Waste Section to the Division
regarding additional equipment and measures necessary
to study the collection and disposal of leachate at
the PCB landfill.
Aug. 28, 1990 The irrigation system at the PCB landfill was tested
and found to be broken.
PCB LANDFILL STATUS
BRIEF BACKGROUND
In 1993, Governor Hunt was briefed by state officials on the status of the PCB
landfill in Warren County. He was told that the contents of the landfill had not been
sampled since construction, and that there was water in the landfill that needed to be
tested and removed. The PCB landfill was constructed to be a dry facility. At the
direction of the Governor, state officials met with Warren County officials in a public
meeting to determine what to do about the water. The intent of that meeting was to
get concurrence on extraction of the water. Several citizens demanded that
detoxification be considered as a prerequisite to dewatering or done simultaneously
with dewatering of the landfill. They also cited the commitment that Governor Hunt
made in a 1982 letter to the citizens of Warren County to detoxify the landfill when
feasible. As a result, DEHNR set up a 16-member working group composed of Warren
County citizens, environmentalists, and state officials to make recommendations to the
Governor about the future management of the PCB landfill.
The working group met for the first time in January 1994. Upon the group's
recommendation, a contract was entered into with Pauline Ewald, head of
Environmental Compliance Organization, on May 1, 1994 for $82,950 (money came
from DEHNR) to serve as the group's science advisor for one year. Her duties were to
recommend site evaluation procedures, a methodology for water removal, a
detoxification technology, and long-term controls for the PCB landfill.
In July 1994, a sampling event was conducted at the landfill by Ms. Ewald's
company and the state. No PCBs were found outside of the landfill. However, the
laboratory that analyzed the state's samples detected some dioxin at the ppq (parts per
quadrillion) level in three of the monitoring wells around the landfill. Opinions varied
as to where the dioxin originated. Despite the fact that Ms. Ewald tried to discredit the
state's findings, she used those findings to conclude in her report that "In the absence
of other likely sources of chlorinated contamination, it is likely that the PCB landfill is
the source for the dioxin and furan contamination noted at the site." The report
prepared by Ms. Ewald was not acceptable to the state. It was peer-reviewed by several
outside sources who were also critical of her report.
The state recommended that the landfill be resampled. The working group
opposed both resampling and removal of the water from the landfill. Ms. Ewald's
report convinced several members of the working group that the landfill was leaking.
Even though several members of the working group acknowledged that the presence of
water in the landfill presented a potential risk, they did not want the water removed.
They have repeatedly expressed concern that if the landfill were made safe by removing
the threat of the water that the state would not proceed with any detoxification effort.
Ms. Ewald recommended that a technology known as base catalyzed
dechlorination (BCD) be used to detoxify the landfill. The state advised the working
group that at least three methods should be considered and that the General Assembly
would want information about various technologies available for detoxification, why
1
✓
certain technologies were approved/rejected, and costs. The working group felt that
the BCD process was a suitable technology and would be acceptable to the community
because it could be done on site. The state and the working group went through the
process of selecting vendors to conduct pilot projects at the landfill using BCD
methods. Two vendors even went through the EPA process for approval. Both
eventually received approval by EPA. Pilot-scale proposals by the vendors included a
cost ranging from approximately $700,000 to $800,000 for on-site testing of
technologies.
Ms. Ewald's contract expired in May 1995.
CURRENT STATUS (July 1, 1995-present)
Membership
The original working group was composed of 16 members. At the working
group's request, the membership was raised to 24 in September 1994. Presently,
there are 21 people on the working group, with Senator Frank Balance serving as an
ex-officio member and Mr. Bill Meyer, director of the Division of Waste Management,
serving as staff. Three positions are vacant (one public safety and two youth).
Approximately 10-12 members show up for meetings on a regular basis, and they are
the decision-makers. The others attend meetings sporadically or never attend. There
are only two elected officials on the working group. County Commissioner Lucius
Hawkins' attendance is sporadic. He was defeated in the spring primary. Ms. Dollie
Burwell, the Register of Deeds for Warren County, is one of the co-chairs and a regular
attendee. She also was defeated in the spring primary.
The credentials of the working groups members, other than the three state
representatives, are basically unknown. The working group very heavily relies on the
state for staff, technical expertise, and support. Yet members have repeatedly said
they do not trust the state.
Expenditures
In March 1994, Warren County was awarded $100,000 from the Solid Waste
Grants Program to be used for capital improvements on the PCB Landfill.
During the 1995 session of the General Assembly, the legislature appropriated
$1 million from the Highway Fund for pilot projects to determine the most appropriate
technology for cleanup of the landfill.
The working group members decided they needed the services of another science
advisor as well as support staff. On March 7, 1996, Mr. Joel Hirschhorn (Maryland)
and Mr. Patrick Barnes (Florida) were hired as science advisors for the working group.
On March 18, 1996, Ms. Doris Fleetwood was hired as a part-time secretary for the
working group. A joint agreement was made between the DEHNR and the Warren
County Board of Commissioners to provide office space, furniture, equipment,
supplies, conference room, kitchen, restroom facilities and parking for the secretary
2
and the two science advisors. The working group's office opened on March 25, 1996, in
the CP&L Building in Warrenton, NC. The $1 million appropriated by the General
Assembly is being used to pay the science advisors, the secretary, and office rent. The
science advisors are each paid at the rate of $100 per hour of work. The cost for the
half-time secretary and office space is $25,000 for one year. As of September 1996,
$60,252 has been expended from that fund, of which $31,809 has gone to the science
advisors.
In the fall of 1995, the Division of Waste Management began working with CP&L
to provide electrical service to the landfill for pilot projects or any full-scale
detoxification effort. CP&L was paid $64,384 for this service from the capital
improvements account. Poles and lines for electrical service are in place, and
transformers will be added when the specific electrical demands are known. This
provides a permanent source of power for detoxification efforts or dewatering the
landfill, as well as other activities that may require electricity.
Master Plan
After talking with the worlpng group and reviewing files and documents related
to working group activities and the PCB Landfill, the science advisors developed a
master plan. This master plan stated why the working group should change its
current strategy and offered an alternative strategy. The working group approved the
master plan at their April 25, 1996 meeting.
The science advisors offered several reasons for changing the current strategy of
the working group. Briefly, the science advisors stated that it would be just as
effective, and less expensive, to invite a few companies to conduct off-site, bench-scale
tests on the landfill's contents rather than pilot-scale projects. This would also mean
that less material would have to be removed from the landfill for the studies. The
science advisors stated that other detoxification technologies must be thoroughly
examined. They also said that a much stronger case for funding from the General
Assembly could be made by spending money on a more thorough site investigation and
remedy design.
The science advisors recommended several key steps in the alternative strategy.
They felt that a more detailed evaluation of detoxification technologies and vendors
should be conducted by the science advisors. They also suggested that a site
investigation be conducted to determine the current status of the PCB Landfill and the
surrounding area. This investigation, if approved, will include the placement of
additional monitoring wells and a resampling of the landfill and surrounding area. The
site investigation will cost roughly $50,000 (excluding state staff costs), and it will be
funded from the $1 million approved by the General Assembly.
The alternative strategy also calls for several other items:
Designing a soil and waste removal plan and selecting a vendor to do
this;
Issuing a feasibility study report;
3
Inviting vendors to conduct bench-scale treatability tests;
Evaluating test results and selecting/ ranking vendors (to be done by
science advisors);
Finalizing the site investigation report;
Meeting with working group/highest ranked vendors;
Selecting best technology vendor (pre-qualified for actual cleanup);
Hiring best technology vendor as design contractor (under current
funding);
Selecting a remedy and issuing a remedial design report.
The remedial design report would be used as the basis for the working group and
DEHNR to formally propose the landfill detoxification project to the General Assembly
to obtain funding.
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
September and four responses were received in October. These responses were
reviewed by the science advisors. Pending some additional clarification, the science
advisors recommended CDM (Camp Dresser & McKee).
The working group, including the two science advisors, held a meeting on
October 23, 1996. At that meeting, Mr. Hirschhorn presented the members with a
draft letter to EPA Region 4 Administrator John H. Hankinson, Jr., accusing the state
of a "serious and prolonged lack of compliance." The letter stated that the state: "(1)
did not carry out all required groundwater monitoring; (2) failed to analyze early data
that we believe show that the landfill has had water entering and escaping it; (3) failed
to act or plan to remove large amounts of water inside the landfill; and (4) failed to
repair a dysfunctional leachate collection system." The letter also stated that "the
serious and prolonged lack of compliance by the state, as owner and operator of the
landfill, also reveals a lack of oversight and enforcement by EPA Region 4 that
demands attention, explanation, and correction." With a few corrections, the working
group agreed that the co-chairs were to sign the letter, and it would then be sent to Mr.
Hankinson.
Mr. Hirschhorn presented the working group with another draft letter to Mr.
Elliott P. Laws, EPA assistant administrator for Solid Waste and Emergency Response.
The working group requested a clear, definitive policy position concerning the extent to
which CERCLA and National Contingency Plan requirements apply to the PCB landfill.
This letter was approved as written.
Mr. Hirschhorn presented the group with a signed declaration stating that in his
professional opinion, detoxification technology appropriate for use at the PCB landfill is
now commercially available. The two technologies he named are gas phase chemical
reduction and base catalyzed decomposition. In addition, Mr. Hirschhorn presented a
written statement that accused the state of "delaying the efforts by the Working Group
4
to complete the current project to assess, test, and select detoxification technology."
He also stated that the issue is not whether detoxification can be done, but whether
the state will honor the commitment made by Governor Hunt in an October 20, 1982
letter.
After considerable discussion about whether to release the letters and the
statements to the news media before or after the November 5 election, the working
group decided to issue a media advisory on November 11 informing the news media
that there would be a press conference on November 12 at 11 am. It was later
announced that the press conference would be held at the Capitol Building.
At the October 23 meeting of the working group, Mr. Barnes noted that he had
met with Senator Frank Balance and US Representative Eva Clayton, at the request of
working group co-chair Dollie Burwell. Mr. Hirschhorn was not invited to this meeting,
and he subsequently wrote a letter to the working group seeking clarification as to who
had the authority to initiate such an action (i.e., could a co-chair or working group
member authorize such an action without the consent of the others).
Mr. Hirschhorn wrote another letter complaining that co-chair Henry Lancaster
had never explained to him that he had the option of being the sole science advisor or
working with Mr. Barnes. Mr. Hirschhorn said that he was given only the option of
working with Mr. Barnes. In his letter, Mr. Hirschhorn stated that he would have
chosen to be the sole science advisor had that option been given to him.
In response to the accusations made against the state in the letter to John
Hankinson and the two statements drafted by Mr. Hirschhorn, the Division of Waste
Management had a temporary engineering consultant review inspection/monitoring
files to determine if the state was in compliance with permit conditions. The following
are the findings:
• Monthly inspection and landfill leachate monitoring reports are complete for
1984-1986 and from 1990 to the present. Reporting was spotty for 1987-
1989. The PCB landfill was closed in 1983, and 1984 was the first full year
of required reporting;
• From 1983-1993, an estimated (based on pumping rates and pumping time)
12,400 gallons of leachate was removed from the landfill. No documentation
was found for 1987-1989. Amounts ranged from a low of 100 gallons in
1986 to a high of 5,297 gallons in 1983. Pumping was not conducted in
some winter months when the temperature was below freezing and the
leachate in the pipe was frozen. In 1994, an estimated 100 gallons was
pumped each month (pumping time available, but calculations incomplete at
this time). In August 1995, pumping of leachate at the landfill was ceased at
the request of the working group. As of November 1996, pumping has not
been resumed;
• Semi-annual sampling has been conducted each year (beginning in
November 1982) except for 1987 when there was only one sampling done. At
5
the request of the working group, semi-annual sampling ceased after May
1995. Semi-annual sampling resumed in early October 1996;
• The Final Technical Report for the PCB landfill project was sent to EPA
Region IV Environmental Scientist Al Hanke in September 1983;
• Background sampling of groundwater, surface water, and surface water
sediments was conducted July-September 1982 (documented in June 30,
1983 letter from Tom Karnoski to O.W. Strickland and is part of the Final
Technical Report to Al Hanke;.
• In the spring of 1990, the Division of Waste Management notified officials in
the Secretary's Office that there was water in the landfill that needed to be
removed, but that funds were not available. A request for funds to dewater
the landfill was not a high priority in the department's legislative budget
package in 1991, and did not make it to the General Assembly. As
mentioned earlier in this report, state officials met with Warren County
officials in a public meeting in May 1993 to determine what to do about the
water. One of the goals of the working group, established as a result of this
meeting, was to assess the need to remove rainwater from the landfill and
recommend to DEHNR the basis and technology for removal or allowing
rainwater to remain in the landfill. The working group did not address this
issue (until the October 23, 1996 meeting) other than to say that it did not
want to dewater the landfill unless done in conjunction with detoxification;
• The RFP (February to October 1996) for the excavation of soils from the
landfill requires the construction of two to four extraction wells into the
landfill. These extraction wells can also be used to dewater the landfill. This
activity will also provide data on the status of the top liner with respect to
liner integrity or leakage.
On October 2 , 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. To the division's knowledge, the sampling plan is the
only document that has been significantly delayed. We had envisioned that the
sampling plan would be ready for the working group's approval in the summer. The
initial draft plan supplied by Mr. Barnes was inadequate and lacking in detail. Division
staff worked with Mr. Barnes to draft a plan that could be implemented. The sampling
plan cannot be implemented, however, until the monitoring wells have been
constructed.
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
6
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2, 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background wells will be
included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
11/7 /96
7
RFP for Excavation, Handlin&, and Stora&e of PCB Soils from Landfill
In February 1996, an RFP was sent to vendors for excavation, handling, and
storage of PCB contaminated soils from the landfill. The original intent of this RFP was
to remove soils for the pilot scale studies. The working group wanted the input of the
new science advisors, so the effort was put on hold. The new science advisors modified
the plans for detoxification studies. The RFP was modified and reactivated in
September and four responses were received in October. However, the RFP did not
clearly indicate that the respondents were to consider the presence of landfill gases,
particularly methane, in design and operation of tasks in the proposal. We have asked
the respondents to indicate their consideration or lack of consideration of methane in
their proposals to the Division of Waste Management. We have also requested all of
the respondents to include an itemized list and cost of all separate elements in their
proposal response to the RFP. The responses are due at noon, Friday, November 15.
The RFP for the excavation of soils from the landfill requires the construction of
two to four extraction wells into the landfill. These extraction wells can also be used to
dewater the landfill. In addition, this activity will provide data on the status of the top
liner with respect to liner integrity or leakage.
PCB Landfill Samplin& Plan
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the
two science advisors for their review and comment. At the October 23, 1996 meeting of
the working group, Patrick Barnes presented some amendments to the draft sampling
plan. The division agreed to those amendments. To date, the division has not received
any written comments from Joel Hirschhorn, and the draft sampling plan has not been
approved by the working group. We had envisioned that the sampling plan would be
ready for the working group's approval in the summer. However, the sampling plan
cannot be implemented until the monitoring wells have been constructed, and the
state has focused its attention in this direction.
RFP to Conduct Dioxin/Furan Testin& on Water, Soil and Sediment Samples
An RFP to conduct dioxin/furan testing on water, soil and sediment samples
from and around the PCB Landfill was sent to potential respondents on November 5,
1996. All proposals are due to the Division of Waste Management by noon, November
22, 1996.
RFP to Construct Monitorin& Wells
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill
was sent to potential vendors on November 6, 1996. An ad was also placed in The
News and Observer to run November 10. There will be a pre-bid meeting on November
18, 1996 for vendors who wish to submit quotes. The meeting will be followed by a trip
to the PCB landfill. Final proposals are due December 2, 1996. This activity will
provide more definitive data on the status of landfill safety and potential leakage. It is
anticipated that an amendment to construct three "off-site" background wells will be
8
included in this RFP. This amendment will be distributed to the members of the
working group at the November 18 meeting.
9
Overview of Current Environmental
Status and History
of the Warren County PCB Landfill
SITE DESCRIPTION
The State of North Carolina owns and maintains a closed landfill
containing PCB-contaminated soils. This landfill is permitted under the
Toxics Substances Control Act (TSCA). This landfill is vinyl and clay lined
and contains approximately 40,000 cubic yards of soils (24 feet thick)
contaminated with polychlorinated biphenyls (PCBs). The average PCB
concentration of these landfilled soils is 300 to 350 ppm, primarily a mixture
similar to Arochlor 1260. Free water is present in the landfill to a height of
approximately 1 3 feet. There is evidence that some anaerobic biological
dechlorination has occurred during the period since the landfill was capped
and became anaerobic in 1983.
The landfill is located on a 142-acre tract of land located just off State
Road 1 604 in Warren County. The containment area or landfill cell is
enclosed by a fence occupying approximately 3.8 acres. Figure 1 is an aerial
photograph of the landfill. The four groundwater monitoring wells are
marked on this figure. The actual landfill cell is somewhat smaller than the
fence shown, but in the same configuration.
Figure 2 shows a cross-section of the landfill structure.
Figure 3 provides a sketch of details of the bottom liner and dual
leachate collection systems installed at the site.
Figure 4 details the single gas vent structure present at the center of
the landfill cell.
Figure 5 details the sand and charcoal filters installed on top of the
north end of the landfill cell to treat any leachate removed from the cell.
A spray irrigation (non-discharge) permit is maintained for the facility,
so that any treated leachate can be routed to an irrigation system installed
along the crest of the landfill. No NPD ES permit is available for the facility,
and no adequate receiving stream is available. The leachate collection pond
structure, seen to the north of the landfill cell in Figure 1 , is dry and has not
been used during the life of the facility. The unpaved entrance road is
maintained by the NC Department of Transportation and was designed to
handle large soil-laden dump trucks.
CHEMICAL PROFILE OF LANDFILL CONTENTS
In July, 1 994, the State executed a sampling plan developed in
conjunction with the Working Group and their Science Advisor. Selected
results from this effort are attached. Table 1 contains all the positive results
from a composite of EPA Methods 8240, 8141, 8270, 8081 for organics
and various methods for inorganics.
Table 2 displays the positive results from EPA Method 8280 and 8290
for dioxins and furans. Note particularly the results for the Wet Landfill
Contents, which represents the bulk of ·the contents of the landfill. Also
note that these results display all positives for these analyses, and thereby,
confirm that the landfill contents do not contain other complicating organic or
inorganic compounds in any significant quantities.
Table 3. Chemicals of interest in contents Warren County PCB Landfill
PCB (all congeners)
Chlorobenzene
1,3 Di-chlorobenzene
1,4 Di-chlorobenzene
Arsenic
Barium
Chromium
Lead
Average 350 ppm
(Range 1 51 to 880)
60 ppb
23.9 ppb
48 ppb
2 ppm◊
23 ppm◊
12 ppm◊
35 ppm◊
◊ TCLP results did not exceed standards.
Tables 4 and 5 present results of physical soils testing performed on a
grab sample of landfill contents. These results are representative of the
landfill contents, but other isolated conditions may occur due to the origin of
the landfill' s contents from 1 4 North Carolina counties
•
,'
FINAL REPORT AND RECOMMENDATIONS
of the
INTERGOVERNMENTAL WORKING GROUP ON PCB DETOXIFICATION
Raleigh
December 12, 1984
to
THE HONORABLE JAMES B. HUNT, JR.
Governor of North Carolina
DANIEL A. OKUN
Chairman
. ,.
EXECUTIVE SUMMARY
Public concern with the establishment of a landfill in
Warren County for the storage of polychlorinated biphenyl (PCB)
contaminated soil removed from North Carolina roadways led
Governor James B. Hunt, Jr. to commit the state to pursue a
program of detoxification of the facility. To this end, he
established an Intergovernmental Working Group on PCB Detoxifi-
cation. This report constitutes the findings of the Group.
Technologies developed up to now for detoxifying PCBs are
directed towards the treatment of material in a relatively "pure"
state. The only EPA-approved method today is incineration, but
this is not feasible for the massive volume of essentially non-
combustible material in the landfill. The biological and chemical
methods under study today are not yet proven. ·The most promising
method for the landfill involves treatment of the PCB-laden
material with a proprietary solvent and reagent in large reactors
with ultimate decontamination by biological treatment or distilla-
tion. The effectiveness of this approach is not yet demonstrated,
the costs are uncertain but certa~nly considerable, and the health
hazards associated with toxicity of the by-products of the process
raise further serious questions as to its feasibility.
Current methods of detoxification, even at the experimental
pilot-plant stage, require destroying the integrity and security
of the landfill. Given that the existing landfill is protective
of the environment, as revealed by monitoring, the exposure and
risks involved in detoxification are not now warranted.
The Group recommends that the landfill should not now be
disturbed. The Group believes strongly.that a thorough and con-
tinuous program of monitoring of the environment in the vicinity
of the landfill and proper maintenance of the landfill should be
given adequate funding and strong institutional support by the
state. In addition, a contingency plan should be available in
the event of any threatening occurrence. Lastly, the state should
maintain surveillance of technology in PCB detoxification so as to
be alert to new developments that might be appropriate to the
Warren County landfill in the future.
'
,t'
MEMBERS
Dr. Daniel A. Okun
Dr. Robert A. Neal
Dr. Robert G. Lewis
Dr. Linda Little
Mr. William W. Phillips, Jr.
Mr •. o. w. Strickland
Mr. Robert Jansen
Mr. George E. Shearin
Mrs. Joyce Lubbers
Rev. Luther G. Brown
Rev. J. Clinton McCann, Jr.
•
REPORT OF THE INTERGOVERNMENTAL WORKING
GROUP ON PCB DETOXIFICATION
In the summer of 1978, the first reports of polychlorinated
biphenyl (PCB) spills along North Carolina highways were received
by the State. Discovery was initially made along N.C. Highway 58
in Warren County •. Subsequently, evidence of such spills was
found on roadway 'shoulders of fourteen counties in North Carolina
and the military reservation at Fort Bragg involving more than
240 miles of secondary roads.
Almost immediately the N.C. Department of Transportation
(DOT) applied a mixture of activated carbon and liquid asphalt
to contaminated areas as a temporary measure to prevent migration
of the PCB and to reduce hazards to the public. Following exami-
nation of the contaminated samples, state officials and the U.S.
Environmental Protection Agency (EPA) determined that the only
viable solution available at that time was the removal of the
material and its storage. _In June, 1979, EPA approved a tract
of land in Warren County as the disposal site for the PCB-
contaminated soil.
Several court actions were filed by local officials and
private citizens to review these decisions. The U.S. District
Court enjoined the state from further action pending a full
hearing. In the meanwhile, the State attempted to have federal
regulations amended to allow for treatment of the contaminated
material in place. These efforts were not successful and the
only disposal of the waste authorized by EPA was by incineration
or storage. In November, 1981, all legal cases were dismissed
by the Court and in January, 1982, the appeals were dismissed.
In May, 1982, state and federal officials signed a cooperative
agreement for the removal of the PCB contaminated soil and
- 2 -
storage landfill, which was largely paid for with funds provided
to the State under the Comprehensive Environmental Response,
Compensation, and Recovery Act of 1980 (CERCLA or "Superfund").
This removal was completed in October and the landfill was
closed in November, 1982. A chronology of the events associated
with the landfill is_ included as Appendix A.
In October, 1982, Governor James B. Hunt, Jr. met with
residents of Warren County who expressed concerns about the
project. In an Open Letter issued two weeks later, he made a
series of commitments, among which were: that no other wastes
would be stored at the site; that no other landfill would be
built in the county by the state; that certain monitoring would
be conducted and the results made public. One of the commitments
was:
"The State will push as hard as it can
for detoxification of the landfill when
and if the appropriate and feasible
technology is developed. We will seek
to establish a joint local-state-federal
working group to pursue this end."
In fulfillment of this commitment, the Intergovernmental
Working Group on PCB Detoxification was organized. Nominations
to the Working Group were made by local, state and federal
officials, and representation from among these constitute the
Group membership. The Group met nine times beginning in June,
1983, and adopted this report at the final meeting in December,
1984. Members of the Working Group and their affiliations are
listed in Appendix B.
Generally meetings were held in state offices in Raleigh;
although one meeting which included a visit to the site, was
held in Warrenton and another was held at EPA offices in Research
Triangle Park. A listing of dates and locations of meetings is
appended to the report (Appendix C). The meetings were open to
the public. The proceedings of the meetings were summarized and
are on file in the Governor's Office.
- 3 -
The Working Group Process
The first meeting was an orientation session. Dr. Linda
Little, executive director of the Governor's Waste Management
Board and a member of the Working Group, presented a report on
the nature of polychlorinated biphenyls (PCBs); what they are,
where they originate, and their properties, including particularly
the health and environmental significance of these contaminants.
Mr. William W~ Phillips, Jr., project director for the PCB
cleanup operation and a member of the group, described the Warren
County PCB landfill, the nature of its construction, and the
monitoring procedures.
A special presentation was made by Dr. Gary Sayler of the
University of Tennessee, a director of an EPA-sponsored study on
microbial detoxification of PCBs. He described research on
microbial decomposition of PCBs and provided a basis on which
the Group could evaluate subsequent presentations.
The Working Group agreed to invite all individuals and
organizations, both public and private, who indicated they had
information of significance to appear before the Group. In
particular, invitations were extended to organizations with
experience in developing and applying PCB detoxification
technology; to engineers employing such practices in real
situations; and, also, to others whom Group members identified
as having something to contribute. A list of all of those who
made formal presentations and their affiliations is appended to
this report (Appendix D). The Governor's Office met the expenses
of all individuals who expressed an interest in making a pre-
sentation, whether that interest was elicited by the Governor's
Office or the Group, or was initiated by the individual or his
organization. Repeatedly the Working Group was commended by
those who participated in later stages of the study for having
conducted possibly the most exhaustive review of the status of
PCB detoxification technology currently available.
•
. .-
- 4 -
Unfortunately, as is described later in the report, the
Working Group found that most of the technology has been devel-
oped for detoxification of PCBs in a relatively "pure" state.
The PCBs in the Warren County landfill are heterogeneously
mixed with soils of various types and fixed in varying degrees
to the activated carbon and asphalt applied to the road
shoulders before removal of the material. A second important
complicating factor in evaluating the technologies offered to
the Group was that .most of the investigations now under way are
directed to materials that are currently presenting a significant
environmental and health -hazard due to their being open to the
environment. In the case of the Warren County landfill, the
material is not exposed and most of the technologies offered
require exposing it for the purpose of detoxification.
The Warren County Landfill
The Warren County landfill, a cross-sectional diagram of
which is attached to this report (Appendix E), contains about
40,000 cubic yards of soil contaminated by PCBs associated with
activated carbon, asphalt, and other impurities inevitably found
on roadway shoulders. Analyses made by the State of six core
samples taken prior to covering the landfill showed the concen-
tration of PCBs to range from 46 to 200 ppm, averaging about
135 ppm. The PCBs in the landfill consist of about 80% Aro-
clor 1260 and 20% Aroclor 1242. The average chlorine contents
of these PCBs are 6.3 and 3.1 chlorine atoms per molecule,
respectively. (The difficulty in degrading Aroclor is a function
of the chlorine content: those with higher chlorine content are
more difficult to decompose.) ThePCBs in the landfill are in
an anaerobic (airless) state becaus~ the landfill seal prevents
replenishment of the oxygen used by microorganisms in the
landfill. Determination of the precise condition of the PCBs
and associated soil materials is impossible without violating
the integrity of the landfill. However, it can be assumed that,
- 5 -
although all drainable water has been removed from the landfill,
the content of "held" water is relatively high because evaporation
cannot take place.
Detoxification Technologies
Currently incineration is the only method generally approved
by EPA for treatment of materials containing more than 50 ppm of
PCBs. Incineration of the 40,000 cubic yards of contaminated
soil in the landfill, given that most of the material in the fill
is not combustible, would involve a mammoth earth moving project
that would be highly impractical in this particular application.
Microbial degradation methods have drawn considerable
attention but the methods studied have been exclusively aerobic.
Far less is known concerning PCB degradation by anaerobic bacteria.
Several chemical methods have been approved by one or more of
the regional offices of EPA for PCBs in oil and other non-aqueous
liquids. These generally involve dechlorination which requires
that the moisture content be low. Incidentally, all EPA approved
processes are for closed systems where batches of the contaminated
material are treated. No definitive laboratory or field work
studies supporting any treatment in the open have been presented
to EPA.
Also, PCBs may be destroyed by ultraviolet radiation, but
this requires that the PCBs be dissolved in liquids that permit
penetration of the ultraviolet light. Therefore, this process
would .not be feasible for contaminated soils.
As listed in the annex to this report (Appendix D), the
following organizations made presentations regarding their pro-
posed technology for destroying PCBs: PPM, Inc.; Bioteknika
International, Inc.; Genex Corporation; Atlantic Research
Corporation; Sybron; and Galson Research Corporation and Polybac
Corporation, jointly. Of these, only the Galson/Polybac proposal
was supported by actual field data on treatment of PCB contaminated
'
- 6 -
soil. Their approach involves an initial chemical dechlorination
procedure using a proprietary sodium based reagent system,
followed by aerobic microbial treatment for final cleanup.
Currently EPA is evaluating the Galson/Polybac process.
Inasmuch as the Galson/Polybac approach is, if it should prove
successful, one of the most likely to be appropriate, some
description of the process is warranted here. For the Warren
County storage facility, the entire landfill would need to be
excavated at a rate so as to be treated in three reactors of
18 cubic yard capacity, each operating on a 24-hour basis for
about 14 months. The reactors, built on the order of cement
mixers, would bring the solvent in contact with the contaminated
soil and the reagent. The composition of the solvent and reagent
is known only to two members of the group, Drs. Lewis and Neal,
under a confidentiality agreement with the proprietary owners of
the solvent. The solvent itself, after agitation with the soil,
would be reclaimed by distillation, and the wastewater would be
decontaminated by centrifugation followed by biological treatment
or distillation. The chemically treated soil would be returned
to the landfill after further biological treatment. Many
questions remain unanswered regarding the exact procedures so
that even an approximate estimate of the cost cannot be made.
The Galson/Polybac representative suggested a range from as little
as $2 million up to as much as $12 m,illion. In any event, before
such a commitment could be made, laboratory and pilot scale tests
would be required. In order for such tests to be undertaken at
the Warren County facility, the landfill would need to be opened
to extract a reasonably representative and adequate sample of
the soil contained therein for study.
The promise of this process is further placed into question
by the field trials conducted for EPA by Galson on PCB contaminated
soils. The results were inconclusive, with soil moisture content
apparently a complicating factor. The process would appear to
work on soil with up to 15% moisture content; however, the soil
- 7 -
in the Warren County landfill is estimated to contain about
30% moisture.
Another complicating factor in all the evaluations is the
uncertain toxicity of the chemicals used for treatment and
more especially the chemical by-products of the decomposition
of the PCBs. Based upon experience with other synthetic
chlorinated hydrocarbons, it is not unreasonable to expect
that some of the degradation products may be as toxic or even
more toxic that ~he original contaminants.
Another process with possible promise, not reviewed by
the Working Group, is a reductive thermolysis method developed
by Huber Corporation, in which the contaminated soil is fed
through a reaction chamber at 4000° to 5000° Funder a nitrogen
blanket. The PCBs are vaporized from the soil and immediately
reduced to carbon, hydrogen, and chlorine or hydrogen chloride.
The soil, which is converted to spherical glass beads in the
reactor, is collected in a hopper. The gases are passed through
an elaborate system of cyclones, activated charcoal filters, and
liquid scrubbers. In EPA authorized tests, sand dosed with
3000 ppm of Aroclor 1260 was fed at 60 lbs/minute through the
reactor with almost total destruction efficiency. While this
process looks promising, the existing unit would require three
years or more to process the soil in the landfill and the cost,
not including the construction of the unit, would probably be
over $8 million.
In summary then, several proc_esses are emerging, some of
which may eventually be applicable to the contaminated soil in
the Warren County landfill. However, all of these processes
presently suffer from one or more of the following difficulties:
1) They require violation of the landfill, generally over
long periods of time, so that exposure of the population to the
PCBs in the landfill may be greater over the period of detoxifi-
cation than over the lifetime of the PCBs in the undisturbed
landfill.
- 8 -
2) Some of the methods require the use of chemicals, the
toxicity of which is currently unknown in the amounts required.
3) In the event that degradation is not complete, a very
likely situation in most such treatment processes, uncertainties
regarding the toxicity of the degradation products would require
extensive studies on a laboratory, pilot, or field basis to
examine these by-products for their toxicity before a large
project is initiated.
4) The disruption in the cotmnunity from these detoxifica-
tion methods would be great. Gaseous emissions, noise, heavy
traffic, and possible contamination of nearby waters from
operations around the landfill are likely.
5) All of the methods would be very costly, probably far
more costly than presently anticipated.
The situation was best SUIIDiled up by Dr. Paul Busch of
Malcolm Pirnie, Inc. a consulting engineer with extensive experi-
ence in disposal of PCB-laden soils. Consulting engineers could
see the potential for profitable work for themselves in such
detoxification projects. Nevertheless, Dr. Busch and his
associate recotmnended against any detoxification of the Warren
County landfill at this time, based upon his firm's estimates
of the costs and the local situation. The firm estimated that
chemical treatment would cost $8-14 million and take one to two
years. Excavationt transportationt and incineration at a
cetmnercial site would require $85 million and four to five years;
on-site incinerationt $6.4 million and three years; and excava-
tion, transportation to and landfilling at the Chemical Waste
Management Alabama facility, even if feasible, would cost $8-
10 million. Malcolm Pirniet Inc. does not believe technology
for in situ decontamination of the landfill currently is
available.
Dr. Busch concluded that the Warren County landfill is
a well-designed, secure landfill and recommended thatt based
upon our present knowledge, a cotmnitment be made to maintenance
- 9 -
and monitoring and the preparation of a contingency plan to deal
with any unexpected problems. Finally, he reconnnended that
periodic reviews of applicable detoxification technologies be
conducted.
From a broad, long range perspective, there are many PCB
problems in the United States far more hazardous than that posed
by the Warren County landfill. These require urgent attack
because exposure is a current problem. Experience in dealing
with these may y~eld solutions or improvements on existing methods
that might, in time, be valuable for application in Warren County.
Moreover, it is not inappropriate that the burden of such inves-
tigations be undertaken by EPA and by those who are required to
-deal with these hazardous situations.
From a specific and immediate perspective, it is incumbent
upon the State to continue reviewing technology as it develops.
Of equal importance, it must be aware of emerging engineering
applications, because it is at that stage that the data obtained
can be translated for possible application in Warren County.
Conducting pilot studies at the Warren County landfill would
be more attractive if it r.rere unlikely that similar studies would
· be conducted elsewhere. The major concern with such a study at
the facility is that the landfill would need to be opened in
order to obtain meaningful results. Furthermore, to get repre-
sentative material from the fill, samples would need to be taken
from several different points in the landfill. The appropriate
time to undertake such pilot studies would occur after others
facing far more serious problems have conducted pilot studies
leading to full scale engineering appliations of detoxification
on a scale similar to that needed for the Warren County landfill.
When such technology is at hand, it would be appropriate to
initiate pilot studies with specific application to the Warren
County landfill detoxification.
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Maintenance of the Warren County Landfill
Although landfill maintenance was not a charge of the Working
Group, the integrity of the landfill is a baseline against which
detoxification technologies must be measured. For example, if
the landfill were found to be leaking PCBs into the local aquifer,
thereby threatening local water supplies, a technology not yet
fully proven would be far more attractive in dealing with the
emergency than where the landfill is known to be secure. Accord-
ingly, our conclusions that technologies are not yet available to
be applied to det'oxifying this facility are based upon the
landfill being of sound construction, adequately containing the
PCBs, and promising to do so for a long period in the future,
hopefully at least until such time as a technology suitable for
detoxification does become available to those who currently have
a far more urgent need for that technology. The Group is
interested in the maintenance program for the landfill. A
presentation was made to the Group by representatives of the
N.C. Department of Transportation, which is responsible for its
maintenance. The following measures are currently being taken:
* The District Engineer and the Warren County Maintenance
Supervisor are authorized to perform routine maintenance work on
the landfill.
* The District Engineer or Maintenance Supervisor makes
monthly inspections of erosion protection, burrowing animals,
surface subsidence, and other observable conditions.
* Seeding and fertilization are done semi-annually for two
years.
* After the initial two years, applications of fertilizer,
top dressing, and seeding for cover maintenance will be made
annually.
* Mowing is done twice a year to a six-inch height to
preclude woody growth.
* The fence perimeter will be treated for vegetation
control.
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* The access road will be maintained annually, ensuring a
ten-inch stone surface with proper drainage and proper vegetation
control.
All of these procedures are to be implemented along with
routine maintenance.
Monitoring of the Warten County Landfill
The design and maintenance of the PCB landfill required the
installation of four groundwater monitoring wells, one on each
side of the landfill, and four stream monitoring stations, two
upstream and two downstream from the site. In addition to
systems for monitoring the area immediately around the landfill,
there are two monitoring systems within the landfill. These
include a leachate collection system above the landfill liners
and a collection system below the liners. The purpose of the
monitoring system is to detect, at the earliest possible moment,
any potential impact on public health by migration of PCBs within
the landfill or through environmental pathways external to the
landfill. The Department of Human Resources, Division of Health
Services, has been charged with the responsibility of monitoring
the PCB landfill.
The Division of Health Services sampled the groundwater
monitoring wells and surface waste monitoring points prior to
any PCBs being delivered to the landfill. Thirty-six private
water supply wells within a one and one-half mile radius of the
landfill were sampled at the request of the Warren County Health
Department. None of the samples indicated the presence of PCB at
a 0.1 part per billion detection level. These data, along with
approximately 100 blood samples obtained for PCB analysis from
Warren County citizens, form an accurate basis for comparison of
future samples and for the determination of potential public
health or environmental impacts from the PCB landfill.
-12 -
After background data were obtained, the Division of Health
Services has continued to sample the groundwater monitoring wells
and stream monitoring points two times per year and the leachate
collection systems within the landfill on a monthly basis. The
groundwater and stream samples have indicated no PCB contamination.
Some rainwater that infiltrated the PCB contaminated soil prior to
placement of the final cap on the landfill had been collected in
the leachate collection system. This water was removed on 37
occasions since th~ closure of the landfill, treated by the
on-site filtration and carbon adsorption wastewater treatment
system and used for irrigation on the landfill surface. Since
March of 1983, no PCBs (at the 0.1 ppb detection level) have been
detected in the treated wastewater. No water has ever been de-
tected in the lower leachate system. This demonstrates that the
liner systems are intact and not leaking. All of these data
indicate that there is no public health or environmental impact
from the PCB landfill.
Sampling locations and analytical data are attached as
Appendix F.
Role of U.S. Environmental Protection Agency
The EPA expects the State to maintain the facility, conduct
the routine monitoring of water, and maintain security. It can
be assumed that if PCBs are detected in any of the monitoring
wells, or if anything else portends difficulty, EPA will parti-
cipate in correction. It was reported to the Group that EPA is
developing a plan for "second phase" management of cleanup
facilities but this program is at least several years away. Under
present policies, EPA will not permit funds for secondary treat-
ment of wastes; (i.e. retreatment of waste which had been
satisfactorily handled under the "Superfund" program) provided
the best proven disposal technology was used and there is no
problem with it.
-13 -
·Conclusions
1) The Warren County PCB landfill is a state-of-the-art,
high-security landfill which exceeds the design requirements
under the Toxic Substances Control Act.
2) Monitoring reveals that PCBs are being contained within
the landfill, and there is no known discernible threat to the
health or environment in the conmrunity.
3) Microbial or chemical processes appropriate for detoxi-
fying the contaminated soil in the Warren County landfill have
yet to be demonstrated. Even if such methods were feasible, not
enough is known to assess potential health hazards associated
with the agents, reagents and/or solvents used in the processes
or with the degradation products evolving from treatment of the
PCBs.
4) Thermal destruction may be possible, but given the
nature of the contaminated soil, the massive earth movement
required, as well as the risk involved in keeping the landfill
open for an extended period, it would entail greater risks than
maintaining the landfill in its present state. In addition, the
cost of thermal destruction would be exceedingly high.
5) While the landfill was very well designed and constructed,
proper maintenance is exceedingly important. The hallmark of a
successful landfill is a sound monitoring and maintenance program.
6) While monitoring results are made public, there is
inadequate perception among the people in Warren County about
the nature of the landfill and the measures that are being taken
to insure its integrity.
Recommendations
In light of the findings, the following recommendations are
made:
1. The Warren County PCB landfill should not be disturbed
at this time.
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2. The program for the routine maintenance of the landfill
should continue with the responsibility being clearly set forth
both in the record and in public.
3. Regular monitoring of the site should continue.
Monitoring of private wells in the area should be initiated. No
fewer than 25% of the private operating wells within a l½-mile
radius of the landfill should be monitored at least once every
four years. The monitoring of the landfill should include
structural monitor~ng to detect subsidence.
4. A contingency plan should be prepared in the event of
damage to the landfill or evidence of PCB leakage. This con-
tingency plan should establish responsibility for corrective
action, sources of funding for such corrective action, and who
would be responsible for compensation to injured parties in the
vicinity. This contingency plan should be updated periodically.
5. The necessary funding and supporting statutory authority
should be provided, if not already in place, to implement
Recommendations 2, 3 and 4.
6. This ad hoc Working Group should be dissolved, but a
mechanism should be established within state government to continue
surveillance of developments in PCB detoxification, with repre-
sentation from the appropriate state agencies as well as liaison
with EPA, Warren County and the research community.
Finally the Working Group appreciates the level of concern
extended to this problem by the Governor and State agencies and
of the support given to the Group in exercising its responsi-
bilities. Particular thanks go to Robert Jansen, Senior Policy
Advisor to the Governor, for his concern and assistance. Also,
William L. Meyer is recognized for his service as rapporteur.
ANNEX TO THE REPORT
Appendix A Chronology
Appendix B Membership
Appendix C Schedule of Meetings
Appendix D Presenters
Appendix E Cross Sectional Diagram of Landfill
Appendix F Analytical Data and Sampling Locations
July .1978
July 30
August ·1918
August 2-5
August 10
August 15
August 18
September ·t978
September 6-19
October ·1978
October 5
November ·197s
November 6
APPENDIX A
CHRONOLOGY
First report of a chemical spill which was
later identified as PCB on N.C. 58 in Warren
County.
PCB located along roadsides in several other
North Carolina counties including Johnston,
Alamance, and Chatham.
Conference held with representatives of the
Department of Human Resources, Department of
Agriculture. Attorney General's Office.
Department of Transportation, Environmental
Protection Agency, and the news media to
discuss the PCB dumpings.
Activated charcoal solution and liquid asphalt
applied along 210 miles of North Carolina
highways where shoulders had been contaminated
by PCB. This action was taken at the recom-
mendation.of specialists at North Carolina
State University, who submitted a plan for
temporarily deactivating the PCB to prevent
migration and to reduce any hazard to the
public.
The N.C. Department of Transportation began
applying a solution of activated carbon and
liquid asphalt to the 210 miles of contaminated
roadside.
Tests conducted along uncontaminated road
shoulders to determine the safety and
effectiveness of equipment to be used in
picking up .the PCB.
Test conducted along a contaminated road
shoulder on Highway 58 in Warren County.
Test results of the pick-up of contaminated
soil along the roadside in Warren County
show that the contaminated soil can be picked
up and treated without harming the environ-
ment or personnel involved.
...
December 1978
December 1
December 12
January ·1979
January 4
January 17
February 1979
February 2
June ·1979
June 4
June 4
June 6
Au~st 1979
August 16
Sept -Dec 1979
July -Aug 1979
Se:etember 1980 .
September 12
- 2 -
The state obtained an option on 142 acres of
land in Warren County to be used to dispose
of the contaminated soil that would be picked
up along the roadsides in 14 North Carolina
counties.
Application filed with the EPA for approval
of the Warren County site as a disposal area
for the PCB contaminated soil.
Public hearing on the Warren County site
conducted in Warrenton National Guard Armory.
Robert Burns and sons pleaded guilty to a
violation of the federal Toxic Substances
Control Act. Burns received an active jail
sentence and his sons were placed on probation.
North Ca~olina petitions EPA to modify its
regulations to permit alternative methods of
disposal of ~CB contaminated soil and debris
(i.e. in-place treatment).
EPA denies North Carolina's petition.
EPA's Region IV administrator approved Warren
County site, and the state's application to
construct a PCB landfill there.
Robert Burns and sons plead guilty to state
charges surrounding the PCB dumping in
Halifax County Superior Court. Burns later
received an active jail sentence and his
sons were placed on probation. Buck Ward was
found not guilty on state charges.
Suit filed by Warren County.
Draft EIS prepared, filed on December 28, 1979.
Comments received on EIS.
Engineering consultant firms were interviewed
by the state and a recommendation was made to
the Capital Building Authority for selection
May 1981
May 22
·November ·l981
November 25
·May •1982
May 13
May 26
May 26
June 1982
June 21
July 1982
July 2
August 1982 .
August 4
August 10
- 3 -
of a firm to develop plans for a PCB landfill
in Warren County.
Buck Ward tried and found guilty of a viola-
tion of _the federal Toxic. Substance Control
Act. He received an active jail sentence
and a $200,000 fine.
Judge Earl W. Britt grants summary judgment
in favor of state and EPA in Warren County
and Twitty suits, resolving legal obstacles
delaying constructing of landfill. Appeals
taken in both cases.
Contract for construction of the PCB landfill
awarded by the Capital Building Authority
pending the approval of federal "Superfund"
money to fund the PCB cleanup project. The
contract was awarded to the low bidder, Jim
Lineberger Grading and Paving Company of
Gastonia.
North Carolina and EPA officials announced the
signing of a cooperative agreement which
provided $2.5 million in federal "Superfund"
money to construct a PCB landfill in Warren
County, and to clean up the PCB contaminated
soil along 210 miles of North Carolina
roadsides.
120 acres surrounding the landfill site deeded
by state to Warren County as buffer zone.
Voluntary dismissal taken by Warren County
in suit on appeal.
Construction began on the PCB landfill in
Warren County.
NAACP files discrimination suit in federal
court requesting preliminary injunction to
prohibit placement of soil in Warren County.
Hearing held before Judge Earl Britt.
Preliminary injunction denied.
September .1982
September 15
October 1982
October 6
October 12
October 27
November ·1982
November 1
December ·19s2
December
December 13
December 27
·January ·19s3
January
January 26
- 4 -
Removal of PCB from roadsides begins by DOT
crews. Protests begin in Warren County and
· a total of 423 adult arrests were made and
100 juveniles were taken into custody over
the following 4½ weeks.
Fort Bragg begins removal operation for PCB
on base.
State finishes roadside removal of PCB.
There were 2.41 shoulder miles picked up;
6,455 truckloads. taken to landfill.
Fort Bragg finishes removing PCB from base;
768 truckloads put in landfill. Total
state/Ft. Bragg truckloads 7,223.
Capping operation begins; plastic liner and
clay liner in place, soil layer added. Bad
weather prevents final soil layer and seeding
of cap to be accomplished.
Heavy rains cause soil erosion on cap and
exposes plastic liner. Bubbles develop in
exposed liner from gas in the landfill caused
by decomposition of vegetation mixed in with
soil. Bubbles vented, soil erosion temporarily
corrected and a temporary seed cover is
installed on the cap. Landfill will be
completed in Spring.
Buck Ward begins sentence at Danbury,
Connecticut, Federal Prison after being
denied petition for certiorari by U.S.
Supreme Court.
Federal Appeals Court affirms Judge Britt's
ruling in Twiddy case.
EPA monitors gas venting from landfill and
reports no significant emissions of PCBs.
U. S. Files civil suit in federal court
against Buck Ward and Ward Transformer, Inc.
·February 1983
February 17
March 1983
March 4
·May ·1983
May 11
May 24
July1983
July 14
July 15
July 23
August .1983
August 3
-5 -
State dismisses state law suits.against Buck
Ward and state allowed to intervene in federal
suit. All counterclaims dismissed by Ward
against state.
Voluntary dismissal taken by plaintiffs in
discrimination suit.
Contractor resumes work on completion of
landfill construction.
EPA grant period extended until July 23, 1983.
Construction completed.
Inspection held at the site and acceptance
made by state officials.
Grant period ended.
Inspection held at the site by EPA officials
and approval given.
Chairman:
Dr. Daniel A. Okun
Department of Environmental
MEMBERSHIP
Sciences and Engineering
School of Public Health
201-H UNC-Chapel Hill
Chapel Hill, N.C. 27514
· Representing ·Federal Interests:
Dr. Robert A. Neal, President
Chemical Industry Institute of
Toxicology
P.O. Box 12137
Research Triangle Park, N.C. 27709
Dr. Robert G. Lewis, Chief
Advanced Anaylsis Techniques Branch
Environmental Monitoring Systems
Laboratory
US EPA
Mail Drop 44
Research Triangle Park, N.C. 27709
Representing State Interests:
Dr. Linda Little, Executive Director
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, N.C. 27611
Mr. William W. Phillips, Jr.
Assistant to the Secretary
N.C. Department of Crime Control
and Public Safety
512 North Salisbury Street
Raleigh, N.C. 27611
. Mr. O. W. Strickland,· Head
Solid and Hazardous Waste Branch
N.C. Department of Human Resources
306 North Wilmington Street
Raleigh, N.C~ 27611
APPENDIX B
Mr. Robert Jansen
Senior Policy Advisor
Office of the Governor
State Capitol
Raleigh, N.C. 27611
Representing Local Interests:
Mr. George E. Shearin
Warren County Board of
Commissioners
Route 2, Box 108
Norlina, N.C. 27563
Mr. Thomas Henry Rooker
(Deceased)
Route 2, Box 12
Warrenton, N.C. 27589
Mrs. Joyce Lubbers
Route 2, Box 50 ·
Warrenton, N.C. 27589
Rev. Luther G. Brown
108 W. Geer Street
Durham, N.C. 27701
Rev •. J. Clinton McCann, Jr.
Warrenton Presbyterian Church
Warrenton, N.C. 27589
Rapporteur:
Mr. William L. Meyer
Solid and Hazardous Waste Branch
N.C. Department of Human Resources
· 306 North Wilmington Street
Raleigh, N.C. 27611
APPENDIX C
SCHEDULE OF MEETINGS
INTERGOVERNMENTAL WORKING GROUP ON PCB DETOXIFICATION
June 2~, 1983 Raleigh
July 21, 1983 Raleigh
September 29, 1983 Raleigh
December 12, 1983 Warrenton (Landfill)
February 9, 1984 Research Triangle Park (EPA)
March 22, 1984 Raleigh
June 6, 1984 Raleigh
August 9, 1984 Raleigh
December 12, 1984 Raleigh
APPENDIX D
· · Consultants
Dr •. Gary Sayler
University of Tennessee
Knoxville, Tennessee
Dr. Robert B. Pojasek, V.P~
Dr. Robert J. Scho~nberger, V.P.
Roy F. Weston, Ip.c.
West Chester, Pennsylvania
Dr. Charles Rogers
Environmental Protection Agency
Cincinnati, Ohio
Dr. Paul Busch
Dr. John Henningson
Malcolm Pirnie, Inc.
White Plains, New York
·Presenters
Dr. Louis Centofanti, Pres.
PPM. Inc.
Tucker, Georgia
Mr. Claude Terry
Claude Terry & Associates
Atlanta, Georgia
Mr. Byron Moe, Pres·.
Dr. Josephine Smith
Dr. John Ludlem
Bioteknika International, Inc.
Springfield, Virginia ·
Dr. Edmund A. Kobylinski
Chemical Engineer
Atlantic Research Corporation
Alexandria, Virginia
Mr. Thomas G. Zitrides, Pres.
CYTOX Corporation
Allentown, Pennsylvania
Dr. David Eaton
Mr. Reid Parramore
Genex Corporation
Rockville, Maryland
Dr. Robert L. Peterson
Mr. Tony Nassef
Galson/Polybac Research
East Syracuse,. New York
Dr. Anne L. Kepecky
Dr. Lois T. Davis
Sybron Chemical Division
Salem, Virginia
LEACHATE POND □ ~ ~ " . CLEAN EARTH/TOPSOIL ARTIFICIAL LINER LEACHATE COLLECTION SYSTEM ~ CLAYLINER ---------, . . ' -~ , -. ---. . -··._/' --~ . · · PCB -.._ J • CONTAMINATED -............_ ....._ -;:. ' SOIL ,,... ~ • ~ , _ ___;,, ; WATER TABLE ._., .. -!•.• .. } ORIGINAL / GROUND ....._'-,I SURFACE ------~ tu tzJ ~ H . :>< tzJ .... '• ... '\,
.,
✓ .
Groundwater
WlA
WlB
W2A
W2B
W3A
W3B
W4A
W4B
Surface Water
RCUSA
RCUSB
RCDSA
RCDSB
UTUSA
UTUSB
UTDSA
UTDSB
Surface Water
RCUSA
RCUSB
RCDSA
RCDSB
UTUSA
UTUSB
UTDSA
UTDSB
PCB LANDFILL ROUTINE MONITORING
ANALYSES FOR PCB's
11/29/82 5/5/83
ND ND
ND ND
Sediments
ND . ND
ND -None Detected
APPENDIX F
11/21/83
ND
ND
D
-For all water samples, none detected means .< 0.1 parts per billion.
-For all sediment samples, none detected means <'.. 0 .1 parts per million.
" fl ... . ''
~
- 2 -
PCB LANDFILL
TREATMENT WORKS ANALYSES FOR PCB's
Date Influent (eeb) Effluent (eeb)
3/7/83 .43 .24
3/11/83 ND ND
3/14/83 ND ND
3/16/83 ND ND
3/21/83 2.47 .18
3/22/83 1.41 .294
3/23/83 1.35 ND
3/24/83 ND ND
3/28/83 ND ND
3/29/83 . ND ND
3/30/83 ND ND
3/31/83 .279 ND
4/1/83 ND ND
4/5/83 ND ND
4/7/83 ND ND
4/11/83 ND ND
4/12/83 ND ND
4/13/83 ND ND
4/14/83 ND ND
4/18/83 ND ND
4/19/83 ND ND
4/20/83 ND ND
4/25/83 ND ND
4/26/83 ND ND
4/27/83 ND ND
5/10/83 ND ND
5/25/83 ND ND
6/1/83 ND ND
7/20/83 1.63 ND
7/29/83 ND ND
11/21/83 ND ND
12/29/83 ND ND
1/26/84 .3 ND
3/7/84 ND ND
4/3/84 .2 ND
5/3/84 .6 ND
ND -None Detected
For all water samples, none detected means <0.l parts
per billion.
{ .
-

3

-
PCB LANDFILL MONITORING CODE
RC -Richneck Creek
UT Unnamed Tributary
OS -Downstream
US -Upstream
SW-CON -Spring Discharge 30 feet above UT
SW-HEAD -Spring Discharge 500 feet
Wl -Groundwater Monitoring
W2 -Groundwater Monitoring
W3 -Groundwater Monitoring
W4 -Groundwater
A -Replicate A
B -Replicate B
Monitoring
Well Ill
Well 112
Well 113
Well 114
above UT
l • #
·Conclusions
(' () L~c.J2.u s i w s. f;~ 0/o.,( 1/h.. Ce ~VJ,\
/0 p,,.,-\ t c,,.,,, u-"' -tcy uJ~,/"I,,. CI,
ervS l.,;:,,,,_,.)?f /yc,C/
-13 -
1) The Warren County PCB landfill is a state-of-the-art,
high-security landfill which exceeds the design requirements
under the Toxic Substances Control Act.
2) Monitoring reveals that PCBs are being contained within
the landfill, and there is no known discernible threat to the
health or environment in the coumrunity.
3) Microbial or chemical processes appropriate for detoxi-
fying the contaminated soil in the Warren County landfill have
yet to be demonstrated. Even if such methods were feasible, not
enough is known to assess potential health hazards associated
with the agents, reagents and/or solvents used in the processes
or with the degradation products evolving from treatment of the
PCBs.
4) Thermal destruction may be possible, but given the
nature of the contaminated soil, the massive earth movement
required, as well as the risk involved in keeping the landfill
open for an extended period, it would entail greater risks than
maintaining the landfill in its present state. In addition, the
cost of thermal destruction would be exceedingly high.
5) While the landfill was very well designed and constructed,
proper maintenance is exceedingly important. The hallmark of a
successful landfill is a sound monitoring and maintenance program.
6) While monitoring results are made public, there is
inadequate perception among the people in Warren County about
the nature of the landfill and the measures that are being taken
to insure its integrity.
Recommendations
In light of the findings, the following recommendations are
made:
1. The Warren County PCB landfill should not be disturbed
at this time.
' .
-14 -
2. The program for the routine maintenance of the landfill
should continue with the responsibility being clearly set forth
both in the record and in public.
3. Regular monitoring of the site should continue.
Monitoring of private wells in the area should be initiated. No
fewer than 25% of the private operating wells within a l½-mile
radius of the landfill should be monitored at least once every
four years. The monitoring of the landfill should include
structural monitor~g to detect subsidence.
4. A contingency plan should be prepared in the event of
damage to the landfill or evidence of PCB leakage. This con-
tingency plan should establish responsibility for corrective
action, sources of funding for such corrective action, and who
would be responsible for compensation to injured parties in the
vicinity. This contingency plan should be updated periodically.
5. The necessary funding and supporting statutory authority
should be provided, if not already in place, to implement
Recommendations 2, 3 and 4.
6. This ad hoc Working Group should be dissolved, but a
mechanism should be established within state government to continue
surveillance of developments in PCB detoxification, with repre-
sentation from the appropriate state agencies as well as liaison
with EPA, Warren County and the research community.
Finally the Working Group appreciates the level of concern
extended to this problem by the Governor and State agencies and
of the support given to the Group in exercising its responsi-
bilities. Particular thanks go to Robert Jansen, Senior Policy
Advisor to the Governor, for his concern and assistance. Also,
William L. Meyer is recognized for his service as rapporteur.
Segment ti 8
1. NC 98, Franklin County -From SR 1708 to NC Hwy 39 in Bunn. From
0.2 mile NW SR 1610 to Nash Co. Line.
Length: 4.70 shoulder miles
2. NC 98, Nash County -From Franklin County Line to NC 231.
Length: l.~l shoulder miles
3. NC 231 , Nash County -From NC 98 to SR 1137.
Length: 0.94 shoulder miles
4 . SR 1137, Nash County -From NC 231 to NC 9,7-<!
Length: 3.48 shoulder miles
5. NC 97, Nash County -From SR 1137 to Franklin County Line.
Length: 4.39 shoulder miles
6. NC 97, Franklin County -From Wake County Line to Nash County Line.
Length: 0.90 shoulder miles
7. NC 97 Wake Co. -From Wake Co. line to Zebulon city limits. From
t he western city limits of Zebulon to US Hwy Bus. 64.
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• • • • • • • • SAMPLE AND ANALYSIS MANAGEMENT SYSTE~ EPA•ESD REG IV ATHENS GEORGIA 07/25/83 SPECIFIED ANALYSIS DATA REPO~TING SHEET SEDI~ENT/SOIL/SLUDGE(DRY WT) SAMPLE ~O,: 83C 125 SAMPLE TYPE: SOIL PROJECT NO,: 82•189F _ PROGRAM ELEMENT: SSF SOURCE: ~C PCB R□ADSIDf, SPILL CITY: srATE: NC STATIC~ I.D.: PT•& NC98 20YDS W OF ~AS~ CO LINE 212•43b STOFET STATION NO: SAMPLE COLLECl'lUN: START D l\ T~:ITIMF. = 8 2 ,o 71V SAMPLE COLLF.:CTION l STOP nATE/'r.!l-',E i _ • J 00 COLLECTED HY: J HOBGOOD RECEIVED FRO~: SAMPLE REC1Cs DATE/TI~E 00/00/00 REC1D BY: SEALED: CHE~ISTZ JMS CHE~IST: ANALYTICAL METHOD: CASE NOa: 212 ORG SAMPLE NOC D O !NORG SAMPLE NO,: ~o CONTRAC~ LABORATORl(DRGANIC): CAL ANAL LABS CONTRACT LABORATORYCitORGANICl: REMAFK: REMARK: SAMPLE LOG VERIFIED ~Y: TBB ***REMARKS••• DATA VEPIFIED BY: HL~ (l **************************************************************** ***FOOTNOTES*** *A•AVERAGE VlLUE *NA•NOT ANALYZED •NAI•INTERFERENCES •J•ESTIMATED VALUE •N•PRESUMPTIVE EVIDgNCE OF PRESENCE OF MATERIAL *K•ACTUAL VALUg IS KNOWN TO BE LESS THAN VALUE GIVEN *L•ACTUAL VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN *O•MATERIAL WAS ANALYZED FOR BUT NOT DETECTED, THE NUMBER IS TrlE MINIMUM DETECTION LIMIT. RESULTS -1000U-26000 7,5 *****ANALYTICAL RESULTS***** UNITS PARAHETER -UG/KG PC8•t242-CAROCLOR-1242)-UG/KG PCB•1260 (AROCLOR 1260) % MOISTURE ;.) ,·: t:. STORET ------------39499 39511 70320
~ / ~ '""' ,.. • 07/25/83 SAMPLE AND ANALYSIS MANAGEMENT SYSTEM EPAt11ESD REG IV ATHENS GEORGIA ··--~-·· --~-. SPtCIFIED ANALYSIS DATA R[PO~TING SHEET SEDIMENT/SOIL/SLUOGE(DRY WT) SAMPLE NO.: 83C 126 SA~PLE TYPE: SOIL PROJECT NO,; 82•189F PROG~AM ELEMENT: SSF SOURCE: NC PCB ROADSIDE SPILL . CITY& STATE: NC STATION l,D.: PT•9 ~C98 AT INTERSECTION OF SR1732 2120•437 STORET STATION ~O: SAMPLE COLLECTION: START DATE/TI~E 10/07/82 0900 SAMPLE CCLLEC1ION: STOP DATE/TIME 00/00/00 COLLECTED BY: J HOBGOOD RECEIVED FROM: SAMPLE REC1D: DATE/TIME 00/00/00 REC'D BY: SEALED: CHEMIST: JMS CHEMIST: ANALYTICAL METHOD: -· CASE NO,& 212 ORG SAMPLE hOI D O !NORG SAMPLE N01: MD CONTRACt LABORATORY(OFGANIC)I CAL ANAL LABS CONTRACT LABORATORY(INORGANIC)t .. --·--·-----REMARK: REMARK: --SAMPLE-LOG-VERIFIED BY: TBB DAT.A VERIFIED -BYt-HLR·--·· --·· --***REMARKS*** -------------·---------0 **************************************************************** RE:SULTS · -·· · --10 0 OU·-2600 5,6 ••~00.'l-NO-'?!S•••~-------· ····· ------·------· ---------·--:·---------····--· ··-· .. ···•A-•AVERAGE VALUE *N~•NOT ANALYZED *NAI•INTERFERENCES Jill_STIMATED,'2,VALUE •N•PRESUMPTlVE EVIDENCE OF PRESENCE OF MATERIAL '~AC'rUAlit.VALUE;.:Is.· KNOWN TO BE LESS THAN VALUE GIVEN ,,~UUA~'lALU&:1--lSi-KNOW~TO-BE--GRSATER--'l'HAN-VALUS--G-I-VEN-----··-·---··-·-··-·• ·-•-··-~~~TERI AL WAS.ANALYZED FOR BUI NOT DETECTED, THE NUMBER IS "'l~ErMlNIMUM DETECTION LIM T1 -~--' ·}:·_::·:i\:;;};it~~-}·· .• ----------·-··---------------. --~,;;~~::h;::~;~:t:·.•i:'~ --·••• -• -----h *****ANALYTICAL fiESULTS***** UNITS PARAMETER · -UG/KG-PCB-1242-fARDCLUR-1242)~--UG/KG PCB•1260 CAROCLOR 1260) % MOISTURE ··-· ·--------------·-· ----------STORET ··-··-----39499-39511 70320 -. .-~ t"I ""
07/25/83 SAMPLE AND ANALYSIS MANAGEMENT SYSTEM EPA•ESD,REG IV ATHENS GEORGIA SPECIFIED ANALYSIS DATA ~EPORTING SHEET SEDIMENT/SOIL/SLUDGE(DRY WT) SAMPLE ~D.: R9C 127 SAMPLE TYPE: SOIL PROJECT NO,: 82•189f PROGRAM ELEMENT: SSF SOURCE: NC PC~ ~OADSlDE SPILL CITY: STATE: NC STATION l.D.: PT•lO NC9B 0.6~I W □F SRl611 SPLIT SAMPLE 212D•438 STORET STATION NO: SAMPLE COLLECTION: START DATE/TIME 10/07/82 1010 SAMPLE COLLECTION: STOP DATE/TIME 00/00/00 COLLECTED BY: J HOBGOOD RECEIVED FROM: SAMPLE REC'D1 DATE/TI~E 00/00/00 REC1P PY: SEALED: CHEMIST: J~S CHEMIST: ANALYTICAL METHOD: CASE ND.: 212 ORG SAMPLE NO: D o !NORG SAMPLE N~.: NU CONTRACT LABORATORYCOFGANIC): CAL ANAL LABS CONTRACT LABQRATOPYCINORGAN!C): ReMARK: REMARK: SAMPLE LOG VERIFIED BY: TBP ***REMARKS*** nATA VEFIFIEP BY: HLR () **************************************************************** ***FOOTNOTES*** *A•AVERAGE VALUE *NA•NOT ANALYZED *NAl•lNTERFERENCES *J•ESTIMATED VALUE *N•PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL *K•ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN *L•ACTUAL VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN *U•MATERIAL WAS ANALYZED FOR BUT NOT DETECTED, THE NUMBER IS THE MINIMUM DETECTJON L!~IT. RESULTS · 10000 11000 16 *****ANALYTICAL RESULTS***** UNITS PARA~ETER UG/KG PCB•t242-CAROCLOR-1242) · UG/KG PCB•1260 (AROCLOR 1260) % MOISTURE STORET ··--3 9 4 9 9----·-·-· 39511 70320
SAMPLE ANO ANALYSIS MANAGEMENT SYSTEM EPA•F::SD,REG IV ATHENS GEORGIA 07/25/83 SPECIFIED ANALYSIS DATA REPORTING SHEET SEDIMENT/SOIL/SLUDGE CORY-WT) SAMPLE NO.: 83C 128 SAMPLE TYPE: SOIL PROJECT~0,:-82•l89F PROGRAM -ELEMENTt SSF SOURCE: NC PCB ROADSIDE SPILL CITY: STATE: NC STATION-llD~: Pt•l1-NC98-AT INT!RSECTION 1610 212D•439 STORET ST TiON NOi SAMPLE COLLECTION: START DATE/TIME 10/07/82 1250 SAMPL~ ~OLLECTION: STOP -DATE/TIME 00/00/00 COLLECTED BY: J HOBGOOD RECEIVED FROM: SAMPLE REC1D: OlTE/TIME 00/00/00 REC1D BY: SEALED:. CHEMISTS J~S CHEMIST: ANALYTICAL METHOD: CASE N0~2 212 ORG SAMPLE NO: D O !NORG SA~PLE NO.: MD 0 CONTRACT LABORATDRY(ORGANIC)t CAL ANAL LABS CONTRACT LABURATORYCINORGANICl= REMARK: REMARK: SAMPLE LOG VEFlfI!D BYi T~B ***REMARKS*** DATA VE~IrIEO BY: ~LR **************************************************************** ***FOOTNOTES*** *A•AVERAGE VALUE *Nl•NOT ANA~YZED *NAI•INTERFERENCES *J•gSTIMATED VALUE *N•PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL •K•ACTUAL VALUE !S ~NOWN TO BE LESS THAN VALUE GIVEN •L~ACTUAL VALUE IS KNOWN TO BE-GREATER THAN VALUE GIVEN *U•MATERIAL WAS ANALYZED FOR 8UT NOT DETECTED, THE NUMBER IS THE MINIMUM DETECTION LIMIT, RESULTS tOOOOUA 1Q.OOOUA 6.2)\ *****ANALYTICAL RESULTS***** UNITS PARAMETER UG/KG PCB•1242 (AROCLOR 1242) UG/KG PCB•1260 (AROCLOR 1260) % MOISTURE STOPET 3 9 4 9 9 ---- · __ 39511 70320
SAMPLE ANO ANALYSIS MANAGEMENT SYSTEM EPA•ESD,REG IV ATHENS GEOFGIA 07/25/83 SPECIFIED ANALYSIS DATA REPO~TING SHEET SEDIMgNT/SOIL/SLUDGECDRY WT) SAMPLE N□.: 83C 129 SAMPLE TYPE: SOIL PROJEC~ NO,; 82•189F PROGRAM ELEMENTt SSF SOURCE: NC PCB ROADS!DE SPILL CITY: STATt: NC STATION 1,ci: Pr~12 ~C98 w o.3MI ~ OF NC39 2120•440 STORET STAT ON NO: SAMPLE COLLECTION: START DAT~/!IME 10/07/82 1400 SAMPLg .COLLgCTION: STOP DAT~/TI~E 00/00/00 COLLECTED BY: J HOBGOOD RECEIVED FROM: SAMPLE REC'D: DATE/TIME 00/00/00 REC'D BY: SEALED: CHEMIST1 JMS CHEMIST: ANALYTICAL METHODI CASE NOf: 212 ORG SAMPLE NO! D O !NORG SAMPLE ~O.; MD CONTRAC LA80RATORY(OR~ANIC): C~L ANAL LABS CONTRACT L~BORATORYCI~ORGAN!C): REMARK: REMARK: SAMPLt LOG VERirIEP BY; TB8 ***Rf':MARKS*** DATA VERIFIED BYr HLR () **************************************************************** ***FOOTNOTES*** *A•AVgRAGE VALUE *NA•NQT ANALYZEO *NAI•lNTERFERENCES *J•ESTIMATED VALUE *N•PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL *K•ACTUAL VA~UE IS KNOWN TO BE LESS THAN VALUE ,GIVEN •L•ACTUAL VALUE IS ~NOWN TO-SE GREATER THlN-VALUE--GIVEN --*U•MATERIAL WAS ANALYZED FDR BUT NOT DETECTED. THE NUMBER IS THE ~INIMU~ DETECTION LIMIT, f<ESULTS 1 ooou -1000U 4.3 *****ANALYTICAL RESULTS***** UNITS PARAMETE~ UG/KG PCB•1242 (AROCLOR 1242) UG/KG PCB•1260 (ARDCLOR 1260) % MOIST.URE STORET ---:39499----39511 70320 --------------------------------------------------------
07/25/83 SAMPLE ANO AN~LYSIS MANAGEMENT SYSTE~ EPA•ESD,REG IV ATHENS GEORGIA SPECIFIED ANALYSIS DATA REPORTING SHEET SEDI~ENT/SOIL/SLUDGE(DRY WTJ SAMPL~ NO,: 83C 130 SAMPLE TYPES SOIL PROJECT-NO,:-B2•189F SOURCE: NC PCB ROADSIDE CITY: PP.OGRAM ELEMENT: SSF SP.ILL STATE: NC STAT10N-1101:-PT•13-NC98 STORET STAT-iON NO: W 0,2MI EOFF SR1001 2120•441 SAMPLE cotiECTIONI START DATE/TIME 10/07/82 1703 SAMPLE--COLLEC-T!ONs --STOP DATE/TIME 00/00/00 COLLECTED BY: J HOBGOOO RECEIVED FROM: SAMPLE REC10: DATE/TIME 00/00/00 REC1D BY: SEALED: ---.. CHEMIST& JMS CHEMIST: ANALYTICAL METHOD: ----CASE NO : 212 ORG SAMPLE NO: D O !NORG SAMPLE CoNTRACt LABoRAT8RYCoRGANIC>: cat ANAL LABS CONTRACT LABORAT RYCINORGAN!Cl: REMARK: REMARK: SAMPLE LOG VERIFIED BYZ T8B ***REMARKS*** OlTA VERIFIED BYt HLR NO,: "'D I) **************************************************************** ***FOOTNOTES*** *A•AVERAGE VALUE *NA•NOT ~NALYZED *NAI•INTERFERENCES *J•ESTIMATEO VALUE *N•PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL *K•ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN *L•ACTUAL VALUE-IS KNOWN-TO BE -GREATER-THAN VALUE-GIVEN -*U•MATERtAL WAS ANALYZED fO~ auT NOT DETECTED, THE NUMBER IS THE MINIMUM OETECTION LIMIT, RESULTS 1ooou 10000 6.. 7 *****AN~LYTICAL RgSULTS***** UNITS PAFAMETER UG/KG·PCB•1242 CAPOCLOR 1242) UG/KG Pca~1260 (AROCLOR 1260) % MOISTURE STOR€T 39499 39511 70320 --------------------· ·----------
PCB LANDFILL STATUS
BRIEF BACKGROUND
In 1993, Governor Hunt was briefed by state officials on the status of the PCB landfill in
Warren County. He was told that the contents of the landfill had not been sampled since
construction, and that there was water in the landfill that needed to be tested and removed. The PCB
landfill was constructed to be a dry facility. At the direction of the Governor, state officials met with
Warren County officials in a public meeting to determine what to do about the water. The intent of
that meeting was to get concurrence on extraction of the water. Several citizens demanded that
detoxification be considered as a prerequisite to dewatering or done simultaneously with dewatering of
the landfill. They also cited the commitment that Governor Hunt made in a 1982 letter to the citizens
of Warren County to detoxify the landfill when feasible. As a result, DEHNR set up a 16-member
working group composed of Warren County citizens, environmentalists, and state officials to make
recommendations to the Governor about the future management of the PCB landfill.
The working group met for the first time in January 1994. Upon the group's
recommendation, a contract was entered into with Pauline Ewald, head of Environmental Compliance
Organization, on May 1, 1994 for $82,950 (money came from DEHNR) to serve as the group's science
advisor for one year. Her duties were to recommend site evaluation procedures, a methodology for
water removal, a detoxification technology, and long-term controls for the PCB landfill.
In July 1994, a sampling event was conducted at the landfill by Ms. Ewald's company and the
state. No PCBs were found outside of the landfill. However, the laboratory that analyzed the state's
samples detected some dioxin at the ppq (parts per quadrillion) level in three of the monitoring wells
around the landfill. Opinions varied as to where the dioxin originated. Despite the fact that Ms.
Ewald tried to discredit the state's findings, she used those findings to conclude in her report that "In
the absence of other likely sources of chlorinated contamination, it is likely that the PCB landfill is the
source for the dioxin and furan contamination noted at the site." The report prepared by Ms. Ewald
was not acceptable to the state. It was peer-reviewed by several outside sources who were also critical
of her report.
The state recommended that the landfill be resampled. The working group opposed both
resampling and removal of the water from the landfill. Ms. Ewald's report convinced several members
of the working group that the landfill was leaking. Even though several members of the working
group acknowledged that the presence of water in the landfill presented a potential risk, they did not
want the water removed. They have repeatedly expressed concern that if the landfill were made safe
by removing the threat of the water that the state would not proceed with any detoxification effort.
Ms. Ewald recommended that a technology known as base catalyzed dechlorination (BCD) be
used to detoxify the landfill. The state advised the working group that at least three methods should
be considered and that the General Assembly would want information about various technologies
available for detoxification, why certain technologies were approved/ rejected, and costs. The working
group felt that the BCD process was a suitable technology and would be acceptable to the community
because it could be done on site. The state and the working group went through the process of
selecting vendors to conduct pilot projects at the landfill using BCD methods. Two vendors even
went through the EPA process for approval. Both eventually received approval by EPA. Pilot-scale
1
proposals by the vendors included a cost ranging from approximately $700,000 to $800,000 for on-site
testing of technologies.
Ms. Ewald's contract expired in May 1995.
CURRENT STATUS Ouly 1, 1995-present)
Membership
The original working group was composed of 16 members. At the working group's request,
the membership was raised to 24 in September 1994. Presently, there are 21 people on the working
group, with Senator Frank Balance serving as an ex-officio member and Mr. Bill Meyer, director of the
Division of Waste Management, serving as staff. Three positions are vacant (one public safety and two
youth). Approximately 10-12 members show up for meetings on a regular basis, and they are the
decision-makers. The others attend meetings sporadically or never attend. There are only two elected
officials on the working group. County Commissioner Lucius Hawkins' attendance is sporadic. He
was defeated in the spring primary. Ms. Dollie Burwell, the Register of Deeds for Warren County, is
one of the co-chairs and a regular attendee. She also was defeated in the spring primary.
The credentials of the working groups members, other than the three state representatives, are
basically unknown. The working group very heavily relies on the state for staff, technical expertise,
and support. Yet members have repeatedly said they do not trust the state.
Expenditures
In March 1994, Warren County was awarded $100,000 from the Solid Waste Grants Program
to be used for capital improvements on the PCB Landfill.
During the 1995 session of the General Assembly, the legislature appropriated $1 million from
the Highway Fund for pilot projects to determine the most appropriate technology for cleanup of the
landfill.
The working group members decided they needed the services of another science advisor as
well as support staff. On March 7, 1996, Mr. Joel Hirschhorn (Maryland) and Mr. Patrick Barnes
(Florida) were hired as science advisors for the working group. On March 18, 1996, Ms. Doris
Fleetwood was hired as a part-time secretary for the working group. A joint agreement was made
between the DEHNR and the Warren County Board of Commissioners to provide office space,
furniture, equipment, supplies, conference room, kitchen, restroom facilities and parking for the
secretary and the two science advisors. The working group's office opened on March 25, 1996, in the
CP&L Building in Warrenton, NC. The $1 million appropriated by the General Assembly is being
used to pay the science advisors, the secretary, and office rent. The science advisors are each paid at
the rate of $100 per hour of work. The cost for the half-time secretary and office space is $25,000 for
one year. As of September 1996, $60,252 has been expended from that fund, of which $31,809 has
gone to the science advisors.
In the fall of 1995, the Division of Waste Management began working with CP&L to provide
electrical service to the landfill for pilot projects or any full-scale detoxification effort. CP&L was paid
2
$64,384 for this service from the capital improvements account. Poles and lines for electrical service
are in place, and transformers will be added when the specific electrical demands are known. This
provides a permanent source of power for detoxification efforts or dewatering the landfill, as well as
other activities that may require electricity.
Master Plan
After talking with the working group and reviewing files and documents related to working
group activities and the PCB Landfill, the science advisors developed a master plan. This master plan
stated why the working group should change its current strategy and offered an alternative strategy.
The working group approved the master plan at their April 25, 1996 meeting.
The science advisors offered several reasons for changing the current strategy of the working
group. Briefly, the science advisors stated that it would be just as effective, and less expensive, to invite
a few companies to conduct off-site, bench-scale tests on the landfill's contents rather than pilot-scale
projects. This would also mean that less material would have to be removed from the landfill for the
studies. The science advisors stated that other detoxification technologies must be thoroughly
examined. They also said that a much stronger case for funding from the General Assembly could be
made by spending money on a more thorough site investigation and remedy design.
The science advisors recommended several key steps in the alternative strategy. They felt that
a more detailed evaluation of detoxification technologies and vendors should be conducted by the
science advisors. They also suggested that a site investigation be conducted to determine the current
status of the PCB Landfill and the surrounding area. This investigation, if approved, will include the
placement of additional monitoring wells and a resampling of the landfill and surrounding area. The
site investigation will cost roughly $50,000 (excluding state staff costs), and it will be funded from the
$1 million approved by the General Assembly.
The alternative strategy also calls for several other items:
Designing a soil and waste removal plan and selecting a vendor to do
this;
Issuing a feasibility study report;
Inviting vendors to conduct bench-scale treatability tests;
Evaluating test results and selecting/ranking vendors {to be done by
science advisors);
Finalizing the site investigation report;
Meeting with working group/highest ranked vendors;
Selecting best technology vendor (pre-qualified for actual cleanup);
Hiring best technology vendor as design contractor (under current
funding);
Selecting a remedy and issuing a remedial design report.
The remedial design report would be used as the basis for the working group and DEHNR to formally
propose the landfill detoxification project to the General Assembly to obtain funding.
In February 1996, an RFP was sent to vendors for excavation, handling, and storage of PCB
3
contaminated soils from the landfill. The original intent of this RFP was to remove soils for the pilot
scale studies. The working group wanted the input of the new science advisors, so the effort was put
on hold. The new science advisors modified the plans for detoxification studies. The RFP was
modified and reactivated in September and four responses were received in October. These responses
were reviewed by the science advisors. Pending some additional clarification, the science advisors
recommended CDM (Camp Dresser & McKee).
The working group, including the two science advisors, held a meeting on October 23, 1996.
At that meeting, Mr. Hirschhorn presented the members with a draft letter to EPA Region 4
Administrator John H. Hankinson, Jr., accusing the state of a "serious and prolonged lack of
compliance." The letter stated that the state: "(1) did not carry out all required groundwater
monitoring; (2) failed to analyze early data that we believe show that the landfill has had water
entering and escaping it; (3) failed to act or plan to remove large amounts of water inside the landfill;
and (4) failed to repair a dysfunctional leachate collection system." The letter also stated that "the
serious and prolonged lack of compliance by the state, as owner and operator of the landfill, also
reveals a lack of oversight and enforcement by EPA Region 4 that demands attention, explanation, and
correction." With a few corrections, the working group agreed that the co-chairs were to sign the
letter, and it would then be sent to Mr. Hankinson.
Mr. Hirschhorn presented the working group with another draft letter to Mr. Elliott P. Laws,
EPA assistant administrator for Solid Waste and Emergency Response. The working group requested
a clear, definitive policy position concerning the extent to which CERCLA and National Contingency
Plan requirements apply to the PCB landfill. This letter was approved as written.
Mr. Hirschhorn presented the group with a signed declaration stating that in his professional
opinion, detoxification technology appropriate for use at the PCB landfill is now commercially
available. The two technologies he named are gas phase chemical reduction and base catalyzed
decomposition. In addition, Mr. Hirschhorn presented a written statement that accused the state of
"delaying the efforts by the Working Group to complete the current project to assess, test, and select
detoxification technology." He also stated that the issue is not whether detoxification can be done, but
whether the state will honor the commitment made by Governor Hunt in an October 20, 1982 letter.
After considerable discussion about whether to release the letters and the statements to the
news media before or after the November 5 election, the working group decided to issue a media
advisory on November 11 informing the news media that there would be a press conference on
November 12 at 11 am. It was later announced that the press conference would be held at the Capitol
Building.
At the October 23 meeting of the working group, Mr. Barnes noted that he had met with
Senator Frank Balance and US Representative Eva Clayton, at the request of working group co-chair
Dollie Burwell. Mr. Hirschhorn was not invited to this meeting, and he subsequently wrote a letter to
the working group seeking clarification as to who had the authority to initiate such an action (i.e.,
could a co-chair or working group member authorize such an action without the consent of the
others).
Mr. Hirschhorn wrote another letter complaining that co-chair Henry Lancaster had never
explained to him that he had the option of being the sole science advisor or working with Mr. Barnes.
4
Mr. Hirschhorn said that he was given only the option of working with Mr. Barnes. In his letter, Mr.
Hirschhorn stated that he would have chosen to be the sole science advisor had that option been given
to him.
In response to the accusations made against the state in the letter to John Hankinson and the
two statements drafted by Mr. Hirschhorn, the Division of Waste Management had a temporary
engineering consultant review inspection/ monitoring files to determine if the state was in compliance
with permit conditions. The following are the findings:
• Monthly inspection and landfill leachate monitoring reports are complete for 1984-1986
and from 1990 to the present. Reporting was spotty for 1987-1989. The PCB landfill was
closed in 1983, and 1984 was the first full year of required reporting;
• From 1983-1993, an estimated (based on pumping rates and pumping time) 12,400 gallons
of leachate was removed from the landfill. No documentation was found for 1987-1989.
Amounts ranged from a low of 100 gallons in 1986 to a high of 5,297 gallons in 1983.
Pumping was not conducted in some winter months when the temperature was below
freezing and the leachate in the pipe was frozen. In 1994, an estimated 100 gallons was
pumped each month (pumping time available, but calculations incomplete at this time). In
August 1995, pumping of leachate at the landfill was ceased at the request of the working
group. As of November 1996, pumping has not been resumed;
• Semi-annual sampling has been conducted each year (beginning in November 1982) except
for 1987 when there was only one sampling done. At the request of the working group,
semi-annual sampling ceased after May 1995. Semi-annual sampling resumed in early
October 1996;
• The Final Technical Report for the PCB landfill project was sent to EPA Region IV
Environmental Scientist Al Hanke in September 1983;
• Background sampling of groundwater, surface water, and surface water sediments was
conducted July-September 1982 (documented in June 30, 1983 letter from Tom Karnoski
to O.W. Strickland and is part of the Final Technical Report to Al Hanke;.
• In the spring of 1990, the Division of Waste Management notified officials in the
Secretary's Office that there was water in the landfill that needed to be removed, but that
funds were not available. A request for funds to dewater the landfill was not a high
priority in the department's legislative budget package in 1991, and did not make it to the
General Assembly. As mentioned earlier in this report, state officials met with Warren
County officials in a public meeting in May 1993 to determine what to do about the water.
One of the goals of the working group, established as a result of this meeting, was to assess
the need to remove rainwater from the landfill and recommend to DEHNR the basis and
technology for removal or allowing rainwater to remain in the landfill. The working
group did not address this issue (until the October 23, 1996 meeting) other than to say that
it did not want to dewater the landfill unless done in conjunction with detoxification;
• The RFP (February to October 1996) for the excavation of soils from the landfill requires
5
the construction of two to four extraction wells into the landfill. These extraction wells
can also be used to dewater the landfill. This activity will also provide data on the status of
the top liner with respect to liner integrity or leakage.
On October 2, 1996, Mike Kelly sent a draft PCB Landfill Sampling Plan to the two science
advisors for their review and comment. At the October 23, 1996 meeting of the working group,
Patrick Barnes presented some amendments to the draft sampling plan. The division agreed to those
amendments. To date, the division has not received any written comments from Joel Hirschhorn, and
the draft sampling plan has not been approved by the working group. To the division's knowledge,
the sampling plan is the only document that has been significantly delayed. We had envisioned that
the sampling plan would be ready for the working group's approval in the summer. The initial draft
plan supplied by Mr. Barnes was inadequate and lacking in detail. Division staff worked with Mr.
Barnes to draft a plan that could be implemented. The sampling plan cannot be implemented,
however, until the monitoring wells have been constructed.
An RFP to conduct dioxin/furan testing on water, soil and sediment samples from and around
the PCB Landfill was sent to potential respondents on November 5, 1996. All proposals are due to the
Division of Waste Management by noon, November 22, 1996.
The RFP to construct monitoring wells (9 deep, 3 shallow) at the PCB Landfill was sent to
potential vendors on November 6, 1996. An ad was also placed in The News and Observer to run
November 10. There will be a pre-bid meeting on November 18, 1996 for vendors who wish to
submit quotes. The meeting will be followed by a trip to the PCB landfill. Final proposals are due
December 2, 1996. This activity will provide more definitive data on the status of landfill safety and
potential leakage. It is anticipated that an amendment to construct three "off-site" background wells
will be included in this RFP. This amendment will be distributed to the members of the working
group at the November 18 meeting.
6
July .1978
July 30
August ·197a
August 2-5
August 10
August 15
August 18
September ·l978
September 6-19
October·197a
October 5
November .1978
November 6
APPENDIX A
CHRONOLOGY
First report of a chemical spill which was
later· identified as PCB on N.C. 58 in Warren
County.
PCB located along roadsides in several other
North Carolina counties including Johnston,
Alamance, and Chatham.
Conference held with representatives of the
Department of Human Resources, Department of
Agriculture, Attorney General's Office,
Department of Transportation, Environmental
Protection Agency, and the news media to
discuss the PCB dumpings.
Activated charcoal solu~ion and liquid asphalt
applied along 210 mires ·:of North Carolina
highways where shoulders had been contaminated
by PCB. This action was taken at the recom-
mendation.of specialists at North Carolina
State University, who submitted a plan for
temporarily deactivating the PCB to prevent
migration and to reduce any hazard to the
public.
The N.C. Department of Transportation began
applying a solution of activated carbon and
liquid asphalt to the 210 miles of contaminated
roadside.
Tests conducted along uncontaminated road
shoulders to determine the safety and
effectiveness of equipment to be used in
picking up .the PCB.
Test conducted along a contaminated road
shoulder on Highway 58 in Warren County.
Test results of the pick-up of contaminated
soil along the roadside in Warren County
show that the contaminated soil can be picked
up and treated without harming the environ-
ment or personnel involved.
December 1978
December 1
December 12
January:·1979
January 4
January 17
February 1979
February 2
June 1979
June 4
June 4
June 6
Au~st 1979
August 16
Sept -Dec 1979
July -Aug 1979
Se:2tember 1980 .
September 12
- 2 -
The state obtained an option on 142 acres of
land in Warren County to be used to dispose
of the contaminated soil that would be picked
up along the roadsides in 14 North Carolina
counties.
Application filed with the EPA for approval
of the Warren County site as a disposal area
for the PCB contaminated soil.
Public hearing on the Warren County site
conducted in Warrenton National Guard Armory.
Robert Burns and sons pleaded guilty to a
violation of the federal Toxic Substances
Control Act. Burns received an active jail
sentence and his sons were placed on probation.
North Carolina petitions ::EPA to. modify its
regulations to permit alternative methods of
disposal of ~CB contaminated soil and debris
(i.e. in-place treatment).
EPA denies North Carolina's petition.
EPA's Region IV administrator approved Warren
County site, and the state's application to
construct a PCB landfill there.
Robert Burns and sons plead guilty to state
charges surrounding the PCB dumping in
Halifax County Superior Court. Burns later
received an active jail sentence and his
sons were placed on probation. Buck Ward was
found not guilty on state charges.
Suit filed by Warren County.
Draft EIS prepared, filed on December 28, 1979.
Comments received on EIS.
Engineering consultant firms were interviewed
by the state and a recommendation was made to
the Capital Building Authority for selection
May 1981
May 22
·November ·l981
November 25
·May .-1982
May 13
May 26
May 26
June 1982
June 21
·July 1982
July 2
August 1982 .
August 4
August 10
- 3 -
of a firm to develop plans for a PCB landfill
in Warren County.
Buck Ward tried and found guilty of a viola-
tion of the federal Toxic.Substance Control
Act. He received an active jail sentence
and a $200,000 fine.
Judge Earl W. Britt grants summary judgment
in favor of state and EPA in Warren County
and Twitty suits, resolving legal obstacles
delaying constructing of landfill. Appeals
taken in both cases.
Contract for construction of the PCB landfill
awarded by the Capital Building Authority
pending the approval of federal "Superfund"
money to fund the PCB cleanup project. The
contract was awarded to ~he low bidder, Jim
Lineberger Grading and Paving Company of
Gastonia.
North Carolina and EPA officials announced the
signing of a cooperative agreement which
provided $2.5 million in federal "Superfund"
money to construct a PCB landfill in Warren
County, and to clean up the PCB contaminated
soil along 210 miles of North Carolina
roadsides.
120 acres surrounding the landfill site deeded
by state to Warren County as buffer zone.
Voluntary dismissal taken by Warren County
in suit on appeal.
Construction began on the PCB landfill in
Warren County.
NAACP files discrimination suit in federal
court requesting preliminary injunction to
prohibit placement of soil in Warren County.
Hearing held before Judge Earl Britt.
Preliminary injunction denied.
. ' .
September ·19a2
September 15
October 1982
October 6
October 12
October 27
November ·19a2
November 1
December ·l982
December
December 13
December 27
·January ·19a3
January
January 26
- 4 -
Removal of PCB from roadsides begins by DOT
crews. Protests begin in Warren County and
· a total of 423 adult arrests were made and
100 juveniles were taken into custody over
the following 4½ weeks.
Fort Bragg begins removal operation for PCB
on base.·
State finishes roadside removal of PCB.
There were 241 shoulder miles picked up;
6,455 truckloads. taken to landfill.
Fort Bragg finishes removing PCB from base;
768 truckloads put in landfill. Total
state/Ft. Bragg truckloads 7,223.
Capping operation begins:; plastic liner and
clay liner in place, soil layer added. Bad
weather prevents final soil layer and seeding
of cap to be accomplished.
Heavy rains cause soil erosion on cap and
exposes plastic liner. Bubbles develop in
exposed liner from gas in the landfill caused
by decomposition of vegetation mixed in with
soil. Bubbles vented, soil erosion temporarily
corrected and a temporary seed cover is
installed on the cap. Landfill will be
completed in Spring.
Buck Ward begins sentence at Danbury,
Connecticut, Federal Prison after being
denied petition for certiorari by U.S.
Supreme Court.
Federal Appeals Court affirms Judge Britt's
ruling in Twiddy case.
EPA monitors gas venting from landfill and
reports no significant emissions of PCBs.
U.S. Files civil suit in federal court
against Buck Ward and Ward Transformer, Inc.
. . ' ' ..
·February 1983
February 17
March .1983
March 4
·&y·19s3
May 11
May 24
Ju1y ·19a3
July 14
July 15
July 23
August .1983
August 3
-

5

-
State dismisses state law suits against Buck
Ward and· state allowed to intervene in federal
suit. All counterclaims dismissed by Ward
against state.
Voluntary dismissal. taken by plaintiffs in
discrimination suit.
Contractor resumes work on completion of
landfill construction.
EPA grant period extended until July 23, 1983.
Construction completed.
Inspection held at the site and acceptance
made by state officials.:
Grant period ended.
Inspection held at the site by EPA officials
and approval given.