NCD980602163_19950608_Warren County PCB Landfill_SERB C_Re Update of Technology Screening Process 1 June 1995-OCR

From: PAULINE EWALD ECO Date: 6/9/95 Time: 12:52:09
E NVIRONMENTAL
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Profoss ional Waste Manaoement Consultants
106 Robinson Street Ashland, Virginia 23005 [phone]
TO:
FROM:
RE:
DATE:
ALL MEMBERS OF THE JOINT WARREN COUNTY STATE
PCB LANDFILL WORKING GROUP
PAULINE EWALD, ECO
MEMO DATED JUNE l , 1995
JUNE 8, 1995
I have reviewed a document entitled Update of Technology Screening Process June l ,
1995, and am very disturbed to find that the criteria presented, which I had been led to
expect would be the BCD Pilot Study vendor selection criteria, is indeed just a rehash
of the EPA remedy or treatment selection criteria that is included in Superfund
feasibility studies.
I had understood that the Working Group had discussed on numerous occasions, and
actually voted to move ahead with the BCD pilot sh1dy, and selection of an actual
vendor to begin this work. As science advisor, I was in full supp011 of the
l:ommunily's wishes and the will of the Working Group to press the pilot study
forward for implementation in spring or summer 1995. The information presented in
the above noted document, retreats the entire process back to the phase of looking at
technologies, and running through an EPA style feasibility study. I have repeatedly
counseled the Working Group to move beyond both of these time and resources
intensive excrcis(:s, to expedite a pilot study which is pre-requisite to the full
remediation of the PCB landfill.
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From: PAULINE EWALD ECO Date: 619/95 Time: 12:53:07
JOINT WARREN COUNTY -STATE PCB LANDFILL WORKING GROUP
JUNE 8, 1995 MEMO
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Therefore, the Working Group must again decide definitively whether to abide by
previous policy and votes regarding moving the process forward, or to stop and
consider the hundreds of various approved and un-approved technologies that may be
available. I must restate, that in good conscience, and according to best technical
opinions of myself, and others on-staff and consulting with ECO,
that we cannot endorse a feasibility type study of the universe of technologies, proven
and unproved, when we are faced with an above federal limit dioxin contamination of
the ground and surface waters at this site.
The criteria presented are only useful in evaluating technologies, not vendors for the
pilot study. Should the Working Group decide to redirect its efforts towards obtaining
a BCD vendor to implement the critical pilot study I believe that criteria similar to
those presented in Table 1, included here, would be appropriate. Please note that
vendor selection criteria are almost universally given percentage weights, rather than
assigned numerical designations.
Please let me know if I can be·of further assistance in expediting the vendor selection
process, and the implementation of the BCD pilot study that you have worked so
diligently to accomplish.
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From: PAULINE EWALD ECO Date: 6/9/95 Time: 12:53:59
...
JOINT WARREN COUNTY -STATE PCB LANDFILL WORKING GROUP
J UNE 8, 1995 lvfEMO
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Table 1: BCD Pilot Study Suggested Vendor Selection Criteria
VENDOR SELECTION CRITERIA RELATIVE \VEIGHTING
IN SELECTION DECISION
Community Acceptance of the proposed
treatment set-up, implementation schedule, 40 %
health and safety plan provided, time frame
and format for reporting results.
Demonstrated Efficacy of the proposed BCD
ln::atmenl on olher sites wilh geologic, soil and 30 %
waste conditions similar to those in Warren
county. This criteria shall encompass the
extent of vendor's prior experience with BCD.
Prior Compliance History to include a full
description of the vendor, and all parent and
off-shoot companies in regard to violations of
any and all federal environmental or fiscal
requirements. A history of compliance in the
various states where the vendors have
performed major site remediations should also
be required. This criteria encompasses safety
and exposure considerations.
Proposed Cost of the pilot study.
Small Disadvantaged Business Status will
benefit vendors who can demonstrate that they
are minority or women owned businesses or
propose to utilize SDBE companies as
subcontractors for this pilot study
15 %
10 %
5%
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