NCD980602163_19950621_Warren County PCB Landfill_SERB C_Eco correspondence June 1995-OCR

,'ii: PAULINE EWALD ECO Date: 6/22195 Time: 01 :14:01
E ~VIRO:'.\\'IE:'.\T AL
C O:VIPLIA~CE
0 RGA:'\IZATIO~
Professional \Vaste Management Consultants
106 Robinson Street Ashland, Virginia 23 005
June 21, 1995
Ms. Dollie BunYelL Co-Ch air
Joint \.Varren County -State PCB Landfill V./orking Group
114 F4CSHJILE
Dear Ms. BunYell:
[phone]
I am v,Titing to you in your capacity as Co-C hair of the Joint PCB Landfill \Vorking
Group to fc,rmall:, request 1hat a cory of the memorandum prepared b: Pat Costner
endorsing ECO's ccmclusiL-ins regarding the situation at the PCB landfill in \Varrenton
be officially entered onto the record as peer re\'iev, of the sampling report.
As y'-,u 1'.-..1iow. iv1s. C .. ,stner is a nationall:· recognized expert on dioxin issues, and her
"illingn.:ss to assist and endorse ECO's 1.York 01; this project represents an honor to
the company, a11d 1111._,re important!:· an adYantage for the commlmit:·. Her
ccncurrence th at this landfill is the only likely source of the dioxin contamination
detectej at the site strengthens m:· already strong recomrnfndation to moYe this
situation rapid!~.-fonYarcl to,,hrds a complete, safe and eft~cti,e remedi ation of the
landfill.
Thank :·ou for your attention to this request. \Ve look fonYard to Ms. Costner's peer
;-e,ie\\ being incorporated into the officia l record for the \Vorking Group .. and to
assisting this comnnmity in re aching all of its remediation objecfr:es fcir the PCB
landfill site.
Respectfull y,
Pauline M. E,,ald
PMEms
.,. .
From: PAULINE EWALD ECO
3REE NP EACE-Costner Date: 6/22/95 Time: 01 :16:05
TEL:[phone] Jun 01,95 Page 4 of 5
11:07 t~o.002 P.01
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~AffNM
Route 7, Box 113, Eureka Springs, Arkansas 72632
Olr [phone] Fax [phone]
pat.costner@g reen2.dat.de ~
1 June 1995
To: Joint Warren County and State PCB Landfill Working Group
Warren County, North Carolina
Fm: Pat Costner
Re: Comments on Integrity of PCB Landfill
In February, 1995, ECO presented the report "Warren County
and State PCB Landfill Working Group: Final Sample Analysis
Report, 11 detailing the detection of polychlorinated dibenzo-p-
dioxins (PCDDs) and dibenzofurans (PCDFs) in water samples taken
from monitoring wells associated with the landfill as we ll as in
the water and sediment from a nearby creek. Analyses of these
same samples found no detectable levels of polychlorinated
biphenyls (PCBs).
At issue is the source of the PCDD /Fs. The landfill has
received substantial quantities of PCB-contaminated materials.
However, the apparent failure to detect PCBs in the same samples
in which PCDD /Fs were present is evidently regarded by state and
federal authorities as evidence that the PCDD/Fs are not leaking
from the landfill but are emanating from another as-yet
unidentified source.
In their report, ECO presents a detailed discussion of the
relative solubilities and transportabilities of PCDD/Fs and PCBs.
The general implication of this discussion is that PCDD/Fs may be
s lightly more soluble and slightly more amenable to migration
t han PCBs. The ECO report concludes that "relE!ase of dioxin from
the PCB landfill is the most likely source for the demonstrated
dioxin and furan contamination in on-site monitoring wells."
Due to the chemical and physical properties described in the
ECO report, the occurrence of either PCDD /Fs or PCBs in
ambient water resources is extremely rare, e ven wh en such
resources are surface supplies. These chemicals can be expected
to occur in groundwater even less frequently. For example,
among more than 230 samples taken .from surface water supplies i n
Ontario and New York, four were found to conta in
octachlorodibenzo-p-dioxin (OCDD) with a mean concentration of
3.16 parts per quadrillion (ppq) and t wo contai ned
octachlorodibenzofuran (OCDF), with a mean c oncentration of 2.45
ppq. (Jobb et al. 1990; Meyer et al. 1989 )
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In}'comparison, three monitoring well samples taken at
Warren County landfill site contained total concentrations of
PCDD/Fs of 1095.7 ppq, 1419.6 ppq and 2262.7 ppq. In these
samples, OCDD concentrations ranged from 59 to 1050 ppq.
It is also noteworthy that various PCDD/Fs were detected in
a raw surface drinking water supply, the Eman River in Sweden,
near a PCB-contaminated area, although PCBs were evidently not
reported. (Rappe et al. 1989) Moreover , the U.S. Environmental
Protection Agency (USEPA) stated in their recent dioxin
reassessment documentation that no data on coplanar PCB congener
water concentrations were found in the literature. (USEPA 1994)
The limitations of the analytical procedures applied to the
E~nvironmental samples taken at and near the landfill must be
regarded as the major factor in the failure to demonstrate the
co-occurrence of PCBs and PCDD/Fs in these samples.
Specifically, analytical procedures capable of achieving
quantifiable results in the parts-per-quadrillion range were used
in the PCDD/F analyses, wh ile those with only parts-per-billion
range sensitivity were evidently used for PCB analyses.
As a result, PCB concentratjons were measurable only when
they were approximately one million times higher than those of
the PCDD/Fs. Given the relatively small differences in the
solubilities and transportabilities of PCBs and PCDD/Fs , it is
entirely unlikely that such concentration differences would exist
in any circumstances in any samples taken from the ambient
environment . Using this much less sensitive method for PCBs, any
?CBs present in the same g eneral concantration range as the
PCDD/Fs go undetected .
In other words, the existing data do not prove the absence
of PCBs in these sam?les. Indeed, if t hese samples were analyzed
for PCBs by a method that has a sensitivity similar to that used
for PCDD/Fs , it seems most probable that PCB con centrations
comparable to those of the PCDD/Fs would be found.
In summary, based on the weight of evidence, specifically
the presence of relatively high concentrations of PCDD/Fs in
on-site monitoring wells , as well as in nearby creek water and
sediment, the landfill is leaking and remediation acticns should
be taken immediately.
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