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Home My WebLink AboutNCD980602163_19950710_Warren County PCB Landfill_SERB C_Bill Meyer Report and response to co-chairs and technology sub-committee requests-OCRi I To; j , I FROM:1 ! , ' Members of Joint Warren County/State PCB Working Group 8111 Meyer Report and response to co;chalrs and technology sub-committee requests ' • 23, 1995. The co-chairs directed the Division to: 1) mall ECO a copy of draft· nd teohnolo~y selectlon criteria and request review and comment ae soon as ; 2) set up meeting with technology sub-committee to Identify technical res,our s needed for the detoxification effort Including science advisor and addltlonal j • I ' • res,our a \f an.d as ~eeded; 3) set up meeting with Region IV USEPA on jurisdiction lssµes e ~ooq as possible (co-chairs offered to Jointly sign letter to EP~ If It was ne~ded 1 to aooelerate the process). I 2. Jun~ 23, 1995. The Division malled one copy of draft vendor and technology se1;ectld~1n 1 ci-lte. 'rla to l:CO (registered mall). On June 26, 1995, another copy was Feder~! Expree ed to ECO. ECO responded on June 28, 1995. A copy was malled to all wc,rkln gro~~'members June 28, 1995. . I 3. :Jun~28, 1Q95. The technology sub~commlttee mat by conference call (Nan Frlgdla d, Kan and Oebarah Ferrucclo, BIiiie Elmore, Jim Warren and BIii Meyer). The sub-co mlttee recommended to modify the vendor selection criteria by changing the "teichnqlog:y proposed" standard to BCD and the "standard evaluation" elements for this et~ndafd to ensure Inclusion of time and residual concentration level. Draft proposed ch~ngs have been made by the Division and will be presented to the full working group s sub•¢omm!ttee recommendations. The sub•commlttee further recommended th•t II mpllance history" be added as a standard and standard evaluation should lnQIUd oonslderatior of parent and subsidiaries. The Division has made draft propold changes by adding this to the criteria . These ere to be presented to the full . wqrkln group as a sub-committee recommendation. Both these changes are Included In ~he rlterla for V~ndor Selection for Warran County PCB Landfill Detoxlflcatlon Prograr,. eI2a196 C>raft (enclosed). I 4. • Junf:: 28. 1995. The sub-committee directed the Division to modify the technology • s&l&etl r, el'lterlei to doflno "community aooephmce11 to Include consldl:'r~tlnn of the follow! g: 1) Community perceived risk offered by a technology; 2) potential for harm to hui9 n hoQlth; 3) actual or potentlal environ manta! relea8e& or Amiss Ions; 4) Impact orl pror8rty Values. • Tkla "iodlfloaUor, hee bee" mudu ,.rnd u draft wlll b• J'r•••ritad t'3 thn f1111 wnrklno group a8 a suo-oommmee recommendation. [note: lhts 111vJlnvt1llu11 16 k, th~ Jur,e t!O , 4006 draft Qropo11•~ by HoQw T■ylv, I 011lv u !':' 1,;111\'1/nlmlty ac.c.optanco crltorlQfl woo modlfl~d. T~e re1malnlng eight crlterl_a_V!_~!:.~ not chang~se.d1__ ___ . . _ I l • Nq wal ht :wa~ assigned to the community acceptance criterion . The sub-committee . dl,cus ed W$lghlng end consideration of this criterion as a mechanism for community veto. ihls tsaue nettds to be r~solved by the full warklno orour S. : Juni2e, 1 ~95. The technology sub~commlttee established four elements (qvestl ns) for consideration of addition~! technical assistance. 1) ability to provide C\ 1_ 1 : cotnm ts!revlew of BCD proposals from ETG-, iroundwaterfechnology, Soll fechnolo~y lb a~~ \NC.-f"~: Q) ttlll\y \y ........ lw■lw J, url vi.mdmlrnnhni:ilooy ~-mor1•: :JJ •ulllly/v'vlllli •~m•~tS lu Go ~ tr:, ex~rcls ths latltude·for offering other technology and vendors, based on their cU-0/f:., ue,;-1,Ur.. / profess onal experience, that might be applicable and appropriate for detoxification; 4) .~. lnf9rm~ Ion needed and approximate cost for providing technical services for the work W02A.J,A. group. i I The te+nology sub-committee directed the Division to contact Pat Costner and Joel Hirsohorn to d$termlne response to the above elements/questions. On JulJ 6, 1995, the Division contacted Pat Costner and Joel Hlrschorn. Both parties expres~ed Interest In providing technical assistance, the need for chemical and physical data on landfill, and copies of BCD proposals . Joel Hlrschorn's fees are $100 per hour an~ he ~s avallable for assistance. Pat Costner's fees are $45 to $50 per hour; however, she stated that her schedule Is full for this summer, and she may not be able to provi~e assistance. Ma. Costner Is to check her schedule and call the Division with a more di flnlte responae . . 7. Jund 28, 1995. The Division set up a conference call with the working group co-chal~s Ken Ferrlucclo and Dollie Burwell to dl9cuss meeting with Region IV USEPA on juri;flctlon IHuaa. The meeting had boon tontatlvoly proposed fo~ July 5, 1995. Th& co• hairs requested that the meeting be set for July 7, 1995. The Division oontoot d Realer, IV 81'\d tk& n,&6tl1·,~ 16 6ol fv, July ,-, 1!HI~. Tltt1 1_;u-d11:1lra directed thtJ DI1./islo to llmlt the ecope of the meeting to jurlsdlctlonal Issues and not Include rt ru11 nm O t 1111 1, • Bil~!! ! !! ! 4 wiul I I I ! t'i'H i'li"'i'J \ .. ..,1 II d ... i!, I' .1, l J LI .. l.. I. I II •• I -II ", I " . . -' ·, / j ril . -~ . ~ t/x_, Ll) -u/~v½ iSLJtl-W-~: t:: ~6-t~ ~L Mc,~ 1uodDi:.&-to ~ - I ! I I • \i i: I AA MODIFICATION OP HOPE TAYLOR'S CRITERIA OF 'UNE 20, 1995 I •. TECHNOLOGY SCRBBNINO: REMEDIATION OF '(HB WARREN COUNTY PCB LANDFILL DRAFtREPORT, July 51 1995 1) omm nhy acceptability is to be based on consideration of four fa'.ctors: 1· communJty percelv d r!sk 6.ffered by technology; 2 • Potential for ham, to human health; 3 -Actual or potentla envtr (llnental releases or emissions; 4 -Consideration of impatjt on property values. Thls cri rion I a measure of tho community's over all perception of technology, after having a present.a lo~ of escrlptions and evaluations of the technology as well as ask questions of technical advisors The ommunlty's assessment of acceptability wlll be prominent1y included with any distrlbu ion o this technology screening infonnation and will be ext~emely important in sele~tio of ctual pilot study and full remediation vendors. (Suggested ratings: 4 - outstan ing, ~·. satisfactory: 2 -marginally acceptable; 1 unacceptable) i ' 2) xtent J prior experience with this technology on soils at similar sites. (Rating based o the n thber· of sites with PCB or dioxin-contaminated soils which have completed . I • pilot or full-s ale projects with this techno1ogy: 4 -more than five sites; 3 three to five sites; 2~ one t two Sites; 1 -no sites using this technology.) 3) S ort t m sa{ety and effectiveness. Includes potential for wor~er and community exposu duet planhed and unplanned releases (excavation, gaseous emissions, solvents) during erati n. (Rating: 4 -in situ and well-contained process or ''closed loop" with essential y no • ance of releases; 3 -technology demonstrates very low release levels within t gt,tlat ry limits; 2 -some releases documented with technical improvements currentl avail ble; 1 -uncontrolled release possible.) ' • •• effectiveness. Reduction of toxicity or volume of tQxic contaminants. onsttated ability to detoxify contaminants to at least 99% removal level; 3 • dem nstra • ability to detoxify contaminants to at least 95% rei:noval level, or to reduce v lume of contaminated soils to less than 30 % of original volume as part of a "treatme t tral "., with greater than 95% removal from remaining fraction; 2 • ability to detoxify r ·co centrJte contaminants to 90 % level or to higher le~els under llmited conditio ; i . echnblogy generally not effective on contaminants and under conditions at the W rren dunty Landflll.) 5) 0 ne1rati rt of residuals and abllhy to handle on-site. (Rating: 4 -no residuals or completet trea ble oh-site; 3 -small volume of residuals, predominantly treatable on-site, 2 -mod ate v 1ume of residuals, mostly treatable on site at added e;xpense; 1 -large volume o lnco pletely detoxified residuals.) I I j 6f rojec~¢ duration of full-scale treatment. (Rating: 4 -less than six months: 3 $ix m<>nth to ;one· year;· 2 -one to two years; 1 -longer than two years.) 7); vailatjllity of pUot scale treatment. (Rating: 4 -available to start immediately; 3 avptlab e to s~rt within three months;,2 -available within six months; l • longer than si~ mqnths or:u~own.) 8) mplerilentab~lity of this technology at Warren County PCB Landfill. Number of vetido available, technical impediments, extent of Infrastructure requirements. (Rating: 4 .; mo e than three vendors available, no major technical problems anticipated, syste'.m largely self~CQntained; 3 -two to three vendors, technical problems are soluble w(th minim 1 e~peqse and time, few unique requirements for infrastructure support; 2 -o~e vendor ayailable, technical problems may delay or increase costs up to 25 % : signlflcart unique nfrastnicture support needed for this technology; l -no vendors available, major techruc 1 problems, infrastructure requirements too expensive or unobtainable at this slte.) 9) stimated cost per cubic yard of contaminated soil treated. (Rating: the projected co~t ra ge will be given and the mid-point of that range will be rated as 4 -less than $ l<)O cu~ic y rd; 3 ... $100 to $300 per cubic yard; 2 -$300-$500 per cubic yard; 1 -$300-$500 per cub c yard; l -greater than $500 per cubic yard.) I . o:raft 6/28/95 Recommendation from Sub-committee dtiterla for Vendor Selection for Warren County PCB Lanpfill Detoxification Program "· standard B.ase at~lyted Dechlorlnatlon cbmp iance History Standard Evaluation -Potential for unplanned releases an4 risk and remediation of unplanned releases -Risk from plarmed releases -Efficiency -rate of decontamination (time to complete project) -Effectiveness -the extent of decontamination -Residual generation and managemaht of residuals on-site, off-site • k Brief description of form of buBlneas to Include partnerships, corporation or • other -Names, addresses and titles of all officers, directors or partners of any parent or subsidiary corporation, . partnership or other form of business: -Names, addresses ·and title of any : projects or faollltles constructed or operated by the applicant . associate/with environmental control pr remediation Including parent or , subsidiary corporation, partnership ot other form of business • A list describing any notice of vlolatloh, warning or any other enforcement action taken against any person or facility Identified above. This Include~ any administrative ruling or order • Issued by any state, federal or local 1 authority relating to a violation of any state, federal or local law, regulation or ordinance related to waste management environmental protection Standard Sxpe enpe With proposed technology Safe ark practlcea/OSHA compliance Perso nel qualifications Finan lal Assurance Monlt ring Capablllty/Capaclty standard EvaluatlQD -N11mhar of projects Initiated. lmpl0montod, oomplotod with same e,r similar materials -Contacts/evaluations from federal/state/local oversight agencle& on these projects ' -Demonstrate safe work practices, e.~. confined space entry. noise control . -Site housekeeping/sanitation procedures -Health and safety plan enforcement : -On site communication security -Academic qualifications -Specific experience of Individuals assigned to projects with similar contaminants -Company safety training requirements -Includes all proposed sub-contractors -Financial statement on strength of organization . -Ability to provide performance bond,: letter of credit, trust fund, Insurance : -Past enforcement/utillzatlon • implementation of financial assurance mechanisms -Sampling/analysis arrangements -Ability to monitor releases from planned and unplanned events .. Soil, air, surface water/groundwater . capablllty (does state assume this role or duplicate vendors efforts) . -ExperlenC$ developing lmplementatlQn QA/QC plan staodards Publl Resp·onslveness Prevl us Co~t Exdeedances ' .. • Proje Cost Estimates standard Evatuatloo -History of working with community (proactive communication, handling · complalnta) -Presence of staff/oapablllty for public relation, -"Desire" commitment to public relations, before, during, after project -History of cost over. runs on previous, projects • -Basis for cost over runs • Cost per unit of material -Cost per unit of decomposition -Cost of management of reslduals -Site restoration coat estimates -Off site/on site and long term O & M •