NCD980602163_19951208_Warren County PCB Landfill_SERB C_Letter from Bill Meyer re R&D projects for the landfill-OCR

State of North Corolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
December 8, 1995
Anthony Trentini
Soiltech ATP Systems
800 Canonie Drive
Porter, IN 46304
Steve Lewis •
Aquaterra, Inc.
4901 Waters Edge Drive
Raleigh, NC 27606
Dear Tony and Steve:
The Division of Solid Waste Management (Division) is attempting to identify any issue that might
delay the review and implementation of the R&D projects for the Warren County PCB landfill.
The Division has identified some issues that may cause delays. Two of these are preparation of
feed soils and monitoring/analysis of the treatment process and residuals.
It's essential that specific volume and optimum moisture content of feed soils be submitted to the
Division. Since untreated soils cannot be returned to the PCB landfill, all excavated soils will
have to be treated. In order to ensure that only the volume/weight of soils needed are excavated,
the Division must know the exact amount of soils needed for the project. At present the Division
plans to make 10,000 pounds available to ETG/Aquaterra and S00 pounds to SoilTech. The
Division will issue a contract, through a Request for Proposals (RFP) process, to an
engineering/construction company for excavation, storage and delivering of feed soils to both
projects. Specific knowledge of the volume of feed soils is essential for the RFP. It is anticipated
that 18-24" bore holes will be utilized to excavate PCB contaminated soils from the landfill. Each
bore hole will have a limited volume for excavation primarily based on depth of bore. The
location and number of bore holes will be determined by the volume of soils. Ifno alternation of
the current estimated volume of soils is received by the Division, 10,000 pounds will be excavated
for ETG/Aquaterra and soo pounds for SoilTech. All excavated soils must be treated once
excavated.
The PCB soil moisture content is another factor of consideration. The landfill contains both dry
and saturated soils. Blending of wet and dry soils may suffice for providing representative
PCB/soil for treatment. However, depending upon the sensitivity of the process to moisture
content, additional drying such as gravity drainage, belt filter process, or heating may be required.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l O'l. post-consumer paper
Tony Trentini & Steve Lewis
December 8, 1995
Page Two
Again in order to draft an RFP the Division needs to know the optimum moisture content of feed
soils. It is the intent of the division to supply a representative volume at optimum moisture
content to both treatment processes. The Division needs this information in order to draft an RFP
as soon as possible to avoid delays in implementing the project, if approved by EP Alf SCA
SoilTech and ETG/Aquaterra should be aware that dioxins and furans, in addition to PCB's, are a
concern to the Division and the Working Group. Sampling and analysis plans must consider
dioxin and furan constituents input or feed soils; all intermediate condensates, liquids, solids; flue
or stack gases and treated residual soils. Both treatment processes will be required to use EPA
method 23 and impingement sampling devices for stack/flue emission testing. Analysis will be
required to be in accordance with method 8290 for tetra-octa dioxins and furans. It is assumed
that there will be a parallel decrease in dioxin/furan constituents relative to PCB destruction. If
this does not occur, it may be a major consideration for the full scale process. If there are any
questions or if this needs clarification, please notify the Division.
One purpose of the R&D project is to determine the applicability and feasibility of BCD for a full-
scale process. A part of the determination for a full-scale process is the volume and
characteristics of any materials that will require off-site management. Both vendors should be
aware that the R&D projects must provide a accurate analysis of the volume and characteristic of
all potential off-site residuals.
The Division will facilitate an air quality permit if it is required for the R&D project. Please notify
the Division if your experience with similar projects in North Carolina or other states have
required an air quality permit. The Division will submit information on the R&D project to the air
quality section in the Department for determination of the applicability of a N.C. air quality
permit.
The Division is enclosing comments and responses on the issues raised by EP Alf SCA for this
project. Please review our comments and respond to the Division. The Division is attempting to
provide a quick response to issues raised on this project. In order to ensure the most rapid
response, it would probably be more appropriate to initiate a process of conference calls to
vendors and EPA The Division thinks this is both better and quicker then trading paper back and
forth. If you agree please let me know. If I can be of any assistance or you need clarification
please notify me.
Sincerely,
~~~
William L. Meyer
WLM/cb
cc Craig Brown, EPA Region IV
Henry Lancaster
Enclosures