NCD980602163_19961217_Warren County PCB Landfill_SERB C_Joint Warren Co. - State PCB Landfill Working Group, 1996-OCR

N.C. ENVIRONMENTAL CAUCUS 1••
To: ENVIRONMENTAL CAUCUS
From: John Runkle
RE: NEXT MEETING IS TUESDAY, JANUARY 14, AT 2 P.M.
facilitated by John Runkle
P.O. Box 3793
Chapel Hill, N.C. 27S1S
9 I 9-942-0600 (o&f)
[e-mail]
December 17, 1 996
The next meeting of the Caucus is Tuesday, January 14, from 2 - 5 p.m., at the office of the
Wildlife Federation, 1024 Washington St., Raleigh. Call 919-833-1923 for directions. The
agende items for the 1 /14 meeting are the environmental agenda and Green Budget for 1997
session.
We are starting at 2 p.m. for a presentation by representatives of Wildlife Resources
Commission and Division of Water Quality on critical habitat and endangered species (where
are we, were do we need to be); contact Jane Preyer, EDF, 919-821-7793.
From the 12/12 meeting:
The Institute for Southern Studies has created Democracy South for education on campaign
reform and related issues. --The Alliance for Democracy has sent letters to Gov. Hunt and
Speaker Brubaker to remove Pearce (Gov. 's campaign advisor) and Shumaker (Brubaker and
Republican Party's PR consultant) from providing PR services for Farmers for Fairness, a hog
industry group. Pearce has removed himself. Contact Pete MacDowell, 919-967-1699.
NC Health and Environment Community Center by Environmental Resource Program (attached).
--The Z. Smith Reynolds Foundation has issued a request for proposals for "electronic
networking alliances" for direct on-site and on-call periodic technical support plus $5,000
grants for equipment, software and related staff costs. Deadline: February 15. Contact
Andrew Foster Connors, 919-932-4743 or [e-mail].
The Science Advisory Board in Warren County has found that State agency staff falsified
documents at the PCB landfill, did not install required leachate collection systems, and
routinely vents PCB to the air. More on this soon in a media outlet near you.
Dayne Brown is retiring from Radiation Protection Division; he has been an open and unbiased
regulator who would not let the licensing decision on the rad dump be a political one. --LLRW
Authority has enough funds until June; rad dump has cost $93.2 million already and may
require generators to fund the remaining at least $80 million required to finish licensing. --
Several groups are complaining to the Southeast Compact about its new "stakeholders" group
made up of utilities and regulators (i.e., no citizens). Contact Mary Mac Dowell, 919-542-
4878.
The NC Environment.al Caucus is sponsored by the NC Solar Energy Association and funded by the Beldon Fund.
Recommendations are being made for Steve Levitas's replacement. Contact Raine Lee, 919-
933-7575. ~ ·
VICTORY ON DURALEIGH --Governor Hunt finally made the decision to stop the road running
through Schenk Forest next to Umstead State Park. Now we need to make sure it is
eliminated from DOT's plans and budgets.
The Audubon Society is opening up the NC office of the national group; will focus on stream,
wetland and forest habitats. Contact Henry Hammond, 919-834-9573.
BREDL reported on the widening of Rt 16 through Glendale Springs; the BREMCO power line
over 3-Top Mountain in Ashe County, and the citizen campaign against the timber sale on Bluff
Mountain (Madison County). Contact Janet or Lou Zeller, 910-982-2691.
Erick Umstead reported on the victory before the Pesticide Board on groundwater report; for
regulators, "the truth is a slippery slope!"
Legislative issues --Bill Holman distributed the draft of the Sierra Club/CCNC agenda, to be
finalized in late January. Highlights (and lowlights) are Transit 2001, marine fisheries,
backlash on wetland rules and Neuse buffers, local zoning of hog operations, utility
restructuring, attack on groundwater through "risk analysis," our response to hurricane, return
of audit privilege, attack on third-party appeals, campaign finance reform, repeal of tax credit
for chip mills, repeal of Administrative Rule Review Commission, attack on watershed
protection act. Contact Bill at 919-755-1329 for a copy.
John Runkle presented early draft of green budget/green scissors. Several groups have
submitted recommendations on park staff funding, Transit 2001, saltwater fishing licenses,
p!ant protection and non-game species, and sustainable agriculture practices. Scissor items
are LLRW Authority, the hog slaughterhouse at NCSU, the beaver control program, DOT
boondoggles (Duraleigh Road will save $52 million),, the chip mill tax credit, Randleman Dam,
and the Administrative Rules Review Committee. A draft should be ready by next Caucus
meeting. KEEP THOSE SUGGESTIONS COMING IN.
NC RISK ANALYSIS FRAMEWORK ISSUES FORUM will be held January 22 at NIEHS in the
Research Triangle Park. The risk analysis framework is expected to be used in all soil and
water cleanups, including UST and brownfields. While attendance is by invitation only, John
Runkle was given 1 2 invitations for the environmental community. Please contact John if you
are interested in attending. For a copy of the Draft Framework or info about the Forum,
contact Sharron Rogers at 919-733-2178x222 or [e-mail]
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I '-'•/•~ " -/ .L. .,.: I .,._,.._, ,_, . ._,. J. 1
Air Quality Division
December I 0, 1996
J\!EMORANDUM
TO: I ,aura Burler, Assistant Chief. Permitting Section
$)
FROM: Tom Anderson;---&reteorologist, AQAB
THROUGH:~ Roller, Supervisor, AQAB
SUBJECT: Dispersion Modeling for \Varren County PCB Landfill
VVarrenton, NC ·warren County
Per your request, T have conduct,:::d a screening-level dispersion modeling analysis for emissions of
PCBs at the Warren County PCB Landfill. Potential emissions of PCBs occur from a single gas
vent located in the center of the landfill. r-/axirnum modeled impacts ,vere less than 0. 1 %1 of tlle
annual AAL specified in NCAC 20, l 100.
E:nissions of PCBs occur from a 4-i.ncb diameter PVC standpipe protruding through the cap of
the landfill which is used to vem biogcnic emissions from the facility. Emissions arc expected to
occur at or near ambient temperature with an assumed exit velocity of .0 l m/s (due to the
J,.,.,,.., ... J p,1,:1~tii11.i'!:, .mi,). Afi !ll!~iuuiu111. 11ruuo of IJ.l o f1 grumc/ooo. (obtain1ud from thi FP .'Ii
research study ]Xiper) was used in the analysis.
SCR EEN3 (96043) was used to evah.:ate simple terrain impacts from the vent. Since the land
around the landfill i:; generally of lower elevation and due to t.he lo\"' relec.:se height and ambient
namre of the emissionsJ complex terrain was not modeled, Receptors were placed at the closest
distance to the fence line ( 45 meters) and extended outward to approximately 3,000 meters. The
maximum impact of 7.4 e-7 mg/m3 occurred at the fence line and is well below the annual .A.AL
of8,3 e-5 n1g/m3.
MEMORANDUM
TO: Linda Rimer
Henry Lancaster
FROM: Bill Meyer
SUBJECT: PCB Landfill
December 9, 1996
During the weeks of November 11-15 & 18-22 and December 2-6, a reporter, Mark Benjamin,
with the Washington Publication Inside Superfund, has called Mike, Pat_: and myself concerning
the Warren County PCB Landfill. Mr. Benjamin, off the record--his choice, provided information
that Joel Hirschhorn is apparently disseminating all the information, reports, and correspondence
generated on the PCB Project to select national networks of sympathetic organizations. Mr.
Benjamin intends to include articles/reports on the PCB Project based on Hirschhorn's reports
and the State's response in future issues oflnside Superfund.
It is my perspective that national focus on the PCB Project has been initiated and will gain
momentum with Mr. Hirschhorn's active support. This effort is consistent with Mr. Hirschhorn's
performance and shift in strategy to confrontation and antagonistic relationships with the State
and EPA. It is my perspective that the shift in strategy is based on Mr. Hirschhorn' s knowledge
and experience that typical risk and cost beneficial remedy considerations would result in a safe
landfill (remove water, repair and monitor) rather than detoxification. It is also my opinion that
Mr. Hirschhorn is aware that detoxification will not be based on technical merit. Detoxification,
as currently proposed by the Working Group will cost $20 to $30 million. In order to obtain this
level of funding, political, social and moral considerations will be required, and must prevail. Mr.
Hirschhorn is very aware of this and very astute at persuing this strategy. I am also convinced
that this strategy will effectively eliminate Environmental Justice as a consideration for funding.
The network that Mr. Hirschhorn has in place is a grass roots environmental network and not
closely associated with E.J.
The Division needs guidance on how to proceed under the situation(s) that exist on the PCB
Project. This guidance needs to come from the most appropriate level of government in order for
short term and strategic policies to be developed and implemented in a timely manner.
MEMORANDUM
TO: Henry Lancaster
Linda Rimer
FROM: Bill Meyer
December 9, 1996
SUBJECT: PCB Landfill -Specific Suggestions for Department Budget and
Other Considerations
I. Provide Funding for An Independent State PCB Project Leader. (Personal Services
Contract@ $100 per hour)
(a) Develop recruiting process at Department level on a priority basis.
(b) Recruit project leader with impeccable credentials with respect to scientific,
academic, experience and credibility with environmental and technical constituents.
( c) Project Leader Suggestions: Dr. Daniel A. Okun -served as chairman of 1984
Intergovernmental Working Group on PCB Detoxification; Milton Heath -
Institute of Government; Jake Wicker -Retired Institute of Government; Steve
Smutko or Leon Danielson -NCSU Cooperative Extension Service/Natural
Resources Leadership Institute; Dr. Robert G. Lewis -US EPA -RTP -Air
Measurement Research Division -and member of 1984 Detoxification Work
Group; or other person with equivalent credentials.
(d) The function of the Project Leader would be to evaluate
comments/recommendations from all sources on the PCB Project and provide
recommendations to Secretary Howes.
( e) The Project Leader would be provided staff resources for information
needed to make recommendations.
If a Single Project Leader is not Appropriate then:
II. Provide Funding and Process (selecting and implementation) for a Panel of Experts to
Advise the Administration/Department on the PCB Detoxification Project.
The Panel should include: Dr. Jenny Webber-NCSU expert on fate and transport
of chemicals in soils; Dr. Dan Okun-water quality expert; Dr. Robert Lewis-air
expert on PCBs; Dr. Greg Richardson-engineering expert on landfill; and George
Bain, hydrologist.
III. Appoint a team of Department technical experts to review data and provide options,
comments and recommendations to the Independent State Project Leader or Panel of
Experts. The team should consist of a landfill expert (DWM), hydrologist (DWM),
toxicologist (DWM or Epidemiology), water quality (DWQ), air quality (DAQ) and
chemist (DWM or Environmental Science Lab). The appointments should be made by the
Secretary and define time, schedule, priority, mission/goals for the team.
IV. The Department should appoint and provide funding for a peer review team for the
information, data and recommendations proposed by staff and science advisors. (The peer
review team could be/should be the same members of the panel of experts if the panel is
not implemented).
V. The Department should consider the following budget items in priority order
for the PCB Landfill:
(I) $200,000 -Capital improvements for automated pumping, collection, treatment and
on-site irrigation of water in landfill
(2) $25,000 -Per year for 2 years for waste water treatment plant operator for removing
water from landfill
(3) $50,000 -Per year for 2-year budget for PCB, dioxin, Furan, VOCs, BNAE, and
metal analysis for all media sampling stations (air, water, sediment, soil, landfill
contents).
(4) $10,000 -Air monitoring equipment including collection and sampling devices.
(5) $10,000 -For analysis of PCB, dioxin, furan of air sampling/monitoring.
VI. The Department should evaluate the existing membership of the joint Warren
County/State PCB landfill working group and make modifications essential for
facilitating progress on detoxification recommendations. Modifications should include:
1. Decrease the number of members to 10 or 12.
2. Not reappoint members of the same family to the working group.
3. Recognize members that have facilitated the process by attending and
participating in a positive manner by reappointment.
VII. The Division Strongly Recommends Immediate Implementation of the following:
( 1) Remove, treat and irrigate water in the landfill in accordance with the
TSCA approval/permit. The water in the landfill is the most threatening
environmental factor with respect to releases. This should be implemented
regardless of any working group members who might oppose it.
(2) Immediately evaluate the surface cap/liner for gas
leakage (using existing equipment).
(3) Immediately install a weather station to include rainfall and pressure.
( 4) Immediately measure pressure and water level fluctuations
(using existing equipment) and continue to monitor on at least
a weekly basis.
Joint PCB Landfill Working Group
October 31, 1996 Press Conference Outline
I. Dollie Burwell, Co-chair Joint PCB Landfill Working Group: (approx. 2-3 minutes)
A. Introduction
B. Historical context
C. Governor Hunt's promise
D. Environmental Justice
E. Introduction of independent scientist, Dr. Joel Hirschhorn
II. Dr. Joel Hirschhorn, Independent Scientist, Joint PCB Landfill Working Group
(approx. 3 -5 minutes)
A. Declaration of Detoxification Technology Feasibility
B. Assessment of Clean-up Process/State's Criminal Non-Compliance
C. Introduction of colleague, Dr. Pat Barnes
Ill. Dr. Pat Barnes, Independent Scientist, Joint PCB Landfill Working Group
(Approx. 3 -5 minutes) \
A. Condition of landfill / rtovi-c~,,,-~
B. Cost of detoxification cleanup
C. Environmental justice for citizens of Warren County
IV. Deborah Ferruccio, Technical Committee Spokesperson, Joint PCB Landfill
Working Group (approx. 1 minute)
A. Conclusion
8. Appeal for support from North Carolinians for environmental justice for
Warren County
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v -1 y-9ic
Youth Representatives to Joint Warren County/State PCB Working Group
Mary Powell
Rt. 1, Box 653
Littleton, NC 27850
919-586-6860
Jaime Wallace
Rt. 2, Box 73A
Macon, NC 27551
919-257 -1195
Dinika Richardson (send to attention of Ms. Naomi Allen)
Warren County Middle School
Highway 158 Bypass
Warrenton, NC 27589
Angela King
463 Baltimore Rd.
PO Box 102
Warrenton, NC 27589
919-257-3438
New Address for Rev. Leon White
Rev. Leon White
8500-203 Olde Station Dr.
Raleigh, NC 27615
919-870-1223
919-417-4449 (mobile phone)
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5
STATEMENT OF DR. JOEL S. HIRSCHHORN,
SCIENCE ADVISOR, WARREN COUNTY PCB
LANDFILL WORKING GROUP
October 31, 1996
Raleigh, North Carolina
My decision to issue the Declaration of Detoxification Technology Availability was
deemed necessary because it had become clear to me that the state of North Carolina had been
delaying the efforts by the Working Group to complete the current project to assess, test, and
select detoxification technology. As a professional, once it became clear to me that detoxification
technology suitable for this site was commercially available I was ethically obligated to inform the
Working Group on this crucial issue. This was necessary because on October 20, 1982 Governor
Hunt had made a commitment to detoxifying the site and predicated future detoxification of the
landfill on appropriate and feasible technology becoming developed. Such technology has been
developed, demonstrated, proven, and fully commercialized. Now the issue is not whether
detoxification can be done, but whether the state is prepared to honor its original commitment to
citizens. There is evidence that the state has known for several years that such detoxification
technology has become available.
My decision was also supported by my recognition that the state had failed to meet its
extensive legal obligations imposed by the U.S. Environmental Protection Agency when the
state's decision to construct the landfill was initially made. The EPA approved the landfill and
provided federal funds for it on the basis of considerable technical requirements for construction,
operation, monitoring, and maintenance of the landfill by the state. These requirements were very
important, because the location of the landfill was far from ideal. But the state has not effectively
policed itself and the EPA has not provided effective oversight and enforcement of the landfill's
permit requirements. The result is a landfill that no longer can be assumed to be "safe and secure"
as Governor Hunt promised in 1982, but that has become increasingly unsafe. Now that
detoxification is available, the state should expeditiously remove the landfill hazard from the
Warren County community that opposed it in the first place as being unsafe.
There are, in fact, two commercially available detoxification technologies. One of these
was invented by EPA scientists and licensed to several companies, it is called base catalyzed
decomposition (BCD) technology. The other is called gas phase chemical reduction, and it has
been developed and commercialized by a company, Eco Logic.
Both of these technologies have been fully commercialized and used at full scale, including
PCB detoxification at several locations in the United States and elsewhere.
1
A technology screening and assessment by myself concluded that no other treatment
technologies can meet all of the requirements established by the Working Group.
Only companies offering the two selected technologies will be given an opportunity to
have their technologies bench scale tested at their facilities in coming months, using PCB wastes
extracted from the landfill. The testing will be required to follow a protocol approved by the
Working Group. The test data will be used to select one company to work with the Science
Advisors to the Working Group in developing a preliminary design for the full scale detoxification
of the landfill. This preliminary design will assure that accurate cleanup costs will be estimated for
consideration by the state legislature. It is anticipated that the total cost of the landfill
detoxification will be at the $25 million level or greater, depending on a number of technical
factors to be resolved in coming months. Considering the size of the landfill, this is not an
unusual cost for a permanent, safe remedy.
Neither of these two technologies were proven or available when Governor Hunt's
Intergovernmental Working Group on PCB Detoxification issued its report in December 1984
concluded that no detoxification technology was sufficiently proven to warrant use.
Summary of professional qualifications:
Earned a Ph.D. in engineering from Rensselaer Polytechnic Institute, Troy, New York (1965).
Full tenured professor of engineering at the Ufil\'.ersity of Wisconsin, Madison. (13 years)
Senior Associate, Congressional Office of Technology Assessment in charge of hazardous waste,
Superfund and other environmental issues. (12 years)
Testified at dozens of Senate and House hearings.
Author of technical books and hundreds of technical papers.
Nationally recognized expert in environmental technology.
Has served as a technical advisor to many community groups affected by federal Superfund sites
or state cleanup sites.
Has served as an environmental expert in many legal cases.
Has been a consultant to many leading companies (such as IBM, Texas Instruments, Warner
Lambert, and Polaroid), government agencies (such as U.S. Agency for International
Development, Department of Energy, and U.S. Information Agency) and international groups
(such as United Nations Environment Program and Organization for Economic Cooperation and
Development).
Contact:
Phone [phone] FAX [phone]
2
MEMORANDUM
TO: To PCB Working Group
FROM: Patrick Barnes, P. G., Science Advisor
DATE: October 23, 1996
SUBJECT: Amendment to the monitoring well installation RFP
I recommend that the Drilling RFP dated September 18, 1996 be amended as follows to include
the following language:
1. The diameter of the proposed wells will be 4 inches I. D.
2. The proposed wells will be constructed of type 316L stainless steel.
3. The depths used for bidding purposes shall be 45' for the shallow wells and 90' for
the deep wells.
4. If necessary the contractor will attempt to drill past potential shallow obstructions
a minimum of three times.
5. The supplemental sampling plan be included as a working plan for the RFP.
...
MEMORANDUM
TO: PCB Landfill Working Group
FROM: Patrick Barnes, P. G., Science Advisor
DATE: October 23, 1996
SUBJECT: Amendments to the Draft Sampling Plan Dated, October 2, 1996
It is my opinion that the referenced plan should be amended by the following list of items:
1. Include a table of contents identifying all components of the plan including
figures, tables, and appendices.
2. Include the jointly agreed to supplemental sampling and testing plan
developed by BF A as an appendix. This is needed to provide critical
support to the proposed new testing locations.
3. SECTION ENTITLED "FIELD SAMPLING OVERVIEW"
a. Include a description of the project background, as previously agreed to so that
the Plan will function as stand alone document.
b.
C.
d.
e.
f.
g.
h.
Identify who will be the site manager, safety officer, and the
individual disciplinary task leaders.
Last sentence of the oversight paragraph, change "a site safety ~--
briefing" to a daily site safety briefing. AB%..ra
Amend safety plan to include safety issues associated with drilling Dt.J .!)__/'? rJA ~
activities. l~JY~J
Change "History of the Site" section of the safety plan to reflect
recent analytical data.
Add definition as to what constitutes being "involved" as described in
the final sentence of the first page.
Include a site plan showing the conceptual layout of exclusion zones
and safe zones.
Define "crucial elements" as mentioned in the third paragraph of the
second page.
4. SECTION ENTITLED "ANALYTICAL REQUIREMENTS AND QUALITY
ASSURANCE"
a. Clarify apparent contradiction in paragraph entitled "Blank Samples." Paragraph
states that equipment rinseate blanks will be prepared to check decontamination
procedures then two sentences later the text states that equipment rinseate
blanks will not be needed.
b. Under Chain of Custody subsection, item number one, change shipment to
delivery.
c. Include a copy of the sample analysis request and receipt of samples form
indicated under item number two and three.
d: .J Critical portions of each of the standards referenced should be included as an
,~ ~~ appendix to this plan. /4,ve· At the end of this section add the following:
_·J ~t} /Y Reporting Procedure-Every laboratory asked in this effort will be instructed not
h
~:~ f"'.~f ji} to provide any data, preliminary or final, verbally or in writing t the State unless
~ r(jt' · the same information is provided simultaneously to both Science Advisors. ,j)i? 5. SECTION ENTITLED "LANDFILL CONTENT SAMPLES"
'
6.
a. Immediately after "Purpose" include a reference to the location of the samples.
b. Change the phrase "a soil sample needs to be taken" to "will be taken."
c. Under "Field Sampling Method" include an appendix reference to all necessary
equipment and procedures.
Under "Sampling Personnel Requirements" describe the proposed "air sampling."
Under "Field Equipment Required' include a table listing all necessary equipment.
Under "Quality Assurance" add a general description of the anticipated
laboratory QNQC. For example what quantity of matrix spikes and matrix spike
duplicates are anticipated.
SECTION ENTITLED "LANDFILL LEA CHA TE SAMPLES"
a. Include field sampling location immediately after "Purpose."
b. Third sentence under "Field Sampling Method." What is considered a sufficient
sample?
c. Under "Field Equipment Required," we may want to consider dedicated
samplef'S .
7. SECTION ENTITLED "GROUNDWATER SAMPLING PLAN"
A Include "Field sampling locations" immediately after "Purpose."
b. Add the word representative before samples in the first sentence of the
"Purpose" subsection.
c. Under second sentence of "Field Sampling Method," after "Purge the Well" add
"field test for equilibration using pH temperature and specific conductance.
Add more specific reference to EPA SOPs, i.e., what page number, what paragraph.
Also tie to an appendix of this document. The second to last paragraph of "Field
Sampling Methods" needs to include a decontamination procedure for submersible
pump.
Under "Field Equipment Required" State proposed procedure to ensure integrity of
samples.
8. SURFACE WATER AND SEDIMENT SAMPLES
a. Move subsection on field sampling location to just below "Purpose."
b. Under "Field Sampling Location" add the following:
the exact location of stream and sediment samples will be determined in
the field by the Science Advisors.
Add one additional sediment sample location to be collected at the confluence of
Richneck Creek and the Unnamed Tributary.
9. SECTION ENTITLED "SEDIMENTATION BASIN SUBSTRATE
SAMPLES"
a. Move "Field Sampling Locations" to directly after "Purpose."
10. SECTION ENTITLED "CARBON FILTRATION BED SAMPLES"
a. Move "Field Sampling Locations" to directly after "Purpose."
11 . ADD SECTION ENTITLED "TEST BORING SOIL SAMPLES" and
appropriate sampling and testing procedures.
FIGURES
a. Add a site location map.
b. Add a smaller scale approximately l" = 50' site map.
TABLES 1 and 2
a. Add test boring analysis for two horizons at each new location adjacent to
the landfill i.e., MWlA, MWS, and MW7 and each of the background
wells.
b. Add sediment sample at the confluence of Richneck and The .
Unnamed Tributary. -/..{)--:.~ <J1L ~LL--1&~-u~ f Wft~
October 21, 1996
To: Technical Committee and Bill Meyer
From: Joel Hirschhorn
Subject: Evaluation of four proposals on excavation
I am using the following criteria:
quality of technical plan
schedule
relevant experience
pnce
I have scored the four proposals on the basis of 25 points maximum for each criterion.
Triangle Environmental
quality of technical plan: high (20)
schedule: good (six weeks) (20)
relevant experience: poor (no explicit PCB experience, little well installation, no detailed
information given on subcontractor that could be requested) (10)
price: very good ($28,700) (25)
total pts. 7 5
CDM
quality of technical plan: very high (25)
schedule: poor (tluee months) (5)
relevant experience: very good (25)
price: poor ($83,400) (5)
total pts. 60
1
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Patterson
quality of technical plan: poor (some poor thinking, insufficient details) (5)
schedule: good (six to eight weeks) (15)
relevant experience: medium (no PCB experience) (15)
price: good ($47,000) (20)
total pts. 55
S&ME
quality of technical plan: medium (15)
schedule: poor (10 weeks) (10)
relevant experience: very good (25)
price: poor ($99,502) (5)
total pts, 55
Summary: Triangle and CDM have the best technical plans, but Triangle has a much lower cost
and faster schedule than CDM.
Recommendation: I feel comfortable with selecting Triangle
Note:
My teclmical recommendations are that:
1. ]be contractor be instructed to maximize the natural water content of the materials extracted
from the landfill so that the materials collected for technology testing are representative of the
landfill contents.
2. The contractor be instructed to evenly or proportionately distribute the extracted materials to
the four or five containers supplied by the state, so that each numbered container is representative
of all the materials extracted from the landfill.
3. The contractor be informed that, after filling of the containers, it will obtain a composite
sample from each filled container (represented top, middle, and bottom levels) per instructions by
the state for laborato1y testing paid for by the state (for PCBs and dioxins/furans).
2
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DRAFT
[Doris here is what I recommend sending]
LETTER TO ELLIOTT LAWS
Dear Mr. Laws:
The Working Group received a letter from John Cunningham, dated January 6, 1997, apparently
in response to our previous letter to you that requested your office to examine various policy
related issues concerning the Warren County PCB Landfill.
We are disappointed in the response from Mr. Cunningham, which takes the position that EPA
Region 4 will be addressing our concerns. When we originally wrote to you we also wrote to
John Hankinson, Region 4 Administrator, but expected Region 4 to address our request for a
comprehensive fregulatory complianceaudit, not to make the Superfund policy determinations we
asked you to examine.
The December 20, 1996 letter sent by Mr. Hankinson to the Working Group, in fact, does run
make a commitment to address the policy related issues we raised in our request to EPA
Headquarters .
We remain concerned that Region 4's activities will not thoroughly or expeditiously address our
Superfind policy related issues. These are not strictly speaking compliance issues for the state of
North Carolina in its conduct as owner and operator of the PCB Landfill. In our original Jetter to
you we raised several illustrative questions relating to the centra1 question of whether the PCB
Landfill is a Superfund site. These types of questions have much more to do with the activites
and decisions of EPA, than with the state of North Carolina. We tried to explain in our original
letter to you our understanding that legal documents semed to have imposed National
Contingency Plan requirements on the state for the PCB landfill and that together with the
CERCLNSuperfund funding provided for the construction of the landfill seemed to indicate that
the PCB Landfill had status equivalent to a Nationa1 Priorities List site as which a remedia1 action
have been taken.
This remains the core question the Working Group wants EPA to answer. We want to know
whether this community has a right to expect the full range of benefits offered by the
CERCLNSuperfund statute and program.
lfEPA Headquarters is ducking this request and handling it off to Region 4, then we want Region
4 to explicitly communicate its commitment to resolving our questions. Nor does this community,
already the victim of environmenta1 racism more th~ the benefactor of environmenta1 justice,
expect to wait for a long time for offical EPA responses to our reasona1be questions.
Thank you for your personal consideration.
For Superfund XVIl Conference, October 1996
CONTAINMENT REMEDIES:
MINIMIZING HAZARD, NOT JUST EXPOSURE,
CUTS LIABILITIES
Joel S. Hirschhorn, Ph.D.
Hirschhorn & Associates
Wheaton, Maryland
ABSTRACT
An important consequence of the trend · to reduce
Superfund cleanup costs has been a definite shift away from
treatment to pure containment remedies. The issue that
merits more attention, however, is whether reductions in short
term costs may be offset by longer term liabilities.
Containment remedies that focus entirely on reducing
exposures and hence risk are vulnerable to various failures of
key components that may not necessarily be prevented by
operation and maintenance programs. A sensible alternative
is to also include some hazard reduction, especially by in situ
technology. By doing so, longer term liabilities associated
with various failure modes of containment remedies can be
greatly reduced. Corporate accounting systems ignore such
liabilities. The insurance industry, large companies,
brownfield developers, and the government are currently
ignoring liabilities that inevitably will become all too real,
because pure containment remedies are not permanently
effective.
INTRODUCTION
Driven by cost reduction the pendulum of remedy
selection has swung very far to pure containment cleanups.
But short term economic gains may be offset by longer term
financial liabilities. A host of failure modes exist for
containment remedies, and these are not necessarily
prevented by ordinary operation and maintenance (O&M)
programs.
It was concern about these failure modes that caused
various changes in the CERCLA statute in l 986 that were
meant to cause greater use of treatment remedies leading to
permanent cleanups. For awhile treatment remedies became
prevalent But now there is a clear trend back to containment
only remedies. For example from FY 92 to FY94
containment only remedies at Superfund sites increased from
22% to 33% of source control Records of Decision, after
holding steady from FY88 for several years, following a
major decline from over 50% before the impact of the 1986
requirements for treatment remedies. ( 1) What the data do not
l
reveal is that early in the Superfund program many
containment only actions consisted entirely of off site disposal
in landfills. But that stopped when the issue of Superfund
wastes going to landfills that themselves became Superfund
sites surfaced. Now, containment only remedies are typically
onsite actions.
Technology has not erased the fundamental failure modes
for containment methods. From a risk management
perspective, it is necessary to understand the choice between
reducing hazard versus reducing exposure. Pure containment
remedies only address exposure. A better balance can often
be reached between near and longer term costs by examining
how reducing hazard in combination with reducing exposure
can be used.
Another aspect of the current condition is that long term
liabilities are really not accounted for. Although some cost is
allocated to future operation and maintenance activities, these
do not really address the high costs for addressing major
failures of containment remedies. Companies that have paid
for containment cleanups are not carrying on their books any
appropriate environmental liability costs caused by the
remaining high hazards at the site.
HAZARD VS. EXPOSURE
A simple and fundamental way to define risk to public
health for any cleanup site is to formulate it as:
Risk = Hazard x Exposure
Hazard refers, for example, to the toxicity and amounts of
chemicals, and exposure to how much of a site contaminant
enters people through ingestion, inhalation, or dermal
exposure over time.
To simplify the fundamental choice in remedy selection,
a pure containment remedy only reduces risk by reducing
current or future exposure to whatever poses a hazard. The
risk management capability of a containment remedy depends
•
on some type of physical barrier between the hazard and
possible ecological or human receptors. In contrast, pure
treatment remedies reduce risk by reducing hazard through
use of some treatment technology, possibly in combination
with extraction technology, that removes or transforms the
initial source of hazard. Of course, the way to optimize both
risk and cost reduction is to envision how some combination
of hazard and exposure reduction can be used in cleanups.
It must also be recognized that extracting or removing a
hazard from a site followed by some form of containment
(e.g., land disposal) is not equal to hazard reduction from a
systems perspective, because the hazard ( and risk and
liability) is merely transferred to another location.
RISKY RISK ASSUMPTIONS
The problem with pure containment remedies is that they
assume that a certain level of risk is achieved through
effective containment elements. A New Jersey study
recognized this issue and resolved it intelligently. It proposed
that state remediation criteria "require an order-of-magnitude
more stringent standard when exposure controls are
employed. This concept was incorporated in recognition of
the fact that these controls may deteriorate and permanent
remedies are most desirable. In addition, a maximum
residual contaminant level must be achieved when exposure
controls are employed. This is to ensure that in the event of
a total failure of all exposure controls a minimum level of
environmental and public health protection is maintained.
This 'safety-net' imposes a more stringent requirement than
current regulations." (2) In fact, the maximum risk resulting
from failure of the exposure control remedy was specified as
10-4 cancer risk or a hazard quotient of 3 for non-cancer
endpoints.
Moreover, the system envisioned would create
opportunities to remove all future liability. However, one
exception was that "TI1e severing of liability recommendation
does not apply to exposure control remediation alternatives."
Exposure controls were defined as "methods which prevent
contact between contaminants of concern and the human
population. Exposure controls include slurry walls, liners,
fences, ventilation, polymer or clay lined landfill, hydraulic
controls, and inimobilization processes which may result in
future contaminant releases. Deed restrictions apply."
This sophisticated approach is very different than the
current Superfund approach and state programs, where pure
containment remedies are justified on the basis of poor
science and poor risk management. Ignoring the intrinsic
shortcomings of containment remedies is penny wise and
pound foolish.
Land Use
2
Another dimension to this problem is that when
containment remedies are used there is likely to be some
assumption on future use of the land. Whether the
assumption is industrial use for brownfield development or
no residential use, the problem is that there are few legal
guarantees that any such land use restriction will always be
implemented faithfully. EPA and state agencies may not
closely monitor or even be able to legally prevent future land
uses that are inconsistent with the original containment
remedy. This too poses a future liability for the party
responsible for cleanup. Moreover, there are major
uncertainties for brownfield development involving
industrial activities that may directly cause failure of the
containment remedy. Over time, site activities could
physically harm containment components.
Covers and Caps
An important example is the use of covers and caps placed
on top of contaminated soil. For a containment remedy, it can
be assumed that there is no future human exposure because
of dermal contact, ingestion of contaminants, or inhalation of
contaminants. This is deemed equivalent to a treatment
remedy that would have removed and destroyed the
contaminants in the soil. Essentially, the key assumption with
the containment solution is that there is zero concentration
of site contaminants in surface soils after placement of the
cap or cover.
The longer term liability that cannot be eliminated,
however, is that over time various failure modes can make the
soil contaminants accessible to humans. There must be a
finite probability that such a major failure will occur. No
technological component of a containment system can operate
at 100% efficiency over all future times. Even the
assumption of a functioning operation and maintenance
program does not reduce the probability to zero. The reason
is that no such program is necessarily 100% effective for all
future times. A lack of funding as well as poor
implementation may occur. Or there may be some
catastrophic failure mode that even a good O&M program
will not prevent. O&M programs systematically
underestimate or ignore major repair, reconstruction, and
replacement needs, and financial accounting systems ignore
such costs.
The drive to reduce costs has resulted in decisions that
have changed the types of covers and caps used as key
containment elements. Whether the cover or cap is necessary
to prevent human exposure to contaminants, or whether it is
meant to prevent water infiltration and contamination of
groundwater, there are many negative scenarios for the
future. Instead of RCRA Subtitle C hazardous waste caps,
increasing numbers of remedies are based on plain soil
covers, soil and a flexible membrane liner (FML), or caps
where several feet of compacted clay are replaced by
geosynthetic clay liners (GCLs). Engineers have a tendency
to compare GCLs with compacted clay layers and focus only
on advantages of GCLs. They ignore various problems with
GCLs, including poor field construction and assembly and
various failure modes over time. Simple soil covers have
obvious limitations and provide no reliable long term
protection. The inclusion of an FML adds a degree of
protection, but there are a multitude of recognized failure
modes.
Subsurface Walls
Many pure containment remedies include subsurface
barrier walls to keep contaminated groundwater in and/or
clean groundwater out. No physical wall, however, can be
1000/o efficient as a water barrier over all future times. While
more technology has entered the field to allow walls to be
constructed in diverse geological conditions, a cost-cutting
tactic is to use partial walls. The concept here is that site
investigation information is deemed sufficient to design a wall
for a certain, limited length on the basis of known
groundwater flow.
For example, at the Agrico Chemical Superfund site in
Pensacola, Florida, the original Record of Decision prescribed
a full barrier wall around the site, as part of the remedy.• But
during remedial design it was changed to a relatively small
partial wall. EPA ignored concerns about the shallow water
table and climatic conditions leading to frequent heavy
rainfalls and flooding.
Natural Clay Layers and DNAPLs
Many containment remedies are based on a natural clay
layer in the subsurface acting like an engineered bottom liner
system in a landfill. The problem is that natural clay layers
are not 100% efficient in stopping the movement of
contaminated groundwater downwards to deeper aquifers,
unless there is a consistent upward hydraulic gradient across
the clay layer. But for DNAPLs, even an upward gradient is
not necessarily effective in stopping the downward movement
of DNAPLs through the clay layer and into deeper aquifers.
(3) Increasingly, attempts to extract DNAPLs are rejected,
largely because of limits to pump and treat methods, making
the issue of eventual DNAPL movement more important.
l11e problem is that natural clay layers have pores that can
be large enough to permit DNAPL penetration and
movement, depending on the chemical composition and
amount of DNAPL. DNAPL penetration is a microscopic,
statistical phenomenon that is nearly impossible to document
directly. Too many environmental engineers make
assumptions that are not valid. For example, using average
pore size rather than examining how the largest pores provide
transport pathways, and using average DNAPL heights rather
3
than larger values at specific locations.
Another aspect of natural clays is that engineers often
evaluate the permeability in order to demonstrate that natural
clays can offer sufficient containment of untreated wastes.
The problem is that virtually any type of laboratory testing of
clay permeability produces values that are much too low. The
problem is that either the clay is recompacted to form test
specimens or cored, undisturbed samples are tested so that
vertical permeability is determined. The issue is that in their
natural state clay layers are likely to have a layered structure,
including high permeability layers, such as sand lenses.
Laboratory testing done on undisturbed samples measures
vertical rather than three dimensional or horizontal
permeabilities, and testing of recompacted samples produces
still lower values because all natural high permeability
pathways are removed The difference between permeability
values measure in situ and such laboratory values can be
several orders of magnitude. Laboratory data inevitably
predict a level of containment capability that is inaccurate and
misleading, especially if recompacted samples are used. In
some cases the exact containment function for a site may be
consistent with low vertical permeability obtained from cored
samples. But even here the problem is that a relatively large
number of samples are needed to accurately portray the
macroscopic variations in permeability in natural clay
formations.
Groundwater Monitoring
All forms of environmental monitoring are exposure
detection, not directly exposure reduction. Proponents of
pure containment remedies, for which spread of contaminated
groundwater is an issue, place considerable trust in long term
groundwater monitoring to detect failures of the containment
remedy, including failures of caps/covers, bottom liners and
leachate collection systems, pump and treat systems, natural
clay layers, and subsurface barrier walls. It is important to
note that even the most engineered hazardous waste landfills,
meeting stringent regulatory requirements "utilize a flawed
technological approach for the development of a landfill
containment system that at best only postpones when
groundwater pollution occurs."(4) Few pure containment
remedies use technology comparable to such engineered
hazardous waste landfills.
There are many significant problems with long term
groundwater monitoring systems. These include: too few
monitoring wells to be effective; deterioration of wells over
long times; use of chemical testing methods with detection
limits that are too high to detect the first indications of
contamination; failures of long term O&M programs to
function as originally designed.
TECHNOLOGY FOR HAZARD REDUCTION
The alternative to pure containment remedies are ones
that include a sensible, cost-effective degree of hazard
reduction through judicial use of in situ extraction or
treatment technology. The point is that addressing a relatively
small portion of a cleanup site can greatly reduce hazard and
future liability. The philosophy of this approach is to
recognize that what makes a containment remedy a liability
are contaminants that, in the event of containment failure, are
the most likely to cause environmental damage or human
· ·· health rt~ks. Hence, it is contaminant mobility and toxicity
tliat matter most.
. It is not necessary to attempt to address all site
contaminants of concern, as in a traditional treatment remedy,
but only to reduce a large fraction of the intrinsic site hazard
through cost-efficient use of in situ technology. With
virtually all in situ technologies the greatest cost efficiency is
in the early stages of implementation, when the amount of
contaminants extracted or treated per unit time is the greatest.
In traditional source control treatment remedies technologies
are pushed to extremes to satisfy stringent cleanup standards,
and 80% of costs may be for addressing the last 20% of
contaminants. Hazard reduction looks at the converse, trying
to address 80% of the contaminants at 20% of the cost. The
goal is to increase the cost of the containment remedy
proportional to the amount of reduction in long term liabilities
accomplished by the hazard reduction.
Consider a simple representation of total remedy costs
under two conditions:
Containment only: total cost = CS + Pf(F)
Containment plus hazard reduction:
total cost= CS+ HR+ Pf(FJ
CS = cost of containment remedy
Pf = probability of major containment failure
F = cost of major failure, containment only
Fh = cost of major failure, with hazard reduction
HR = cost of hazard reduction
While CS and Pf may be assumed equal, Fh will be much less
than F. The goal is to have HR+ Pf(FJ be much less than
Pf(F), so that total remedy cost is reduced through hazard
reduction.
For example, consider a pure containment remedy based
on a cap to address health risks related to contact with or
ingestion or inhalation of site contaminants, chiefly VOCs,
with a total cost of $5 million. Limited use of SVE in a
portion of the site, to extract some 50% of the site's VOCs,
adds $1.5 million. The question is whether this incremental
4
cost increase makes sense in terms of the reduction in long
term liabilities. Clearly, if the site was located in a remote
area, it would not be sensible. But for a site in a populated
urban or suburban area likely to undergo increasing economic
development, it would make sense, because any future
releases of VOCs could cause serious consequences,
including public health risks, civil suits and emergency
responses, that would cause a high cost of containment
failure.
Repair of the containment system, possible use of
excavation, and potential civil litigation costs could easily
exceed $10 to $50 million. It was exactly this logic and
scenario that motivated a citizen group to want intentional
VOC extraction at the Brio Refining Superfund site in
Houston. Large amounts of buried VOCs were in discrete
pits and the containment remedy was based on a cap and full
subsurface wall.
One approach is to define hot spots of contamination for
which a traditional ex situ treatment remedy would be used.
Although there has been some attention to defining hot spots,
such as in EPA's guidance for municipal solid waste landfills
(5), for the most part hot spots are underutilized. Part of the
problem is that it can be difficult to use site investigation data
to accurately define hot spots. In many cases, the site may be
much too large or complex to even imagine seeking hot spots.
More attention can be given to using site investigation
methods that are effective in defining subsurface
contamination levels, such as soil gas testing for VOCs.
When subsurface sampling is necessary, defining hot spot
boundaries is difficult, but not impossible.
If hot spots can be reasonably defined, then either in situ
technology, such as soil vapor extraction (SVE) or in situ
stabilization/solidification, or excavation followed by off site
treatment should be examined. At the Bailey Superfund site
in Texas, a remedy based on complete soil/buried waste
treatment plus some containment was replaced with a
containment remedy that addressed some hot spots.
Another approach is to examine how in situ technologies
can be used as a component to a containment remedy for the
entire site. The key concept to use is that a technology does
not necessarily have to be used to achieve stringent cleanup
levels determined on the basis of risk assessment. Instead, it
can be practical to examine how the in situ technology can
achieve a major reduction in hazard with less extensive
application. For example, SVE can be used to extract a major
amount of VOCs and then stopped, once removal rates drop
substantially ( even after pulsing), rather than used for long
times to achieve some concentration of specified VOCs in the
subsurface soil. In other words, the in situ technology can be
used not as a source control method, but as a component of a
containment remedy. Air sparging can also be applied in this
manner.
Some engineers hope for hazard reduction through natural
degradation processes. But rarely is there data to support a
predictable, reliable amount of toxicity loss over periods
likely for containment failure.
CONCLUSIONS
Overreaction seems to be a historic hallmark of
environmental activities. The reaction in the late 1980s and
early 1990s to high cleanup costs has been excessive use of
pure containment remedies. Pure containment remedies are
replacing treatment remedies selected previously, as well as
being selected in new cleanup decisions. Such remedies are
not "permanent'' in any sense, because they leave the original
hazards associated with hazardous substances intact at the
site. By not reducing hazards, pure containment remedies
pose long term risks and liabilities.
Long term containment liabilities are currently being
ignored from a financial perspective. A more effective
strategy is to balance the low costs of containment methods
with some hazard reduction. The incremental cost of hazard
reduction needs to be balanced against the high, uncertain
costs of containment failure and consequent liabilities for
additional remediation and possible civil litigation. Ordinary
O&M programs do not remove these longer term risks and
liabilities of pure containment remedies.
Environmental firms conducting Feasibility Studies and
Remedial Designs should give more attention to use of
hazard reduction components of containment remedies, and
where appropriate sound value engineering type analysis to
support higher short term costs because of long term benefits.
Even with using reasonable uncertainties for future costs, it
is possible to estimate costs and benefits to establish the
boundaries of sensible hazard reduction measures as part of
containment remedies.
REFERENCES
(I) EPA, Innovative Treatment Technologies: Annual
Status Report, EPA-542-R-95-008, 1995.
(2) Draft Report of the Environmental Risk Assessment
and Risk Management Study Commission, New Jersey, Nov.
1995.
(3) Hirschhorn, J. S. Do Natural Clay Layers Really Stop
DNAPL Penetration?, Proceedings Superfund/HazWaste
West, May 1996, pp.59-67.
(4) Lee, G. F. and Jones, A, Superfund Site Remediation
by On-Site RCRA Landfills: Inadequacies in Providing
5
Groundwater Quality Protection, Proceedings
Superfund/HazWaste West, May 1996, pp.313-329.
(5) EPA, Conducting Remedial Investigations/Feasibility
Studies for CERCLA Municipal Landfill Sites, EP A/540/P-
91/001, 1991.
r "UI I • L.C:1 '1 L.d. V H"LIC"H
ECO LOGIC
Media Relea!e, ELI Eco Logic Inc.
Toronto, Ontario
TSE Trading S}mbol for Common Share~: ELI
CDN T1adinr: S)n1bol foI Wanants; ELll.WT.A
rnurn::: ,~u. • c:t:J.l004t:J..J~o
TOXIC CHEMICAL
5PECIAUST5
For lmmediatt Rtltast
September 2, 1996
ECO LOGIC AND WESTINGHOUSE TEAM FOR POTENTIAL BULK-SITE CHEMICAL
WARFARE AGENT DESTRUCTION
ELI Eco Logic Inc. ("ECO LOGIC") nnd We$tinghouse Electric Corporation, Government and Environmental Services of
PitUburgh, Pennsylvania have announced that they have signed n teaming agreement under which Westinghouse will act as prime
contractor, with ECO LOGIC as subcontractor. upon the ECO LOGIC technology being selected for an 11ward ofcontraet in the
U.S. Army"s Alternative Technology Program for Chemical Wnrfnre Agent Destruction. ECO LOGIC and Westinghouse have
developed an approach which offeis a sound alternative for application at the bulk chcmieat warfare agent focilitics at Newport,
Indiana and Abetdeen. Maryland.
The ECO LOGIC Proccu was initially selected in November 1995 by the U.S. Army for further evaluation of its efficacy for the
ootruction of chemical Wilrf~ agents. The Company decided to tcnm with the best U.S. corporation to strengthen the breadth and
depth of its capability. Dr. Douglas Hallett, Chief Executive Officer of ECO LOGIC said, "ECO LOGIC and Westirtghouse
believe that this integrated pl.ant concept will provide a viable altei,,ative method ofmteting the Army's gonls."
The US Army has been seeking alternative technologies manue enough to meet the needs of the Chemical Stockpile Disposal Program
for the safe disposal of HD and VX. nerve agent stored at Abc-decn Proving GroWld, Maryland, and Newport Army Ammunition Plant.
lndi.uia. Based on the technological merits of the ECO LOGIC Pr0te~,. it was one of only three private sector technologies selected
for furthcr evaluation by the U.S. National Research Council's Alternative Technology Panel.
ECO LOGIC has rclcascu full independent test data to the U.S. Ann~ and the National Research Cotmcil confirming destrucrion of
the Army's VX nerve agent, HD blister mmwd and hydrolysed VX nervt: agmt. ECO LOGIC conducted its tests at the U.S. Anny's
to:-<lc test facility in Abenlttn. Maryland. Not only were the desttuction results excellent, but no harmful by-products "M:re produced
and the process water met applicable drinking w:1tcr st:mdards.
ELI Eco Logic Inc. 's business is to solve ~xic chemical problem$ in a safe. ~anent, cost effective manner. The ECO LOGIC
Pro<:tsJ it an imcrvative technology that converts on-site, organic hazardous WHtes into reusable or di!>posnble products. this non•
incineration proctSS has gained high public and regulatory acceptance. ECO LOGIC's worldwide hv..atdous wnste cleanup marker
includes PCBs, elecnical equipment. contnminntcd soils, eh~cal warfare agents, penochemical wastes, cert;iin low level radioactive
mi'\ed wastes, and mwucipal sludge.
-30-
Please contact:
Maggie Treanor
Assistant to the President/ lnvestor Relations
ELI Eco Logic Inc.
143 Dennis Street
Rockwood, Ontnrio · NOB 2KO
Telephooe: (; 19) 8;6-959 l
Facsimile: (519) 8S6-923S
Web Site: http://www.eco.togie-inll.com
Email: [e-mail]
143 Dennis SI., Rockwood, Ontario, Canada. NOB 2KO
Rockwood (5191 856-959 l
Fax [phone]
FROM LEN La VARDERA A-0--E NO. 2016640328 Oct. 10 1996 02:07PM P2
TOXIC CHEMICAL
Sf>ECIAL/5TS
ECO LOGIC ---------1(:«)
l'ress Release, ELI Ec:o Logic Inc.
Toronto, Ontario
TSE Trading Symbol for Common Shares: ELI
CON Trading Symbol for Warrants: ELII. WT .A
For Immediate Release
September 24 , 1996
PILOT SUPERFUND REMEDIATION CONTRACT AW ARDKD TO ECO LOGIC AND SAIC
ELI Eco Logic Inc. ('ECO LOGIC") announced today thal it ho, been awarded • contract for pilot-9calc t"c$ting of the ECO
LOGIC Process at the New Bedford Harbor Superfund Site in Massachusetts. A pilot-tteale unit will be taken to New Bedford in
early November for seven days of on-cite testinc. The contract. valued 11 USS 235,580, has been iuucd by Foster Wheelei
Environmental, Inc., the U.S. Environmental Protection Agency's Supcrfund cleanup conuuctor in EPA Region 1, to ECO LOGIC
and its U.S. strategic nwkcling partner, Science Applications International Corporation (''SAIC").
Art Shattuck. Vice President of SAIC, indicated, "Based on successful pilot-scale testing RSults at the New Bedford Harbor Superfimd
Site, ECO LOGIC will be a leading candidate for the cleanup of the reported 14,000 cubic yards of PCB contaminated sediment"
Dr. Douglas J. Hallett. ECO L0GIC's CEO, noted, ''llus represents ECO LOGIC's fust entry into the U.S. Superfuud nwket
lhe ECO LOGIC Process is already commerciillly available for the mnediation of~ New Bedford Harbor Supemmd site." The
New Bedfurd Hanxr Supcrfund Site pollutants, namely, PCB,, PAH1, and metalc, are the same pollutants which the ECO LOGIC
_ l'rocas bas prcviomly trcutcd und destr~ n,e ECO LOGIC rrocess. a non-incineration process, has been previomdy valida1ed
and permitted in the United States, Canada, and Austrolia. Significantly, it wu imduated for Superfund Site cleanup by the U.S.
Environmmtal P~on Agency under its Supcrfund Innovative Technology EYaluation Program. It is now commcrcialiied with
two units constructed and operating for industrial clients in Australia and Canada.
El.J Eco Logic Inc.·• business is to solve toxic chemical problems in a safe, pennanent, cost effective manner. The ECO LOGIC
Process i9 an innovative lechnology that converts on-site, organic h.uardow Wll!te9 into reusable or disposable products. Thi! non-
inc:inc:ration process 1w gnincd high public and regulatory ac«ptan~. ECO LOGIC', worldwide hazardou!I waste clcunup mark.cl
includes PCBs, clcctriatl equipment, ronl3Jrun.ll!od soils, chemical warfare agents, pcbochemical wastes, certain low level radioactive
mixed wuks, and municipal sludge.
-30-
Please coniatt;
Maggie Treanor
Assist.mt to the President/ Investor Relations
ELI Eco Logic Inc.
143 Dennis Stred
Rockwood, Ontario NOB 2K0
Telephone; [phone]
Focsimilc: [phone]
Web Site: hnp://www.eco-Jogic-intl.com
Email: halh:[e-mail]
143 Dennis SI., Rockwood, Ontario, Canada, NOB 2KO
Rockwood (5191856-9591
Fax [phone]
1 -:--:2?-1 996 8 :•43 PM FROH
August 29, 1996
To : Technical Committee
From: Joel Hirschhorn
Subject: Recommendations on decision making process and several actions
en Process
A) My advice is that the TC an.d WG use a more formal means of collllll.unicating requests
to the state. There is a need to prepare carefully Mitten memos or letters from the WG to either
Bill Meyer or a higher state official. Verbal requests or motions at meetwgs, such. as what
happened this week on the issue .I raised about EPA permits for removing materials from the
landfill, are inadequate, unless they are followed up immediately by a written document that
precisely spells out the details of the request. Details and creating a documented record of
requests and responses are very important in these .matters.
B) My advice is that the TC adopt a standard procedure for making decisions about
actions recoromeuded by the Science Advisors. I am referring to action memos, not :informational
memos, nor submission of work products. My recotnDlended process is:
1. The SA faxes an action memo for the TC to the WG office for immediate distribution
by fax to TC members and the other SA.
2. The office arranges for a phone conference eall within 24-48 hour.s for the TC to
discuss and make decisions on recommended actions.
3. During that call with the SAs, the TC asks questions and discusses action
recommendations and either makes decision(s) on action item(s), allowmg followup activities by
SA(s), or some other decision is made. Secretary maintains minutes of such calls.
4. Within 24-48 hours:
a) As appropriate, the SA(s) faxes a work product to office for distribution to TC
(unless instructed to take soine other action directly, such as sending a memo or m.a.king a call to
some party on behalf of the TC or WG) to facilitate the TC or WO implementing the decision .
OR
b) The TC or WG takes final action. Secretary keeps record of exactly what is
done.
l
P. 1
J -28-1996 8 :44PM FROM
Ul Federal stratw
My advice is that the TC consider and the WG adopt the following strategy to initiate
steps to build a case for federal intervention and actions that support the goal of detoxification of
the lmdfi.U. My analysis of the history of this situation leads me to conclude that the en.tire
strategy of the community has been to depend on eventually obtaining the desired decisions a:od
funding from the state. lbis strategy has several disadvantages, not the least of which are: a
fundame.ntal conflict of interest the state has between being the owner and operator of the landfill
as wen as the .Protector of public health, and all of the difficulties in building a tecbnicaL
environmental, and economic case sufficient to obtain substantial state funding . My
recommendation is that it is in the community's interest to develop a parallel strategy that is based
on the plausibility of forcing federal interest, answers to requests, and various interventions or
official positions that provide either pressure on the state to take ce.rta.in actions, or supply
important support for what the WG tecolllllleo.ds to the state.
There are three immediate action recommendations:
a) The WG should submit a written request to the state for a compliance audit and
summary report giveu to the WG within 30 days. The WG would ask ve1y specific, carefully
c,afted questions, based largely on various federal requirements that the state was required to
satisfy.
b) The WG would submit a written request to the EPA Region 4 Administrator to conduct
an official EPA compliance investigation under TSCA for the landfiJl, based on EPA examination
of its records, state reco.rds, and a ucility inspection, if necessary. The need for very expedient
implementation would be made. Specific concerns would be identified.
c) The WG would submit a Mitten request to Assistant Administrator Elliott Laws at
EPA Headquartets for his office to examine specific policy issues under CERCLA/National
Contingency Plan by asking key questions affecting potential cleanup of the landfill. The Jetter
would cite the details of the agreement between the EPA and the state, in the form of a
cooperative agreement that was funded under CERCLA/Superfund. Specific policy
determinations would be requested on specjfic issues, such as whether the current form of the
NCP applies to the landfill, and whether the statutory requirement for review of the remedy every
five years applies.
£3) Stratm for RFP for ql,taining a tech.ooJogy vendor
The issue is .how to most efficiently follow state requirements for obtaining detoxification
technology companies for conducting bench-scale tests and for one selected company to assist the
SAs and WG in preparing a conceptual design of the desired ,:er:n.edy for inclusion in the p1<Jposal
to the state legislatwe. My idea is to use one RFP to cover both activities to save considerable
2
1 -2.8-1 996 8 : 44PM FROM
time. My recommendation is that the WG consider my proposal and fonnally submit it to the
state and seek a decision on whether it can be implemented in its present form or how it can be
modified to meet state legal requirements.
The key components of the proposal are:
--The RFP would be described as the solicitation of a contractor that after completing a
successfu.1 bench or pilot scale test of detoxification technology will provide professional seivices
in developing a oonceptual engineering design of the fullreroedial action at the landfill, mcluding
an onsite demo.nstration test prior to full ~ale use of the selected detoxification technology.
--The RFP would define the following step& for interested parties;
a) Based on information given in the RFP (including site background, aud scope of work
for test) 1 to 3 vendors will be selected on the basis ofRubmiUed proposals to conduct a bench or
pilot scale test at their own facility on lan.dfill materials provided to them
b) After the selected companies submit the required repo.rts on test results ao.d provide any
additional infonnation required, one company shall be selected to provide the conceptual des.ign
services, based on both. th.e test results, other information provided, and the bids in the company's
proposal
--The RFP would ask for proposals that must contain c.crtain types of information,
including bids for the initial testing and, if selected, for the design services, based on scopes of
work for rhe two phases given in the RFP. Technology companies would be urged i11 the Rf'P to
select a subcontractor ( such as an environmental design and engineering firm) that has the
capabilities to contribute to the conceptual design of the total remedial action based on but not
liruited to the detoxification technology.
--The state would enter into an. initial contract with the companies selected for the bench
or pilot tests. This contract would contain a provision stipulating that the company is being pre-
qua)ified or short-listed by virtue ofbemg selected to conduct the test for final selection as the
provider of the design services and that no other RFP wm be issued by the state. Subsequently,
after one company is selected, the state would enter into the final contract for !he pro,·ision of the
design sel'\,ices.
1.1) Detoxificatiop cleanup goals
In order to obtain useful bench scale tests1 it '\\'ill be necessary to infom1 potential vendors
in the RFP what the numerical goals of the detoxification are for key contaminants. In other
words, we Dlll&t specify what level of PCBs and dioxins are acceptable in residual treated
materials that would, presumably, be backfilled into the excavated landfill. These levels would be
3
P.3
1-28-1996 8 :45PM FROM
the preliminary cJeanup goals (PCGs) or perfonnance reqwrements for waste treatment. They
would be given as preliminary ones, mainly because they might be changed after all the test resuJts
are obtained ( either mcreased or decreased).
The technical problem is deciding on what basis to use for the PCGs. There l'lle two
principal approaches. A regulatory cleanup level may already exist that eithe.r mu&t be used or
may be used. For examp.le, certain file documents indicate that EPA would require treatment to
achieve a level less than 2 ppm for PCBs, but the state may typically require less than 1 ppm
(parts pe.r million). Whenevef a state has a more stringent requirement than EP~ the state one
prevails.
The second approach is to use health risk based cleanup standards. Some risk based
concentrations already exist in the fonn of EPA generic Superfund Soil Screening Levels. These.
however, are based on certain specific exposure and risk assumptions that may not be completely
applicable at specific sites. When they are not, only a site specific risk assessment can generate
other numbers. There a.re many tough issues for such risk assessments.
Consider PCBs, EPA data reveal a 10·6 cancer risk level for residential soil ingestion
exposure of 70 ppb (parts per billion). However, EPA uses .• value of 1 ppm (1,000 ppb) as an
SSL and under its PCB cleanup guidance. This means that .i ppm equals a risk of I . 4 x lo-~ ( a
tenfold higher risk).
But if dioxins are also present, they must be considered. If dioxins only are co.ns.idered,
then the 10·6 cancer risk level is 2 ppt (parts per trillion) for cumulative ingestion, inhalation, and
dermal ex'})osure to surface soil or 4 ppt if only ingestion is considered. EPA often attempts to
use a very high .level of I ppb for soil cleanup decisions, which is blatantly unacceptable. [I do not
now have a risk based con.centration for PCBs based on three exposure pathways, which would
be less than 70 ppb, possibly around 40 ppb.]
If both PCBs and dioxins are present, however, then cumulative risk must be considered,
meaning that levels BELOW the 1 o·6 levels obtained for them indMdually would couclaH! with
10·6 cumulative risk.
The problem is whether detoxification technologies can achieve very lo•1/ residual
contaminant levels corresponding to 10·11 risk levels. Therefore, while PCGs can be set very
stringently, actual test data may show that no feasible detoxification technology can. meet them
reliably and consistently ( especially with varying waste inputs, in terms of contaminant and water
levels, for example). In other words, tbe technical feasibility of detoxification techn.ology for thjs
application ·will depend on exactly what cleanup perfonnance requireroeuts are demanded. The
more protective the WG wants to be, the greater the probability that no feasible technology can be
shown to exist. One of the more subtle issues that must be considered is whether typica.l exposure
pathways are relevant for the site after poSt-treatment residuals are backfilled into the la.ndfill. 111
other words, if treated residues are buried in. the ground and cove,-ed with clean soil, th.en there
4
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1-28-1996 8 :4.SPM FROM
may be no plausible exposure pathways ( as long as the containment 1eroains effective), because
people will not ingest the material, or inhale airborne particles, or have ditcct dermal contact v.i.th
the material. There might be some concern about leaching of the contaminants over time into
growidwater, but because both PCBs and dioxins have low water solubility and high soil
adsorption, such leaching an.d migration will normally result in much higher acceptable levels than
those obtained on the basis of cancer risk.
EPA often uses this reasoning to justify higher acceptable cleanup levels. In the extreme,
it justifies NO treatment because hazardous chemicals are buried in some type of containment
system.
The WG must decide what cleanup goals to use. Here are some ahematives:
--Least stringent: 1 or 2 ppm for PCBs and 1 ppb for dioxins (max 5 x l 0-4 risk)
--Stringent: 70 ppb for PCBs and 4 ppt for dioxins ( 4 x 10"6)
--Very stringent: 40 ppb for PCBs and 2 ppt for dioxins (2 x 10·6)
--Extremely stringent: 20 ppb for PCBs and 1 ppt for dioxins (max l x 1 O.r, risk)
[All of these risk figures ignore synergistic effects.]
Note that consideration of non-cancer hea.lth effects generally results in higher
contaminant levels th.an those obtained on the bas.is of cancer risk assessment.
A practical problem is that if the RFP cites very low cleanup levels for PCBs and dioxills
in residues., some companies may .not be interested in pursuing the work. Or, companies may
pursue the work, but have to increase the intensity of their treatment, or plan on ,etreating some
residues, that would increase costs substantially. The incremental treatment cost mcreases for
incremental risk reductions can be very large.
My recommendation is that the WG use the Stringent alternative above as PCGs,
recognizing that the RFP will make clear that the lowest possible residual co.ntaminant levels are
desired, consistent with obtaining a cost-effective cleanup, and that the test results from the
several vendors selected for tb.e testing phase and other infonnAtion they provide \.Vill be used to
se.lect final cleanup goals. After the WG makes a decision, I recommend that the &tate be
informed in writing of that decision and asked for its concurrence.
(5} lnfog:matioo on :water in landfill
A major complication for detoxification is the presence of water in the landfill, because it
affects technology performance and cost. There is a need for more complete an.d reliable
information from the state to assure that the RFP and design of the bench scale test is adequate.
My recommendation is that the WG submit a written request for infonnation to the state. 111e
request would be for a technical sUJllIIW)' of all key information on water in the landfill and
5
P.5
1-28-1996 8 :d6PM FROM p 6
,. . ' .
answers to specific technical. questions. Note the interest is NOT on what caused the water, but
rather on the details describing the nature of the current water,
{6} Biorcmediation
I have seen evidence that the state is still pursuing bioremediation as a weans of
detoxifying the Lmd.fill. .I have concluded that no form of bioremediation is a candidate for
se.Jection as a feasible technology for this application. Three other evaluations over the years also
reached that conclusion. Therefore, I recommend that the WG formally request the state to stop
all activities related to bioremediation use for the landfill, because their resources are far too
limited and are needed for many other m.ore important activities. ,(,; l .,
1J-l ~v~/ .~~ {J-·Y yr i J \\~. f'~
r,,P'~¥ ',t1f~
qf(\;11)~oM'r
(
6
August 9, 1996
MEMORANDUM
TO: Henry Lancaster
FROM: Bill Meye~_./
Pat Williamson~
SUBJECT: Briefing for Governor on Status of PCB Landfill Working Group
Enclosed is the draft memo that Monica prepared for Carolyn Coleman to
brief the Governor on the status of the PCB Working Group.
We do not know when the Governor was last briefed on the status of the
working group, so we prepared a brief background. We included much of what
Monica had in her draft report and answered the questions she asked (included
in report).
We feel that Joel Hirschhorn's comments, contained in his progress
report to the working group and dated July 8, 1996, should be included with
the other attachments that Monica requested.
We are sending this information to you for your review rather than
sending it directly to Monica.
Thanks, Henry.
\
July 2, 1996
MEMORANDUM
To : Bill Meyer
From: Bob Glaser, Grover Nicholson, Larry Rose, and Pete Doorn
RE: Proposed Sampling for the PCB Landfill
Mr. Barnes , Science Advisor for the Warren County Working Group, has proposed another
sampling program for the PCB Landfill. This program is described in the 6/13/96 draft
document titled "Warren County PCB Landfill, Supplemental Site Investigation Plan".
Members of the Division staff have reviewed the sampling program and discussed, at length,
the program with Mr. Barnes. From the review and the discussions, the staff believes that
Mr. Barnes is approaching this site as if little or no previous work had been done. It also
appears that Mr. Barnes' approach assumes that the contents of the landfill are in question and
a release may have occurred anytime between 1979 and 1996. In response to Mr. Barnes '
proposal , the staff has developed an alternate sampling program. The staff's program will
generate data to supplement the existing data . In the development of this plan, the Division
staff assumes that: 1) if a release has occurred, then the release is continuous or cyclic; 2) the
movement of contaminants would be limited because of their low soluability; 3) the contents of
the landfill are known; and 4) the landfill construction and filling procedures are known.
After reviewing both sampling programs, one can see that there are significant differences in
the approach and scope of work. Mr. Barnes' approach is to sample along each of the
contaminant pathways (overland flow and movement via ground water) from the landfill to the
adjacent surface water. The scope of work includes: 1) the collection of soil and ground water
samples adjacent to the landfill; 2) ground water and surface water samples in each of the
draws; and 3) surface water and sediment samples from Richneck Creek and the unnamed
tributary. The Division staff's approach considers ground water as the only transport
mechanism for the lateral movement of contaminants. The scope of work includes the
installation of nine additional wells, to further characterization of the ground water flow
adjacent to the landfill, and implementation of a ground water monitoring program.
As mentioned above, the staff has discussed the merits of both proposal's with Mr. Barnes.
These discussions have helped the staff understand the rationale used in developing Mr.
Barnes' proposal, however, they have been unsuccessful in moving us towards a compromise ..
One approach the Division/Department may consider in resolving the differences in the two
proposals is to hire an independent, third party contractor, to review both workplans.
GOAL:
NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
PROPOSED PCB LANDFILL SAMPLING PROGRAM
The goal of this sampling program is to confirm the ground water flow direction in the vicinity
of the landfill and monitor the ground water quality downgradient of the landfill. The
Division staff considers ground water to be the contaminant pathway of concern for the
contaminants in the landfill.
SCOPE OF WORK
The scope of work includes the installation of nine additional ground water monitoring wells
and implementation of a ground water monitoring program.
The nine wells would complement the existing monitoring system and should address any
unresolved questions pertaining to ground water movement in the vicinity of the landfill.
Once the wells are installed, a monthly water level monitoring program should be implemented
for one year. The one year monitoring requirement is necessary to evaluate any seasonal
variation in the ground water flow direction. At the end of the one year, a ground water
quality monitoring program would also be implemented at each of the downgradient
monitoring wells and an upgradient well(s).
The specific locations for the nine additional wells are identified on the attached figure. The
list of constituents to be monitored in the ground water would include each of the constituents
on Table 1 (under the heading of groundwater) in Mr. Barnes 6/13/96 draft "Supplemental Site
Investigation Plan" .
EVALUATION OF DATA
After each water level monitoring event and each ground water quality sampiing event, the
data would be evaluated to determine if the appropriate zones are being monitored and
adjustments to the ground water monitoring program would be made.
SITE HEALTH AND SAFETY PLAN
FOR
WARREN COUNTY PCB LANDFILL
Project: Warren County PCB Landfill
Operation and Maintenance
Off of SR 1604
EPA ID#: NCD 980 602 163
Location:
Warren County
Project Date: July, 1996
Health Department Official Contacted:
Date of Contact: June, 1996
Briefing Date:
Debriefing Date:
July, 1996
July, 1996
Project Participants:AII project participants have read the Site Health and Safety Plan
and are familiar with its provisions.
Participants: Title: Signature: Date:
Peter Doom
Johnny Ford
Bob Glaser
Pierre Lauffer
Grover Nicholson
Larry Rose
Surabhi Shah
Gray Stephens
Pat Williamson
Harry Zinn
Plan Prepared by: Pierre Lauffer,
Health and Safety Coordinator
Sharron Rogers,
Branch Supervisor
Reviewed by:tfi!:.e
Pie e ~ /. . 'treF,
Health and Safety
Coordinator
B. SITE/\V ASTE CHARACTERISTICS
Waste Typre(s) Liqid__ Solid Sludge__ Gas
Characteristics Corrosive
Volatile
Other
CHE1\11CAL HAZARDS:
Properties
PCB mild petroleum odor, resinous
Ignitable __
Toxic
MCL
0.5 ppb
Radioactive
Reactive
TLV
0.5mg/m3
Federal
Action level
50ppm
Toxic effects include chloracne, pigmentation of skin and nails, excessive eye discharge,
swelling of eyelids and gastrointestinal disturbances. Listed as cancer causing.
FACILITY DESCRIPTION:
Total Size: 142 acres Landfill Size: 2.54acres
Buildings: one storage building
on Landfill
Site History:
Between June, 1978 and August, 1978, roughly 30,000 gallons of industrial waste material
identified as PCBs (Arochlor 1260 and 1262) were discharged deliberately along the shoulders of
approximately 150 miles of NC Highways. In June, 1979, EPA approved a tract ofland
(previously used for agriculture) in Warren County as the disposal site for the PCB-contaminated
roadside material. The landfill ( constructed in 1983-1984 and permitted under the Toxic
Substance Control Act (TSCA) contains about 40,000 cubic yards of soil contaminated with
PCBs. The concentration of PCBs in the landfill ranges from 0-3 l0ppm.
C. SITE HAZARD EVALUATION
Based on past sampling results, the cap of the landfill does not contain any substantial amount of
PCBs. Samples of the leachate from the pond-outlet, near outlet, middle, filter 1 and 2-on the
northside of the landfill showed to have between <0. IOppm, <0. IOppm, 0.53ppm, 1.15ppm,
1.45ppm respectively.
Samples from inside the landfill (retrieved from the bottom of vent pipe on top oflandfi.11) consists
of wet and dry contents and were found to contain 151.8ppm and 301.4ppm PCB respectively.
Soil samples from the est side oflandfill (along the side) found to contain 0.22ppm PCB, this was
to measure runoff
C. SITE HAZARD EVALUATION-CONT.
RECOMMENDATIONS:
Level of Personal Protection Equipment for work/sampling operations: Modified Level D
Indications:
Tyvek splash suits
Latex safety gloves: inner lining
Nitril safety gloves: outer lining
Safety boots
Chemical protection overboots
Safety glasses
Long sleeve shirts and pants
Those sampling contents of landfill (through vent):
Facial splash guard
Observers, Media members, work group members, etc.
Safety boots
Long sieve shirts and pants
D. WORK PLAN INSTRUCTION
Map attached: YES
Perimeter identified: The gate at the entrance to the property is the outer perimeter and
is considered the outer exclusion border. Only work DWM team members
and authorized members of the media/work group/public are permitted into
this area. The fence to the landfill proper will be considered the inner
exclusion zone border. Only those who have received a safety briefing and
employed the proper PPE for conducting sampling may enter this zone.
Persons who are members of the public, media, etc. and are not conducting
sampling, but wish to observe the project may enter upon receiving a safety
briefing and given proper PPE.
Command Post: Located on the western side oflandfill outside of the inner
fence next to driveway
Contaminated zones identified: YES
Surveillance Equipment:
The Organic Vapor Analyzer will be employed to monitor the level of methane inside the
vent pipe on top oflanfiil. If the methane level is higher than 10,000ppm, the Combustible
Gas Indicator will be employed to measure percentage of LEL. Oxygen meter will also be
employed
D. WORKPLAN INSTRUCTION-CONT.
Decontamination Procedures:
All PPE will be disposable and will be dispose of upon leaving the landfill at the fence
entrance to the landfill proper.
Modifications ------------------------
E. EMERGENCY CHEMICAL INFORMATION CENTERS
Poison Control Center-State Coordinator
Duke University Mdical Center
Tele: 800-672-1697
P .O. Box 3024
Durham, NC 27710
Asheville Western NC Poison Control Central
Memorial Mission Hosp.
509 Biltmore Ave., 28801
704-255-4490
Charlotte Mercy Hospital
2001 Vail Ave., 28207
704-379-5827
Greensboro Moses Cone Hosp.
1200 N. Elm St., 27420
910-379-4105
Wilmington New Hanover Mem. Hosp.
2131 S. 17th St., 28401
910-343-7046
Jacksonville Onslow Mem. Hosp.
Western Blvd., 28540
910-577-2555
.....
EMERGENCY PRECAUTIONS
Route of Exposure First Aid
~ • • . • • • • . • . . . . . • • . • . • • . irrigate immediately
Skin . .. .. • .. .. • • .. .. . . . . . . soap and water wash
loha!atjon • • • • • . • • • . . . • . • • • • fresh air and artificial respiration
Ingestion • • . • . . • . • . . • • . . • • . get medical ·attention immediately
Location of Nearest Phone: unknown
Nearest Hospital (Address and Phone Number)
Maria Parham Hospital Ruin Creek Road at l-85 Henderson NC 27536
can handle chemically contaminated patients
Emergency Transportation Systems (Phone Numbers)
Fire lli
EMS ill
Rescue Squad lli
Emergency Route to Hospital Travel west on SR 1604 then turn left onto SR 1125. lust past Cokesbury
turn right onto SR 1510 then left onto SR 1001, Stay on SR 1001 until just outside of Henderson then turn
right onto SR 1508 which wjll lead you to 1-85 Jake 1-85 South to the Ruin Creek Road exjt the hospital is
well marked
EQUIPMENT CHECKLIST
__ Air purifying respirator
__ Cartridges for respirator
__ Dust Mask
_X_O2 Indicator
_X_Eye Wash Unit
_X_HNU
_X_OVA
_X_Combustable Gas Meter
___ Radiation Monitor
_Detector Tubes and Pump
X First Aid Kit
-X_3 gal. Distilled H20
__ Rainsuit
_ X _Gloves (PE/PVO'n itri le/cloth)
X Boots/Boot Covers
-X Coveralls (tyvek/saranex)
_X_ Eye Protection
_X_Hard Hat
_X_ Decontamination
Materials.
PROJECT MANAGERS PROJECT ACTIVITY REPORT
PROJECT MANAGER: ______ _ PROJECT: ___________ _
INVESTIGATION DATE: _____ _
Materials Used (Please insert a number in the blank)
Air Purifying respirator cartridges
--Detector tubes == Eye Wash Units
First Aid Kit == Gloves (polyethylene)
Gloves(PVQ
Respirator Worn By
Gloves (nitrile)
_._._Gloves (cloth)
Boot covers
__ Coveralls (tyvek)
Coveralls (saranex)
__ Auger Brushes
Approximate Time in Respirator
Air Monitoring Data (Include Calibration Reading)
HNU: ------------------------
OVA: _________________________ _
Combustable Gas Meter: --------------------
Radiation Meter: -----------------------
If the maximum personal protective equipment as outlined in the Hazard
Evaluation Section was not used, please justify:
Visitors Present Organization Represented
-c\L/SR/Revised 5-94
June 12, 1996
MEMORANDUM
To: Bill Meyer
From: Bob Glaser, Grover Nicholson, Larry Rose, and Pete Doorn
RE: Proposed Sampling for the PCB Landfill
In the June 7, 1996 meeting , we were provided with a May 28 , 1996 memoranda and a June
4, 1996 letter from the PCB Landfill Working Group's (Working Group) Science Advisor,
Patrick Barnes. These documents set out a specific sampling program for the landfill.
After reviewing these documents, we are proposing an alternative sampling program. We
believe this program addresses each of the concerns of Mr.Barnes. The major differences in
the two programs are: 1) the sequence of activities; 2) the use of site specific ground water
data in the selection of proposed sampling locations; and 3) the proximity of the additional
monitoring wells to the landfill. We believe our proposal describes a sound scientific
approach to address each of the potential contaminant pathways. Eventhough cost was not a
factor in our proposal, we believe this program is more cost effective also .
We recommend that our proposal be reviewed/edited by the appropriate staff and submitted to
Mr. Barnes as an alternative to his proposal. We believe that our proposal or some "hybrid"
proposal (combination of his and our proposal) may be agreeable to Mr. Barnes. Since Bob
Glaser has contacted Mr. Barnes earlier and discussed Mr Barne's proposal in detail, Bob may
be the appropriate individual to submit the alternate proposal.
GOALS:
NORTH CAROLINA DIVISION OF WASTE MANAGEMENT
PROPOSED PCB LANDFILL SAMPLING PROGRAM
The goal of sampling program proposed by the Division of Waste Management (DWM) staff
is to address each of the potential contaminant migration pathways for the contaminants of
concern at the PCB landfill. Each of these migration pathways were considered in Mr Barne' s
proposal. The potential migration pathways are: 1) ground water and 2) overland runoff of
PCB contaminated media during the filling of the landfill.
SAMPLING PROGRAM:
The DWM proposes the following activities, in two phases, to accomplish the goals of the
sampling program.
PHASE I:
The initial phase of the sampling program would be to identify the potential water
quality sample locations considering ground water as the transport mechanism. The
first field activity would be to establish additional ground water monitoring stations
(wells) in order to collect ground water surface elevations. These same wells would be
suitable for the collection of ground water quality samples in the second phase of the
program. The specific locations for the additional wells are identified on the attached
figure We believe ground water surface elevation and hydraulic head data from these
wells will provide sufficient data to construct a ground water flow net for the area
surrounding the landfill. The flow net will illustrate ground water flow in both plan
view and cross section. With the flow net and the approximate locations of the ground
water seeps (ground water discharge points) on the 7 .5 minute USGS quadrangle sheet,
we believe that the appropriate surface water quality and ground water quality sample
locations could be selected.
PHASE II:
The second phase of the sampling program would be to identify and sample each of the
appropriate locations upgradient and downgradient of the landfill. These sample
locations would include both the water quality sample locations and the sediment
sample locations. Specific sample locations would be selected after considering the
data collected in PHASE I. The specific parameter list would include each of the
constituents agreed upon by the Working Group and the DWM.
Both ground and surface water quality sample locations would be selected after
considering the ground water flow net and the ground water discharge locations. All of
the wells hydraulically downgradient of the landfill would be sampled. Downgradient
surface water sample locations would also be included. Surface water sample locations
would include each of the ground water seeps hydraulically downgradient of the landfill
as well as several locations from the perennial stream downstream of the seeps. As a
quality control measure, both upgradient surface and ground water samples would be
collected.
Stream sediment sample locations would be identified after considering the surface
water sample locations and a topographic map of the landfill and surrounding area.
Overland flow is the potential transport mechanism for potential contamination at these
locntions, These locntiom would most likely be comistent with those proposed by Mr.
Barnes.
C:\SPCIAL-P.ROJ\PCB\6-96SAM.PRG
~ A Environmental Consultants
Barnes, Ferland and Associates, Inc.
June 4, 1996
Mr. Bill .Meyer
North Carolina Department of Environmental Health
and Natural Resources
401 Oberlin Road, Ste. l 50
Raleigh, N.C. 27605
BFA #95-017
SVBJECT: Coordination of and Responsibilities for Sampling and Testing Activities
Dear Bill .
Relative to the above I understand the following :
• The State v.-ill assemble a team of samplers who will collect environmental samples in a
phased approach as outlined in our memo dated May 28 , 1996.
• The field team leader will closely coordinate all activities with the Science Advisor.
• The sampling activities will be in accordance with the existing Sampling Plan and our
proposed supplement.
• Approximately 25% of samples will be split with the Science Advisor and analyzed by a
fully qualified but independent laboratory
• Bf A will provide a location map containing all proposed sampling points.
• The State will advise me as to whether or not it can make available all terrain drilling
equipment and when.
Other issues which have resulted from two recent attempts to field verify proposed off-site
sampling locations are:
• The potential need to coordinate with and/or obtain easements from adjacent property
owners.
• The need to perform clearing and grubbing activities such that the samplers can easily
access each sample station.
The Hollister Building • 3535 Lawton Road• Suite 111 • Orlando. Florida 32803
Office [phone] • Fax [phone]
Mr Bill Meyer
June 4, 1996
Page 2
At this time it is assumed that these activities will be performed by the State. Please notif)· me if
you recommend otherwise.
Attached is a draft map of the proposed sample locations. Several of these locations have already
been verified and flagged . Substantial clearing will be required to access sites to the west of the
landfill. Larry Rose of your department is very familiar with the procedure being used to identify
surface water, sediment and groundwater sample locations. If the State is to arrange for and
contract the necessary clearing activities. it is recommended that. if possible, he be involved in
that process.
P AB psi; ·r.--1W\1 I .,foe
cc Working Group Members
Joel Hirschhorn
John Watson, BFA
Sincerely,
Bar~:::1/d and As:_:~!a
/~//4~~·
Patrick A. Barnes, P G.
Science Advisor
,s.~ 07: 3'.2 4tt78%1822 ---------
I £1'5 /30/1-8% 13: os 407E:'351 E:22
..BFA Environmental Consulta1
Post-It~ Fax Note 7671
Barnes, Ferland and
MEMORANDUM
TO:
FROM:
Bill Meyer and W.orking Groupz. e13 rs
/}/ r £,
Pat Barnes (Science Advisor) . af
DATE: May 28, 1996
Phor;e # (40l
Fax # 40
SUBJECT: Implementation of Phase I Supplemental Environmental Sampling
at the PCB Landfill
PAGE 01
As we agreed, the analytes, QA/QC and Health and Safety procedures for the existing Field
Sampling Plan are acceptable for fi.tture sampling activities. Severa! additional sampling locations:
liowever, should be added for a more comprehensive evaluation. I would recommend a phased
approach for the next group of samples. We are in the process of preparing a Phase I sample
location map and a supplement to the existing plan. Proposed Phase I sampling would include the
following :
1. Repeat first round sampling and analysis for all locations and corresponding matrices
excluding soil samples collected on the landfill cap and mon.itor wel.ls .
2. Sutface soil samples in the northern settling basin.
3. A total of six (6) soils sediment samples, one from each of the major draws surrounding
the site.
4. A total of five (5) sediment samples located in sedimentation prone areas along Richneck
Creek and the unnamed tributary.
5 A total of six (6) surface water samples, one from each of the major draws as close to the
landfill as possible (if water is present).
Proposed Phase U sampling will involve the following :
l. Hydropunch technology will be used to collect groundwater samples directly adjacent to
the toe cf the landfill The hydropunch data will be used to identify if leaks may have
occurred as well as the vertical distribution of water quality
2. Permanent monitor wells will be designed and located based on results of the hydropunch
data. At a minimum, one monitor well cluster should be placed uphill from each of the
draws.
The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando. Florida 32803
Office [phone] • Fax [phone]
05/30/1996 13:05
l\tlEMORANDUM
May 29, 1996
Page2
BARt--lE:3 FERLAHD A~SOC F'AGE 02
3. Groundwater samples wiH be collected and tested from each of the monitor wells.
We are in the process of reviewing the previously proposed, expanded groundwater monitoring
plan and will incorporate its recommendations into our Phase II supplement. It is recommended
that the State move quickly with the Phase I sampl.ing activities. A Phase I supplement should be
submitted to your office by June 7. 1996.
cc: Joel Hirschhorn
BF.A =======
.,.,.
January 3, 1996
Mr. William Meyer
Division of Solid Waste Management
ENVIRONMENTAL TECHNOLOGY UNLTD.
9220 Industrial Blvd.
Leland, N.C. 28451
910-371-2007
Fax: [phone]
N.C. Department of Environment, Health, and Natural Resources
401 Oberlin Road
Raleigh, NC 27605
Dear Mr. Meyer,
Recently, in discussions with Headquarters of the USEPA, I learned that Aqua Terra
Environmental Company of Raleigh in conjunction with Blue Bell Environmental
Company of Pennsylvania had submitted an application for a National R&D Permit to
study Base Catalyzed Decomposition for North Carolina more specifically the Warren
County PCB Landfill. Environmental Technology (ET) is presently holds a National
R&D Permit from USEP A to study soil washing and solvent extraction technologies for
the remediation of PCB' s in soil.
ET has built and demonstrated a pilot unit to the USEPA. We expect to obtain our
second National Alternate Disposal Permit for PCB's in 1996. Presently, we are
searching for a treatability study to participate in. ET is very interested in the Warren
County project and would very much like to be considered in the initial treatability work.
We can start immediately either on site or here in this facility.
-Enclosed is a copy of our current SOQ as well as some information on our soil unit.
Please call me with any questions.
Sincerely,
Lyle Hunnicutt
Vice President Operations
Enclosure
SOQ
METHEX BROCHURE
I
' '
■ I --
STATEl\rlEN'I' of QUALIFICA'l'IONS
for
ENVIR.C>NMENTAL TECIINOLf)(;Y UNLIMITED
CORPORA TJON
9220 Industrial Boulrvnnl
Leland, NC 28451.
[phone]
ENVIRONMENTAL PATHWAY TO 1HF. FUTURE
..
The ME11-IEXTM process developed hy Fn•,irnnrnental Techn<'lngy ( FT) is a lllobilc unit used to
extract and remove PCB's, Chlorobenzrnes. <1nd Dioxins fro111 •:,,if The process is an economical
alternative to disposal of affected soil at a T~CA-approvcrl inri,w,at<'r or TSCA-approvcd landfill.
The METHEXT"' process vastly reduces th e amount of conta111i11atcrl waste generated. It also
minimizes liabilities that are associated with disposal at );rndfills
The METHEXTM process offers a viable altcrmtive to lnndfilling and hc1s many advantages over other
process methods of soil remediation and dig-and-haul. Some oft he lwnefits arc as follows:
• Reduced liability through decontarnin:ition rather than di ,posal
• Waste reduction through distillation ;111cl carbon c1clsorptiPn .
• Expedited remediation time as a result of the extreme effectiveness of the METHEX™
process and environmentally sound orgc1nic solvent.
• Cost effectiveness.
• USEP A approved
• Completely mobile adding versatility c1nd case of handling. Greatly reduced mobilization and
set-up times.
State of North Carolina 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
Lyle Hunnicutt
Vice President of Operations
Environmental Technology
9220 Industrial Blvd.
Leland, NC 28451
RE: Warren County PCB Landfill
Dear Mr. Hunnicutt:
January 9, 1996
NA
DEHNR
I appreciate the information that Environmental Technology (ET) presently holds a
national R&D permit from USEP A to study soil washing and solvent extraction technologies for
the remediation of PCB's in soil. ET's interest in the Warren County PCB landfill with respect to
a treatability study is also appreciated.
The Joint State/Warren County Working Group is considering detoxification of the PCB
landfill and has recently hired a science advisor. One responsibility of the science advisor is to
recommend alternative technologies for detoxification of the landfill. I will refer the information
that you have submitted to the working group and science advisor for consideration.
If you have any questions please contact me at [phone], ext. 202.
Sincerely,
J~c!P?ut~
William L. Meyer
WLM/cb
cc Henry Lancaster w/ attachments from E.T.
'Pat-Williamson w/atfifchment! from E: T~vr·
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
~ .JS L ~~---'-~ \_\. VISITOR SIGN-IN SHEET PLEASE FILL OUT COMPLETELY ? v <-~ t~ ~~ -DATE BADGE VI;ITO~ # NAfylE I../"", 9-/11 .<( /11 ~ 61£',ArJ/ /Ir v1 M~tP~11/:v-2·17 4 v\..05,. 1-/7 ( fevt. Ot ·h~, 'le,,,.. <-I} · 2. 'cc: t -S""i-1-ti-v (,, <;/1:_ f ?c· ' ~17 I~ ·uUcd!ML I I J) DoY) t1 7 7~~~ "" &; l LI I e_ -H LA__ V\ \i\ \ ~ ~~ ~c_~ ~-~~r--PHONE NUMBER STAirU' YOU ARE VISITING TODAY · TllvIE IN kPv~~1 -:!] ~&;}-{£JC,;;), 0 I /(01.,.. r. W-tSfcf\, .:½le. I /Ob lbs 511-,,2'/-I 1:?f' C brl\ £-~~1'c.c¼VAn.1t ~c_. £co l-06'/C-\vl\..l.. A-OV•.S~ C11,)gstf-D7'7'1 I Olo6J GJv. ,;f_ &au..y 5✓c..~,/N'-. I '-I•::,~ ~7l:, tnv;,u,1,11e.,r~,( J:,.c... 610-'Ml -;rim Vt='L/ r:r C ·z--cJ O ?ID) LLD 1w Jb5 f/r "'IS'-/..,6_21~ P'i 9-9997 /J-qu..e._-~~-;J__:.__<!.., . !V/,4-37.\ -ioo 7 ·3 -HJJl__ TllvIE OUT 1/11 D~IS1£~2~ w ~~!~ MANAGE~~~r!~lvlslr1ms.fr111 } 17 J:CL14---fktSC!l l.4 H. TvRr~F ·1;.;~--J.<:;c-/ ~), n~~11')} r,[ /t!1i'),,1l/;,~1n-l
Ray S. {Stan} Taylor, PE Principal P.O. Box 41087 Raleigh. NC 27629 ----~ ---919-876-5i15 800-849-5115 FAX [phone] ,,. ...... -; -···-· ·-· ..................... 1 . Solvated Electron Technology (SET) Chemical Treatment Tecl-1nology.for. · .. ·Destroying Toxic Organi~ Contaminants·· •: COl\MODORE . ADVANCED SCIENCES, INC. 2340 Menaul Boulevard NE, Suite 400 Albuquerque, NM 87107 505~872~3508
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 "release of dioxin from the PCB landfill is the
most likely source for demonstrated dioxin and furan contamination in on-site
monitoring wells." 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.
1
,,
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 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 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
2
,.
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 secre\t,IX.~ office space is $25,000 for one year. As of September
1996, approximEtfely ~~has been expended from that fund, of which
$~ has gone to the science advisors. ~ 31 1 Y04
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 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
3
\
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 groups. 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. Mr.
Hirschhorn is currently working on this item. They also suggested that a site
investigation be conducted to determine the current status of the PCB Landfill
and the surrounding area. Mr. Barnes and state officials are currently working
on this item, and a plan will soon be presented to the working group for
approval. 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
4
and DEHNR to formally propose the landfill detoxification project to the
General Assembly to obtain funding.
5
',,
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
checked to find the source and remove it. 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 expressed an interest in detoxifying the landfill. 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 group's membership later increased to
22 members.
The working group met for the first time in March 1994. Upon the group's
recommendation, Pauline Ewald, head of Environmental Compliance Organization, was
hired 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 recommendation evaluation
procedures, methodology for water removal, 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 dioxins at the ppq (parts
per quadrillion) level in three of the monitoring wells around the landfill. Opinions
varied as to where the dioxins originated. 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 a resampling as well as removal of the water from the landfill.
Ms. Ewald recommended that base catalyzed dechlorination (BCD) be used as a
detoxification method for the landfill. The state told the working group that a variety of
methods should be considered and that the General Assembly would want information
about the 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.
Ms. Ewald's contract ran out in May 1995.
Current Status (July 1, 1995-present)
During the 1995 session of the General Assembly, Senator Frank Balance got
the legislature to appropriate $1 million from the Highway Fund for pilot projects to
determine the most appropriate technology for cleanup of the landfill.
The working group members felt 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 was opened on March 25,
1996, located 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 for
office space ( see attached PCB Landfill Fund).
The science advisors developed a Master Plan for the working group denoting
their process of operations (see attached copy of Project Master Planning). 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. 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.
Mr. Hirschhorn peer-reviewed the earlier report prepared by Ms. Ewald and
reported his findings in a progress report, dated July 8, 1996, to the working group
(see attached progress report).
At this time, the DEHNR's Division of Waste Management is working with Mr.
Barnes to develop a sampling plan for the PCB Landfill. It is expected that a sampling
plan will be submitted to the working group for approval in August and the actual
sampling event can take place in September. Mr. Hirschhorn is currently investigating
and reviewing technologies that might be used to detoxify the landfill contents.
8/9/96
,
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
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 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.
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 checked to find the source and remove it. 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 or simultaneously
with dewatering 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, Pauline Ewald, head of Environmental Compliance
Organization, was hired 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 evaluation procedures, methodology for water removal,
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. 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 an expensive detoxification effort.
Ms. Ewald recommended that base catalyzed dechlorination (BCD) be
used as a detoxification method for the landfill. The state told the working
group that a variety of methods should be considered and that the General
Assembly would want information about the 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 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 ran out 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 Bill Meyer, director of the Division
of Waste Management, serving as staff. Three positions are vacant (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 never attends the
meetings. 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
During the 1995 session of the General Assembly, Senator Frank
Balance got the legislature to appropriate $1 million from the Highway Fund for
pilot projects to determine the most appropriate technology for cleanup of the
landfill.
The working group members felt 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 was opened on March 25, 1996, located 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 for office
space. 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, approximately XXXXXXXXX has been expended from that
fund, of which $XXXXXXXXXX has gone to the science advisors.
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. 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 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.
The science advisors offered several reasons for changing the current
strategy of the working groups. 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. Mr.
Hirschhorn is currently working on this item. They also suggested that a site
investigation be conducted to determine the current status of the PCB Landfill
and the surrounding area. Mr. Barnes and state officials are currently working
on this item, and a plan will soon be presented to the working group for
approval. 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.
4
FACT SHEET: Evaluation of BCD Process at the FCX-Statesville Superfund site.
HISTORY
• FCX-Statesville was an agricultural distribution center for pesticides and fertilizers. There
may be approximately 5,000-10,000 pounds of pesticides buried on site. The site was
proposed for inclusion on the NPL in November 1990 and is a fund-lead site. Soil sampling
at the site revealed about 7,000 cubic yards were contaminated with pesticides and PCP.
• ROD (OU-2) signed on 22 November 1994.
• Site has not been remediated and the bidding process is scheduled to begin in 1998.
Remediation is scheduled to begin in 1999.
REMEDY SELECTION PROCESS
• Soil cleanup goal is 1 ppm for pesticides and 3 .2 ppm for PCP.
• Soil cleanup remedies evaluated included !)capping, 2)on site BCD, 3)on site thermal
desorption, and 4)off site excavation.
• Comparing criteria ratings and costs of these four alternatives, on site BCD treatment met
all of the criteria and was chosen as the remedial method.
BCD TREATMENT PROCESS EVALUATION
• EPA's experts from the Cincinnati lab, John Gilbert and Terry Lyons (513-569-7537),
question BCD's effectiveness. They feel the BCD process does not work.
• Ken Mallary, RPM for the site, is reevaluating the effectiveness of the BCD treatment
process. In May 1998 he was unable to find any success stories for this process and in a
public meeting (21 May 1998) indicated that BCD would not be used at the site.
• Weston, EP A's ARCS contractor, is continuing the evaluation of the BCD process for EPA.
Ralph McKeen (770-263-5438) of Weston had not found any positive information about the
BCD process until ETG Environmental submitted data. Weston is currently evaluating
ETG's claims and is scheduling a conference call with EPA and the State in early September
to discuss BCD's effectiveness.
Weston faxed the State a copy of ETG's BCD literature. Evidently, Southern Maryland
Wood Treatment site is a pentachlorphenol site similar to Koppers but there is no data, as
remedy has yet to be implemented.
A (D&Jit __ j /VrJ /l ~ __,< • · /J. I) I ~ ,-~~J#JJ,F/ ~ Wt2ul/4
WARRENTON -The Joint Warren County/State PCB Landfill Working Group will hold
a rally in front of the Legislative Building on Wednesday, July 15, at 11 :30 AM to show support
for detoxification of the PCB Landfill. Working Group members will be joined by other Warren
County residents and interested citizens seeking funds from the General Assembly for
detoxification of the landfill.
For the past four years, the Working Group, which is composed of Warren County
citizens, representatives from environmental groups, and state officials, has worked together to
determine the current status of the landfill and the availability of technologies to detoxify the
PCB contaminated soils using $1 million appropriated by the General Assembly in 1995 for this
purpose. Under the guidance of two independent science advisors, the Working Group selected
base catalyzed decomposition (BCD) as the detoxification method for the landfill because it is a
chemical/low thermal process that can be used on site, it is effective with PCBs, and it presents
low risk to public health and the environment.
The detoxification effort is anticipated to cost about $24 million based on a preliminary
draft design of the full-scale BCD operation. Governor Jim Hunt has requested $15 million in
his proposed budget, with the rest coming from other sources. Senator Frank Ballance of Warren
County has introduced legislation requesting the full $24 million for detoxification of the
landfill.
PCBs are polychlorinated biphenyls, a chemical once widely used as a liquid insulation
material in electrical transformers. The chemical was banned in the mid 1970s.
In July 1978, PCBs were illegally dumped along more than 200 miles of roads in 14
counties in North Carolina. The roadsides were scraped and about 7,200 truckloads of PCB-
contaminated soils were taken to a landfill in Warren County designed specifically to hold the
soil. Until more recent years, there was little feasible technology to detoxify PCB-contaminated
soils.
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