NCD980602163_19970103_Warren County PCB Landfill_SERB C_Joint Working Group - Air Sampling Plan-OCR

6-04-1 996 1 :OSAM Fl?OM
Ja.ouary 3, 1997 ................................. .' ................................................ by FAX
To: Technical Committee and full Working Group
From: Joel Hirschhorn
Through: Doris --for immediate distribution
Subject: Response to state's Afr Sampling Plan
Today, at 12:30 PM I received that attached cover letter and Plan. Note that the Plan is dated
December 18 and that testing is scheduled to begin this Monday, January 6. I find the state's
behavior in providing the Plan for review at this late tii:ne both discourteous and disrespectful.
I r~ject the entire Plan and advise the Working Group to raject the study for the foJlow:ing
reasons:
TIJe key stated premise of the .Plan is "it is not believed that there are uncontrolled PCB
emissions." And the stated objective of the study "is to test this premise by determining if there
are uncontrolled PCB emissions. 11 hl other words, the "scientific" position of the state is that
there are no emissions and their study will prove this. In fact, the Plan states that "Generally the
vapor pressure of PCBs under n01n1al conditions in the PCB landfill in Watl'en County is too low
for volatilization and cannot be emitted directly into the air surrounding the land.fill." If this
position was scientifically correct, then why did EPA conduct its study to measure PCB emissions
and why did EPA actuaUy measure PCB emissions? The Working Group and concerued citizens
should reject this biased state study from the outset. There is absolutely no reason to tmst the
study.
With this kind of bias the public should not accept a state agency and state personnel conducting
the sampling and th.e laboratory testing. An independent contractor and an. iudependeut
laboratory should be used, and the Science Advisors should be given adequate time to fully
examine and review the details of the sampling and testing methods.
Technically, I do not believe that the planned sampling methods are acceptable~ nor do they fully
co1Jforrn with the recommendations of the EPA study.
It seems as if the state is committed to use any tactic to attack the previous work on.. PCB air
emissions in the past. Even if sound sampling and testing found no PCB emissions today, it
would not in any logical or scientific sense prove that there were no significant PCB air emissions
in the past.
11Je planned study is to include a risk assessment, but this too should not be considered objective
or reliabJe by the public. . ·,
( cc: Mike Kelly ·-----.
-----~---~. -.... -··•· . ·-·· . . .... _________ ---->
P . I
,./
January 3, 1997
MEMORANDUM:
TO: PCB WORKING GROUP
FROM: MIKE KELLY
SUBJECT: AIR SAMPLING AT TIIE PCB LANDFILL
Today I faxed out copies of a sampling plan to be used next week at the landfill to pull a
series of air samples from inside the landfill and around it as well. If you recall, I talked about
this sampling event at the meeting on December 17th and said that the projected start date was
January 6.
I have had members of my staff working on this event for severaLweeks, ordering
equipment and preparing the necessary items, as well as coordinating with the laboratory. At the
meeting in December, I was asked to do two things: 1) not have this event or similar things done
by the Division detract from the main project of detoxification, and 2) to send the science
advisors a copy of the plan. I clearly stated that we did not plan to do an elaborate plan because
this was an initial one time event, but I would send what I could to the advisor's as soon as
possible, but I did not plan to hold up the event for any "approvals" because it was (is) not
designed to be anything more than a "look" at the air coming from the landfill. There are many,
many things to consider for the future in long term monitoring, this is only a start, a snap-shot, if
you will.
The plan was completed at approximately 11 am this morning, and was faxed via a
broadcast fax beginning around 11 :30. For some reason the fax did not go through to Joel
Hirschhron on the first try and I re-faxed at approximately 12:30.
I have discussed this plan with Joel following receipt of his memo this afternoon. This
sampling event is not designed to be a one time deciding event or "catch all", nor is it supposed
to be in response to the "recommendations of the EPA study". Rather, it is designed to pull air
from the landfill and surrounding area and measure for PCB's and to determine if there are
airborne PCB's emitting from the landfill now. Joel has opposed it. I agree with him that we are
not using the most sensitive sampling methods available, however, we will have detection limits
which will coincide with published air standards to be used as a point of reference. I will
instruct the lab to achieve the lowest possible level of detection (LOD) for this method. Any
future, long term, air sampling and monitoring will follow a detailed implementation plan.
As implied in the plan, we have not had any reason to suspect uncontrolled PCB
emissions from the landfill, however, the science advisors have cast doubt on this reasoning, and
we wanted to pull some samples as soon as possible in response to the raised questions, just as
we responded by putting a carbon filter on the vent pipe. Unlike some comments, we are not
trying to cast doubt on everything, but continue ahead with testing and actions deemed necessary
as time goes by.
We will continue to deal with facts, not conjectures and miscellaneous comments.
Technically, I have no reason not to continue with the planned sampling event. Several scientific
people have been working on this for weeks, and it is certainly adequate for what we want to do
at this point in time. It is disappointing that comments like "absolutely no reason to trust the
study" and "biased state study" are being made. No one from the state is trying to be
"discourteous and disrespectful". I would appreciate the same type of professional behavior from
others as I think we could all get a lot more productive work done.
Copy: J. Hirschhorn
P. Barnes
B. Meyer