NCD980602163_19970117_Warren County PCB Landfill_SERB C_Re PCB Air Emissions-OCR

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Air Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Alan W. Klimek, P.E., Director
MEMORANDUM
TO: Alan Klimek, P.E.
.AVA
DEHNR
January 17, 1997
Lee Daniel, Chief, Technical Services Section
FROM: Laura S. Butler, P.E., Chief Jlb/
Air Permits Section (}/"
SUBJECT: PCB Air Emissions
Hirschhorn Recommendation January 13, 1997
PCB Landfill
Warren County
Attached please find Joel Hirschhorn's January 13, 1997 recommendation for
"Preferred testing for PCB air emissions; peer review''. By way of this memorandum, I am
requesting your review, comment and recommendation on Mr. Hirschhorn's report.
Your earliest review is requested. The Warren County PCB Landfill Working Group
continues to be concerned about potential human health effects and environmental
impacts from PCB emissions.
LSB:bw
c: Bill Pate
Bill Meyer
Lee Daniel
George Murray
Ernie Fuller
Attachment: ( 1 )
P.O. Box 29580, Raleigh, North Carolina 27626-0580
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Ja111.u1ry 13, 1997
To: M"ike Kelly •
From: Joe.I Hirsehhom
Subject: Preferred testing for PCB air emiasioris; peer review
As to the prefetted testing mothod$ fo1 det~t~,g ••wheth~r there is a problem" at the Wa.n·en
Comity Laudnll, X now have had till.le ·to. research the iSill~. My reoommendation to the state iR
that if a.oy testJng for PCB air emissio1u: is OOJ1duoted by the state that it &hould follow the
n1ethods etnployod by Indiana University m its work "Lt.ng-Term Meuuremonts of Atw.osphc1ic
Po.Jychlorinnted Biphenyls in tbei Viciuhy ofSuperfim.d DtUDl)S,'' (M.H. R'ermanson and R.A.
H'nes, F..nvirc,n, Sci&, 1'oohnoJ,, v.23 1 n.lO, 1989, pp,12543-1258).
n,c experim~atal approaoh \lsed in this relevant work was far more s01.1sitivc,, 8lld oomprebensive
than tne EPA work in 1982. PCB level~ in air at three community loo11tions, miles ft·om
Su1)erfund dump sites, wero mAdo.
The Indrana work correctly pAid attention to tho large effect of ambient temperature on PCB
levels .. eoncctly rnep~red PCBs in botl.l vapor and particulate forms, used high volume sampling,
had a detection limit very muoh l<>wer than in EPA's work, and measured and reported tote.I PCB
co.ugcne1 levels rnther than only two commercial mmures (f.e_, A.melon).
Noto that Professor Hites, one of the authors of the above &tudy, i& one oftbe two pei·sous Bill
Meyer asked fot a review of the W()rk cbndueted by EPA and my CQmments on it, Howover, I
stro.tt.gly object to th• way Bil Meyer $ought extcmaJ rovlcws. For·exampte~ l would want to
know the, eKtent to which Prof. Hites has funding nom B.PA. And &om whom did Bill Meyer
obtain the nameg: of the two persons he oholie to solicit reviews fi'oni'l No.r do we. know what
kind of stat~ts may have been made to Prof Hites by BID Moyel·. In any event, there is a clear
published record of the methods u~d by Prof. lft.tos vo.r,us those used by EPA. Intere$tiugly,
althouih the 1985 paper by Dr, Lewis et al of EPA was ref'erenoed in th.6 Indian~ paper, not OJLC
piece of data was cited, even though a large tunount of published data on PCB air lovels was
prese~tod l,y .Pro£ Hites in hii paper.
Ra~ed on my professional experienoo, I would not expect Pro£ Hites to say anything that Dr.
J,.cvvis of EPA lajght find disagreeable, because Ptof Hh6t would h~ve a lot Jl)Orc to lose than to
gain professionally. The 11une is true for the C.nadian regulatory off;'icial asked for a review. In
foot. most professionals pla.oed in the position that Bill Meyer c1·eated wo'Uld bo blased in fqvor of
a senior EPA petson. In order to rwoid this siguiijcant oonstrnint, someone in Bill Meyer's
position wo,dd have to crc$te saf~guards1 such as by assurlug oomplett oo:nfldentiality of the
H:vi(:Wcr's \d~ntify. And of co\ttse, if Bill Meyer wantod to be fair, he would have asked me to
n()minat.<, pertont for tu.ch • peor revlc\v.
cc: Technioal Committec,
I •