NCD980602163_19971007_Warren County PCB Landfill_SERB C_Joint Warren Co. - State PCB Landfill Working Group Meetings and Minutes-OCR

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~ MEETING REMINDER
The Joint Warren County/State PCB
Landfill Working Group will meet
Tuesday, October 7, 1997
at 6:30 p.m.
at the Warren County Office.
Joint Warren County/State PCB Landfill Working Group
draft September 22, 1997 Meeting Minutes
The regular meeting of the Joint Warren County/State PCB Landfill Working Group was called to
order at 6:30 P.M. Monday, September 22, 1997 by co-chair Henry Lancaster. The meeting was held
at the office of the Working Group.
NEW BUSINESS
Triangle Environmental, Inc. Letter
Mr. Lancaster called for discussion on the letter sent to the Working Group by Triangle
Environmental, Inc. (Triangle). Joel Hirschhorn began the discussion by saying that he sent a letter
to Triangle (See Attachment) and phoned them. He added that he was not impressed with what he
learned and that he did not see any bases for honoring their request. Mr. Hirschhorn said that he feels
sure that the Triangle's technology has not been tested full scale.
Deborah Ferruccio added that material for testing cannot be requested under the Freedom of
Information Act. She concluded by saying that what would keep other companies from requesting
material to sample. She recommended that a letter be sent to Triangle to advise them that the process
is closed.
Daria Holcomb asked what could be requested under the Freedom oflnformation Act. Mr. Lancaster
responded information only.
Tommy Cline suggested that a letter be sent to Triangle saying that you did not respond to the RFP
within the time allotted, however if the process is reopened then we will contact them. This statement
became a motion and was seconded by Jim Warren and carried.
UNFINISHED BUSINESS
Site Investigation Report
The site investigation report was given by Patrick Barnes with assistance from Mr. Hirschhorn.
Mr. Lancaster noted that the report was marked draft and asked what is needed to make this report
final . Mr. Barnes said if something is not clear in the report or if something has been left out, these
things would be corrected. That would make the report final. Mr. Lancaster asked Mr. Barnes to
summarize the document and then there would be time for questions. He, Mr. Barnes began my
explaining the goal of the investigation, which was included in the executive summary, the first
section of the report. The second section dealt with reviewing the files and learning what was in the
files and what was not. Section three dealt with the. procedure followed. He explained that the
sampling plan was followed with a few modifications. Section four dealt with the analysis of the
field-testing results. This section discusses the regional geology, site strata distribution, soil
permeability and groundwater flow. It continues with landfill soils/wastes, leachate, offsite
groundwater, offsite surface water, offsite soils and sediments. It concludes with air testing for
PCBs, landfill_integrity, _top liner, water in the landfill, the bottom liner, and the Richardson report.
draft September 22, 1997 Meeting Minutes
Page 2
During this discussion, Mr. Hirschhorn noted that there are different concentrations of wastes in the
landfill. He added that during cleanup this could cause some engineering problems. Mr. Barnes said
that there are some variations in concentrations but they are not extreme. Next discussed was the
presence of a dioxin not usually found in PCBs, 2,3, 7,8 dioxin. This may indicate that there is
something in the landfill other than ordinary PCB said Mr. Hirschhorn. He added that 2,3 , 7,8 was
also found in a sample that Eco-Logic tested. Ms. Ferruccio added that she remembers newspaper
articles that said that a higher form of PCB came from Fort Bragg. She asked the state if there are
any records of what came from Fort Bragg. There is no information in the files on what came from
Fort Bragg said Mr. Hirschhorn. The Working Group has requested this information from Fort
Bragg, but at this time they have not responded to that request.
Air emission was discussed next. Mr. Hirschhorn stated that air testing takes several weeks. He
added that most of the air releases have already occurred. However, there was one sample close to
the main vent that had a very high concentration of PCBs. Dollie Burwell said if most air emissions
have already occurred, is there no way to make a correlation to what is happening now. Mr.
Hirschhorn said there is not enough data to make a correlation. He added that the air emissions now
are "bulging and burping," not a steady flow . Ms. Ferruccio said that years ago EPA found air
emissions and recommended that air monitoring be done. Why did the State not follow that
recommendation? Mike Kelly advised that the State did some testing over a period and found no
emissions, so it was decided not to continue the testing. The air emission was high enough to require
regular monitoring and will be add to the recommendations said Mr. Barnes. Dennis Retzlaff asked
the Science Advisors if they could give a worse case scenario of the health effects of PCB air
emissions. Mr. Hirschhorn responded that there are so many perimeters to consider and there are
standard ways to quantify. He added that a health study should include the people who lived closest
to landfill at the time it was installed, they would be most impacted.
During the discussion of the landfill integrity, Mr. Kelly said that there needs to be more discussion
included on the top liner. Mr. Warren added that information on the clay liner should be included as
well. Mr. Barnes agreed to include additional information about the top liner and the clay liner.
Section five, of the' report, is the conclusion section; Mr. Barnes and Mr. Hirschhorn conclude that:
I) There are significant levels of PCBs and dioxins/furans in the landfill and the
concentrations vary.
2) There is no evidence of off-site contamination in surface waters, sediments,
groundwater or soil.
3) There is evidence suggesting some limited impact of the landfill on subsurface
materials immediately outside the landfill.
4) Contamination was found in two (2) groundwater wells, which indicates some failure
of the containment system.
5) _Water is entering and leaving the landfill and taking some contaminates with it.
6) There is loss of containment efficiency in the landfill's top liner.
7) There have been releases of PCBs into the air.
draft September 22, 1997 Meeting Minutes
Page 3
The last section of the report is the recommendations; the Science Advisors recommend the
following:
1) Additional testing, especially of material beneath the landfill. This would determine
the full extent of contamination outside the landfill that may need detoxification.
2) The Phase II contractor should use a contingency figure of an additional 25% of
material that may need to be detoxified.
3) The Phase II contractor should consider different cleanup standards for PCBs and
dioxins.
4) The Phase II contractor should be made aware of the varying chemical composition
of materials in the landfill. This could require blending of materials or a design
to handle maximum possible concentrations of contaminates.
5) In response to EPA requirements for regulatory compliance, the State should
determine if actions they take are effective in removing water trapped in the landfill.
6) Volumes of water extracted from the landfill should be analyzed to determine the
extent to which the leachate collection system needs repair.
After the report was complete it was agreed to give the members two (2) weeks to comment. The
Science Advisors should receive comments by October 6, 1997 and a final report produced by
October 20, 1997.
Technology Assessment and Selection Criteria
Mr. Hirschhorn began by saying that the criteria for selection were developed in the RFP. Mr. Barnes
added that he put together a scoring system based on those criteria. Ms. Burwell said that this is not
the detailed criteria. It is the legal criteria said Mr. Hirschhorn. After discussion it was decided to
wait to make the final recommendation after all the questions submitted to both companies have
received a response. Mr. Hirschhorn agreed to take the lead on a final report which will include a
narrative and a comparative analysis. A draft will be prepared by October 3, 1997 if all information
is received by Wednesday, September 24, 1997.
Legislative Session
Mr. Lancaster advised that they were not successful in getting the additional funds ($125,000.00) to
meet the Science Advisors needs. He will be meeting witQ Secretary McDevitt to see if the funds are
available to come from within the Department if Environment, Health and Natural Resources.
Other Business
First, Mr. Hirschhorn raised the issue of a request from Mike Kelly to shorten the time given for the
Phase II report.-He advised that originally the company was given seventy-five (75) days to produce
the report and now it has been reduced to thirty (30) days. Mr. Kelly responded saying that when
draft September 22, 1997 Meeting Minutes
Page 4
the contract is awarded, the company will be asked if they can produce the report in thirty (30) days.
They are not being told that they must produce the report in thirty (30) days. If the company does
not agreed, then the State would adjust accordingly. He explained that this is an effort to expedite
the process since the State has been accused of delaying the process. After discussion it was agreed
that Mr. Kelly could discuss this with the company.
Next, the Working Group was advised of a letter received from Eco -Logic announcing an open
house they have planned for October 2, 1997. After discussion Mr. Cline made a motion to send a
letter to Eco-Logic to encourage them to come when the Working Group holds it public meeting, if
they are the company chosen for the detoxification. The motion was seconded and carried. Mr. Kelly
agreed to send the letter from the State and the Working Group.
Ms. Ferruccio asked when is the Working Group going to be reconstituted. It was motioned by Ms.
Ferruccio and second by Mr. Retzlaff to send a letter to Secretary McDevitt asking him to
reconstitute the Working Group as soon as possible. The motion carried.
The last item discussed was a date for a public meeting. After discussion it was decided to have the
public meeting on November 1, 1997 with an alternative date of November 8, 1997. Details of the
public meeting will be discussed at the next Working Group meeting.
ADJOURNMENT
The next meeting is scheduled for Tuesday, October 7, 1997 at 6:30 P .M .. Ms. Burwell asked Mr.
Kelly to see if Bill Meyer can attend the next meeting to address the issue of noncompliance. The
meeting was adjourned at 9:45 P.M ..
HIRSCHHORN
@~ASSOCIATES ~ A Division of Hygienelics Environmental Services, Inc.
ATTACHMENT
l _j
✓
Suite 411
21101 Bluerldge Avenue
Wheaton, MD 20902
September 22, 1997 ............................................................................... by FAX
To: C. Thomas Hendrickson
From: Joel Hirschhorn
Ph one : [phone]
fr1x: [phone]
Re: Request by Triangle Environmental to test materials from Warren County PCB Landfill
I am writing to you in my capacity as a Science Advisor for the Joint Warren County/State PCB
Landfill Working Group, and because I have just received a copy of your 15 September letter to
Ms. Burwell and Mr. Lancaster.
I have played a major role in the work on cleanup technology assessment and activities for our
project. I would very much appreciate it if you would fax me as much material as you possibly
can that would provide information on the following points:
1. At the pre-bid meeting in Raleigh on February 17, 1997 for the bench-scale detoxification
technology testing RFP a Lyle Hunnicutt attended. Did that person have some relationship to
your company and the two technologies mentioned in your letter?
2. Can you provide any detailed technical data for the two technologies mentioned in your letter
on their effectiveness in removing and destroying both PCBs and dioxins/furans from soil
matrices?
3. Can you provide any infonnation on exactly where both technologies have been used full-scale
for actual remediation projects and, particularly, whether any of those projects included work on
PCBs and dioxins/furans? If there are such projects, would you be able to supply detailed reports
on how both technologies performed?
4. Nothing in your letter indicates that you would follow the exact protocol and requirements
established in the RFP for the bench-scale testing, which two other companies have complied
with. Are you suggesting that you are familiar with the RFP and would follow the protocol and
requirements, even though your company would bear all costs?
The \Vorking Group is having a meeting this evening and, therefore, I request that you fax
the requested materials to my attention at the \Vorking Group's office in Warrenton as
soon as possible and hop~fully before the close of business today; the fax number there is
919 257-1000, I expect to be in the Warrenton office by about 4:00 PM and the phone
number there is 919 257-1948,
3-0_1 -19~7 10 .02PM FROt.1
COMPARATIVE EVALUATION OF THE TWO PHASE I
REPORTS ON DETOXIFICATION TECHNOLOGY TESTING
OF MATERIALS FROM THE WARREN COUNTY, NORTH
CAROLINA PCB LANDFILL
Prepared by:
Joel S. Hirschhorn, Ph.D., Hirschhorn & Associates
in association with
Patrick A Barnes, P.G., BFA Enwonmental, Inc.
October 1, 1997
1.0 Introduction
In response to a Request for Proposals to evaluate treatment technologies on soils
extracted from the PCB Landfill. Warren County, North Carolina, issued by the Division of Waste
Management ofDENR on January 31, 1997, two proposals were selected for funding. The Rf P
had clearly identified two detoxification technologies as meeting the requirements established by
the Joint State/Warren County Working Group; these were Base Catalyzed Dechlorinat,cm (BCD)
and Gas Phase Chemical Reduction. The RFP notified potential proposers that the project was
divided into two phases and that mwtiple companies might be chosen for Phase I, but that only
oue complt.lly would be awarded a contract for Phase lJ.
Section 2.1.4 of the RFP specified the following selection c1iteria for choosing one
company for the Phase II part of the RFP:
a. The ability to meet Phase I performance criteria as demonstrated through Phase I
test data. The performance criteria were presented in Section 2.5 oftbe RFP. For post-
treatment solids the Principal Preliminary Remediation Goals were 20 ppb for total PCBs
and I ppt for Dioxin TEQ. The Air Emission Performance Goals were 8x10--1 micrograms
per cubic meter (ug/cm) for PCBs and 5x10·K ug/cm for Dioxin TEQ.
b. The quality of the Phase I test repon.
c. -The ability of the vendor to provide full-scale equipment at the Wan-en County
PCB Landfill site.
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d. The ability of the vendor to provide a safe, reliable and cost-effective full scale
application of the selected technology at the Wa1Ten Cowity Landfill. Section 2.2 of the
RFP further clarified the goals and objectives of the testing, particularly in tenns of
determining feasibility for full-scale deto,ci6cation and that, in addition to the meeting the
performaoce criteria, feasibility would also be determmed by considering the safety of the
technology, the rate of detoxification, the cost per unit of detoxification, 1he reduction in
long term potential for environmental releases from residuals of the treatmem process.
e. The quality and cost of the proposal for providing Phase ll s~ces.
This report by the two Science Advi~ors for the Working Group is the ~ompa.rative
evaluation of the two Phase I reports submitted in this project and is provided to the Working
Group aud the Division of Waste Management for the pwpose of assisting with tbe selection of
the Phase ll contractor. All reports and responses to questions submitted by the two compllllies,
ETG Environmental. Inc. (ETG) and ELI Eco Logic International Inc. (EL), have been
considered in preparing this report. The format is to present a discussion of the relative pros and
cons. or advantages and disadvantages, of each company's proposed technology for each of the
above seJection criteria. Finally, a summary comparison and recommendation is presented in the
last section.
2.0 .1\leeting the performance criteria
2. I Post-treatment solids -total PCBs
ETG conducted four test runs and in all four cases the total PCBs were reduced to levels
Jess than 20 ppb. The average of the four runs was 0.8 ppb. A consideration is the variatiou in
PCB levels in the input (raw feedstock) materials, which in. thls case averaged 506 ppm. Because
nondetects (NDs) are often reported, detection limits are also a factor in evaluating results. In
comparing two the companies the isrue that arises is if NDs are reported but the detection limits
(DLs) are different, then the NDs are not exactly the sam.e. With higher DLs the NDs are less
impressive, because the potential level of undetected PCBs is higher. Another way oflooking at
this issue is to realize tb.at with lower DLs it is possible to have positive hits or findings of PCB
isomers while if higher DLs were used, then those findings would not be present.
EL conducted three test runs and reported NDs for .all three results; however, the DLs
were significantly higher than in the ETG testing, primarily because smaller size samples were
used in the EL testing (i.e., 0.010 kg versus 0.030 kg.for ETG). The only scientific way to h~let
compare the two sets oftest data, therefore, is to recalculate the total PCB levels by using the
worst possible case in which it is assumed that the NDs are actually equal tc the DLs. This has
been done and the recalculated levels for both companies' data are given in the following table by
using tl1e data given in the respective reports. It can be seen that by following this procedure, that
the recalculated avenge for ETG increa&e~ to 1.84 ppb and for EL tJ1e average chan.ges from
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what might be intelJ)reted as zero to 3.63 ppb. Thus, while it is correct to say that both
companies were able to meet the pe.rfonnance criterion, it is also correct to conclude that ETG
performed better than EL, particulady because ETG conducted four runs while EL presented data
for three rans. Additionally1 the average PCB level in the raw niate:rials tested \\'aS 237 ppm for
EL but 385 ppm for ETG, which makes the ETG results even more significant, because a higher
fraction of PCBs were removed.
Company/sample Original total PCBs (ppb) Recalculated total PCBs (ppb)
ETGWCl-3 .74 1.33
ETGWCl-4 2_55 3.06
ETGWC2-3 0(ND) l.80
ETGWC2-4 O (ND) 1.18
ETG average 0.8 L84
EL l O (ND) 4.10
EL2 0 (ND) 3.40
EL3 o (ND) 3.40
EL average 0 (ND) 3.63
2.2 Post-treatment solids -dioxin TEQ
ETG reported data for four runs, with an. average dioxin TEQ of 0. 91 ppt, however one of
the runs had a value of 2. 96 ppt, but this was for the sample with the highest level of PCBs. fo
fact, ETG had optimized its process based on a much lower level of chemic.al treatment (BCD)
adclitive, which would explain why in this one run both the PCB and dioxin TEQ fovels were the
highest in the residual treated solids. In fact, the TEQs for the other three runs were exceptionally
low, with an average of about .23 ppt, which is insignific~t. It should also be noted that even the
2.96 ppt level is very low and that EPA and most states have not approached this level for dioxin
cleanups. For examp.le, for the Koppers Supernmd site clean11p in Morrisville, North Carolina the
dioxin cleanup level was 7,000 ppt.
EL reported data for three runs_ However, the dioxin analy!-ie~ were redouc for 1.uns l and
3, but not run 2, because of overly high detection limits in the original testing. Also, some dioxins
were originally found in run 2 mat~ despite high detection levels, because ofhjgh dioxin levels
that resulted from run 2 representing a process f.ailure due to too low a tempenture ju the TR.J\.1
desorption unit.that did not aUow removal of dioxins for chemica) reductjon in the second hig.h
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temperature stage. This is discussed in length later in this report. The originaJ TEQ values for
IWlS l and 3, based on using detection limit values was reported by EL as 15 ppt and 32 ppt,
respectively. If the value for run 2 is included, then the average for all tb.ree runs in the original
data is very high at J 42 ppt, and with the data from the retesting it is 127 ppt. The data are
summarized in the follo,ving table.
It is shown how comparable data can be used from both companies, in te.rms of either data
from all runs or only the best runs, and for EL for original and revised data. For exaJJ1p]e, tJ1e
average for the two best EL runs can be compared to the average of the three runs of ETG that
represented their best p.rocess perfonnance. In other words, if all test data are considered for
both companies, theo. EL clearly fails to meet the pexfonnance criterion, and if only the best runs
are considered for both companies, then EL meets the c-riterion but ETG has superior
performance. From a community perspective, it is valid to judge the companies on the basis of all
their data, because they are responsible for suboptimal nms.
Average Dioxin TEO Levels (ppt)
TF.ST RUNS ETG ECOLOGIC ECOLOGIC
original data re\ ised data
·-
Allnms .91 142 127
Best runs .23 24 .50
It should be noted that the average dioxin TEQ level in the raw materials for EL runs 1
and 3 (the best runs) was 186 ppt, and 175 ppt for the three best runs of ETG. Proportionally,
ETG had slightly better perfornunce (i.e., 99.89% versus 99. 73% removal).
2.3 Air release.s -total PCBs
ETG reported data for three runs in terms of both stack discharges and modeling results
for a property liue assumed to be 200 feet from the equipment, which is a proper procedure for
addressing an exposure concentration (and that had been deemed appropriate at the pre-bid
conference for the RFP). In f.act, the performance criteria bad been established on the basis of
exposure concentrations for a very low risk level. The average of the ETG data was .87xl0·4
ug/cm, or about one-tenth the performance criterion of 8xI0"'ug/cro.
EL reported data for three runs in terms of stack gas concentrations only, for which the
average was l.26xl0·4 ug/crn, which is below the performance criterion at the stack, and which
automatically makes it below the criterion at any distance to an exposure point.
The ETG data for the stack concentrations were significantly higher than for the EL data.
However, air sampling methods and equipment were not identical and, therefore, a direct
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compariso.o of stack data alone is not necessarily complete. The main problem is that an air
sampling procedure that is more efficient and effective in removing material and obtaining low
detection levels will have a higher probability of detecting contaminants. For example, sampling a
larger volume of gas will increase the probability of detecting contamin8lltS. For example, the
stack gas flow rate in the ETG tests were about three times larger than in the EL testing,
suggesting a higher sensitivity in the ETG air testing. It must be emphasized that the performance
level set for this testing was e>..1.reme]y low and stringent and that the data from both cowpanies
indicate3 that o.o health hazard would be caused by PCB air emissions from the detoxification
process. Indeed, in all probability there may be greater concern about potential PCB air releases
from site excavation and mateiial handling pJior to treatment in equipment, but 1his issue shouJd
be addressed in the Phase Il work.
Based on available info.nnation it can be said that both companies are comparable on this
sub-c.riterion.
2.4 Air releases -dioxin TEQ
ETG reported stack and model data for tht ee runs. The model data had an avenge of
.52xto•t< ug/cm. about a tenth of the perlonnance criterion.
EL reported that no dioxins/furans were found above detection limits, but tJ1at the highest
possible level was I. 7d o·~ ug/cm, which is higher than the performance criterion. Thtrefore, EL
said that ''Due to these sampling and analytical constraints, it is not pos!;ible to demonstrate the
ability of the ECO LOGIC Process to meet the dioxin TEQ performance goal .. '' The highest
possible EL level is some 1000 times greater than the perfonnance goal. However, if EL would
have modeled its data to address levels at some reasonable exposure point, then it would hove
been able to show compliance, because its stack level was wnil.ar to that found by ETG.
The Science Advisors conclude that ETG has the advantlge on this sub-criterion.
3.0 Quality of the Phase I report
Making a professional judgment about the quality of a technical .report can involve many
consideration:; Certainly, the reports should present the informatjon rnquired in the RFP in a
user-friendly format. Additionally, however, the quality of the report can be consiclcled to be
higher when there is considerable attention to particuLirly important issues and ·when additio.nal
in!ormatjon is provided to a.,sist the understanding and evaluation oftbe testing. It must also be
noted that EL submitted a draft report which was then m.odified in response to V:i..rious questions
and comments to produce a final report, while ETG submitted only one initial final report.
Therefore, to some extent the one submission by ETG is comparable to the second submission by
EL that correGted deficiencies in the original draft report.
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As an important example of a difference in presentation quality, consider the Tables 4-5
and 4■6 in the ETG report, which presented in easily understood tabular form the primary data ou
treatmeut effectiveness for PCBs and dioxins/furans for all the test runs, and for all the individual
· i!;oro.ers or congeners in each category. A reader could immediately see how the post-treatment
levels compared to the original raw material levels, and when nondects were reported the
detection limits were also presented. In contrast, the EL report presented the analogous data in
two separate tables (Tables 8 and 9), and the contractor had to be instructed to provide detection
limits in the final report, and neither table presented the data for all the individual isomers or
congeners in the useful way employed by ETG.
Another factor was that ETG presented more information than was strictly required. For
example, ETG presented the results of testing to show that their process bad actually destroyed
PCBs and also obtained data on particulate levels in emissions and water content in raw feed
materials.
It must also be noted that the quality of the report is merely a surrogate for the quality of
the bench-scale testing. In this sense, it is important to note that EL conducted three runs versus
four for ETG, and that one of the EL runs (run 2) was essentially a f.ailUie because of an operalo.1
on-or that caused the initial TRM desorption part oftbe process to fimction poorly due to a low
temperature that did not separate dioxins/furans for chemical reduction in the second pa.rt of the
process. A major aspect of any type of technology testing is to see how well a company conducts
itself and operates its o\\-n equipment to demonstrate a very high level of competence that
provides confidence to potential clients that the very best performance will be obtained in frill-
scale usage. The main guestion tha! mrnts attention for this aspect of the EL te~g is wh)'. the
senior persons in charge ofthe test did not identizy the low tew,crraturc;_problem dwjng the 1m
period and rta1eat the test run, This was especially important because only three runs were used.
Also, in discussing this event EL has referred to a minimum temperatnre in the TRM 11Dit
of 5 50"C, but the unit is supposed to operate at 600°C according to the information in the EL
report. EL did .not provide detailed data for run 2 on exactly what temperature was used or for
how long a suboptimal temperature existed duriug the run, except that the te.mpenture dropped
to 500"C. However, it reported average mill temperatures of 595°C, 572°C, and 628"C fo1 test
nms 1, 2, and 3 respectively. It is interesting that two of the runs did not have average
temperatures of 600.,C. The fact that the average temperature in run 2 was above the 5 S0''C
minim.um that EL has mentioned also raises a question of uncertainty about what actually
occurred in run 2 to so thoroughly cause no treatment of the dioxin contamination. The
jnfonnation suggests that out of the total of 15 minutes in the TRM unit even a small amount of
time at suboptimal temperature is sufficien.t to cause a·complete f.ailure to remove ruoxin
contaminants from.the feed material, which is a serious sensitivity to low temperatme excursions.
EL also had a problem with an important part of its dioxin testing, which it blamed ou the
testing laboratory. However, much of what has been said by EL simply does not hold up under
close scrutiny ... Part of1;he competence of a COJ11)any in the remediation technology business is
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expertise for obtaining the best analytical services. If a company provides incomplete or
misleading information to a chemical analysis laboratory, then the laboratory may perform poorly.
In the EL testing, some of the most critical dioxin testing was inferior because of high detection
limits that resulted from unusually small sample sizes for the testing. EL dai..'llS that this resulted
from its telling the laboratory that there were high PCB levels, and that this caused the laboratory
to use lower than normal sample quantities. There are two problems, however. First, tJ,e overall
PCB levels in the .raw materials (information given .in the RFP) were not exceptionally hlgb for
PCBs. Second, certainly there would be no rational reason why EL would want the Jaboratory to
believe that PCB levels were high in their treated materials. EL also said something that any
experienced professional who deals with dioxin testing of solids knows is inco,rect, namely that a
target value of 1 ppt dioxin TEQ is impossible to obtain or verify for method 8290. lnis .is plain
wrong; as any examination oftest results for this method clellrly shows, including the dioxin test
data obtained for the project's site investigation work. as well as the dioxin testing for ETG .from
the same laboratory used by EL. In the opinion of one of the Science Advisors, who does
considerable work with dioxin contamination and cleanup and who discussed this is.sue with both
companies, EL did not exhibit a high degree of knowledge and experience in thfa area. ETG
verified that at no time did it change its instructions to the analytical laboratory that both
companies used, nor is their any logical basis for believing that actions taken for EL samples
would have affected ETG work in the very large laboratory. The one key fact th.at seems to
explain the cause of the dioxin testing problems f.aced by EL was the info1matiou it provided to
the laboratory which caused them to use irregular, low sample volumes for testing.
Another issue is that EL did not clearly represent what mate1ials it tested relali,..e to the
materials it bad received. EL wd that it received three 5-gallon buckets but that only two were
used. But no information ~as provided to indicate exactly ·what materials were tested in EL's
three runs. In contrast, ETG clearly indicated what materials had been received and tested in each
of their four ruus.
The professional judgment of the Science Advisors is that the ETG report followed the
requested format of the RFP more closely than the EL report, and that the ETG repo1t vvas in
general easier to follow and presented key information in a more concise manner than the EL
report. As the above discussion i.ndicatest the conclusion is that the quality of the ETG report 1U1d
its testing '"·as better than the EL report and its testing.
4.0 Ability to provide full-scale equipment
Both companies are in the position of roost technology vendors, na.m.ely t!J.at ejtlJer an _
existing piece of equipment could be transported to the site and used, or new equipment would be
constructed for the particular job. Both oompanies have indicated that they would need up to six
months to provide necessary equipment> which is consistent with industry practice for large
cleanup projects. But there is more to consider for this evaluation criterion. The ability to
provide full-sc!!le equip~ent is legitimately related to the stability and viability of tl1e corupauy,
7
PB
3-01-1997 10 :06PM FROtvl
because some significant investment is necessary for a large projed, which this one would be
potentially. ETG is actually part of a business that is well established commercially and quite
substantial financially, and it has performed in similar remediation applications for U.S . clients
over some years.
Interestingly, in the BCD treatment technology arena, which. is based on companies
obtaining licenses from EPA, ETG has outlasted other companies. In c-ontrast, EL i:; more of a
sta1t-up technology developer that has had few clients (and none in the U.S. for actual full scale
work) and is not the same level of a stable, .financially successful company ·with a long commercial
track record as ETG. There may also be some significance to the fact that ETG is a U.S.
company located nmch closer to North Carolina, while EL is a more distant Canadian company.
It is also of some relevance that a very recent study for a major federal Superfund site at which
dioxin is a major contaminant (the Escambia Treating Company site in Pensacola, Florida)
examined potential treatment technologies, and the EPA contractor doing the Remedial
Investigation/Feasibility Study screened out EL and its technology a.t the earliest stage of
technology evaluation. but included BCD treatment and cited ETG as the source of the BCD
technology. While EL has performed treatability and demonstration tests in the U.S . it has not yet
secured any actual remediation project. In contrast, ETG is the vendor cleaning up the Southern
Maryland Wood Treatment Superfund site, where it will treat some 145,000 tons of material.
This job is closer to the Warren County project than any work that EL has perfonned.
Tue Science Advisors conclude that overall the ability to provide necessary full-scale
equipment for the Warren County project is better for ETG than for EL.
5.0 Safety, reliability, cost, and long term releases
5.1 Safety
There 1ue two major ways to look at the safety issue. First, the intrinsic nature of the
tec-hnology can be assessed in terms ofinherent ha:urds. For example, any process thnt utHizc:s
hazardous materials is fundamentally .more hazardous than one that does not use any hazardous
materials, and one that operates at either higher pressure or temperature than anothei one poses
more potential for unsafe situations.
The second approach is to consider how vulnerable a process is to human error, because
most unsafe conditions and accidents relate to human error. Some technologies are inherently
safer because they are much simpler than other technologies, for example. As for treafability 01
demonstration testing~ it is presumed that a company will logically use its best trained and
qualified personnel. If human errors occur in testing, it does not portend well for full-8cale
company operations.
ETG technology operates at a lower temperature than the EL p.rocess, roughly about
8
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onehalflower temperature. The ETG process also operates under vacuum conditions, while the
EL process operates at ambient pressure, and this reduces the potential for system leaks and
discharges of contaminants into the environment. The EL technology uses hydrogen gas, which is
intrinsically hazardous, while the ETG technology uses no hazardous materials, \:lr1th the exc•.!ption
of sodium hydroxide which is corrosive but not combustible or toxic. The EL process also
utilizes a bath of mohen tin, which raises a safety concern.
Although EL has made a good argument that industrial processes have used hydrogen
very successfully, there is still an inherent hazard that cannot be entirely dismissed, especially
when one recognizes that safety issues generally are centered on unusual, unintended and
unforseen incidents or accidents .. While process control instrumentation and monitoring
equipment may be u&ed, the problem in the real-world are low probability events that consist of
several things going wrong to create an actuaJ problem For example, for everyone of the nine
factors that EL has cited to assure the safety of using hydrogen it is possible to identify a
condition that nulli.fi.es the factor. For example, EL says that no open flames or smoking are
permitted onsite, but any experienced professional has probably seen just such human behavior oo
actual industrial sties where the prohibitions exist. Similarly, leak proof process "essels in th e
fieJd can be rendered unsafe by, for example, a bullet piercing a piece of onsite equipment. The
use of nitrogen purging to avoid mi"allg v.ith oxygen can f.ail when someone uses a wrong gas
tank or makes a 'M'ong connection.
On the issue of human error, it is also relevant that in the bench-scale testing for this
project, there was a clear, admitted case ofhtunan error in the EL test, v.--hen a temperature was
not properly controlled in run 2 in the TRM unit. EL also acknowledged a second "operator
error'' when the excess gas burner that was supposed to be operated at 800°C was a,::tually
operated between 300 to 400°C, apparently for all the runs. The company also had problems ,..,ith
equipment, including a micro-Ge instroment that was supposed to be used but was not
operational, and a broken mill shaft "vhich happened twice and caused delays.
Another safety issue is the potential for the air pollution control system to function
effectively to prevent unacceptable discharges of hazardous substanc.es. In this regard} the ETG
report paid considerable attention to this issue and provided extensive discussion of how the
company would employ the most sophisticated technology to collect and treat dut-1.
The Science Advisors conclude that, assuming that either company would employ the best
industrial safety practices in design and operation of their equipment, the ETG technology has ai1
advantage over the EL process. · ·
5.2 Reliability
ReliabUity can mean many diffcl'ent things, but one key engineering concept is whether a
process technology will offer the best performance under varying field and raw material
9
3-01-1997 10 :08PM FROM
conditions. In other words, some technologies are more sensitive or vulnerable to variations in
key conditions or parameters and become Jess reliible because there are upsets created. Some
technologies a.re very complex: 'With multiple steps or stages and the need for very oompJex
process control and monitoring equipment. All of these issues can reduce reliability. The use of
computers and sophisticated equipment has not eliminated major problems in industrial processes.
An issue of concern in the current project is the degree to which the detoxification technology
may become unreliable because of high water content in feed materials, for example. To some
degree it seems as if the EL process would be less sensitive to water content~ but in fact a dose
examination of discussions of this topic by the contractors reveals essentially the same prnblem.
That is, both processe~ can handle higher moisture levels, but both would be negatively impacted
in terms of throughput, efficiency and processing time. Moreover, ETG actually measure.tl water
content and concluded that no dewatetin.g of nuteri.aJs will be required.
An important fea.ture of the ETG process js that there is solid phase BCD treatment of
PCBs and dioxins in the thermal desorption part of the process and then more BCD liquid phase
treatment of oily condensate, if necessary. Their test resuhs showed that the solid phase
detoxification was successful. In contrast, in the EL process there is no detoxification of PCBs
and dioxins in the first stage thermal desorption unit, and detoxification is dependent on first
separating the c;ontaminants into a vapor phase that then undergoes high temperature reduction.
As the testing showed, the EL process was vulnerable to poor performance when the thermal
desorption stage was not operated at optimal conditions and, there.fore, dioxins were not
detoxified.
It is the opi11ion of the Science A~ors that the ETG process is intrinsically simpler and
Jess prone to problems created during full-scale use that would reduce reliability.
5.3 Cost
EL has said that it foresees a cost of $300 to $350 per ton, llased on processing 100 to
200 tons per day v.-;th a 70 to 80% availability, leading to a project dlll'ation of 90 to 123 weeks.
The availability rauge used by EL is not impressive and may indicate its experience in actual
projects where there has been significant down time. This cost does NOT include ce1tain
activities, such as excavation, performance testing or disposal of processed solids, but it DOES
include system mobilization and commissioning, all waste preparation and processing, lab costs
for process outputs analysis and system demobilization.
ETG has said that its estimate of$390 per ton pertains to a processing rate of 300 to 400
tons per day with 100% availability. ETG's cost is all mclusive and includes excavatio11. and
backfilling of soil, which the EL estim.1te did not. ETG has also indicated that if less stringent
cleanup performance standards were used, then the cost could be decreased by some 35% if more
typical criteria ~ere used for PCBs and dioxins. In fact, it is highly probable that the stste would
use its normal cleanup criteria and that the ETG cost would likely be less th.an $300 per tou. It
10
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..... '
should be o.oted that there is less intrinsic capability to reduce operating costs in th~ EL process,
as compared to the ETG process, and that EL did not offer a similar obseivation. Note that the
processing rate for ETG is about twice as high as the EL figure, meaning that total project
duration might well be reduced by 50% and require about one year rather than two years.
The Science Advisors conclude that for cost and cost-effectiveness the ETG process is
superior to that of EL.
5. 4. Long term releases from residuals
Any detoxification technology will create certain types of residuals. byproducts or waste
effluents that might pose longer term risks because of releases. Both companies hav~~ paid
sufficient attention to this issue and provided similar discussions about the safe and effective
handling of all process residuals and wastestreams. and neither has an advantage. Tite more
confidence there is in the company's ability to reduce residuaJ Jevels of PCBs and dioxins to tbe
lowe~ possible levels, then there i~ minimal concern about long term releases from post•treatment
residuals replaced on the landfill site.
6.0 Quality and cost of Phase II proposal
The initial proposals that responded to the RFP included a proposal for the Phase II work
For the most part, both companies submitted comparable proposals that addressed the
requirements of the RFP. Both companies teamed with large, experienced environmental
eugineering .firms for the Phase Il \vork. However, the cost of the ETG Phase Il work ,,as
significantly less at $89,000, while EL proposed a cost of$115,000.
The Science Advisors conclude that ETG offers a significant cost advantage for the Pha~c
Il work, especially in light of currently limited funding for all aspects of the current pro,iect. l11at
is, the saving of $25,000 offers the potential ofbeittg able to accomplish other fimctions and 11e.eds
prior to the state legislature authorizing funds for the full .detoxification of the landfill.
7.0 Summary comparison and recommendation
The following table presents a simplified swmn.ary of the conclusions reac.:.hed for the
individual evaluation criteria. Rather than using an artificial and subjective numerical rating
system, the Science Advisors have indicated a net advantage in terms of a + sigu for the company
\.\ith the best capability. When both companies were comparable. both received a+.
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3-01-1997 10: 09Pt-1 FROM
,. .....
SELECTION CRITERION ETG ECOLOGIC
Perfo:r:mance
solids -PCBs +
solids -dioxin TEQ +
air-PCBs + +
air -dioxin TEQ +
Quality of Phase I report +
Ability to provide full-scale equipment +
Safety, reliability, cost, long term effects ++++ +
Phase II proposal, quality and cost +
As can be seen from the table, in most categories ETG was judged to have an advantage.
lbis is not to say or imply that Eco Logic and its technology was inferior, poor or completely
unacceptable, but only tltat, in this particular testing and for this specific application., ETG has a
number of advantages, as presented in the previous discussions. On the basis of visiting the te~
sites, having discussions with company personneL and examining the reports, the Science
Advisors agreed that ETG seems a more engineering oriented company, while EL seems more
R&D or science oriented, with less of a practical, engineering constructio.n focus.
Also, a close examination of all documents provided by EL indicated the following: ( 1) the
c-ompany probably has not met the stringent dioxin cleanup criteria used in this project iu previous
projects; (2) the September 1994 EPA report on the thermal desorption unit found that it "did not
perform to design specifications" and that the company "experienced material handling problems;"
and (3) tl1e company does not seem to .have been able to perfotDJ commercial projects at a pro.fit
aud may be experiencing uncertain financial conditions. On the latter point, the last two annual
reports from EL indicate th.at the company has continued to be unprofitable, despite rising
revenues, while the information supplied by ETG indicates a medium size euvironmental services
company that .is profitable. For example, the highest revenue stream for EL in 1996 was less than
$5 million annually (for which the annual Joss was nearly $12 million), while the company that
ETG is a division of grosses about $50 million and is profitable.
In conclusion, the Science Advisors agree that .ETG is the best qualified c:ompan)"
for receiving the Phase II contract and advise the Working Group to accept this selection
and to formally communicate its recommendation to the Division of W.aste Management.
12
P 13
F'CB l.1.ICIFK I t'-JG 13RCIUF' Fax :[phone] Feb L·? '97 8 :48
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
720 Ridgeway Street
Warrenton, N. C. 27589
Phone [phone] -Fax [phone]
Fax Cover Sheet
TO: Pat Williamson
FROM: Doris Fleetwood
DATE: February 27 , 1997
Number of Pages, including cover sheet: 2
Pat:
Here is the article that appeared in the Warren Record.
F·. 01
..,...-------
F'CB l_dl]RkrnG 13F::IJUP Fax :[phone] Feb 27 '97 3 :43 vvorK cxpec,ea , 10 Deg1n ner-e
...
. .---'
On Cleqnup Of PGB Landfill
, .. ' ' '; !~; • \·· ~-~ . '
Work. is expected to begin · million/' Warren said. 1
this week in Warren County to-N.C. Senator Frank Ballance,
ward clean-up of a problem-rid-whose bill led to the state 's
den, state-owned PCB landfill. 1983 pledge to decontaminate
This wcekt under the guid-the site, said he was .. happy that
ance of science advisors hired we arc finally geuing close to a
by the Joint Warren C6unty/ resolution of this issue, and that
State PCB Landfill Working our efforts to secure St million
Group. state work.e~ and inde-in the 1995-96 legislature to
pendent contractors are perfonn-begin this process is now paying
ing tests to help cvaluatf the fa-dividends.". • .
cltity's current status. · I, · In 19'J3;' the state acknowl~
According to PCB Working edged that over a million gallons
Group member Jim Warren, of water are trapped inside the
contractors are drilling addi ~ , · PCB landfill. · ,
tlonal monitoring wells around · "The two science advisors
the Afton site to help determine expressed concern that water is
whether PCBs and dioxins have ., migrating in and out of the PCB
leaked out of the landfill and landfill, but the e,ttent of any
possibly migrated off flSite. . , chemical releases into area
In addition, comprehensive ground or surface waters is
air sampling is expected to help uncenain," Warren said.
identify weaknesses in the top "PCBs and dioxins are highly
liner of the landfill. toxic chemicals associated with
In March, sediment samples .. a wide. range of human health
will be taken .from key areas ~amage," he said.
around the site to identify re-The . Working Group has
leases which may have occurred asked EPA .. to conduct a
during the construction or op-. ''thorough regulatory compli~
eration of the landfill. ance audit for the entire history
Warren explained that sci-of the dump.''
cnce advisors hired by the Warren said that the science
Working Group have perf onned advisors have identified "several
a feasibility study for detoJli-imponant areas where the state
fication technologies and have has not met federal requirements
identified two processes deemed for the facility's design and op-
suitablc. ' enttion."
"Next week, contractors are ·· At the request of the Working
expected to remove several Group, the state installed a car-
hundred pounds of the contami-• bon filter on the landfill' s air
nated soil from the PCB landfill vent in December to prevent re-
which will be sent for bench-· leases of PCBs.
scale testing of the two tech-· Warren said that Govemor
nologies," Warren said. Hunt has been invited to partici -
He said that results of the pate in a public meeting in War-
. bench-scale studies, expected ren County to ~iscuss silc de-
this spring. will be used to mea--: · contamination.
: sure the safety and effectiveness · ·.. The Working Group, com-
. of the clean-up process and to · prised of local citizens, envi -
develop a preliminary design ' · ronmentalists and state officials
with accurate cost estimates for has developed a "process to
full-scale decontamination of move towant honoring a pledge
the site. · " made by the state to decontarni -
' "It ts believed the clean-up . nate the site when feasible to do
will cost ln the range of $25 .. ,. ,o.'',, . . , .. ,
l.•
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