NCD980602163_19980324_Warren County PCB Landfill_SERB C_Mermo from Mike Kelly to PCB Working Group re Air Monitoring and Methane Testing at Landfill-OCR

F'1B uJIJRK rnG GROUP Fax:[phone] Mar 24 '98 12:17 P.01
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
CO.CHAJRS:
l>Ot-UEB.BURJYELL.
111!Nlff LAf,J(.:Anvt
720 RIDGEWAY STREET
WARRE:NTON, N.C . 27569
PHONE Q 19-257-1948 -FAX 91 !J-257-1 000
-~ FAX COVER SHEET ·:.-r; . •·, ~
(,.'· '··;"J
TO:
FROM:
DATE:
Laura Butler
Dollie B. Burwell
Tommy Cline
Nan Freeland
Deborah/Ken F erruccio
Mike Kelly
Henry Lancaster
Sharon Moore
Dennis Retzlaff
Bobbie Riley
Jim Warren
Doris Fleetwood, Secretary
PCB Working Group
March 24,_ 1998
Number of pages (including cover sheet): 0
919-733-5317
919-758-102 l
919-733-1431
919-832-9100
9 l 9-257-2604
919-715-3605
919-715-3060
919-733-2120
919-257-2897
919-431-1453
919A93-6614
F'CB uJIJRK rnG GROUP Fax : [phone] Mar 24 '98 12 :17 P.Oi •
,,.-Meeting Reminder
The Joint Warren County/State PCB Landfill
_ Working Group will meet
Thursday,
March 26, 1998
at 4:00 p.m.
at the Warren County Office.
P~B IJJORf< rnG GROUP Fax :[phone]
March 231 1998
MEMORANDUMi
TO:
FROM:
PCB ioR.KINo OR.OUP
PAT,-uCK BARNES
JOEL HIRSCHHORN .
MIKEKBLLY
t1ar 24 '98 12 : 18
SUBJECT: AIR MONITORING AND METHA~'B TESTING AT LANDFILL
P.03
As you will recall, wo had aareed to continue to do aome routine air monitoring at the PCB
landfill. I just wan~d to let you know that I have penonnel who will be at the landfill on
Wednesday and Thi4llday, the 25th & 26th.
We will be settins up three high vo lume PCB air terting pie~s of equipment for a 21' hour
period. In addition, methane monitoring will be done in the v!nt and extraction wells, and
providod that the 1round is not too wet, we will also put in some additional pluas around 1he
landftll and test for Methane.
P jerre Lauffer and Wendy Peacock will be leadini the staff effort, as thoy hlve done in the put.
CC: Bil! Moyer
H~rn)·~tor
DollicB~ll
PCB WORKrnG GROUP Fax:[phone] Mar 24 '98 12 :18 P.o)
March 24. 1998 ............................................................................ " ... by FAX (3 pa£c:&)
To: PCB Working Gtoup
,
'Ibrough: Doris Fleetwood (f.ax to m~ers if possible)
From: JoelHnschhoni
. Br: Ml»YI fill: mttlill& this Tbw,day. March 26
Th" purpose of this memo is twofold. First, I. want to provide some more expla.,atiou and
support for the figures f'or community relations activities I provided to ETG in my comments on
their fir-st drJ.ft Pn•se TT repon. Second, I want to make the case for including some Language in
the report concerning state recovery of a portion of the total cost of detoxification.
l. Recommended bud2et linejtem cost for commu.ruty rdatiom
In my earlier work I proposed three components to this c-0st: S2S0,0OO for two Sc1cncr:
AdviiWrs over the entire course of the detox project, $75,000 for all office operation. and S'75.000
for v:arious community outTeach activities, for a total cost of $400,000. 1.n~rnaio tota.lly
convinced that these are reasonable and appropriate figures, yet there is no inwcation that DB"R
is willing ta acceµt them and advise ETG to use them, not does it ~eem that the Working Group
hu. fonmlly &Ci)eJ)ted these figure~ Based on o.i:ady 20 years of e,i>erienc.e with de11rrnp si.tc:~
and projects I believe that thesr; i.pending levels are appropriate and necessary to ensure the
highest quality and &afe&t possible detox project that in all ways benefits the local community. It
would be unwise for anyone to plan on seeking other sources of funds for these activities. Now is
the correct tim~ to build these costs into the total detox budget request, '-Viu.ch will have a tot.ii
v~· close to $24 million. Cleai·ly, $400,000 is a very smAll percent of the total rnst (Jes!< th1il1
2%) and does not in anyway inflate the project cost or make it infeuible or less attuctiv;:
Members mould appreci..tte the very extensive need for independent tec..hnfoal advisors
haviu& primary respon.~y to ufeguard the interests oftbe local communit)· for such a majr.r
project. Here is mor~ explanation of what 1 believe is the full scope of such ad\'isor:-,, acti, ities
~· Upon funding of the project by the legislBture, the advisors should review all DEN.It activitit;;;
re1at~ to releasing one or more RFPs to obtlUII one 01 more ~ntractors to implement the project
This is a most crocial phase, bCQause of the potential for DBNR to directly ot rubtly provid::
opportu.lllties for usine detox or remedial technologies other than the BCD te.::.huology sel~cted
from the Phase I/II activity. Advis.ors n~d to review very closcl), a.U language that DE"l\fR 1J~e!. in
.RfPs, which.migln be issued for a des.ign and oonstnlction package, or for each scpant-ely. The1e
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F'r.:B ldCIRf< WG GROUP Fax :[phone] Mar 24 '98 12: 18 P.05
is a major potential for DENR. to uie:Oompletely different technical approach than BCD.
depending ofcouue on whether very explicit language requiring BCD is use-d by the legislat ;.1re
-·Advison could al.&o participate int.he selection of contractors to ensure the highest quality and
ufesi project_
-·Advisors would have to ex.amine an enonnous amount of material in the final desigil ofrh~
project. The ClllTeDt Phase D preliminary design report probably repre~ts no more than about
l 0% ~-hat v.ill probably be the 6nal design package. I have played this advisory role for a number
of communities and bow that review &nd comman.ts on de.agn of such projects is a very labo1
intensive activity.
{· -~ There must be some additional site investigation work to determine whether thee are any
materials outside or below the landfill thti.t merits detox. This activity, &oni design through
implementation, requires close review to ensure that all nuterials warranting detu,c are actually
determined to so-by DENR and the conuaetor.
-·Onc.e a .final design is accepced and a selected contractor mobilius. tvery step or stage of the
process requires close scrutiny, Equipmmt, prooeduns, and processe~ mu~ be .:areti.illy
examined to ens:u.re both compliauce with the final design and the safest po~ble i1t1jllt:roer1tat.iou.
There a.re endlesg fi.e1d decisions and new circumstances not entirely anticipated m th~ final design,
which means that thort are inevttAbly a multitude of degigu change~ made during pro_jert"
unp!emeutation, Reports and onsite activities require con.sider time and ctlort h) aJ·.isors.
Especially duriug an in.iti~l onsite demonstration of technology the close ~"nlt-in,:v of e4ulpment
conditions . test equipment, protocols . .and data is extremely intporu.nt. Detenniuing whether
detox treau:ne:ut equipmeut is r~al.ly working effectively and s.afefy. and whethet l11 onsi.te
mouitoring equipment is fimctionini properly and at low enough detection timiti;; ne cmcial
Tbc-r~ is .an enormous amoWlt of da.ta to eX2.mine cloSt}y Natura.l)y, the activities of DFNR as
well as the oonttactot and Aibcontr:;u:ton tnuSt b~ watched.
,.()n,~e full seal~ oui,jte detox activities im:: initiated it remains a challenge to eH:iure that budfi_lJ
ex..:avatioo, waste detox. protocols for dete.rminins whether the treatment n::siduals can be
hackfill~d, and all environmental monitoring are all being implemented acc-0rd.ing to design md
regulatory requirementi..
--The advisors should, of course, .!l.lso play a role in all community relations act:vities frmn start to
finish, which means keeping either the Working Group or ~o~ new Community Advisory Board
fully informed about sll activities and whether there i, a need for explicit a.:.tlons to oblain
\J.natever is needed to ensure I safe tnd effective project The advisors would al;;o pl.a:' a role in
i;oa,munity outreach activities. 2nd would also play a role in ensuring that loeaUy av.lilable lahm
and supr,liers are being utilized by the contractor(s) to the maxinmm extent possible
--Eventually.,.. decisions about fully accomplishing all project requirements must bi: can;full-,,·
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Fl:B WORKING GROUP Fax :[phone] Mar 24 '98 12:19 • P.06
ex:amined aud the safe demobilization of on site equipment and resrontion of the sjte assured
l. Reim,huoomcnc 0( pr;oJ,s;t con, by the V,S, Am1y
It .i.& abundantly clear that the Army has a legal obligation to reimburse the state for its fair
share oftbe detox project costs. It iJ highly desirable that the Phue II report include a small
section within the cost estim.11te part of the report and the executive summary Lhat clearly informs
readeTS,, particularly the legislature, that there are clear and unequivocal records shoW1ng that the
Army has already accepted its responsibility to cover the disposal coits of the ~bsuntial amollllt
ofFo:n Bragg PCB wa~es originally placed in the Landfill Records froro tbe Army clearly show
that the . ..\nny paid the state initially for part of the original e-0~ of construct;ng the landfill.
Therefore, there should be no uncertainty that the Anny is similarly responsible for ib fair share of
the detox project. Records show that the Fort Bragg waste represented abuut I 0%> of the total
amount of material in the PCB landfill. Therefore, the Phase II report should clearly stat~ th1t it i~
appropriate for the state to request the Army to pay l 0% of the total detox project costs..
Assuming a total of about $24 million, the Army would pay about $2.4 million, which dearly
soften:; the impact of the request for project funding. But the $2.4 million is a small enough figure
for the Army to absorb without creating any issue about it. The Anny wou.ld probably not waut
to create any publicity about its waste and use of the Lmd.fill
Although I have raised this issue there is no evidence that DFNR will instmct ETG to
include this material in their report, and the Working Group needi to clearly recommend that it do
50.
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