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HomeMy WebLinkAboutNCD980602163_19980518_Warren County PCB Landfill_SERB C_Patrick Barnes correspondence (Science Advisors) 1996 - 1998-OCR4· ..BF A Environmental Consultants ~?%== = = = ~-=s=== Barnes, Ferland and Associates, Inc. MEMORAi~'DUM TO: FROM: DATE: SUBJECT: Mike Kelly Patrick Barnes May 18, 1998 Information for Your File on Incineration Pricing As we have discussed, I made a few calls and researched the internet and have discovered the following: l . Off-Site -Laidlaw's list price for TSCA incinerables (soils is $0.50 -$1.00 per pound or $1,000 -$2,000 per ton, which does not include transportation). Another source obtained from the net (I was unable to pin point the site) gave a price range of $1,500 -$6,000 per ton . . 2. On-Site incineration is much cheaper. At a Lock Haven PA site, 280,000 tons of PCB t"AT'\f'~'t"n;..,.,'!::t.+~A SC:: ; h-=-~nrT 1.'nr;ru::aro;:1-f-,::arl a+ ,;a i-nc-+ ,......f <t: A 1 1 /tnn ,..,h;~l, ;s rT?'PO+P'T" +hoT'l th~ -t.'l~'7 ltn" __ , ... U-A,L ... a.a._ ... ~ .. -u. ~. I v-....... 6 VA>• ......... ~~"'" ..... c,A~ ~ "'V~""" VA . .....,t::;; 4 J . i..v.11. Y¥Jl.l'-'1.J J, 6'·"' .... ""'j, "11"4.J.J. \.LI.'-' """""'VI I \.V.lJ. Warren County pnce tag. It is also important to note that because of the smaller volumes at Warren County the unit price for incineration would be larger. These are very rough ballpark numbers. For a true comparison, which takes into accow1t all variables, a much more detailed analysis is needed. Attached is a copy of the material I pulled off of the internet for your file. PAB/psgl5-I8MK 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 nffi~,=. f.d.n7, ROR-ARnA • ~,:-,v r&n7\ Aa~.1A?? > ; I '! Site Name !Peak Oil Site :jiampa, FL t111p:11p1pes.ensg.s111c.com1secuon""'-"··'·"'rn, L:::·z -t~u;~~~:::~---Jo~~t ~A::~11$1so,o~:::~m•tric ·•i I Wall infrared mobi1e (PCBs and I ton ($164-$730/ton) ·1 I i 1 1 EPA RREL incineration unit lead) 1 .! 1 26 West 11 :i :i 1 M.L. Kim~ I :I ·: lnr. -r 1~ i ! t-1'"{1 L,J I • ! I Cincinnati,_/✓ l>a' 1 ·: i OH 45268 ~ II) ·1 / :I :_I __;;____;_;___:__i_ ~!~~_691 . 1 :J-~f-z._ _ _ 1 _ __ .. __ .. _I ..... . . i ·\Savanna AD J:, ·'.: 1 , )!Savanna,-~ !I Michael G. I Full scale 1,000 ppm r I ppm ·1 $180/metric ton ·-1 , Cosmos I transportable TNT 1_ 1 ... , .. i, (_$ __ 1 __ 7_3?,o ____ ?_) ___ i_n ___ c,·_lusive ·,:_· 1 1 ! Roy 'F. incineration system -. : ----· -., ; Weston, Inc. j175,000 tons of soil ! \1 j1 :I One Weston i! I !I ii 1 Way ij1 l I West '. ! · ' Chester, PA ' 1· :j !!~ -'---'-"'---'-----'--'--"'j[~{EL3 .... L .. -·-i,;..;..1--..:...a.---'-'--'-"-'-~I ' ·----'•_II ! Lauder i Michael G. : Full scale ; 12,000 ppm J~! $200/metric ton ; Salvage Yard 'Cosmos i ~r~spo~able : PCBs ii \ ($180/ton) :I :,Beardsto\\rn, Roy F. mcmerat1on system :1 !i 11 1 :In W t T ,I II ii :1· ;I~ P<: "", nc. :1 I : t One Weston _i 1 J i ' ;i ' :II 1::~1 'i I : I i Chester, PA 1 : 1 i i 19380 :: 1(610) I 1101-1423 -'----'--"---'-'-'---'--'-~-"-'-~'-'-';."-----';..;.;..:..:.~-=---:.c;.;.:_.....:.;..__,.;,.;...._;.._....:;._--'-'---"·-----·.......;_..,;..;._-""'.---'--""'--'-'----'-'-------_.c..; Note: NA;;;; Not Available. ---.. -------- Poi 4 cf5 5/7/98 1 :40 f>M ~ .2 ·; ltK:incration Contact 1· ii j •····· Government Agency . ········-··•· .. ····," .. ,. --------~----, !Donald A. Oberacker IEP~~~ ., !Joseph McSorley EPA l1ttp://p1pc:s.e11sg,.~a1C.Cl)ffi,SCCUOl1-t,-. _-:·.ii llii, JI ····.·1 tti{i!~:;ff~J[~t:~~~H~~' I ilc919) 541-2920 I Alexander Dr. i Air & Energy ERL I : Research Triangle Park, NC j \ ... J ,,t .. ., Previous : S . M . ,t. .... ~.r , , ·. Section .. creerung atnx .. , .. ---.. Front Page \ 17711 .. ------. .. 11lrn_rn r11 ,n.n 11,mii ui ■r ■Tn iiWn !ll41U) b) 1-lU~l! l'l!~!M-. ..!L-!!.!J _UJ'U, rax: (410) 1 J\,1I) 21010-s401 . :._612-~~36 ... 11 Table of Contents -- 1-·. ,-11' ·., • . · ,!!It , .. ·,-, l of 5 1-:-· .. \4\. l."".Ll.&f-'....,.ll,H,u.l.\,,,,.., U.j-' LA..I u r u _, \ .&. ,"-''-''-' ,a. .J• Incinerator off-gas requires treatment by an air pollution-control system to remove particulates and neutralize and remove add gases (Hci NO~, and SOX). Baghouses, venturi scrubbers, and wet electrostatic precipitators remove particulates; packed-bed scmbbers and spray driers remove acid gases. Limestone or caustic solution added to the combustor loop removes acid gases in the CFB. incineration, primarily off-site: has been selected or used as the remedial action at more than 150 Superfund sites. Incineration is subjc:ct to a series of technology-specific regulations, including the following federal requirements: CAA (rur emissions), TSCA (PCB 5/7/9S I :40 PM 5/7/98 l :40 PM .. . ; 4.23 Incineration Previous Section Screening Matrix Table of Contents Contaminant Class Search Next Section ,( ··•··•·-•·•---· ... 'I l \1 • . . _ 'fech11ol~.~ ....... _! . .. . .. _ Desc~.~p!i°-~ . • {soil, Se~im:t, a~~.-~~1:1~~~ ..... . .. . .. . .---"--~--·• ;!3.6 Ex Situ I hermal l'reatment {as13u111ni excavai1on) I ' . . .. . . . . . . ..... •-· -... .. . . .. .. . .. ... .... . . . ·-. . .. ---··--I j' 4 23 Incineration i High temperatures, 871-1,204 °C ( 1,600-2,200 °:F), are used to · i I combust (in the presence of oxygen) organic constituents in hazardous , <0'.> ti ( .. J ~~~~~S.. .. ·• . . . .. . . .. .. . ·-. ···--· .. , .. .. ;::: '..'. .: ...... ; .••. :L ,,,,, Description: Figure 4-23: Typical Mo bile/I ransportable Incineration Process High temperatures, 870 to L200 °C (1,400 to 2,200 °f), are used to volatilize and combust (in the presence of oxygen) halogenated and other refractory organics in hazardous wastes. The destruction and removal efficiency (DRE) for properly operated incinerators exceeds the 99, 99% requirement for hazardous waste and can be operated to meet the 99.9999% requirement for PCBs and dioxins . Commercial incinerator designs are rotary kilns, equipped with an afterburner, a quench, and an air pollution control system. The rotary kiln is a refractory-lined, slightly-inclined, rotating cylinder that serves as ~ combustion chamber and operates at temperatures up to 980 °C (] ,800 °f). An experimental unit, the circulating fluidized bed (CFB), uses high-velocity air to circulate and suspend the waste particles in a C~mbust1·~n loop and op~ra•~s ~+ •em .... .,. .. .,,t .... "'S ..... 'tn 'il7 0 o,·, /1 6"()() V U \,, "'"' Q.\. \. U ,!)\.,_.&,U. UJ."-" U}-' LV VI '-~ \J.,'-.VV °F). Another experimental unit, the infrared unit uses electrical resistance heating elements or indirect-fired radiant U-tubes to heat material passing through the chamber on a conveyor belt and operates at temperatures up to 870 °C (1,600 °F). Incinerator off-gas requires treatment by an air pollution-control system to remove particulates and neutralize and remove acid gases (HCl, NOx, and SOx). Baghouses, venturi scrubbers, and wet electrostatic precipitators remove particulates; packed-bed scrubbers a...7.d spray driers remove acid gases. Limestone or caustic solution added to the combustor loop removes acid gases in the CFB. Incineration, primarily off-site, has been selected or used as the remedial action at more than 150 Superfund sites. Incineration is subject to a series of technology-specific regulations, including the following federal requirements: CAA (air emissions), TSCA (PCB 517198 1:40 PM "'.2; Incineration Appiicahiiity: Limitations: Data Needs: Performance Data: · Cost: .· 2 oO nnp:11p1p~s.<:-U~f::$.:,ttJ\;.',;\_l)lf/::)\.,\,UVlnf"T _ ..:.../.IL~IJ.I' treatment and ct1sposai), .KC.KA (.nazarctous waste generation, treatment, storage, and disposal), NP DES ( discharge to surface waters). and NCA (noise). Incineration is used to remediate soils contaminated with expiosives and hazardous wastes, particulariy chlorinated hydrocarbons. PCBs, and dioxins. Factors that xp.ay limit the applicability and effectiveness of the process include: • Only one off-site incinerator is permitted to burn PCBs and dioxms. . • There are specific reed size and materials handling requirements that can impact applicability or cost at s~i:6c sites. • Heavy metals can produce a bottom ash tl1at"requires·-····· --~· · stabilization. • Volatile heavy metals, including lead, cadmium, mercury, and arsenic, leave the combustion unit with the flue gases and require the installation of gas cleaning systems for removal. • Metals can react with other elements in the feed stream, such as chlorine or sulfur, forming more volatile and toxic compounds than the original species. Such compounds are likely to be short-lived reaction intermediates that can be destroyed in a caustic quench. • ~oa•· ana' Ot' ·\, .. ~ c-_~ t ____ ----,1+.!...,.,... --.:-• .... '"'h-.r i--h~t ~an ..., lUill p a551=.u IUuu ll..lW 1uc:1uug 1-'"'llll a.:,11-..;,-, LIJ.U.< '-'HU attack the brick lining and form a sticky particulate that fouls gas ducts. A detailed discussion of these data elements is provided in Subsection 2.2.1 (Data Requirements for Soil, Sediment, and Sludge). In addition to identifying soil contaminants and their concentrations, infonnation necessary for engineering thermal systems to specific applications includes soil moisture content and classification (no sieve analysis is n.~essary), ·the soil fusion temperature, and the soil heating w:Juc. If an off-site incinerator is used, the potential risk of transporting the hazardous waste through the community must be considered. Approximately 20 commercial RCRA-pennitted hazardous waste incinerators and approximately IO transportable high temperature units are operating. The commercial unns are large capacity rotary kilns with afterburners and sophisticated air pollution control systems. Soil treatment costs at off-site incinerators range fr.om $220 to $1 , l 00 per metric ton ($200 to $1 ;000 per ton) of soil~ including all project costs. Mobile units that can be operaied on-site will reduce soil transportation costs. Soils contaminated with PCBs or dioxins cost $1 ,650 to $6,600 per metric ton ($1,500 to $6,000 per ton) to incinerate. t ,I{,,//;, ft...e foJkf l!.-€ tf) yf~ 7 5/7/9~ l:40 Pl- -.--· ........ -~ ...... References: · · ··. Site Information: 3 of5 EPA, 1987. Incineration of Hazardous Waste, Fact Sheet, EPA, Office of Solid Waste, Washington, DC, EPN530-SW-88-018. EPA, 1988. Experience in Incineration Applicable to Super.fund Site Remediation, EPA, RREL and Center for Environmental Research Information, EP N625/9-88/008. EPA, 1988. Hazardous Waste Incineration: Questions and Ansvvers, EPA, Office of Solid Waste, Washington, DC, EPN530/SW-88/018. EPA, 1990. Mobile/Transportable Incineration Treatmenr, Engineering Bulletin, EPA, OERR and ORD, Washington, DC, EPN540/2-90/0l4. EPA, 1988. Shirco Infrared Incineration, EPA RREL,-series -ineludes Technology Evaluation Peake Oil, EPA/540/5-88/002a; Technology Evaluation RoSe TowTIBhip, EPA/540/5-89/007a; Tedmo1ogy Evaluation Rose Township Vol. II, EPN540/5-89/007b, PB89-16791 0; Applications Analysis~ EP A/540/S5-89/01 0; Technology Demonstration Summary~ EPA/540/S5-89/007; Demonstration Bulletin, EP N540/ MS-88/002; and Technology Evaluation Report Peake Oil Vol. II~ EP A/540/5-88/002B1 PB89-116024. EPA, 1989. American Combustion Oxygen Enhanced Incineration, EPA RREL, series include Technology Evaluation, EPN540/5-89/008; Applications _A_11.a!ysis, EPA/540/.A.5-89/008; Technoiogy Demonstration Summary, EP Ai540/S5-89/008; and Demonstration Bulletin, EPA/540/MS-89/008. EPA, 1992. Ogden Circulating Bed Combustor McCall Super.fund Site, EPA RREL, Technology Evaluation, EPA/540/R-92/001 ; Demonstration Bulletin, EP N540/MR-92/001. EPA, 1993. X-TRAX .Model JOO Thermal Desorption System Chemical Waste Management, EPA RREL, Demonstration Bulletin, EP A/540/MR-93/502. Noland, J.W., et al.~ 1984. Task 2: Incineration Test of Explosives Contaminated.Soils at Savanna Army Depot Activity, Final Report. Savanna Illinois, USATHAMA Report DRXTH-TE-CR 84277. 5f7/9g l :40 PM Post-Ir Fax Note To MEMORANDUM TO: FROM: DATE: SUBJECT: Mike Kelly Joel Hirschhorn and Working Group Co-Chairs Patrick Barnes, P. G. April 17, 1998 Fax# Format for ERC Presentation 7671 Da.te 4 Based on my notes from our last meeting (March 26th) an outline of our proposed ERC presentation was to be jointly developed by today. Assuming a 30-minute presentation I recommend the following general structure: Duration Topic Speaker 5 Min. History of Facility and the Promise Dollie Burwell -· 4 Min. Overview of $1 Million Expenditure Mike Kelly or Bill Meyer 8 Min. Integrity of the Facility Pat Barnes 8Min. Detoxification Technology Selection Joel Hirschhorn Process and Results 5 Min. Funding Request, Economic Benefit and Henry Lancaster Schedule for Implementation We also need to discuss the general look of the presentation, our theme, and how we will bridge the various speakers. As requested, I have contacted Dr. Daly to see if the South Warren Elementary students can provide colorful ''Detoxify Now" posters as a back drop. Maybe Doris can set up a conference call within the next few days so we can discuss these issues. PAB/psg/M7MK fax Date J;'fyf 12. Number of pages including cover sheet Phone 'YJo/-f~~-f9$ Fax Phone /-e(f'-£/ S: _ zqOS: CC: REMARKS: I Barnes, Ferland and Associates, Inc. 3655 Maguire Blvd. Suite 150 Orlando, Florida 32803 Phone (407) 896-8608 Fax Phone (407) 896-1822 D FYI O See Attached O Urgent O For your review O Reply ASAP D Please comment /1{1ie µ 1 w~ t/4~5,e/ 1efa/~. <Jo d~i~ h:f/z.__1 .Z-~ 1/ µl/'/4 '/0 ~7: bv~~s~~) -P)'¼ 'ff' tdJA 5 {tJ/5) -:5 o if of4!z;:;!6/2 -~1tk.. f Pie r✓✓1/vc 1«-{, ,~ )-?e<>f-f ,~--::3s,ooo -a ✓~ r( a;,nli -f'cl'o/4 ~ I _#6',:POO ~fat,,.,u)b I -, ,..., -----.;.. '7,:)y/7(~,:;,,(e;-o/./+ x-;;,_06 X ~ ~ /; )/4_ . ..BF A Environmental Consultants = ~ Barnes, Ferland and Associates, Inc. MEMORANDUM BFA #95-017.01 TO: Steve Detwiler ETG Environmental, Inc. FROM: ~ DATE: SUBJECT: Warren County PCB Landfill Preliminary Design Report Review Comments 1. J Purpose and Ob;ectives Following the pattern already established: the detoxification projects should be let in a Design/Build fom1at. The Design/Build Team will include the following components: • System Design • Technology • Construction • Minority Business Utilization • Public Relations A conceptual Project Organizational Chart is provided as Figure 1. l . Please add the followiog text or something similar. 1.2 Sc:ope of Work 2.1 1. Working area site work -stormwater management, sediment containment and control, grading, pad construction, etc., -should be listed as a preliminary design area to be addressed. Site Description/Background 1. Location map should be included. 2. Landfill cross section description should reference drawing 70809-PD3 (pg. 5). 3. 60 inch clay liner permeability should be noted -at least design permeability should be referenced. 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 I j MEMORANDUM March 2, 1998 Page 2 2. 3 Selection of BCD Process 2.6 3.1 1. Preclusion of thennal destruction methods (i.e., incineration) should be noted. Regulatory Overview 1 . It should be noted that the required treatment standards are more restrictive than Federal/State standards. Purpose 1. First paragraph, 61n line should read ''professional expenence and eiting of compliance with Federal and State regulations. 2. List of-conceptual drawings lists "Site Preparation Plan", but there wasn't a drawing provided. 3. Suggest indicating drawing# in parenthesis after each drawing title, i.e.: • Existing Conditions Plan (#70809 -PDO) Permitting Plan 1. Listing of "Permit, License or Certification'' should provide more inforn1ation such as: a. Agency responsible for issuing pennit. b. Relevant site functions covered in permit~ i.e., is "Earth Disturbance Pem1it" required for any/all site work or only relevant to contaminated earth removal from landfill cell. c. "Certification Report" -to whom and what is being certified? 3. 3. 2 Site Preparation Plan 1. Size of ''clean soil staging area" should be noted. Drawing indicates ± 15 days storage capacity -Report should state storage capacity required based on anticipated lab turnaround time (i.e., what is it?) and backfilling operations. 2. Size of "oversize material stockpile" area should be noted. Will this area also be roofed? 3. Has the prevailing wind direction been considered in the site layout? 3.3. 3 lnfrastructure/Utilitiq Plan 1. Is electrical power supply adjacent to site sufficient for treatment facilities' needs? 2. -Is available water supply sufficient? 3. How will domestic wastewater needs be met? 4. How and where will the road be monitored for contamination? HFA .. ' MEMORANDUM March 2, 1998 Page 3 3.5 Excavation Plan 1. Page 19, first bullet -it is stated that the water will be held in the pond to the north . Will the pond be lined? 2. Page 20, how will stormwater entering the excavation be minimized? 3. Page 22, 2nd paragraph -what method will be used to perfom1 decontamination oversize material? 4. Page 23 , 1st paragraph -stockpiled contaminated soil should be covered v.ith tarp to prevent wind-blown erosion. 3. 6. 3 Treatment Plan {or PCB Contaminated Soils 1. Process flow diagram showing the following should be provided: a. Process flow and all sidestreams b. Unit design through -puts and unit sizing c. Side stream treatment d. All related emissions from the process including: • afr • solids/soil • water 2. Size of process treatment area site should be noted. Will this site be concrete pad or geomembrane lined soil? 3. Water treatment system concerns. a. How will sand filter backwash be handled? b. UV oxidation process -will ozone serve as oxidation agent? c. Is system intended to be sized to handle construction run-off water? (i.e., is this the "wastewater treatment system" discussed in Stonnwater Management Plan?) 3.6.8 Stormwater Management Plan 1. Preliminary design criteria and construction water containment sump volumes should be provided. 3. 7.2 Decontamination 1. Please describe proposed water treatment system mentioned at the end of page 46 . 5. 2 Estimated Costs 1 . I suggest the cost table be more detailed in order to provide a better basis of economic feasibility. I recommend the following: · BFA ...... ~ ff ----- MEMORANDUM March 2, 1998 Page 4 • Final Design, etc. • Mobilization • Site Prep • Set up • Start-up/Perf. Demo • Excavation • Soil Treatment • Water Treatment • Back Fill • Reclamation • Decon., Dismantle, Demob. TOTAL ' 2. A low (5% -10%) project contingency may be prndent to cover vanous project unknowns such as additional investigations and soil treatment. Recornmended Text 4. Community Involvement "Maximizing community involvement at all project levels is considered to be critical to the actual and perceived success of the detoxification project. The Joint State PCB Landfill Working Group has forged a new direction for collaborative efforts in an Enviromnental Justice community and we assume will continue that effort tlu-ough successful detoxification." 4. 4.1 Community Oversight/Funding ' We recommend that the proposed CAB be replaced by the Joint Warren County State PCB Landfill Working Group. Replace 2nd paragraph with: "Community oversight will be facilitated through the Working Group which is the current structure to handle such. matters. The Working Group will continue to be advised on an as-needed basis by independent Science Advisors. Approximately $50,000 should be included for this effort. -The organizational structure for community outreach "viii be as indicated in Figures 4.1 and 4.2. The Design/Build Teams' public relations member will be lo MEMORANDUM March 2, 1998 Page 5 responsible for ensuring that all stakeholders are apprised of the project's status, goals, objectives and needs. The Public Relations lead will report directly to the Program Manager and the Working Group. The State's access to the project's Public Relations personnel will be through the Working Group. The dissemination of all monthly project status reports and quarterly newsletters will be the responsibility of the Team's Public Relations Manager. This individual could work for the Design/Build Team and be hired directly from local talent; or be hired as a Subconsultant. The community outreach will include substantial utilization of local and minority ven_pors, suppliers and Subconsultants. It will be the responsibility of the MBE Coordinator to ensure maximum economic impact through Subcontracting Thi s team member will report directly to the Design/Build Program Manager and the Working Group" Drawing 70809-PDJ 1. ''Clean drainage" along west bank of landfill is subject to contamination from Yehicular traffic as noted on drawing ➔ suggest construction of access roads with culve11s for landfill to treatment area traffic. 2. BCD treatment area and contaminated soil holding areas should be concrete pads, not soil with geomembrane liner. 3. Process fuel tanks should be located closer to access road to improve fuel delivery truck access. 4. Site plan should provide storage area for gasoline/diesel for heavy equipment. Area should include secondary containment. Where will equipment maintenance be performed? Drawinf;J 70809-PDJ 1. Contaminated soil stockpile area should have concrete pad. 2. Toe of contaminated stockpile should be± 1 minimum from toe of containment be.nn. 3. Contaminated soil stockpile should have tarp cover to prevent windblown emissions. 4. Utilitv line trench section~ depth of compacted bedding around pipe not shown. BFA GENERAL PROJECT ORGANIZATIONAL CHART Program J\'lanagen1ent Design DENR Design/Build Team \Vorking Group and Science AdYisors Technolog)' Construction 1\-Unority Business Utilization B~A ... -MINORITY BUSINESS UTILIZATION STRUCTURE .Joint State PCB Landfill ,vorking Group Design Build Team Program l\.1anager PR Team l\.1ember • • Team l\.Unority Business Utilization l\if e1n her National l\1inoritY Suppliers Development Council •' Resources i\finority Contractors Group State Certified Suppliers/Vendors Local Contractors -INFORMATION Dl~EMINATION STRUCTURE Joint State PCB Landfill \Vorking Group Design/Build Team Public Relations Manager Design/Build Team Program l\ifanager Local/State ~ledia National l\fedia and Environmental Groups Local Political Leaders State and National Political Representatives • Job Placement Groups • \Velfare to Work • Labor Pools Church and Civic Organizations Schools and Job Training Groups i!f I II I '\ • ~ I I . 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'MOE ACCESS ROAD 't_ CONSTRUCTION RUNOIT DIVERSION BERM {PROJECTED) CONSTRUCTION RUNOFF SUl.4P CBDS_S__SECTION OF EXISTING Fl_CB LANDFILL NOT TO SCALE l~~:~:m:--; -C)h I '~1 ; I (2 REO'D) TO COLLECT CONSTRUCTION RUNOff FROl.4 ACCESS ROAD ON WEST SIDE OF LANDFll..L EARTH nLL BERl.4 ~------VEGETATION ~//,~ s· TOPSOIL 18° CLAY ------------------• --+--TREATED SOILS ;_:;:,~~~~;~'.~;I:~;~;~~~:;:±;~;'.i;,i~: :1 :.l ~:~ ABRIC so· CLAY '.--1----12• FILL ---30 l.41l PVC GEOl.4EMBRANE t. '·"·'·;\:;;_ ';;_,i:_t;:J g· SAND SECTION CROSS SECTION OF• PROPOSED COMPLETED LANDFILL NOT TO SCALE BURIED UTlUTY IMRKING TAPE 8°-12"1 -I 30· (1.41N.) COl.4PACTED AGGREGATE BEDDING/BACKnLL W.TERIAL ·, (Dpt1; nor sAo...,) SECTION ' COl.4PACTED SOIL B>,CKnL.L W.TERIAL GROUND SURFACE EXCAVATE SIDESLOPES AS VERTICAL AS POSSIBLE IN ACCORDANCE WITH APPLICABLE OSHA REGULATIONS ? UJILITY LINE TRENCHING NOT TO SCALE NOTE: ELECTRICAL AND WATER LINES SHAU. BE INSTALLED IN SEPAAATE TRENCHES AT LEAST 10· APART. ~ PREPARED SUBGRA0£/ / / -----l----z---_ CONSISTING OF nLL __ _ LINC: ROAD BASE GEOl.4El.4BRANE WITH GEOl.4£!,IBRANE nLTER f ABRIC 'ONE OR AGGREGATE r: /,,,," :::;--~-;~~ • ~ • .,..~.., -<.>,. -~ SECTION CONSTRUCTION SUMP NOT TD SCALE g· COl.4PACTED AGGREGATE ~ !.':<'7:N::>"tl'-">~'-'O"tl'-'<nl~'-'O'tA:,"\,'o;& _T~~ GEOTEXTILE L' PREPARED SUBGR>.OE ♦ICFKAISER SECTION "CLEAN" ACCESS ROAD -PARKING AREA NOT TO SCALE SCALL •s SHO""' I -= BY: 0-'TL JAl-4. 29. 1998 ORA.WN BY: 0. [\. CHECKED BY: P .J! STATE OF NORTH CAROLINA WARREN COUNTY PCB LANDFILL ETG ENVIRONMENTAL. INC. SECTIONS (/r HO. 3015,~ SH([T NUMS(R OAAWIHC HUWB(R 70809-PC I Environmental Education http:Jl~.eng.clemson.edulRe ... h.()pportulities/on_Educat.html 1 of 1 ;..,., ENVIRONMENTAL EDUCATION Proposals from school districts, educational institutions and other nonprofits for grants to support environmental education projects should be postmarked to the Environmental Protection Agency by February 21. This program seeks to increase public knowledge about environmental issues. and to provide the public with the skills ( critical thinking, problem-solving, etc.) needed to make informed, responsible decisions. "Environmental education does not," EPA noted, "advocate a particular viewpoint or course of action." Examples of potential projects include but are not limited to: (1) designing, demonstrating or disseminating environmental curricula (use of existing curricula is preferred); (2) designing and demonstrating field techniques, including assessing environmental and ecological conditions or specific environmental issues or problems; (3) training teachers or related personnel; (4) fostering international cooperation in addressing environmental issues in America, Mexico and/or Canada; (5) educating low income and culturally diverse audiences about environmental issues; and ( 6) educating the public about environmental issues in their communities through community-based organizations or through print, film, broadcast or other media. · Grants can range up to $250,000, but is% of all awarded funds will be for grants of $5,000 or less; thus most awards by far will be $5,000 or less. In FY 1996, over 350 proposals were received; only nine were funded, the largest being for $145,000. For more program information, including detailed application guidelines, refer to the December 10 Federal Register, p. 65106-17. More information is also available on the Web at: "http://www.nceet.snre.umich.edu/grant.html". The EPA contact person for proposals requesting more than $25,000 is George Walker at (202) 260-8619; for those requesting less than $25,000, it is Maria Pirie at (617) 565-9447. For information on non-EPA grant programs on environmental education, request copies of "Grant Funding For Your Environmental Education Program" (available @ $5) from: North American Association for Environmental Education, Publications and Member Services, P.O. Box 400, Troy, Ohio 45373. 02/05/98 17:53:14 ~1Au_f- ~c-✓I~ ;-~- --. '.,,,, \ fax ··.-~ ~;.;a~\! \ ri\\~ 1~ }~~~ B~rnes, Ferland and Associates, Inc. ;--·, 3655 Maguire Blvd. Suite 150 ........ ---~:-•·t Orlando, Florida 32803 Date Number of pages including cover sheet To: Phone Fax Phone CC : J)ErlNk:' _i From: ,~ 01 Phone (407) 896-8608 Fax Phone (407) 896-1822 REMARKS: 0 FYI [3""';ee Attached O Urgent D For your review D Reply ASAP D Please comment , t )lcnse c a\\ me af'-W' ~OL'-f-C\.i ieuJ "tl\t.S' BF A Environmental Consultants Associates, Inc. MEMORANDUM TO: Working Group , FROM: Patrick A. Barnes, P.G. DATE: August 29, 1997 SUBJECT: Review of the Warren County Bench Scale Test Report Submitted by ETG Environmental, Inc. and ELI Eco Logic Inc. BFA #95-017 BFA reviewed the two referenced pilot scale reports using the follov.ing fonnat: l. Form and Content: The documents were reviewed to determine if the prosecution format and technical content was consistent v.~th the requirements of the RFP and industry standards. 2. Consistency: The documents were reviewed for internal consistency. 3 RFP Criteria: They were reviewed in light of the criteria outlined in the State's RFP. A memorandum summarizing the results of that review is attached. 4. Scoring: Finally, a point system was established for each of the major criteria as outlined in Section 2.5 of the RFP as follows: a) PCB and Dioxin Removal b) Quality of Phase I Test Report c) Ability to Provide Full Scale Equipment d) Safety and Reliability The scoring is detailed as follows: TOTAL ETG 30 10 15 20 75 Ecologic 30 5 15 lQ 60 40 Points 15 Points 20 Points 25 Points Based on the above, we recommend proceeding to Phase II with the ETG team. 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 ()ffir.~ /.dn7\ AO~LARm~ • l=,;iv f.dil7\ ~o~.1 i:l-,-, MEMORANDUM TO: Patrick Barnes, P.G. FROM:· Ted Hortenstine, P.E. ~ DA TE: August 28, 1997 SUBJECT: Review of the Warren County Pilot Scale Test Report Submitted by ETG Environmental, Inc. and ELI Eco Logic Inc. BFA #95-01 7 The reports were reviewed based on the selection criteria presented in the Request for Propos~1l (RFP). A discussion of each of the five selection criteria as stated in paragraph 2.1.4 is provid ed as follows : a) The Ability to Meet Phase I Criteria (Section 2.5) as Demonstrated through Phase I Test Data: 1) PCB and Dioxin Removal Performance -In general, both processes demonstrated the ability to treat the contaminated soil to the levels requested (Total PCB less than 20 ppb ) for Total PCB's. Eco Logic expressed concern that the level of treatment could not be demonstrated for Dioxin TEQ due to the detection limits achievable for soil samples using method 8290. Reported values for Eco Logic were ND (non-detectable) for two runs and 380 ppt for one of the runs. The 380 ppt wa5 attributed to low temperatures during Run 2. ETG Environmental, Inc. did not express any concerns regarding detection limjts. ETG Dioxin TEQ values ranged from ND to 2.96 ppt. Eco Logic was able to demonstrate compliance with PCB emissions at the exhaust (gas) stack. However, they were unable to demonstrate compliance with the Dioxin TEQ emission performance requirement. Eco Logic attributed this problem to sample size and analytical detection limits. ETG Environmental, Inc. did not meet the stated performance at the exhaust stack. They did report compliance based on an EPA dispersion model (Screen 3) which predicts air pollutant concentrations within a certain distance (200 fr. was used). 2) General: Based on th.is review, ETG Environmental, Inc. appears to have a slight edge on soil treatment perfonnance. Overall, it appears that each process can meet the treatment performance requirements ·with slight modifications in the full-scale unit or ·with a slight relaxation of performance requirements. MEMORANDUM August 28 , l 997 Page 2 b) The Quality of the Phase I Test Report: 1) Format: Neither company adhered to the format required by paragraph ;.7.2 of the R.FP . 111e report submitted by ETG Environmental, Inc. seemed to follow the requested format more closely than the Eco Logic report. 2) General: The report submitted by ETG Environmental, Inc. \vas easier to follow. Information was presented in a more concise manner. Strictly based on the quality of each report, the ETG Environmental, Inc. was a better report. c) TI1e Abilitv of the Vendor to Provide Full-Scale Equipment at th~ __ ylarren Cotmty PCB Landfill Site: Although ETG Environmental, Inc. discussed the capabilities of their full-scale units, no statements were made concerning availability of these units. A phone conversation ·with Mr. Steven Det'.viler of ETG Environmental, Inc. con.finned that an existing treatment unit could be relocated, or that a new treatment unit could be constructed depending on the timing of . . the project. A maximum period of six months would be necessary prior to start-up. Eco Logic discussed their situation in detail. They are in the same situation as ETCi Environmental, Inc. Either an existing unit could be relocated or a new unit could be constructed. They would also need up to six months pri.or to start-up. d) The Ability of the Vendor to Provide a Safe, Reliable and Cost-Effective Full Scale Application of the Selected Technologv at the Warren Landfill: 1) Safety: Neither company addressed the issue of safety as it relates to the full-scal e system. Based on the review of the reports, the system proposed by ETG Environmental, Inc. appears to be inherently safer than the system proposed by Eco Logic due to the follo-..ving reasons: • The ETG Environmental, Inc. system operates at 600 -650° F, while the Eco Logic system operates at 800 -900 ° C (1,472-1,652° F). • The ETG Environmental, Inc. system operates under vacuum conditions which minimizes system leaks or discharges. The Eco Logic system operates at ambient pressures. • The ETG Environmental, Inc. system does not appear to introduce any potentially explosive materials while the Eco Logic system utilizes hydrogen gas. MEMORANDUM August 28, 1997 Page 3 The above observations were based on infonnation contained in the report. Since no full- scale safety data was presented by either firm, additional data should be requested to substantiate or refute these observations. 2) Reliability: Neither compan.y addressed the issue of full-scale system reliability. Due to the complexity of each of the systems, no observations could be made to compare each of the systems. Additional information should be requested from each company. 3) Cost Effectiveness: Minimal information was provided by each company concerning cost effectiveness. An economic comparison of the two systems cannot be made w1less more substantial cost data is provided. e) The Qualitv and Cost of the Proposal for Providing Phase II Services: Not Applicable: Proposals for providing Phase II services will be submitted after acceptance of the Phase I reports. TH/psg/8-181-'B I ~ I l l ME!\IORANDUM TO: FROM: DATE: Workina Group (Strategy Meeting Attendees) Patrick A. Barnes, P.G. ~ February 2, 1998 I ,,. SUBJECT: General Outline for the Development of Various Strate&r Components As requested of me during Saturday's Strategy Session the following is a general outline of the broad topics that each strateay component should include. 1. Introduction -What is the program and why is it necessary? 2. Goals and Objectives -Discuss the overall goal and the objectives necessary to achieve it. 3. Program Approach • How the program will be implemented should be discussed in a stl!p by step fashion. 4. Implementation Schedule -How long will it take to implement the program approach? A timeline should be given for each task in the program approach. 5. Manpower and Cost Requirements -What are the manpower needs and associated costs of implementing the program approach? 6. Roles and Responsibilities -The program should include a section on who will do what - not just individuals, but also what organization we are asking to participate. If you feel other items should be included please feel free to do so. 3655 M.gutre Boulevard • Suite 150 • Orlando Florida 32803 Offir.A (407) 896-8608 • Fax (407) 896-1822 BF A Environmental Consultants Barnes, Ferland and Associates, Inc. MEMORANDUM TO: Steve Detwiler Mike Kelly Joel Hirschom d FROM: Patrick A. Barnes, P.G. ,. ~~- DATE: November 12, 1997 SUBJECT: ADDITIONAL TOPICS FOR DISCUSSION AT THE NOVEMBER 14 PHASE II DESIGN MEETING In addition to the topics mentioned in Joel's memo dated November 12, 1997 the Phase II design team should be prepared to discuss the following detoxification site design concerns: 1. 2. 3. 4. 5. 6. 7. 8. Area required for project implementation including site layout and work zones Site operations and logistics --..s 116 / t Q v ,fr't, (,\J :· :cc ,..,,r?.. i ry Construction of contamination reduction facilities if necessary / Temporary storage facilities Other potential temporary and permanent horizontal and vertical construction Storm.water management / • Ponds • Need for infrastructure , ':;1.iitSJL~ lf ~v-J- Phasing of fill removal and clean fill placement Detailed estimates of quantities to be removed in each phase 9. Site plan showing anticipated final topography of each cell as it is closed ~ fJl'I J Drv-w (.is;. ·:_,1'.r,c{JJd _. 2.l c). 10. Permits necessary -local, state and federal · St--((~ Jv\.o ..,__ ', \-c:, ..,.. ', ~ 3655 Maguire Boulevard • Suite 150 • Orlando . Florida 32803 Office (407) 896-8608 • Fa x (407) 896-1822 b-L/ ;,1;_ I)~ f1c.--r r·~ October 21, 1997 ............................................................................... by FA.'X To: Mike Kelly From: Joel Hirschhorn and Patrick Barnes We regret that your office did not inform us or the Worl-.ing Group that in early August you contracted Environmental Efficiency to pe:rform au evaluation of a ponion of the dioxin/furan tes1 results obtained for the PCB Landfill site investigation. Because we have just received your contractor report we now make certain requests. We request that your office officially submit the contractor report prepared fo1 your office by Eu\ iroumental Efficiency to the appropriate official at Southwest Laboratory of Oklahoma, the laboratory that the state contracted with for the dioxin testing used in the PCB Landfill in"\estigation, and request that Southv\·est prepare a \\11.tten technical response to your contractor report Specifically, we request that you ask Southwest to address the follov.ing issues: 1. Did the analysis of Environmental Efficiency fairly and comprehensiYely address all of th e testing for dioxins/furaus conducted by Sonth\\est" 2 (A) Does Southwest believe that the Region JV guidance uocL1IDent used b) Envirollllleutal Efficiency represents generally accepted and applied EPA procedures used by Southwest0 (B) Are there any specific differences between the Region IV guidance and other applicable EPA guidance used by Soutb"\-est? (C) Would South·,vest have used different testing procedures if the state had requested compliance with the Region IV guidance9 3. Are there any technical issues, findings, inte1rretations, or conclusion s presented in the Environmental Efficiency repo1t that Southwest disagrees with, or ·wishes to discuss or amplify on° 4 . To what extent do the findings and conclusions given by Environmental Efficiency apply to dioxins/furaus other than the ones examined by Em,ironmental Efficiency? 5. After considering the Environ.mental Efficiency report, does Southwest --..v:ish to moctif)· any of its previously submitted data and reports provided to the state? Would you please request that Southwest provide responses as soon as possible. Please provide us vvith copies of your request to South\vest and any reply by them. \Vould you also provide us with some description of the procedure used to select Environmental Efficiency. the scope of work used by the state, the competing firms considered, and all bids received .from competing firms. Has Environmental Efficiency provided previous contractor services to the Division of Waste Management? cc: Working Group Technical Committee · BF A Environmental Consultants ===2~ =2=t=~a=====~ Barnes, Ferland and Associates, Inc. MEMORANDUM TO: Mike Kelley and the Working Group FROM: Patrick Barnes, P.G., Science Advisor DATE: October 15, 1997 SUBJECT: Water in the Landfill BFA #95-017.01 The purpose of this memo is to clearly state my position coocerrung the water in U1e landfill . As you know, in my opinion, the site investigation and data analysis performed strongly indicates that water is both entering the landfill through the upper liner system and leaving the facility through the bottom liner system. Moreover, this is supported by the results of the analytical testing of two wells adjacent to the facility (lA and 5D) which both indicate the presence of dioxins. The period of record reviewed indicates that leakage out of the facility has been occurring for at least the last 5 years. This means the potential exists that a substantial area of impact exists immediately beneath the landfill. The soil or groundwater immediately beneath the facility was not tested. Although the severity of the impact beneath the landfill is unknown, it is known that the existence of approximately 15 feet of water in the landfill acts as a driving force for continued releases. I realize that the desire exists to keep the facility in as poor a condition as possible to strengthen the case for detoxification, however, it is more important that prudent steps to protec.t the environment be made whenever possible and as quickly as possible. Moreover, no temporary measure could ever take the place of the long-term detoxification solution. The need for detoxification must be able to stand on its own, which I feel it clearly can. · I therefore strongly recommend that the Working Group formally ask the State to proceed irnmedia1ely with a program to safely and effectively remove the water from the facility . I have analyzed the geotechnical data on the landfill contents and can assist in the design of an extraction system, ·-----··-·· Po11t-1r Fax Nole 7671 Oate 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fa)( (407) 896-1822 J);d _ .. , ' -p--.:> E"" · ~ p..-:A. E~vironmental Consultants fi,/ ,Barnes, Ferland and Associates, Inc. fo1# .,I~ 1 yir((~ MEMORANDUM (A.'j)S TO: Mike Kelly and The Working Group FROM: Pat Barnes, Science Advisor DATE: June 13 , 1997 SUBJECT: Review of Landfill CAP Evaluation I have reviewed the June 5, 1997 report from S&ME evaluating the Landfill Cap System and disagree with the statement that the PVC liner "appears to be in fair condition". My points of concern and questions for S&ME are summarized below: 1. S&ME states that the specifications of original PVC liner was not available for comparison. I am concerned that by comparing the test results given in Table 2 to a "typical 10-mil PVC" liner, we may not be comparing apples to apples. Can a range of values be provided for various types of 10-mil PVC liners available so that a more detailed comparison of test results can be made? 2. I am uncertain how the PVC liner condition could be considered fair if the seams showed root penetration along "several seam sections". Root penetration means the PVC liner has failed and if it has failed I'm not sure its condition should be considered fair. 3. As mentioned, pinholes were present in PVC Sample B-1 . This was obvious to everyone present during the field activities as well. Was an effort made by S&ME to quantify the density of the pinholes using a light table? This method is much more accurate than the use of sunlight in the field. A light table may have yield pinholes in Sample B-2 as well . 4. In the field I observed at least one hole in the PVC liner which was approximately 1/2 inch in diameter. This hole was not mentioned in the S&ME report. The hole was obviously not caused by the excavation process because it had roots growing through it. It was either missed by S&ME or considered a pinhole. Both of which I find hard to believe. 5. I recall that the condition of the liner was documented in the field with photographs. Were more detailed pictures taken in the laboratory as a part of the analysis? If so, can copies with descriptive text be provided. I feel that this could be of tremendous value to Working Group members who were not present for the excavation activities. 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 ,,. MEMORANDUM June 13, 1997 Page 2 6. Portions of the PVC liner in the north excavation were severely wrinkled and significant depressions in the surface of the PVC liner were present in the south excavation. The depressions appeared to be made by a track hoe prior to placement of the PVC liner. The S&ME report does not address whether or not this condition of the top liner may result in increase potential loss of integrity. 7. As I mentioned in a previous memorandum to the Working Group, a portion of the PVC liner seam at the south excavation (B-2) appeared to contain no adhesive. This matter was not discussed by S&ME. 8. With respect to the integrity of the liner system, the conclusions of the report are not as definitive as they should be. Especially, given the obvious poor condition of the PVC liner as observed by several in the field . If, as suggested by Joel, there is an earlier draft to this report submitted to the State, I too would like to review it. Changes to the report in moving from draft to final could possibly explain the contradiction between the first and the second sentences of the final paragraph of page 8. I fail to understand how the PVC liner condition could be considered fair if it is breached "along several seam sections". PAB/psg/6-l JWGJ.doc cc : Joel Hirschhorn BFA ===:: :::: Post-Ir Fax Note 7671 Fax# TO : Mike Kelly and The Working Group FROM: Pat Barnes, Science Advisor DATE June 13 , 1997 SUBJECT: Review of Landfill CAP Evaluation I have reviewed the June 5, 1997 report from S&:ME evaluating the Landfill Cap System and disagree with the statement that the PVC liner "appears to be in fair condition". My points of concern and questions for S&ME are summarized below: l . S&ME states that the specifications of original PVC liner was not available for comparison. I am concerned that by comparing the test results given in Table 2 to a "typical 10-mil PVC" liner, we may not be comparing apples to apples. Can a range of values be provided for various types of I 0-mil PVC liners available so that a more detailed comparison of test results can be made? 2 . I am uncertain how the PVC liner condition could be considered fair if the seams showed root penetration along "several seam sections". Root penetration means the PVC liner has failed and if it has failed I'm not sure its condition should be considered fair. 3. As mentioned, pinholes were present in PVC Sample B-J . This was obvious to everyone present during the field activities as well. Was an effort made by S&ME to quantify the density of the pinholes using a light table9 This method is much more accurate than the use of sunlight in the field. A light table may have yield pinholes in Sample B-2 as well. 4. In the field I observed at least one hole in the PVC liner which was approximately J /2 inch in diameter. This hole was not mentioned in the S&ME report. The hole was obviously not caused by the excavation process because it had roots growing through it. It was either missed by S&.ME or considered a pinhole. Both of which I find hard to believe 5. I recall that the condition of the liner was documented in the field with photographs. Were more detailed pictures taken in the laboratory as a part of the analysis? If so, can copies with descriptive text be provided. I feel that this could be of tremendous value to Working Group members who were not present for the excavation activities 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 MEMORANDUM June 13 , 1997 Page 2 6. Portions of the PVC liner in the north excavation were severely wrinkled and significant depressions in the surface of the PVC liner were present in the south excavation. The depressions appeared to be made by a track hoe prior to placement of the PVC liner The S&ME report does not address whether or not this condition of the top liner may result in increase potential loss of integrity. 7. As I mentioned in a previous memorandum to the Working Group, a portion of the PVC liner seam at the south excavation (B-2) appeared to contain no adhesive This matter was not discussed by S&ME. 8. With respect to the integrity of the liner system, the conclusions of the report are not as definitive as they should be. Especially, given the obvious poor condition of the PVC liner as observed by several in the field . If, as suggested by Joel, there is an earlier draft to thi~ report submitted to the State, I too would like to review it. Changes to the report in moving from draft to final could possibly explain the contradiction between the first and the second sentences of the final paragraph of page 8. I fail to understand how the PVC liner condition could be considered fair if it is breached "along several seam sections". PA.8 psg 6-HWOJ.dc>c cc: Joel Hirschhorn .BFA Environmental Consultants Barnes,· Ferland and Associates, Inc. DRAFT MEMOJ,lANDUM TO: FROM:· DATE: Dollie Burwell and Working Group Patrick Barnes, Science Advisor May 22, 1997 SUBJECT: Background Community Data Collection BFA #95-017 Dollie, I strongly recommend that the Working Group begin an effort to formally gauge the opinions of the community as it relates to the PCB Landfill. This information is an important first step in preparing for comprehensive community involvement. The data collection can be accomplished with a simple survey form which would be distributed by mail, at community centers and churches. The survey will ask questions such as: • How close do you live to the landfill? • How long have you lived in the area? • On a scale of I to I 0, how do you feel about the landfill being in your community? • How do you rate your interest in learning more about PCBs and the PCB landfill? • Would you attend a community forum to discuss recent developments in our understanding of the PCB landfill? I don't believe the Working Group has formally established a community outreach committee. My working with such a sub-group is discussed in my scope of services. Please let me know if you agree with the need to move forward formally with the project's community involvement component. PAB!psgl5-22DB2.doc 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office ( 407) 896-8608 • Fax ( 407) 896-1822 I • I I I Poet-It-Fa,: Note 7671 Tn MEMORANDUM TO: Mike Kelly and PCB Landfill Working Group FROM: Patrick A. Barnes, Science Advisor DATE : May 12, 1997 SUBJECT: Questions Concerning Recently Receh,ed Landfill & Area Te1t Data As discussed during our May 8, 1997 Working Group Meeting, there are several questions and comments which I have concerning the above referenced laboratory data. 1. The analytical data reported by the State laboratory are all recorded by hand. Although there is nothing inherently wrong with this, it undoubtedly could result in transcription errors. How much of the data being reported by the .State is actually being manually derived from strip chart recorders? · 2. In addition to the identification number assigned by the Science Advisors, the State assigned two sets of additional numbers. l believe that Hus introduces other sources of possible transcription errors. 3. The detection levels for several of the v()latiles and semi-volatiles are much higher than those standardly used by commercial labs and in many cases higher than the North Carolina Standard for Ground Water (GA or GSA (Tl SA: 02L.0202)). Some examples are : Standard Detection Limit Benzene Chlordane T etrachloroethylene (PCE) Trichloroethylene (TCE) Vinyl Chloride t ppb .027 ppb .7 ppb 2.8 ppb .015 ppb s ppb 2 ppb 5 ppb 5 ppb IO ppb 4 Some pesticides are not reponed, including DDT. Others such as heptachlor, heKachloro- benzene and chlorodane are reported sometimes and sometimes not. It was my understanding that pesticides and herbicides would be run and reported consistently for all analytes, for the identified samples 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896·1822 ,I - . I MEMORANDUM May 12, 1997 Page 2 S. We were not given any QNQC data or summaries for any of the State's results . Does the lab have such things as method blanks, internal control standard recovery, matrix spike or laboratory duplicate infom1ation. 6. The results of the air monitoring presented at the Working Group meeting indicate the presence of Arochlor 1242, 1254 and 1260 at at least one of the locations on the facility, near the area of evaluation. Although no other monitors apparently registered PCBs including those in the excavation, the re~ults are indicative of what would be expected for this facility design and correlate well with the other data gathered thus far . PAB/p.,f.15-12MK I.doc .BFA =-= = =- March 27, 1997 To Mike Kelly, Working Group and Joel Hirschhorn From Pat Barnes SUBJECT: Pilot Scale Testing Proposals from ETG and Eco Logic As we discussed by phone and after reviewing both proposals, I believe the prices are high I think the primary reason the prices are elevated is the prior understanding of the vendors that they were competing in a limited field. Although Eco Logic took a more comprehensive approach with their proposal preparation, they neglected to include the preparation of a report at the conclusion of the pilot testing Such a document is imponant to discuss the efficiency of the testing and the suitability of the waste streams to be recycled for alternative uses. They also did not include a line item for coordination \vith the State and the science advisors. Both of these items were included by ETG It is possible that Eco Logic plans on performing these services but neglected to break them out on their cost itemization. However the Eco Logic's proposal did attempt to address community involvement, a.n issue which in my mind should be a major point of focus by the working group for all future work acti\'ities related to the Landfill. By including Guild fncorporated as a subconsultant to work on behalf of the community, they have at least recognized that this is not just a technical project. My major point of concern stems from the Phase I costs outlined in the ETG proposal These costs are the subject of Joel's March 27, 1997 fax . ETG has included $26,000 in their proposal to upgntde their equipment. This should be unacceptable unless upon completion of the project the equipment ( or separately functioning portions thereof) will become the property of the State. The other questionable line item is $23,400 for equipment rental. I cannot understand how a rental cost of $23,400 could be accrued in a 2 week period. The State should request further details on this line item. The Phase Il costs presented by both firms are also higher than one \VOuld expect given the stated product delivery time, It is important to note that the Eco Logic team proposes to perform a 60~-i:, preliminary design document. This appears to be a more substantial effort than that proposed by ETG. However, because both values are comparable and because there were only two respondents, the Stat.e's hands are somewhat tied. 3655 Maguire Boulevard· Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 Recommendations: I . Have ETG remove the cost of equipment upgrades. 2 Have ETG provide supplier verified equipment rental costs. 1 Verif)1 that Eco Logic will provide a testing report at the conclusion of pilot testing. 4. Request an hourly cost breakdown for Phase II activities from both proposers. :i Inform both respondents that the State reserves the right to negotiate a final Phase 11 price proposal separately prior to Notice to Proceed with those activities. 6_ After all avenues have been exhausted and even if no, or only limited, concessions have been made, [ recommend that the State proceed quickly with Phase I contract awards to both companies This recommendation is based on the fact that both companies appear to be technically qualified and the fact that time is of the essence on this most important objective of the Working Group BFA ~ PCB l.1.ll]Rk I Nl3 C3RCIUF' Fax:919-257-1000 Mar 4 '97 10 :45 P.01 PCB Landfill Working Group / Tec~~~--C~ttee , ,,<.Y .,,,.,, . .-/ /. ,</' ~-_<...-/ Pat Barnes, Science Advisor /·:;::.y· k_:--:.:.:~~_., i \...------- DATE: March 3, 1997 SUBJECT: Status of Landfill Work Activities 2/20 through 2/28/97 Monitorin1 Well Drillin& Groundwater monitoring wells continued to be installed at a steady pace. The focus shifted from the off-site or background wells to the well located in the gorge ( draw) features. The drilling activities demonstrated how irregular the depth to bedrock is at the landfill site. The following is a summary of the approximate depth to rock below landsurface for the landfill locations drilled this past week. Approximate water levels during drilling is also given_ Monitoring Welb Depth to Rock AP.~roximate water level MW-6 59' 25' NW-8 16' below bedrock MW-9 19 1/2' 10' MW-10 761 2 1/21 "MW-7 461 25' MW-3A 65' 20' MW-4A 40 1/2' 17' This varied depth to rock underscores the importance of implementing a comprehensive drilling program prior to landfill facility siting. Drilling will continue next week on the monitoring wells closest to the landfill_ Because it is not always easy to predict groundwater flow, it is important that the monitoring network be as comprehensive as possible. Therefore, upon further review of the site topography, I strongly recommend the installation of two additional monitoring wells directly adjacent to the landfill. The wells will be located near the northwest and comers of the landfill. I have discussed this e~ensively with Mike Kelly and he has agreed to it. PCB WORKING GROUP Fax :919-257-1000 Mar 4 '97 10 :46 P.02 Liner Inspection S&ME and their subcontractors removed portions of the 10-.mil PVC liner for integrity testing on Friday. The procedure used generally included cleaning the surface of the 10-mil liner, cutting it with a utility knife, removing the liner material to be tested and replacing it with a 20-mil patch. The patch was installed by solvent welding. (Note this is of parti.cular interest because air monitors used during the liner operations are likely to detect vapors from the solvent compound.) After the liner was cleared, cut and removed, it became very apparent that it contained several breaches. I saw several holes in the liner. Most were very small pin holes. However, the liner also contained a failed seam. The seam failure was evident by extensive root growth through it and beneath it. The liner removed from the north excavation appeared to be in worse condition. However, both had obvious signs of significant failure. In fact, portions of the seam exposed on the south excavation appeared to contain no adhesive. The observations made are consistent with normal means of liner failure and support the hydrologic data analyzed previously, which indicate that water is entering the landfill facility. The contractors completed their patching work by solvent welding the liner material to the PVC well casing. A geotextile material will be placed over the liner prior to backfilling of the excavation. Backfill of the excavation is scheduled to occur:-Monday, March 3, 1997. I recommend that the integrity of the liner be a topic of discussion at the next Working Group meeting. Analytical Sampling The sampling event has been rescheduled to occur during the week of March 10, 1997. Craig Brown with the EPA, has postponed their planned March 17th event and instead will plan on performing a separate sampling event only if the results of the March I 0th event warrant it. The EPA will still be present for the State1s sampling event and plans on splitting 20% of the samples. As discussed in the last Technical Committee phone conference, I have informed Mike that we would like to include analysis of pesticides and herbicides in the monitoring wells and landfill soil samples. Mike and I will meet this week to determine the location of additional sediment samples. MEMORANDUM TO : Working Group FROM: Patrick Barnes (Science Advisor) DATE : February 20, 1997 SUB.JECT: Status or Work Activities at the PCB Landfill (February 13th through February 19th) BFA #95-017 As you know, several of the long awaited work activities began last Wednesday . The following is a general update of what has occurred thus far. Wells A total of four groundwater monitoring wells have been installed. Three background (off-site) monitoring wells and one of the gorge wells. Both the Austin well was completed and Sommerville off-site wells were completed to top of rock which was approximatety 43 feet and 42 feet below land surface, respectively. The Davis well was completed to 35 feet. We terminated above rock at this location. Upon further review, I recommend that the Sommerville location not b~ analyzed because of trash identitled in a near-by gorge. The State concurred and has made arrangements to use adjacent property to the west. The gorge well number 6 which is located to the south of the facility was completed today to a depth of approximately 60 feet . The driller will continue to construct the wells in the draw (gorge) features and the ott:..site wells prior to moving directly adjacent to the landfill. The welJs have been going in at a rate of approximately one per day. Ambient Air The State finalized the ambient air monitoring at about noon on Monday. Because of the need to move forward w.ith the landfill drilling, the decision to halt ambient air monitoring wa.c; made jointly by Joel and my~elf H'nwr:vc-.r, it i~ important to n.ote that some of the air samplr-, did not reach the targeted 1500 liter volume. The air monitors were repositioned (moved in closer) to monitor for potential releases associated with the landfill drilling. 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 Analytical Sampling The major sampling event is scheduled for the first week in March; however, to help determine if the equipment used by the drillers to install the wells is being cleaned properly, a rinseate sample blank was collected on Tuesday. A soil sample from the water table interface from one of the background wells was also collected. As called for by the Working Group, I was responsible for sample labeling. The samples will be held and analyzed concurrent with those collected in March. Landfill Drilling Joel was on-site for the soil sampling to characterize the physical condition of the material in the landfill which occurred Tuesday morning. The samples did not appear nearly as saturated as we had envisioned they would; however, after the well was installed the saturated thickness in the landfill was measured to be about 12 to 13 feet which is in line with what we have seen from measurements both in the central vent and the leachate access pipe. The contractors were apparently able to obtain the material for bench scale testing without problems . P A,81p1g/2· 201tv / .doc .BFA ~:n== - ~ ..BFA Environmental Consultants and Associates, Inc. MEMORANDUM TO: FROM: Mike Kelly Working Group Pat Barnes .. DATE: February 10, 1997 BFA#95-017 SUBJECT: Proposed S&ME Work Plan for Landfill Liner Testing/Soil Removal and Water Recovery Well Installation ... Mike, as we discussed, please have S&ME add the following to their proposed work plan. 1. Exact procedures which will be used to obtain soil for testing. Will the soil be collected off of the auger flights or with large diameter samplers placed inside the Hollow Stem Augers (HS As), or, does S&ME Plan to spin the augers until enough material reaches the surface? Because our goal is to obtain relatively undisturbed material, I recommend the use of either large diameter solid stem augers (SSAs), or large volume samplers with HSAs. With SSAs, a continuous vertical profile of the material within the landfill can be obtained with minimum disturbance of the material. Depending on the outside diameter of the flights, successive passes into and out of the landfill may be required. Over spinning to bring material up is not recommended. It is best to slowly tum the augers in to the full depth ( determined by prior sampling, as outlined in the Work Plan) and then upon their removal simply take off the soil needed for analysis. If HSTs are used for soil removal, material can be obtained both with large diameter samplers placed inside the augers and as with SSAs, from the flights upon removal. Once again, overspinning is not recommended because it will alter the water content of the soil. 2. Soil volume calculations for the selected method. Please include the estimated volume of soil contained on the string of augers proposed to be used. Include a procedure for recovery well design. Screen slot size and filter pack selection should be based on the results of sieve analysis from the anticipated screen interval. PAB/psg/2-JOMKJ.doc cc: Joel Hirschhorn 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 , r~' , ~ft~;-;,.BFA Environmental Consultants 'i '/'-''; t fjy, Barnes, Ferland and Associates, Inc. MEMORANDUM TO: Mike Kelly Working Group FROM: Pat Barnes, Science Advisor 1 DATE: January 29, 1997 SUBJECT: Comments to Final Draft of Bench Scale RFP BFA #95-017 It is good to see that things are finally moving along quickly. With respect to the subject RFP, the ranking system would be nice because it would help us to obtain more comparable bids However, it is not necessary and given that the State has written a fairly tight package, I recommend proceeding without it. The affirmative action language is very weak and does not do justice to the history of this project. I recognize, however, that it is the standard language. I recommend that you personally contact the Co-chairs of the Working Group to discuss this issue. PAB!psgll-29MKI.doc 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office ( 407) 896-8608 • Fax ( 407) 896-1822 ..BF A Environmental Consultants ---Barnes, Ferland and Associates, Inc. i\lEMORANDUM TO FROM: DATE: Working Group Patrick Burnes, Science Advisor January 24, 1997 BFA #95 -017 SUD.JECT: Comments Concerning EPA Letters to Bill Meyer dated 12/19/96 and the Working Group Co-Chairs dated 1/6/97 Please incorporate the following thoughts in the Working Group's proposed response to the recent EPA letters : I. 111 addition to the p1 oposed review of landfill operational records we would like Lhe EP ,\ to review the documents detailing the analyses performed by our Science Advisors 2. The December l 9th letter indicates that a review of EPA files has already been performed. What in that review prompted the proposed collection of groundwater samples? Both the Science Advisors and the State agree that the current groundwater monitoring net'>;ork is not suflicient to detect possible releases. It is good that the EPA wishes to collect additional groundwater samples, however, it would be more beneficial if new locations were selected to supplement the existing ones. The Worl<lng Group welcomes the collection of grab samples which could easily be obtained from surface water in the gorge features near the landfill or of sediment in depositional areas/surface water flow choke points. 3 The Working Group wishes to have at least one of our Science Advisors present during the proposed EPA sampling. Poat-It' Fa)( Note 7671 Dale I To Co/Dept. co. PhOne • Pho~ I 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 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 n.Q1 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 poHcy 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 letter to you we raised several illustrative questions relating to the central 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 National Priorities List site as which a remedial 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 CERCLA/Superfund statute and program. IfEPA 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 environmental racism more than the benefactor of environmental justice, expect to wait for a Jong time for offical EPA responses to our reasonalbe questions. Thank you for your personal consideration. /4-or~-!s ~~ ~ ffi~ ~ tAl_f_M_ .· -~o f,r;._ cl',_,j ~sAAQI~ -~_d, 1<23-'77 /4{_ . f ~ddn<A ~~7 -,j:~«f,,,~ /'L f rL ;mfj (n r'M au ~1,rx,,, -~o fr,;., ~ 4J'j -ddd. 1-;11-97 /4L-: J1 d~ n--;fFP .s -~o r/<_;y,__ # ~t'.Y· kd, /-,;l/-o/7 ~--t?~_,_~ ,,f ,z-1)_,_ c{ft/ -~o c/, ~ O:J dl~c/;/2o-n-, -da:f ~c . 1-,;J.d--9? .,u_ .· f(rr' r _,bd)-?,a /4'!J -;--_,,,17fa-,!vrlL-i7 ol,o/ -1~0 t.,,;µ /2&-~ -da:f ...<d'.'. /--23-97 AL-: .bfo~.L {2,-i ,J~r717 f,..,_ /c::0 vrads I • I "': c \ -\ Mt_ It dt.."~~k f ~ 1~1J1 ... }y, \--::J:IF A Env!f?nmental £o~sul~ Barnes, Ferland and Associates, Inc. MEMORANDUM TO: Mike Kelly Working Group Joel Hirschhorn FROM: Pat Barnes DATE: January 23, 1997 SUBJECT: Proposed Air Sampling for PCB Impacts To formalize what we discussed Tuesday, prior to the Working Group meeting, I feel that more focus should be given to the need for immediate sediment samples. As you know, the air is a very dynamic media and the results of any analysis performed, unless positive, will be inconclusive. Moreover, a negative sample will yield no new information on potential past releases. Perhaps the best reason for performing air analysis now is to begin to establish a baseline of air quality data within the vicinity of the landfill, which will be a very valuable tool for future impact assessments. With that in mind, it is therefore very important that the locations and analytical approach established today be well thought out and as comprehensive as possible, because future changes to the plan, unless additive, should be minimal. In our conversation, I recommended, and you concurred, that an additional location be added to cover potential discharges in the vicinity of the leachate treatment systems. Like the main gas vent, the septic tank vaults and effluent discharge line have a direct connection to the landfill waste material. It may be prudent that the lids to the concrete vaults be redesigned to be air tight or fitted with gaskets to minimize the potential for PCB vapor discharges. A filter may also be necessary on the effluent outlet pipe, or any other gas release point of the treatment system. Concern over the environmental impact of past releases at this point can be best addressed by the collection of sediment samples at surface water flow choke points. There should be several such areas within close proximity of the facility. Mike, you have agreed that this effort makes good sense, however you suggested that it be addressed as a part of the full sampling. Since well drilling will not begin until early next month, and because samples will not be collected until after the new wells are installed, which is likely 3 0 to 45 days later, I recommend that we consider collecting sediment samples concurrent with the proposed air samples. The locations can be selected after one field day's work within the coming week. Please give me a call to discuss this matter. PAB/psgll-23MKJ.doc 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office ( 407) 896-8608 • Fax ( 407) 896-1822 January 23, 1997 .................................................................... by FAX (2 pages) To: Mike Kelly Working Group Pat Barnes From: Joel Hirschhorn Re: Recommendations 1egarcling state's plan for testing for PCB air emissions To follow up on ow· discussions last Tuesday, I offer the following recommendations for on.site testing by the state. 1. Your office should follow the recommendation by Laura Butler in her memos of December 23, 1996 and January 10, 1997 that the Science Advisors be given the opportunity to provide oversight of tl,e a.ir monitoring your office performs or has performed for it. 2. The vo.1u.tne of air samples taken for the purpose of measwing PCB levels should be at least 1500 cubic meters. I emphasize that it is sample volume not the velocity of the sampler that is most important with respect to obtaining low detection limits. 3. The sampling method used should provide the capability of measuring both PCB vapors and PCDs attached to particnlates. It should also include a means for verifying the extent to which breakthrough of sorne PCB vapors may have occurred with respect to the collection medjum. 4. The analytical methods used should be capable ofidentifying the full range of PCB congeners. 5. The test results should be provided in terms of total PCB concentrations, as well as in terms of at least three Aroclou (1260, 1254, and 1242). 6. The test results should be l'e:portcd in texms of PCB vapor concentrations as well as particulate pl,ase .levels. 7. The combiuatiou of sample size and analytical methods should result in a capability to reliably detect and report PCB levels as low as 0.1 nanograms per cubic meter vapor, and 0.01 nanograms per cubic meter particulate phase. 8. l11e sampling and testing protocol should include several .field and lab blanks, as well as spiked samples to determine recovery rates. 9. Accurate, complete, and reliable meteorological data should be obtained for all air S8.JllI)lcs so that ambient conditions are known over the entire period of time that air samples are collected. 1 Changes in wind direction relative to sampling location. are particularly important. Obviously, sampliug events should be bused in favor oflocations and times when the locations are downwind of the landfill. 10. Soil or sediment samples taken for PCB analysis should be in locations that c.an reasonably be considered places with PCB air releases may have been deposited . . 11. All PCB laboratory test results and documents diould be provided simultaneously to tl1e Science Advisors and the state. 12. Any public statement by the state concerning the test resuJts must pay explicit atteutio.n to the possibility of current fat.se negative findings with ,espect to PCB levels that might have been higher at previous times and at past or futwe periods when ambJent temperatures ate higher. 13. A number of samples collected primarily for measuring methane levels should also iuclude sufficient air sarnples for testing for PCB levels. 2 January 22, 1997 To: Mike Kelly, Working Group, Pat Barnes Fmm: Joel Hiischhom Re: Rf P for technology testing/preliminary design LIKE THE PREVIOUS DRAFT I REVIEWED, nns DRAFT IS TOTALLY UNACCEPTABLE AND TIIE STATE SHOULD NOT PROCEED WITH ISSUING THIS RFP UNTIL A VERSION IS PREPARED TIIAT IS ACCEPTABLE TO ME AND THAT I CAN RECOMMEND 10 THE WORKING GROUP. Here are my co.mmeuts and recommendations for the draft faxed to me today: 2.0.5 Conect language to read '' ... are app.ropriate and potentially feasible ... " My point is that the technology assessment/screening already performed has addressed the issue of approp.tiate folly and this should not be invoked as something 1equiring verification through bench-scale testing. Also, this .is the section that ought to include a refe1ence to some type of appendix document that supports the selection of the two technologies noted. Attached is the documeut that I recommend usiug. 2.0. 7 The language should be conected to read " ... testing on representative waste or contaminated soil matetials from the PCB landfill." · 2.1.1 The language for Phase II should be corrected to read " ... use of the detoxification. technology selected o.o. the basis of Phase 1 results to .... " 2.1 .4 · Add, nfler first sentence: "It is anticipated that the Phase II contract will be awarded v-.ithiu 30 days of obtaining the final Phase I Test Report." 2.2. l Delete "appropruteness and." \ ·', 2.2.2 Delete fust sentence. The language in second senteo.ce ~houJd be corrected to read "The pn:limiaary goal for .... '' . ' 2.2 .3 U~e fom1er first sentence of2.2.2, changing Appropriateness to Feasibility, and use as fir~1 sentence here. Modify new secmld sentence as "Feasibility will also be detemJined .... '1 2.3. l Add some language " ..... effectively, reli.ably, and safely .... " 2.3.4 Add: "1be technical and economic implications and equipment necessaty fol dewatering in the fuJJ scale detoxification of the landfill must also be thoroughly discussed." 1 2.3.6 Add: " .... facilities, possibly during some of the actual bench-scale testing." 2.4 .1 Add: "111e degree to which materials handling aod dewatering can be minimized in foll scale detoxification at the landfill is an evaluation criterion for judging the overall effectiveness pc1formance of the technology in Phase I and for selecting one Phase I vendor for pro~·iuing Phase 11 services. 11 2.4.2 Correct language: " .... are present m ppq to ppb concentrations. 11 2. 6.1 Moclify language: " ... for obtaining and presenting test data ... '' 2.6.3 Add: "The implications of varying perfornwi.ce for reliability for fuU sea.le use of the tech.nolc,gy must be discussed." 2.8.3 For (fJ, add: " ..... including onsite and o.ffsite monitoring and testing for PCB air emissions as vapors and particulates." 2.8.4 Improve language: '' ... several meetings (probably at least fow-) in No11l1 Carolina . " 2.8.5 Conect language in .first sentence; " ... no later than 75 days ... " 2.10.2 Add: " ... disposa~ preferably ht a pre-proposal submission prior to or at the pre-proposal conference." 2. 10. 3 Add at beginning of fast sentence: "H necessary, .... " 2.11..5 lnsclt: " ... key personnel. .. " 2. 11 . 6 If this Iauguage was not used in the three pre\ious RF.Ps, then this section should be fully deleted. 2.11. 7, 2.11.8, 2.11. 9 These sections should be .fully deleted, because they are w.wecessary, inapp1opriate, and overly burdensome. 2.11 . l O Improve language in second of three points: " ...... for risk communication, prnvision of techoical information for nonprofessional audiences, and community relations ." De.let~ third point altogether. 2.12.3 This is redundant and unnecesS8.I}' and should be fully deleted. 2. 124 This section seems to introduce a totaUy new key work product. other than. the fiu3l Test Repo1t from .Phase I and the final .Preliminary Design Report .fro.m Phase II and, therefore, is 2 .. ' inappropriate, unnecessary and overly burdensome. It must be fully deleted. 2. 12. 5 This section ( which contains only six of the nine evaluation criteria in the Su1,erfund program) is unnecessa11\ overly bwdensome and mould be fully deleted. Such cdteri~ are used when comparntive evaluatio.ns of alternative remedial options are made, and when a specific one of the options is selected and justified. Such analyses and justifications are not part of what the vendors are being asked to do in Phase I and II. This section should be fully deleted! 2. 13 As I have ah-eacly discussed, this entire projected schedule is unacceptably long. In paiticular, 2. 13.4 needs to be addressed NOW and a more expeditious appi:oa,h obtained from EPA l want to obtain a determination by EPA that all BCD licensees and the Eco Logic technology is fully acceptable for the Phase I testing. 2.13. 7 is an \mclear statement, because it is not stated what the recommendation is for. Is it fox the Phase II contractor? If so, then still more time is necessary for co.nducting Phase 11, which puts the entire schedule proposed by the state at more than a year! techdp4. doc 3 .. Appendix for technology RFP EXFLANATION OF SELECflON OF'IWO DETOXIFICATION TECHNOLOGIES A detailed technology screening, evaluation, assessment and comparative analysis has been performed for tl,e W~rren County PCB Landfill. All but two treatment technologies were screened out. Ouly .Base Catalyzed Deco.Jl1)0sition (BCD) and Gas Phase Chemical .Reduction technology were found to be appropriate and potentially feasible. The 01iginal use of the term detoxification technology by the state of North Carolina implies th:1t technologies that are considered cleanup or remedial technologies but that do not by themselves detoxify PCBs are not 11ppropriate for the Warren. County situation. Potential feasibility has bad to be demonsuated through prior successful full scale use of a technology for PCB detoxification work. All forms of containment technology such as caps and subsurface barrier walls have beeo ruled out as being inappropriate. All forros of separation technologies that do not actually detoxify through treatment have been · ruled out. TI•ese include, for example, thermal desorption, solvent extraction, soil washing, and soil vapor extiaction. All forms of stabilization/solidification have been eliminated as inappropriate, because they have not been thorough.ly prnven to actually and permanently destroy PCB molecules, rendering them penrtanently nontoxic. Any use of high temperature incineration has been ruled out as being inappropriate because of ils potential for causing harmful toxic air emissions and its long history of being deemed unacceptable by c.ommunities, especially when used in locations close to residential areas. All fonns of biotreatment or bioremediation have been screened out on the basis of insufficient prnven effectiveness. For many years various forms ofbiotreatment have been pursued for PCB cleanups. The coucJusioo has been reached that biotreatment ;snot yet proven effecili·e and reliable enough for full scale use either as an in situ or ex situ technology, in aerobic or anaerobic form or some combination. of them, for the Warren County application .. Jn situ vitrification has been sc.teened out because of insufficient full scale application. Thjs technology has been under extensive development for many years, chiefly within tbe DOE system. While so roe people have viewed this technology as a variant of incineration, chiefly because it employs very high temperatures. it usually is considered as a unique technology. Bwied wastes can be heated to m.elt all materials and form a vitreous or glassy material. The process thennally destroys organic contaminants and an extensive offgas, air pollution control system is used. luterestiugly, in October 1995 EPA granted Geosafe a National TSCA Operating Permit for the 1 . ' n.atiomvtde treatment of PCB& within a large number of prescribed circumstauces, inclllding n1axiruwn average conccutrations of 14,700 ppm md maximum hot spot concentratiou.s of 17,860 ppm TI1.e company obtained Ws regulatory permit on the basis of a site demonstration that achieved various performance criteria, including six nines destruction. and removal efficieucy arid less than 2 ppm PCB& in vitrified product. No detectable dioxins/flmin.s were found in offgases. But the demonstratio1J was not on in situ wastes similar to the Warren Co\Dlty situation. This technology must be con.sidered detoxification, and it offers the comparative advantage of being inuinsically applicable for in situ treatment, avoidin.g the need for excavatio.n of materials. In theory, the techoology could be applied directly to the Warren County Landfill, perhaps '\\ithout dewatering the site, although the site's location would pose significant problem for using the extensive equipment. lhe conclusion has been reached that this technology is not acceptable or feasible for the Warren County application, and that it could not be suitably evaluated through bench-scale testing. Because the objective is to select a detoxification technology that has already been proven effective for PCB detoxification thrnugh full scale, commercial use, and that will be demoustrated effective for full scaJe aJJplication at the Warren County PCB Landfill on the basfa of bench-scale testing of site contaminated soils, no technology that bas not yet been fully deployed in a full scale detoxification of PCB wastes will be considered appropriate and potentially effective for thls application. No technology that exists only as a research or developmental technology is deemed appropriate and potentially feasible for this application and, therefore, for bench-scale testiug. 2 State of North Carolina 1 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 MEMORANDUM: TO: FROM: SUBJECT: MIKE KELLY\ UPDATE ON Rf P'S January 21, 1997 The following is the current status of Requests for Proposals: 1. MONITORING WELLS: The contract for monitoring wells is being sent to Environmental Investigations at a cost of $69,615. They can be ready to start digging within two weeks of signing the contract, and based on my conversation with them we should be putting the wells down by mid-February. 2. DIOXIN FURAN TESTING: The contract will be awarded to Southwest Laboratories of Oklahoma at a cost of $28,560. They have a representative in the Raleigh area that will participate in the sampling event and take custody of the samples. I will speak with them in the next couple of days to finalize the time frames. 3. BORE HOLE/EXCAVATION WELLS: It is anticipated that the contract will be awarded to S&ME at a cost of $38,576. I anticipate working closely with them in the next few days to begin submitting the necessary documents to EPA for approval. I have spoken with EPA this morning and they will try to expedite the permitting of this activity. 4. BENCH SCALE PILOT STUDY: On January 2, Joel Hirschhorn submitted his plan for this RFP, which we put into the state format. There has been an initial review of our first draft and the second draft is available for review. Contracts and purchasing is also involved in this loop to help expedite the RFP. EPA has supplied a list of their approved vendors for BCD. The RFP will state that only BCD and gas phase chemical reduction technology will be considered. We should have this RFP finalized next week and anticipate getting it out by February l. As of today, we have not set up the schedule of events to coincide with this study. P.O. Box 27687, Raleigh. North Carolina 27611-7687 Voice 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/lOo/o post-consumer paper 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 MEMORANDUM: January 21, 1997 Er'A a a lAcsrm aw a DEHNR TO: WARREN COUNTY PCB WORKING GROUP FROM: MIKE KELLY SUBJECT: ACTIVITIES AT THE LANDFILL Attached are copies of an overview on three planned activities the Division of Waste Management plans for the next couple of months at the PCB landfill: 1) AIR MONITORING 2) METHANE GAS MONITORING 3) WEATHER STATION INSTALLATION As discussed with this group last month, we had planned to do some air monitoring at the landfill the week of January 6th; however, we were unable to get the materials to the science advisors quickly enough to allow them to review it in as great as detail as they wished. As of now, we have not rescheduled this event, but hopefully will get it done in the next 3-4 weeks. A copy of the protocol is attached and we have incorporated many of the suggestions from Joel Hirschhorn, and plan to include an additional sampling site in the sand filter bed based on a recommendation from Patrick Barnes. Patrick also suggested that we do additional sediment samples in the area, which we will incorporate in the major sampling event we hope to conduct next month. We also are gridding off the area of the landfill to check for methane leaks in the liner of the landfill. This testing will be ropart of our check on the integrity of the top liner and provide us with safety information to be utilized in the digging and well construction in the landfill. We are likewise working on the installation of a weather station at the landfill to record and provide us real time data to be used in a variety of ways as we push towards detoxification of the landfill. . All of these events will be done exclusively by Division personnel and with Division funds. Participation by members of the Working Group and science advisors is welcome. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Voice 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 1()% post-consumer paper PROJECT: I,ROJECT PARTICIPANTS: PROJECT DATE: PURPOSE/OBJECTIVE: Methane gas monitoring as a measure of liner integrity on the Warren County PCB Landfill Larry Rose Wendy Peacock Bill Sessoms Open Gases, primarily methane, are being generated from microbial decomposition of vegetative matter in the PCB Landfill. Methane concentrations of 5% the lower explosive limit, LEL, of the air vent gases have been measured. The presence and flow of methane indicates that the gas pressure in the landfill cell is greater than ambient pressure. The PVC liner was designed to contain gases and provide venting only through the existing air vent. If the PVC liner system is functioning as designed, there should be no gas leakage through the liner. Methane measurements can indicate the status ofliner integrity. If methane is measured, then the source and cause can be determined and options for remediation proposed. The purpose of the project is to implement methane monitoring as a means of determining surfidal liner integrity MATERIALS AND METHODS: The PCB waste disposal site in Warren County as-built plans are by Sverdrup & Parcel of 1981 and will be used to identity the landfill disposal cell. During the week ofJanuary 13-17 the staff will establish baselines on the landfill site. These baselines will be used to locate grid patterns on the surface of the landfill cell at some future date. For proposed methane testing the landfill surface will be marked with temporary wire flags on a 50 foot grid interval. This will provide between 50 to 80 methane sampling sites. At each of the sampling sites, a sliding hammer probe will be used to drive a three-fourths inch diameter by twelve inch deep void space in the landfill topsoil layer. The void space will be plugged with a rubber stopper for 12 hours to allow accumulation of methane. After the 12 hour accumulation the void space will be sampled for methane with a infrared gas analyzer. The gas analyzer is a Landtec GA90 model. The analyzer has an internal vacuum pump to extract gas from the void space through a flexible hose into a detection chamber. An infrared beam is projected into the chamber and through the gas. The gas concentration is determined by the degree of absorption of the infrared beam at the detector. An internal microprocessor calculates gas concentration and the result is displayed as a digital readout on the instrument. Gas concentrations are measured and displayed as percent by volume, parts per million and lower explosive limits (LEL). The instrument can also measure CO2, 02, and Static Pressure. The range and resolution for methane concentrations are: Range: 0-100% CH4 0-60% CO2 0-25% 02 Resolution:, 0.1 % 0.1% 0.1% The readouts will be logged at each grid location. Grid locations that indicate methane will be used for further investigations. The grid spacing will be reduced to 5 feet intervals around the initial grid location for additional methane monitoring. If no methane is detected the grid spacing will be reduced to 1 foot intervals. This process will identify specific areas of leakage, If methane is detected at the 5 foot grid intervals a second, third or more 5 foot intervals will be monitored to identify the area of leakage. All methane monitoring results will be presented to the Working Group for discussion and recommendations. Oversight of this project by the Working Group is welcome. c:wpfiles/pcblflmisc/ gas-mon. pro . I State of Norfh Carolina Department of Environment, Health and Natural Resources Division of Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary WIiiiam L. Meyer, Director MEMORANDUM DATE: January 17, 1997 To: Mike Kelly FROM: Bill Sessoms Wendy Peacock Larry Rose REF: PCB Landfill 6-·rA n •· ~,LU A DEHNR We have established baselines at the PCB landfill to facilitate obtaining gas samples. The outline provided by Bill Meyer was generally followed. The end risers of the irrigation system were used to establish: a centerline. Using this centerline, stakes were placed at 238-f eet from the center vent. Corner stakes were set 116-feet at 90-degrees from the centerline. To aid in re-establishing these points, stakes were set at the fence in line with the corner stakes. Appropriate measurements to these stakes were recorded. Flags were set at 50-foot intervals along the exterior baselines established by the four staked corners. The intervals were measured from the centerline stakes in the east- west axis and from the south end in the north-south axis. These baselines yield 55 to 77 sampling locations depending if the north-south axis baseline points are utilized. Two sketches are attached showing the layout that was established. C:\SESSOMS\PROJECTS\MISC\PCBMEMO. 1 P.O. Box 27687, Raleigh, North Carolina 27611-7687 Voice 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper . ' A LANJTEC W!/. i if,r lANDFlll CDNTRDl TECHNOIOGIU ,..... I oi::-Z ....-Providing Environmental Compliance Solutions for Landfill Gas Management. (BOO) LANDTEC Nationwide. A LANJTEC fi_P :g:; I (W LANDFILL CDNTRDL llCHNDLDGIEI ....,.... ,,. Providing Environmental Compliance Solutions far tandfi/1 Gas Management. (BOO} LANOTEC Nationwide. PROJECT: PROJECT PARTIClP ANTS: PROJECT DATE: PURPOSE/OBJECTIVE: Meteorological Station at Warren.County PCB Landfill Ed Mussier, P.E. Open Provide site specific rainfall, temperature, barometric pressure for monitoring landfill environment. Site specific data for evaluating recharge and discharge events including response of groundwater monitoring wells. This data will also be valuable during detoxification of the landfill. MATERIALS AND METHODS: It is proposed that instrumentation be installed for continuous monitoring of ambient conditions, internal and external, at the PCB landfill. The proposed equipment would be a weather station consisting of an ambient temperature probe, barometer, and tipping bucket rain gauge. Readings would be collected by a CR 1 OX date logger. The data logger is battery powered and the information may be down loaded into laptop computers for transport to the office. It is proposed to install the data logger and power supply in the existing maintenance shed, with the measuring devices located outside and attached to the shed. To monitor the conditions in the landfill it is proposed to install vibrating wire strips piezometers in the leachate line and the measuring tube in the gas vent. These devices measure the internal temperature of the landfill, the internal pressure, and the water level in the monitoring points. The data can be collected continuously and is stored in the same data collection device described above. The line from the instrument in the air vent will be run under the sod layer of the cap, to prevent damage from routine maintenance of the landfill. The Division currently owns a weather station. It is proposed that the data recorder, barometer, and rain gauge from this station was borrowed. Additional equipment will need to be purchased by the division. The following is the equipment proposed for use at the landfill: 1 Campbell Scientific CRI OX data recorder l Campbell Scientific A VW4 4-Channel Vibrating Wire Interface l Met One Instruments 8" 370-Tipping Bucket Rain Gauge (0.10 inch sensitive) l Met One Instruments 26/32-1 Barometric Pressure Sensor l Met One, Campbell Scientific, or equivalent, temperature probe and radiation shield 2 Slope Indicator VS Piezometer (vibrating wire strip) (0-50psi water sensitive) plus associated signal cables 2 24 amp/hr jell cell rechargeable batteries, battery trickle charger (Sears or equivalent), miscellaneous cable, alligator clips, wire etc. [Available locally] All data will be submitted to the Working Group on a monthly basis. The frequency of reporting may be changed if needed by the Working Group. The Working Group is welcome to oversight this project. · · ' c:wpfiles/pcbWmisc/met-sta.pro • ,I . ! ···f· , ! I.· ,i, ,I •, ... fi. ' .. · 'l t . . ' f i.• .. , ! \ . ,. 1· 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 r4f•;h • a zl.ca,mas a DEHNR January 17, 1997 MEMORANDUM To: Mike Kelly Deputy Director Division of Waste Management From: Pierre Lauffer e;;{J Health and saVr c!oordinator Re: PCB Landfill Sampling/R.A. Hite's Study Review I read R.A. Hite's study titled, "Long-Term Measurements of Atmospheric Polychlorinated Biphenyls in the Vicinity of Superfund Dumps," and I generally have concluded that there is really no problem at all in addressing Joe Hirschorn's concerns regarding our sampling strategy for monitoring ambient air conditions at the PCB landfill, Warren County. If Dr. Hirschorn wishes the Division of Waste Management to have the samples analyzed for the congeners of PCUs (ic. dichlorobcnzene, etc.) as well as for PCBs, we can easily perform that monitoring at a cost that not much above the current cost projections. Dr. Hirschorn also stated that the analysis in Hite's study was much more sensitive than the EPA methods of 1982. While this is correct, we will not be employing those sampling methods and analysis as we will be employing sampling and analysis methods of 1997. For example, at that time, the typical procedure was to employ polyurethane foam (PUF) filters with a filter head containing glass-fiber filters. The procedure required the sampler to manually load the PUF into the filter. This process presented many quality control/quality assessment issues. Today the sampling procedures for PCUs state that ORBO-60 tubes are to be used in combination with glass-fiber filter cartridges. The ORIJO-60 tube is, in fact, a manufacturer loaded PUF filter combined with norisil filter plugs. ORBO-60 tubes consist of two 30/48 mesh norisil sections. The first section is proceeded by glass wool and contains JOO mg and the backup section contains 50 mg. There are two PUF sections: between the norisil sections and artcr the norisil backup section. These filter tubes will be manifolded to glass-fiber filter cartridge heads as required under NIOSH sampling and analysis methods. There was also a concern by Dr. Hirschorn regarding the air-now volume rate we will be employing as part of our study. The now rate is according to NIOSH sampling method #5503. We could increase that air-now to as high as 5 liters/minute (air now volumes of 2.5-5.0 liters/minute are considered high volumes), but we would not be sampling according to any established sampling methods now recognized, but using a study done by a nationally recognized professional. The sensitivity of Hite's study is also not a major problem. The laboratory we picked for the analysis is an American Industrial Hygiene Association accredited laboratory and is subject to the quality control and analysis sensitivity requirements for such accreditation. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Voice 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/10"/o post-consumer paper ... ·1: SAMPLING PLAN SUMMARY FOR: MEASUREl\tlENT OF FUGITIVE ATMOSPHERIC EMISSIONS OF POL YCHLORINATED IlIPHENYLS FROM THE PCB LANDFILL WARREN COUNTY, NORTH CAROLINA ·I ,, .. I .; . Sampling Plan Date: January 9, 1997 Sampling Plan Preparer: Pierre Lauffer Project Participants: Health and Safety Coordinator · .: , : Division of Waste Management ,. Raleigh, North Carolina 27605 Pierre Lauffer, HWS-Health and Safety Coordinator (Project Manager and Sampler) John Kirby, HWS-Environmental Chemist (Project Chemist and Sampler) Projected Sampling Dates: February, 1997 Site History: Between June, 1978 and August, 1978, over 30,000 gallons ofindustrial waste material identified as polychorinated biphenyls (Arochlor 1260 and 1262) were discharged deliberately along the shoulders of approximately 210 miles of North Carolina highways. In June, 1979, EPA approved a tract ofland (previously used for agriculture) in Warren County, North Carolina as the disposal site for the PCB-contaminated roadside soil. The landfill ( constructed in 1982-1983 and permitted under the Toxic Substances Control Act·(TSCA) contains about 40,000 cubic yards of soil contaminated with PCBs. The concentration of PCBs in the landfill range from 150 to almost 900 part per million (ppm), averaging about 350 ppm (1), based on 1994 subsurface soil sampling results (these were retrieved from the bottom of the vent)., Polychlorinated Biphenyls (PCBs): PCBs are a family of aromatic compounds consisting of two benzene nuclei bonded with two or more chlorine molecules. The PCBs of concern in this study (the type existing in the landfill) are the Aroclors. Aroclors are characterized by four digit numbers. The first two (the number 12) indicate that the mixture consists of biphenyls. The second two digits state the percentage by weight of chlorine in the mi xture (2). · · They tend to be colorless to light yellow oily substances with a specific gravity of 1.4-1.5 (3). Due to their stability and nonconductive properties, PCBs had many industrial uses including use as insulation coating in electrical capacitors. PCBs possess, as a whole, high open cup flashpoints (348-356° F.-Aroclor 1242, none for Aroclor 1254 and 1260), but do readily distill at temperatures above 325°F. The distillation range for Arodor 1242 is 325-366°F; for Aroclor 1254, 365-390°F; Aroclor 1260, 385-420°F (4). Toxic effects from exposure to PCBs in human include chloracne, pigmentation of skin and nails, excessive eye discharge and swelling of eyelids, and gastrointestinal disturbances. PCBs are considered carcinogenic (5). Because of their high toxicity, detrimental harm to the environment and stable molecular structure (structure remains intact in the environment for long periods of time) PCB manufacture was discontinued in 1976. Objective: The objective of th.is study is to determine if there are uncontrolled PCB emissions originating from the Warren County PCB Landfill. This study will involve.ambient air sampling to determine if PCB contaminated air particulate matter and vaporized PCB (Aroclors 1242, 1254, and 1260) emissions are present. Retrieved samples will be analyzed by an independent American Industrial Hygiene Association accredited laboratory. Southern Testing and Research Laboratories, Inc. of Wilson, North Carolina has been selected for conducting the sample analysis. The results of the analysis will be submitted directly to the workgroup and DWM. A risk assessment will be requested from the DEHNR Epidemology Division to determine if the PCB emissions (if found) are a risk to the surrounding community. · · Materials and Methods: Air sampling will be performed with low-volume (L V) and high-volume (HV) constant air-flow sampling systems. The components of the sampling systems consists of battery operated constant air-flow pumps (L V or HV) (Gilair Pump by Gilian™, Models: Gilair3(L V) and Gilair5(HV)), 13 mm Gelman Swinney filter cartridges with 13mm, lµm pore-sized glass fiber filters manifolded to ORBOm-60 100/SOmg, 6 x 70mm florisil sampling tubes. The pumps will be calibrated by the Gilian Gilibrator ( digital calibrator) prior to and after each sampling period. The glass fiber filters will be precleaned prior to loading filter cartridges by the North Carolina Public Health Laboratory and loaded at the laboratory by laboratory personnel. The sampling head will consist of glass fiber filter cartridge followed by the florisil tube. The two will be manifolded together by tubing. The purpose for this sampling system is to; I) catch any possible PCB contaminated particulates from the air, 2) to filter PCBs which may have vaporized. This system will then be manifolded to the sampling pump with plastic tubing. There will be five sampling periods of five hours. The sampling sessions will begin at roughly 10:00am, 3:00pm, 8:00pm, 1:00am, 6:00am. Each sampling period will be separated by one day. The reason for this delay between sampling events is to provide time to recharge the air- flow pumps (they require 16 hours of recharge time). Each sampling period will consist of seven air-flow pumps and sampling units. One unit will be located inside the vent on top of the landfill. Two more units will be located two meters downwind from the vent (these will be seperated from each other by one meter). Two other units will be located diagonally downwind at the landfill fence line. One unit will be located 200 meters straight downwind from the vent. The air-flow rate will be calibrated to NIOSH guidelines. NIOSH Sampling Method #5503: Sampling for Polychlorobiphenyls states that air-flow rate should be 50-200cc per minute. The flow-rate per unit will correspond to its distance from the vent-the further the pump is from the vent, the greater its flow-rate. Another sampling unit will be located 200 meters upwind and will act as a background sampler. Approximately fifty samples will be obtained. Prior to each sampling event, the wind direction and temperature will be indicated by a portable weather station established on the east side of the landfill. Funding from the DWM operations budget rather than the PCB detoxification budget will be used for this project. NOTE: Please see attached diagram of the landfill showing sampling locations and a copy of the NIOSH lab procedure. c:wpfiles/pcbUi'misc/sarnplere. wpd ------------ r-----------------·-·-------·---------------·• l.,_ -------------------.. -·-·-·-·•-•-· ...... --------·-- ----------------------------_ ---31 -i -------- ···-·-----:···-·-_____________________________ /R3~ _jJ..;_, -------- , ... -... -----------------'------------------:=3 ... .,~5~5Q~'--===========~~ -----------. -----------·-----·---- .. ---------. --~--::~ ~ ➔-.S ~JV ---.--."=·-.. , fl -~.-------. ------------------------------k&"" :' ~ ... ~ -----, . -------. -~-~-----------. ~=--_ ------~---···----··-~-----1· -- . ····\_ -.. .. --.. -··-------... - l--···(Jh \ -------: '------. I:_ -;., -- ....;.....~ ) .Sl;L:..P -·-: -.. --. ---~ ..... --,-c=-. -_J.----------u ---v ~ -----~ ----- , <. ____ Jf5S_::5 7 ---, G :r.< --· ➔ --- ~ S--ttv~t ... :1".J. ~ -(; C. ~ II I ~<.L:i.~--~ 1\1 ' ___ , ... ,: -~ ---~-- ···--·--·-···-. ·----------------. --. ·····-···-----------·--·---------· ------···-------. ····-· .. --·. ·-····-· BF A Environmental Consultants ==::: ~ ===:::::::::~-== Barnes, Ferland and Associates, Inc. MEMORANDUM TO: FROM: DATE: SUBJECT: Mike Kelly, Deputy Director d/'J Pat Barnes, Science Advisor ~ January 16, 1997 Status of Background Monitoring Well for PCB Landfill BFA#95-017 Can you please provide an update on the above referenced subject? Were you able to get clearance from the three property owners in the regions discussed? If so, please provide a map showing the proposed general background well locations, the actual locations will be field determined. Thank you. PAB/psgll -1 6MKJ.doc cc: Working Group 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 f (_,C, :-Tit-::-'/(-< I~ r( ~f/ ~If c~(le-/ /-''l ,,, ; BF A Environmental Consultants Ferland and Associates, Inc. MEMORANDUM BFA#95-017 TO: FROM: DATE: January 15, 1997 SUBJECT: Draft RFP for Bench Scale Testing I have reviewed the referenced RFP as well as a draft project description/scope of work developed by Joel. The SOW is in agreement with the detailed discussion which he and I have had with the Working Group concerning a two phase bench scale testing/ preliminary design implementation for this effort. This approach was developed strictly as a time and potentially cost saving measure. From reading the draft RFP, it does not appear that the State is in full agreement with key components of that approach. I would like to echo the technical concerns raised about the draft RFP. I would also like to make the following recommendations: 1. Include criteria for evaluation of Phase I of the proposals. 2. Include an evaluation and scoring system for each major component of the RFP. This will allow the respondants to focus on the more important areas . 3. Scoring system should establish weights for both technical and non-technical components of the proposal. 4. Given the social and political nature of this project and the racial make-up of the surrounding community, I strongly recommend the establishment of Affirmative Action evaluation criterion. These criterion could take three forms : a. Contractors could be asked to complete a form delineating the racial make-up of their professional work force. The forms will be provided. Bonus points can be given to those technically qualified firms with a diverse work force. 3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 I' i :MEMORANDUM January 15, 1997 Page 2 b. Firms which subcontract technical components of the scope of work or agree to incorporate a mentoring relationship with an African American owned firm for this project will also receive bonus points. c. Technically qualified minority businesses which submit as the prime contractor or as a joint venture with a majority owned firm and agree to subcontract to other minority firms portions of the work, will be awarded the maximum amount of bonus points. The bonus points should be approximately 15 to 25% of the maximum total score. It may be necessary for us to meet to discuss these issues as well as those mentioned earlier. Please contact me to discuss these matters. PAB/psgll-15PWJ.doc .BFA ::::::: = General PCB LANDFILL HYDROLOGY AND LINER LEAKAGE By: Patrick A. Barnes, P.G. PCB Landfill Working Group Science Advisor In March, 1983 , shortly following construction, the State reported that a significant amount of water had entered the landfill as a result of storm water events wmch had occurred during the construction process (September -November, 1982). By June, I 983, the State had removed S,000 gallons of water through the leachate collection system. It is unclear whether the 5,000 gallons removed represented all the water thought to be in the landfill at that time or not Over several subsequent years the State continued to remove small amounts of leachate through a largely inoperable collection system. Based on available data, the total leachate quantity removed is approximately 8,000 gallons. In 1993, the State reported that the landfill contained approximately 13. 5 feet of water based on water level measurements made in the leachate collection system. The increase stress on the bottom liner system coupled with several other complicating factors has apparently resulted in a breach of the bottom liner integrity. Additionally, either through normal wear, manufacturing defects or improper installation the upper composite liner of the landfill also appears to be breached Liner Desi,m Recent studies performed by Lee and Schroeder show that the composite liner system similar to that designed by the State for this facility has high leakage rates associated with it. The study evaluated six liner designs using the HELP model and found the most effective system included a drainage layer, followed by a synthetic liner, a low penneability soil layer, and additional drainage layer, synthetic liner, followed by a final soil layer. It concluded that composite liners where the synthetic liner is not in direct contact with the compacted clay layer are more likely to fail . The PCB landfill bottom liner system includes one foot of fill between the synthetic liner and the compacted clay layer. I The initial siting report indicates that the State made use of on-site clay materials in construction of the clay liners. AJthough this material would have been substantially reworked and compacted, the fa ct that this material comprised a portion of a thick section of material which was weathered in place implies that over time it will tend to form cracks and avenues for percolation The 30 mjJ synthetic bottom liner was severely damaged by vandalism during the early phases of construction. Some of these holes are depicted in pictures I through 12. Given the substantial nature of the vandalism, the State should have probably considered placing an additional synthetic liner above the damaged one rather than patching the damaged liner. 95-017 L~tcgrildoc -1- The top liner system includes a synthetic PVC liner in direct contact with a low permeability soil layer; however, the PVC liner is very thin ( l 0 mils) this, in addition to the numerous problems which could arise from during manufacturing and installation, are reasons to suspect possible failure. Problems during construction (see pictures 1 through 12) may have also contributed to a loss of integrity . Rainfall Occurrence The monthly rainfall amounts for Warren County (AJcola) were reviewed to characterize its relationship to the monitoring well hydrographs and the leakage level fluctuations. The graph shows that the area receives a significant amount of rain consistently throughout the year with peaks in early spring and early summer. Rainfall for Alcola for the past four years is given on Figure l. The peaks align quite well with the peaks in the water table hydrograph showing that precipitation recharges quite readily within the landfill area. This is panicularly inte..-esting because low penneability of the native clays was a significant factor in the State's decision to select the Warren County site. Based on review of"this data it is apparent that, although the onsite clays have very low laboratory permeabilities, the effective permeability of those same sediments is actually much much higher. The average rainfall per year for the Warren County area is approximately 45 inches. The area received approximately 9 inches of rain during the months of September, October and November. 1982. The period of time attributed to water inflow by the State. The 9 inches does approximate the 13 feet of water initially reported by the State. In 1995, which was a wet year, the average rainfall increased by over 10 inches, to 56 inches. Consistent with liner leakage, this increase in rainfall was also ultimately represented in a rise in landfill water level. J..,/onitoring Well Hydrograph The obvious source of this rapid groundwater recharge is secondary porosity such as cracks in the native silty sand and clay layers. The effective recharge of precipitation as analyzed by at least a one year hydrograph is a necessary first step in the hydrogeologic evaluation of potential landfill sites, and was apparently not performed by the State prior to site selection. As would be expected, the rainfall variations match very well with the monitoring well hydrographs particularly for monitoring wells 2, 3 and 4. MW-1 appears to be partially plugged and does not respond in phase with the other wells. Generally, it appears that significant rainfall events wruch occur during the early spring and late fall directly translates to a rise in groundwater levels while large rainfall events which occur during summer months go largely unnoticed in the groundwater system . This is due to the much higher evaporation which occurs during the summer months. The increase in evaporation in summer months is a very important part of the hydraulic cycle and as will be discussed later, plays an important role in the landfill water level hydrograph and the proposed leakage dynamics . Another very interesting aspect of the monitoring well hydrosraphs when compared to both the landfill water level and the precipitation amount&, is that the general trend of the wells is towards 9,.0,1 lntcgnldoc -2- decreasing water levels, while both precipitation and landfill water levels are increasing The concurrent rise in rainfall amount and landfill water levels strongly indicates that precipitation and thus leakage is controlling the landfill' s water level. Landfill Water Level Hydrograph As would be expected in a lined landfill, the peaks in landfill water level do not align with that of rainfall, instead they are shifted into the future on the leachate level graph (Figure 2). Although this behavior is slightly masked for several smaller peaks, the highest rainfall months recorded, March, 1993, 1994 and 1995 are consistently followed by peaks in the landfill water level six months later in September. A second peak in rainfall in June, 1995 is once again followed by a very high landfill water level peak six month's later in December. This regular pattern could not be coincidental. It obviously represents the period of time it takes water to travel through the top liner system eventually reaching the landfill water table. With the exception of the six month shift in the hydrograph, the landfill water level is behaving as would be expected for any natural system in direct connection with the emironment. It has a water balance as would be expected for any flow basin . This is particularly disturbing because the system was engineered to remain isolated from surface and groundwater influences. More importantly, perhaps, as will be discussed later is that the landfill water level has consistently rose during the period of record. · Leakage Dpiamiq The various components of the landfill water level hydrograph can be explained as follows : 1. Quickly following large rainfaU events the two foot layer of top soil becomes saturated and small amounts of rainfall seep through improperly seamed or worn areas of the upper synthetic liner. The majority of leakage through the upper liner probably occurs during periods of low evaporation when the soil above the liner can remain saturated for much longer periods following rainfall events. This increase in water level increases the threat to the environment by increasing the pressure on the bottom liner. 2. Percolalion then occurs through the clay portions of the liner. Both by granular conveyance and th.rough cracks this process takes approximately six months and is the major component in the offset between the landfill water level rise and monitoring well hydrograph rise. 3. Flow continues downward through the unsaturated landfill contents. 4 Typically, during the months of July though November, the water level within the landfill rises as a result of the leakage which occurred across the top liner during December through June. Significant leakage through the top liner does not occur within these months (July- November). 95-017 lntcgrit.doc -3- 5. The resultant increase in pressure on the bottom liner attributed to the water level rise results in leakage across that composite liner (primarily during December through June) which subsequently decreases the water level within the landfill. 6. As Figure 2 indicates, the cycle repeats itself; however for the period of record more water enters than leaves the system, i.e., Qin>Qout. Although for several months at a time the reverse is true Qout>Qin. Delared Rise As discussed, the rise in water levels within the landfill is approximately six months out of phase with the monitoring well hydrographs and rainfall data. This delay is primarily due to the effective permeability of the 10 mil PVC and 2 ft. thick clay top liner. It is believed that precipitation seeps readily through the 10 mil PVC liner via openings due to manufacture defects, improper seaming and installation and/or normal wear. Once under, this potential leakage water is protected from evaporation and can seep through the clay under condition of saturated flow, or through a system of fractures within the clay. Using the groundwater velocity equation the leakage rate across the 24" clay layer can be estimated as follows : V=Kl 8 V • Velocity (length/day) K = Penneability (length/day) I -Gradient (ft/ft) 8 = Porosity (unitless) K = I 0·7 cm/sec l=dh= l=I dL 2 8 = .03 (Todd) V = l0-7qn/sec{l} = 3.33 -6/cm • 1 inch • 86.400 sec . . 03 sec . 2.54/cm day V = .113 3 in. • 180 days .. 20 inches day 6 months 6 months This fits very well with the approximate thickness of the clay top liner (24 '') indicati11g that even with a conservative permeability value (the one used by the State for the intact clay layer) water can be transferred as shown by the hydrograph within an approximate 6 month period. leaka~e Rate Each season for the four yellrs of record there is a rise in water level of approximately 12 inches followed by a drop of about 11 inches. This cyclical pattern has resulted in a net increase in water 9,-01, lnt.cgrit.doc -4- level over the period of approximately I foot . Because of improper documentation and reporting early on, it is difficult to say how much of the total volume of water present in the landfill originated from storm events and improper stormwater management. However, we have already established that the effective permeability of the clay will allow transmission of water across it with the assumption that rain water readily passes through the synthetic Liller through breaches. · It is assumed that the landfill materials have an average effective porosity (specific yield) of 5% or . 05 . The approximate 1 0 inch fluctuation observed over a six month period can be attributed to approximately 1/2 inch of leakage through the liner systems. For the period of record the landfill area ex.petienced over 45 inches of rain per year, one-half of an inch of leakage represents only _ 1 % of the total rainfall . Volume oflandfill The volume of the landfill can be approximated by calculating the area of a plane midway between the top and base of the landfill and multiplying it by the height. The mid point is equivalent to the average of the top area and the area of the base. Top Area= 240' x 475' = 114,000 ft.2 Bottom Area= 100' x 300' = 30,000 ft.2 Mid Point,,,, 144,000/2 = 72,000 ft.2 Volume= 72,000 ft.2 x 22 ft .,.. ~ 1,584,000 fl.3 i·olume of Water The volume of initial water in the landfill can be calculated using the same general procedure and substituting the thickness (22 ft.) of the landfill material with the height of the l3 fl. water column. as follows : 9S--O 17 lnltgrjldoc Top Area (at Water Surface)= 400' x 175' ""70,000 ft.2 Bottom Area= 100' x 300' =-30,000 ft.2 Mid Point= 100,000 ft .2/2 = 50,000 ft.2 Volume ""50,000 ft.2 x 13 ft. = 650,000 ft.~ x 7.58 gal ft.) = 4,862,000 gals. , .05 (specific yield) = 243, l 00 gals. -S- The base elevation of the landfill is 320' MSL. If the initial height of water in the landfill was 13 feet as reported by the State, that would equate to an elevation of approximately 333 ft . In February, 1996 the average elevation was approximately 2.5 ft. higher at 335.S ft . MSL Since the water in the landfill was first reported, there has been an increase in the amount of water in the landfill by approximately 2.5 ft. The current volume of water (Nov., 1996) in the landfill based on the historical rise in water level is estimated to be approximately 320,000 gal. (this includes an additional .2' of water level rise between February and November) which represents an increase of 77,000 gallons over the t 4 yea, landfill life or an average net increase of approximately 5,500 gallons per year. If it is assumed that during periods of landfill water level rise only very small amounts of water is being discharged; and if it is assumed that during periods of falling water levels that only slight amounts of new leakage is coming in, then the annual inflow and outflow of water to and from the landfill can be approximated as seen on Table 1. Because of the shape of the landfill it is necessary once again to use an average area to estimate inflow and outflow The surface area used is that of the landfill at elevation 335 ft. MSL The estimated 3,000 gallon net incre11se in landfill water matches fairly well with the 5,500 gallon amount estimated based on the 2. 5 ft. rise in water levels over the life of the facility, especially given that the State's initial height estimate was a rough estimate. Di1char2e Table I Estimate Water Balance Last 3 l' ean of Data · .ruse: •ndiF111i tr{l~¢h~- · ·y,.r1 teaf~: · Y.~~r 3 Annual J\yel".age Leakage : lnch~s Volumt Q Out 9 12 12 11 .0 25,965 gallons Leakage (.45) (.60) (.60) (55) (.55 in) -- Q In 12 10 15 12.4 29,033 gallons Leakage (60) (.5) (.75) ( 615) (.615 in.) Note: The decimal given in the parentheses is the amount of leakage either in or out of the landfilJ which is required for the observed rise and fall in landfill water level (the number immediately above it). 95--017 lnttgrit.doc -6- Construction Pt'ocess It appears that the Contractors involved in the construction of the PCB Landfill were faced with several problems which could have compromised the integrity of the landfill from a very early date, not the least of which was weather and vandalism. We were unable to obtain copies of the field construction logs; however, pictures 1 through 12 show some of the construction I elated problems. They were obtained from the State's files. As can be seen, the landfill was largely unprotected from precipitation which resulted in a significant inflow of rain water. Additionally, the top soil material appears to have been inappropriately selected and/or compacted which resulted in exposure of the top synthetic liner The pressure build-up below the PVC top liner as shown in the attached pictures is strong evidence for the existence of fractures in the upper clay layer. These fractures would represent one avenue for possible downward leakage of precipitation. The pictures also shows the vandalism discussed which may have also played a key role in the lo:i.is of lower liner integrity. It is uncertain why this liner was not replaced instead of repaired by the State contractors. System Design & Leachate Management The landfill system appears to be improperly designed in two key areas. 1. Top Liner System Pictures 11 and 12 show significant ripples in the top soil across the landfill surface. In several areas, these ripples resulted in the exposure of the PVC liner. These features may represent areas where surface water could pond and enhance percolation. The top liner should have been designed to minimize slumping and potential water ponding, 2. Leachate Collection System The leachate collection system which the State has indicated is largely inoperable, can only pump very small volumes at any given time and is improperly designed . A significant prnblem with the system design is the apparent absence of a perforated pipe extraction system. In order to effectively remove water from the silty soils present in the landfill, a much more extensive system of leachate collection encompassing a significant portion of the bottom area should have been employed. The soil present within the landfill originated on road shoulders throughout the State, typical road shoulder material is designed for stability meaning it is usually very poorly sorted . This does not appear to have been a consideration in the system design 95-017 touigril. doc -7- Monitoring The State is currently in gross non-compliance with the TSCA monitoring requirements. No samples have been collected and analyzed from any of the four groundwater monitoring wells or four surface water stations since July, 1994. Based on documents reviewed dated June, 1983 and on the State· s Operational Plan environmental samples were to be collected twice per year until otherwise stated by the EPA regional Administrator. The State has missed four consecutive sampling events Of particular concern to me is that the site only contains four monitoring wells which in my view are not only improperly located but also poorly designed. The surface water stations selected also appear to be dictated more by accessibility than environmental science. The State was very much aware of the site hydrology and in fact used it heavily in the selection process. In the 1980 Environmental Impact Statement the landfill site's drainage is described as being controlled by six major draws around the landfill site. Given that statement, it is difficult to understand why no monitoring wells were placed directly at the head of any of these features. Also, after spending a significant amount of time in the field inspecting the hydrology of the 5ite l find it incredible that no surface water samples have been collected at the several contact springs which surround the site. These features represent the most likely points of origination for any discharge which might result from the landfill bottom liner. Additionally, based on discussion with State staff, it appears that the stream sediment samples are being collected at the same locations as ithe water samples (approximately mid -stream). Given that this is not the most likely location for sedimentation to occur, it is doubtful that they are indicative of the potential impact from the landfill . Discussion The graph shows the fluctuation of water level as measured in the leachate access pipe and the central vent observation well. The rise and fall of this water level was thought by the State to be directly related to the heating and cooling of the landfill materials. We agree that heating and cooling may result in some fluctuation; however, the heating and cooling process in a system with very little organics (less than 2%) should not result in a long-term increase in water levels a.s shown by the green line. Moreover, the frequency of the peaks and valleys align very well with that of the monitoring well hydro graphs. In our opinion, this is a strong indication that the landfill is functioning as a natural system that is receiving and releasing water. This pattern is not in phase (the peaks of the water in the wells don't match with the peaks of the water in the landfill) with the surrounding area because it takes the water several months · to flow through the composite liners . The delayed yield shown is roughly analogous to that which you would expect in a semi-confined, two aquifer system. It is the result of the time it takes water to seep through the upper composite liner . For the period of record, it appears to be fairly constant; however, it is important to note that the rate of leakage will increase over time. The leakage rate is directly related to the permeability of that material, flaw~ in the liner system resulting from pinholes and 9}.Ql7 lntegtit.doc: -8- holes formed during seam welding, manufacturing defects and vandalism Another potential source of failure is stress cracking or brittle fracture. The average increase of the water level by approximately 1 foot over the four year period of record is in line with seepage rates used by the USEPA for flexible membrane liners and represents approximately 1/2 inch of leakage per year. It is our opinion that this increase is a good indication that water is seeping into the landfill. The fact that the increase is not a steady incline but varies seasonally is an indication that the system is also discharging water through the bottom liner. There is a net increase in the landfill water level because more enters than leaves the system. In summary, if no new leakage water was entering the system the water level would remain fla1, and if no water was leaving the system the water levels would not decrease then increase in a cyclical pattern. 9,-011 lntcgrit doc -9- RAINFALL (inches) 0 ~ t1I CJ) -0 Nov-92 Jan-93 Mar-93 May-93 ~ z ;;a £ (T, J.il-93 :;o s m z Q s~p-93 ;:;.. 0 ::J' IJ'I 0 l Nov-93 C: :T z ::, ~ 0 Q. JM-94 -< a, ~ ~ ""I (ll Mar-94 "C' -iil z r,, "T1 (ti ~-May-94 > 3 r-~-r I/! Jul-94 0 5 <O ~ 0 ... :::, Sep-94 > (") 0 -► 3 "2.. Nov-94 :;o ltt ~ 0 ~ 0 Q) Jan-95 s; s <O Ill (/) C Mar-95 <0 ► (1) 0. O> -I ni May-95 -0 z Ju!-95 -· Sep-95 Nov-95 Jan-96 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 AVA DEHNR December 3, 1996 MEMORANDUM TO: Patrick Barnes, Science Advisor Joint Warren County/State PCB Landfill Working Group FROM: DWM Staff for the Joint Warren County/State PCB Landfill Working Group SUBJECT: BF A 12/2/96 Memorandum Air Emissions of PCB and Associated Health Risk Please provide scientific and epidemiological substantiation for BF A's statements that, with respect to the Warren County PCB Landfill, "so-called landfill represents potentially significant health risks" and the State's "apparent disregard for the safety of the citizens of Afton". Please also provide any data on air quality modeling or other technical basis for the statement that the "PCBs which have been deposited by air emissions may have accumulated in these surface drainage features and thus may still present a threat to the environment." It would also be helpful to the staff if BF A submitted the qualifications, expertise and experience of personnel providing the statements and response to our request. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Voice 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/l()"lo post-consumer paper fax Date Number of pages Including cover sheet To: IZ( t Phone Cj' ,, ..--. / Fax Phone I' J-T / ') _ 5 C, 0 ~ CC: REMARKS: Barnes. Ferland and Associates, Inc. 3535 Lawton Road Suite 111 Orlando, Florida 32803 Phone ( 407) 896-8608 Fax Phone (407) 896-1822 D Urgent D For your review O Reply ASAP D Please comment jZ,t rf-( 11r0~ /Li,/;--4,J bid ·~U-t_ t dcl ~ 4 Ccj,__x ~r~µ ~:~ #r- BID FORM SUPPLEMENTAL DRILLING .INVESTIGATIONS WARREN COUNTY PCB LANDFILL I ,/ Item # Description 1. 2. Mobilization/Demobilization Indemnification 7" Hollow Stem Auger w/SPT \....o.V • Provide and Install 2" Stainless Steel Well Casing and Grout Provide and Install 2" Stainless Steel Well Screen and Filter Pack Well Development 2-1/2 Ft. Protective Cover w/ Well Cap & Lock & 4'x4' Concrete Pad Containerize Development & Slug Test Water for Temporary On-Site Storage Possible Fractured Rock Drilling 6 x 6 x: 6 Fence Enclosure Provide Full-time Qualified Field Geologist r4. l.J, Develop Final Report including Analysis of Slug Test Data 5. I Est. Qty 1 l L.S. L.S. EA. EA 750 L.F. 750 . L.F. 160 L.F 16 HR. 16 EA. 16 55 Gal :Omm 120 3 --HR If£ Unit Pnce -- ., - BID FORM SUPPLEMENTAL DRILLING INVESTIGATIONS WARREN COUNTY PCB LANDFILL Item# Description Est. Qty Unit Unit Price Total 1. Mobilization/Demobilization 1 L.S. 2. Indemnification 1 L.S. 3. Equipment/Decontamination 16 EA. 4. 7"O.D. Hollow Stem Auger 750 L.F. w/SPT 5. Provide and Install 2" Stainless 750 L.F. Steel Well Casing and Gout 6. Provide and Install 2" Stainless 160 L.F. Steel Well Screen and Filter Pack 7. Well Development 16 HR. 8. 2-1 /2 Ft. Protective Cover w/Well Cap & Lock & 4'x4' Concrete Pad 16 EA 9. Containerized Development & 16 55Gal Slug Test Water for Temporary Dru On-Site Storage 10. Possible Fractured Rock Drilling 120 L.F. 11 . Provide Full-Time Qualified HR Field Geologist 12. Develop Final Repost Including HR Analysis of Slug Test Data * Total Estimated Project Cost: ~· . ~ BF A Environmental Consultants _, -m as -= nu r wrnz..te= Barn••• Ferland and Associate•. Inc. MEMORANDUM BFA #95-0l7 TO Working Group Members FROM Patrick A. Barnes, P.G. Science Advisor DATE October31, 1996 SrBJECT: Joel Hinchhorn Memos dated 10/24/96 and 10/29/96 Although I originally intended not to ) the purpose of this memo is to provide the Working Group with a formal response to Mr . Hirschhom's rather emotional and inflammatory memos related to my personal activities· and iotentions with regard to the evaluation and detoxification of the PCB landfiU My g~nera! observation is that 1\ilr. Hirschhorn has an egocentric petccption of the current activities His conclusion that the Working Group, State and my persona! actiyjties and objectives are steeped in conspiracy to avoid any responsibility or action to achieve dcto~catio11 of the landfill contents 1s completely inaccurate. While claims of his professional experience art made throughout these memo5, I p,;rsonally find their content and tone highly unprofo;sional, counter- productive to the project, and extremely self-serving . Jn response to Mr. Hirschhom's ,oncems regarding my meeting with Senator Ballance and Congresswoman Clayton, the only meeting l have hitd with these individuals was on October 22 during my last v,sit Dollie Burwell invited me to the election office to meet the Senator and Congresswoman and our discussion involved m)· profcuional ba.i;kgrnund and a general overview of the work: being performed on the project. The opinions expressed by the individuals wcr~ just that, individual opinions, and did not constitute a "co-option'' or "marupulation"' by che government As my scope of services. with the Working Group includes political liaison , I felt. and still feel , that the opponunity to meet political body representatives was proper and in complianc.e with my project responsibilities. However, no 11ttempt w11:s made to develop a plan or strategy to 1;oopt or manipulate the Working Group or seek Federal project funding. I personally fee i that Mr Hirschhorn's comments and insinuations do the Working Group and myself a tremendous di:1xrvice With regard to the Science Advisor selection process, I am very awa~ of the high Je..,el of complexitie:'j which arise from the potentially complicating goals and objectives of the working members; however, I am somewhat confused by Mr. Hirschhorn's volatile, contradictory and. once again. egocentric tirade. Fir:stly, it is my understanding that both Mr Hirschhorn and myself The Hollister Bu ildinij • 3635 Lawton Road• Suite 111 • Orlendo. Florido J280J · Office (407} 896-8608 · Fex (407) 896.1822 OOOT-lSC-616 :XE~ ✓ MEMORANDUM October 3 l, 1996 Page 2 were selected as Science Advisors because our professional expertise was complementary and provided the Working Group with comprehensive expertise to address all the landfill and detoxification issues When I was asked by Mr Lancaster whether I could work with Mr Hirschhorn in a dual Science Advisor arrangement) I responded in the affirmative ba.sed on m, pen;i:ption that we offered complementary p,ofessional expertise. I, in no way, felt manipulated nor felt that the question belied a "hidden agenda!) In fact, in numerous consultant selection processes that I have been involved in, the ability to work with staff or an entity's already existir.g consultants is a common selection criteria and question asked during presentation The point of such a question is simply to ensure that a consultant has the opportunity to state his/her objections to such an arrangement and/or point out potential problems that could arise . Mr . Hirschhorn states that when presented with this question he answered "yes" but would have answered "no" if he had known that by doing so he would have been selected as the sole Science Advisor He also states that he has "several important reasons'' for obje(;ting to the dual Science Advisor arrangement I am somewhat confused by his logic in that when he was given an opportunity to object to the dual Science Advisor arrangement and provide his ''several impcrtant reasons" for such, he failed to do it In fact , he states that he would have made the objections only if he knew that by doing so, he would be selected as the sole Science Advisor In other words, given the opportunity to milki:: his case for the selec:tion as the Science Advisor. he chose to forgo it and accept a duaJ Science Advisor arransement Now, instead oftaking respomibility for his own decision, he blames the State. cloaking it in a conspiracy to manipulate the Work ing Group. As your Science Advisor, it is my responsibility to present the technical facts related to the project as I see them In summary, some of those facts as they relate to rny area of experti5e are The State has knowingly placed an inadequate amount of groundwater and surface water monitoring locations around the landfill; 2. The monitoring wells which are present are inadequately designed to detect discharges,; 3. The landfill leachate system wa.s not properly designed, 4 The bottom landfill liner design is among those composite liners with the highest failu re rate; S. The fractured rock :;y:itcm at the site can result m enhanced groundwater tlow; 6 The State has delayed submittal of key project documents to the Working Group for action ; 7 The State is not in compliance with the TSCA monitoring requirements, and, 8. The landfill is appa.rently taking on and discharging water The Hollister Building • )535 Lawton Raad• Suite 111 • Orlando, Florida 32603 Office (407) 896•8608 • Fax(407) 895-1822 £:O 'd SS:9t 96 , t£ lJO OOOT-LSZ-616 :Xe~ d~Jd9 9NI~d0~ 8Jd -• MEMORANDUM October 3 I. l 996 Page 3 As a licensed Professional Geologist and as President of a li,ensed Engineering and Geological Services firm, misrepresentation of data or unethical behavior can easily result in rcvocat1cm of my license to pr11ctice. It is for this reason that my conclusions must be strongly justified . For the record, I would like to pledge the following : 1. I will continue to represent the facts of the project as I see them to the Working Gro;.ip m an independent manner. 2. Twill never allow anyone to alter my opinion of the facts with unsupported claims. 3. l will never reson to slander of any individuals involved in this project as a means of accomplishing my services as Science Advisor and the ultimate objective of total detoxification in an expeditious manner. In closing, the role of the Science Advisor is to analyze the data, and form conclusions and recommendations as a re:,ult of that analysis in an independent manner, I feel that I have fulfilled that role in an objective and professional manner and find the insinuations of being coopted and manipulated by the State personally offensive In fact, much of my work has been adversarial to the State's position. I appreciate the opportunity to provide the Working Group with my perspective on the isrnes raised by Mr Hirschhorn and trust we can put it behind us and maintain our focus on the several landfill issues at hand i'.,(I#•p1g• J 0-J I WCil.drJc The ~olli1ter Bvilding • 353!i Lawton Roeo • Suite 111 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 l70 'd OOOT-lSl-616:XE~ .BF A Environ~ental Consu,ltants Barnes, Ferland and Associates, Inc. MEMORANDUM Post-ir Fax Note TO: Bill Meyer FRO.M: Pat Barnes~ DATE October 30, t 996 BFA #95-0 17.00 7671 Data (l From Co. Phon<J # Fax 11 SUBJECT: Response to Memo from Joel Hirschhorn about Selection of Soil Extractioo Contractor Before negotiations, CDM should provide their detailed itemization of .estimated cost so t.hat specific areas can be better targeted for modification by the State. I disagree with eliminating the electrical leak detection The RFP includes top liner assessment and this appears to be a comprehensive way of accomplishing that. Before we der.ermine if it is cost prohibitive we need to have CDM itemize its cost Generally speaking, su1iace geophysical methods such as this are very cost effective. Bill, please also inquire of CDM if their drilling subcontractor would consider replacing the proposed t 0-mil plastic containment system with a bermed steel pan. A steel pan will provide a much better working surface. cc: Technical Committee The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 ... BF A Environmental Consultants Barnes, Ferland and Associates, Inc. MEMORANDUM BFA #95-017.00 Post-it" Fax Note 7671 Date TO: Bill Meyer From Pat8arnes ~ FROM: Co. Fax II DATE: October 30, 1996 SUBJECT: Response to Memo from Joel Hirschhorn about Selection of Soil Extraction Contractor Before negotiations, CDM should provide their detailed itemization of estimated cost so that specific areas can be better targeted for modification by the State. l disagree with eliminating the electrical leak detection. The RFP includes top liner assessment and this appears to be a comprehensive way of accomplishing that. Before we determine if it is cost prohibitive we need to have CDM itemize its cost Generally speaking, su1iace geophysical methods such as this are very cost effective. Bill, please also inquire of CDM if their drilling subcontractor would consider replacing the proposed 10-mil plastic containment system with a bermed steel pan A steel pan will provide a much better working surface. cc. Technical Committee 10/30/96 Patrick, *Called 12:20 and left short message (got cut off) *Agree with first sentence *Not aware of Joel's memo *Agree with second sentence >'<Agree with last sentence with attempt to get better Containment ie metal vs. plastic -we can always add/change this in contract if not in proposal Bill The Hollister Building• 3535 Lawton Road· Suite 111 • Orlando, Florida 32803 Office ( 407) 896-8608 • Fax ( 407) 896-1822 FROM 9 1971~360~ SOLID WASTE DI U ' ~ ate of Not Carbllno ; epQrtmen of Env.lrQnment, : eoln, ~nd aturQI Resourcet OMslon of Solid Waste Monogement : I Jomea B. Hunt. Jr,, Governor Jonathon 8. HQw•s, Se'.er•t ory Wllllorn L. Meyer, Director ~morandum To: Doris Strickland From: Bill Meyer Subject: R.PP re1pqn1e for "ExcaJation, Handlins, and Storage, of;PC contaminated soils from the Warren County~CB Landflll1' : Enclosed are the rankings for the~our respondents to tho RFP. Tho nkini wu performed independently by Joel Hirschhorn and Pat ck Barnes (Science Advisors for the CB Working Group) and the Division. Thero wu consensus t .at COM would bo the selected res ondcnt. However, all parties were concerned with .the coat of CD M's proposal. ' It i1 the Division's undcmandini t~t once tho mpondon;a have aubml proposals that only personnel in the Department of Adminljation, Division of Purchue and C tract, i_nay contact or neaotiatcrwith respond-('· The DMtion would like to suggett that the appropriate ageney consi er options to address coat concerns. One option is to send· a toqucst to all respondents roquirina itemization of cost in aeeordan~ with (a) throuah (k) of aoc1ion 2.2.1. This could be accompl shed bofon, the tinaJ respondent aclection wu made (May ·the Division do thla?). P.O. 80,c 27687, Ro1elgh . North CorolJno 27611-7687 Voice, 919-733-4996 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 OVER VIEW" a. Include a description of the project background, as previously agreed to so that the Plan will function as stand alone document. b. Identify who will be the site manager, safety officer, and the individual disciplinary task leaders. c. Last sentence of the oversight paragraph, change "a site safety briefing" to a daily site safety briefing. d. Amend safety plan to include safety issues associated with drilling activities. e. Change "History of the Site" section of the safety plan to reflect recent analytical data. f Add definition as to what constitutes being "involved" as described in the final sentence of the first page. g. Include a site plan showing the conceptual layout of exclusion zones and safe zones. h. 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. Critical portions of each of the standards referenced should be included as an appendix to this plan. e. At the end of this section add the following : Reporting Procedure-Every laboratory asked in this eff(?rt will be instructed not to provide any data, preliminary or final, verbally or in writing t the State unless the same information is provided simultaneously to both Science Advisors. 5. SECTION ENTITLED "LANDFILL CONTENT SAMPLES" 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. d. Under "Sampling Pers<?nnel Requirements" describe the proposed "air sampling." e. Under "Field Equipment Required' include a table listing all necessary equipment. f Under "Quality Assurance" add a general description of the anticipated laboratory QNQC. For examole what quantity of matrix spikes and matrix spike duplicates are anticipated. 6. SECTION ENTITLED "LANDFILL LEACHATE 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 samples:$, 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., MWIA, MW5, and MW7 and each of the background wells. b. Add sediment sample at the confluence ofRichneck and The Unnamed Tributary. ~ f>cB (;J(} Bill, (so,~ e,.:Jw.e/2~10 10-23-96 Bid Evaluation I looked at each of the criteria as listed in the RFP. I assigned a 1 to 4 value based on what I thought was best or worst of the 4 plans. The final scores are as follows: CDM with 70 S&ME with 61 Triangle with 60 Patterson with 49 Other observations: PATTERSON Patterson just falls short in too many areas and besides they are not the lowest bidder. TRIANGLE Triangle was the cheapest and was almost second in the scoring. It lacks some key points like: * No surveying of boreholes * Only 2 boreholes planned * No contingency plan or monitoring plan for releases It DOES include a provision for a Work Plan which might be used to beef up those areas not addressed in the bid. Maybe the cheapest one can work if we can tailor the work plan to address those weak areas of the bid. Experience does not appear to be as good as CDM or S&ME. CDM CDM I think has the best design with 4 boreholes but it was the second most expensive. CDM also seemed to have the best experience including work with PCBs. The H&SP and Work Plan will need to be developed which will give an extra element of control. In addition to visual inspection and sampling of the liner and clay, they also include an electronic leak detection plan to completely check upper liner integrity which none of the others do. S&ME S&ME was the most expensive but only had 2 boreholes. It has an extensive QA/QC section but seems to include a lot of unnecessary sampling and analytical tasks. They did not specifically address the issue of wet & dry soils or how they were to be blended. S&ME probably has the best design with the steel containment tray for contamination and to protect the landfill liner. They do however appear to be using full sized drill rigs where the other companies are using lighter weight rigs to protect the integrity of the top liner. Of course S&ME had a very good experience record. This was not included in the RFP but no one proposed any air monitoring in their bids. I think this would be a good thing for someone to do when this work actually starts. This will supply some data to show if any airborne contamination was released. Bid Evaluation Excavation, handling, and storage of PCB contaminated soils from the Warren County PCB Landfill Scale = 1 to 4 ( 4 is the best, 1 in the worst) RFP Crit. Patterson 2.2. la 3 (3 boreholes) 2.2.1 b 3 (survey) 2.2. lc 2 (manually mixed) 2.2. ld 3 (low press veh.) (plastic/boot) ( repair liner) 2.2. le 2 (visual/3 samples) Triangle 2 (2 boreholes) 2 (1 sample/ft) 4 (free drain) 3 (low press veh.) (plywood/plastic) (repair liner) 2 (visual/2 samples) 2.2.1 f 3 (plastic/absorbants) 2 (plastic) 2.2.1 g 2 (minimal/no figs) 2 (minimal/no figs) 2.2. lh 3 (outline) 2 (H&SP TBD) 2.2.1 i I (infiltration only) 3 (6" well/collar) 2.2. lj 2 (Pre-decon/plastic) 3 (Work Plan TBD) 2.2.lk NA NA 2.2.2a 2 (manually mixed) 4 (free drain) 2.2.2b 2 (manually mixed) 4 (proportioned) 2.2.2c 1 (plastic/boot) 3 (plywood/plastic) 2.2.2d 1 (no mon. plan) 1 (no mon. plan) 2.2.2e 3 (adequate) 3 (adequate) 2.2.2f 3 (outline) 2 (H&SP TBD) 2.2.2g 2 3 (Work Plan TBD) 2.2.2h NA NA (Sub-Section 2.2.3 deleted) 2.3.l (See above) 2.3.2 (See above) 2.3.3 (Deleted) 2.3.4 ,., ($47,000) 4 ($28,700) .) 2.4. l 2 (some) 2 (some) 2.4.2 (see 2.3.4) 2.4.3 1 (not stated) 3 (T&C form) 2.4.4 I 2 2.4.5 4 4 Total 49 60 CDM S&ME 4 (4 boreholes) 2 (2 boreholes) 3 (survey) 4 (survey/samples) 3 (pour off drum) 1 (not stated) 3 (light vehicle) 2 ( drill rig) (plastic/gravel) (steel pan/plastic) (repair liner) (repair liner) 4 (visual/4 samples) 3 (visual/2 samples) ( electric leak detect) 3 (plastic/absorbants) 4 (steel pan/plastic) 3 (better/ldiagram) 4 (best w/ diagrams) 2 (H&SP TBD) 2 (H&SP TBD) 3 (4" well/collar) 3 (6" well/collar) 3 (Work Plan TBD) 4 (QA/QC Plan) NA extra sampling 3 (pour off drum) 1 (not stated) 4 (proportioned) I (not stated) 3 (plastic/gravel) 4 ( steel pan/plastic) 3 ( contig. plan) 3 (mon. plan) 3 (adequate) 3 (adequate) 2 (H&SP TBD) 2 (H&SP TBD) 3 (Work Plan TBD) ..., .) NA NA 2 ($83,000) ($99,502) 4 (landfills/PCBs) 3 (landfills) 4 4 4 ..., .) 4 4 70 61 lVIEMORANDUl\tl TO: To PCB Working Group FROM: Patrick Barnes, P. G., Science Advisor DATE: October 23, 1996 SUBJECT: Amendment tot 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. :B,F A Environmental Consultants Barnes, Ferland and Associates, Inc. TECHNICAL MEMORANDUM TO: Technical Committee FROM: Patrick Barnes, P.G., Science Advisor DATE: October 21, 1996 SUBJECT: Potential Source of Water in the Landfill BFA #95-017 The attached figure is a hydrograph showing water levels in and immediately around the PCB Landfill for a 3 year period. The bottom four lines represent the water levels in the monitoring wells MW-1 through 4 which are generally situated east, north, west and south of the landfill, respectively. Hydrographs are very useful in determining how water levels change with the season and by assessing how the individual monitoring points ·relate to each other, the general direction of flow can be ascertained. : As can be seen, with the exception of MW-2 which appears to be in the predominant down gradient direction, groundwater flow is largely radial. Specifically, as it relates to the region covered by MW-1, 3 and 4. Typically, well water levels peak in the months of March, April and May, and are at their lowest in the months of October, November, December and January. This cyclical pattern of raising and falling water levels is typical of natural groundwater systems. It is for this reason that we have stated in previous documents that MW-I, which has not responded to recent increases in water levels, has apparently failed. The graph at the top of the attached figure represents the fluctuation of water level as measured in the leachate access pipe and the central vent observation well . The rise and fall of this water level was thought by the State to be directly related to the heating and cooling of the landfill materials. We agree that heating and cooling may result in some fluctuation; however, the heating and cooling process in a system with very little organics (less than 2%) should not result in a long- term increase in water levels as shown by the green line. Moreover, the frequency of the peaks and valleys align very well with that of the monitoring well hydrographs. In our opinion, this is a strong indication that the landfill is functioning as a natural system that is receiving and releasing water. This pattern is not in phase (the peaks of the water in the wells don't match with the peaks of the water in the landfill) with the surrounding area because it takes the water several months to flow through the composite liners. The delayed yield shown is very similar to that which you The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando, Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 ,.,,.TECHNICAL MEMORANDUM ·-October 21 , 1996 Page 2 would expect in a semi-confined, two aquifer system. It is the result of the time it takes water to seep through the upper composite liner. For the period of record, it appears to be fairly constant; however, it is important to note that the rate of leakage will increase over time. The leakage rate is directly related to the permeability of that material, flaws in the liner system resulting from pinholes and holes formed during seam welding (Banaparte and Gross, "Field Behavior of Double-liner Systems"). Another potential source of failure is stress cracking or brittle fracture (Lee and Jones, Municipal Solid Waste Management In-lined, "Dry Bomb" Landfills). The average increase of the water level by approximately I foot over the four year period of record is in line with seepage rates used by the USEP A for flexible membrane liners. It is our opinion that this increase is a good indication that water may be seeping into the landfill . The fact that the increase is not a steady incline but varies seasonally is an indication that the system is also discharging water through the bottom liner. There is a net increase in the landfill water level because more enters than.leaves the system. Additional data such as monthly precipitation and average temperatures will be collected and reviewed; however, it is not anticipated that the information will change the general conclusion. In summary, if no water was entering the system given the low percentag_e of organic material the water level would remain flat, and if no water was leaving the system the water levels would not decrease then increase in a cyclical pattern. PAB/psgl10-2JTCJ.doc The Hollister Building • 3535 Lawton Road • Suite 111 • Orlando, Florida 32803 Office(407)896-8608• Fax(407)896-1822 T'"" J~nes-Lee and Lee, 1993 "Groundwater Pollution by Municipal Landfills: Leachate Composition, Detection and Water Quality Significance." While the latter paper focuses on municipal solid waste landfills, similar issues arise and situations occur for hazardous waste landfills. Whether lead or some other hazardous/deleterious chemical is in a "dry tomb" type municipal solid waste landfill or "dry tomb" type hazardous waste landfill does not, for many constituents, affect the overall period of time that the constituent will be hazardous in that type of landfill. Deficiencies in Landfill Groundwater Monitoring Systems While typically landfill applicants and their consultants assert that the groundwater monitoring system for a landfill will detect groundwater pollution by landfill leachate before widespread pollution occurs, in fact, when critically examined, it can be readily ascertained that the proposed groundwater monitoring system will not be effective in detecting pollution of _groundwater by landfill leachate before widespread pollution occurs. Dr. Cherry (1990) of the University of Waterloo was the first to point out that typical groundwater monitoring systems involving vertical monitoring wells spaced at buodreds of feet apart around a landfill have a low probability of detecting leachate leakage from the · tandfi11 that can pollute groundwater before widespread pollution occurs. - Dr. Jones-Lee and the author published a review article on this topic in which they have utilized Cherry's findings to point out that minimum Subtitle C (hazardous waste) and D (municipal solid waste) landfills that utilize typical vertical monitoring wells will not be reliable for monitoring landfill pollution of groundwaters by the landfill before widespread pollution occurs (Lee and Jones-Lee, "A Groundwater Protection Strategy for Lined Landfills," 1994b). J:!!is situation is easily understood by the fact that the initial leakage through the flexih~ membrane liner of the composite liner for a minimum design Subtitle C landfill or the equiyalent, can initially leak through holes, rips. tears or points of deterioration within the flexible membrane ~ Such leaks will produce finger plumes of limited dimensions compared to the spacing of _ groundwater monitoring wells. Groundwater monitoring wells of the type typically used will have zones of capture of about one foot on each side of the well. - The senior author has found that. many landfill applicants space the primary groundwater monitoring wells at about 400 feet apart at the down groundwater gradient edge of the waste management unit. This means that the finger-like leachate plumes produced from the initial leakage through the flexible membrane liner of a landfill could readily fail to be detected by the monitoring wells. There is a space of about 398 feet between the monitoring we))s through-which the finger plumes of leachate. which could be on the order of a few feet wide at the location of the monitoring wells, could pass and never he detected. The deficiencies in groundwater monitoring in lined landfills are not new. In addition to the reports by Cherry (1990), Parsons in Davis (1992) discussed these issues in an ASTM 19 z 0 -I m -I ::::T ui' ::!1 <O C cil ui' C" Q) (/) (I) C. 0 :::, ~ Q) -(I) ., (I) < ~ C. Q) -Q) -0 0 < C: (I) C. C" '< -::::T (I) (/) -Q) -(I) I v.,,, §J s ~ ~ c=;) t s: ! + s: ::E N + s: ::E w f s: ::E 1,. f r s: ! + < m z -l ~ 6 0 N <D Ul 6 0 MONITORING WELL ELEVATION (FT) w 0 0 6 0 w 0 Ul 6 0 11/24/92 I ■ I I. ll,.J 12/23/92 · 1/26/93 2/26/93 -3/26/93 ... 4/23/93 ·•· 5/20/93 ·• 5/21/93 ... 6/25/93 ·•· 7/23/93 · 8/30/93 ·• 9/27/93 · 10/22/93 -11 /18/93 -11/19/93 12/17/93 1/25/94 ·• 2/24/94 3/25/94 -1 4/28/94 ·i 5/18/94 5/19/94 · c 6/27/94 · )> -l m 7/28/94 8/26/94 -9/26/94 · 10/24/94 · 11/13/94 · 11/16/94 · 12/19/94 1/25/95 · 2/23/95 1· 3/29/95 -4/27/95 ... 5/24/95 · 5/25/95 · 6/22/95 -7/21/95 8/28/95 ·• I 9/25/95 -10/24/95 · 11/20/95 ·• 12/20/95 ·• 1/26/96 · 2/23/96 ., w N .i,.. 6 0 w N OJ 6 0 w N OJ 6 0 w w 0 6 0 w w N 6 0 ~ 0 6 0 w ~ 6 0 ELEVATION LMW-1 & VENT (FT) ~ Ul 8 w w OJ 6 0 ~ 8 w w OJ 6 0 G) ;;o 0 C: z 0 "ti :E (") )> OJ -I r m l> ;;o z mo r ::!! mr <r )> -I 0 z (/) ,. \ . t . . • October 15, 1996 Note TO: Patrick Barnes FROM: Joel Hirschhorn / Mike Kelly \\Ji~- SUBJECT: RFP'S FOR EXCAVATION HANDLING AT PCB LANDFILL Enclosed are three proposals for the handling of soils at the PCB landfill. We are also sending one copy to the Committee. Please note that on the one from Soil & Material Engineers are copies of pages which should be inserted into their proposal. These corrected pages were received on Monday, the 14th. The new pages have been inserted into our copy and the Comminee's copy, but I left them out of yours so that you can see exactly what changes were made, and why, in case there were any questions on them. Thanks. 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 AVA DEHNR October 14, 1996 To: From: Science Advisors Joel Hirschhorn, Patrick Barnes BillMey~ Subject: RFPs, Schedules, Processes ♦ The responses to the RFP for providing soil materials from the landfill to vendors bench scale investigations were due October 11, 1996. We received four responses. ♦ The Division will Federal Express copies to each science advisor on October 14, 1996. Please provide recommendations for evaluation, review and selection process as deemed appropriate. Please provide a schedule for the process. The RFP fot constructing additional groundwater monitoring wells was forwarded on September 20, 1996. Please provide comments and recommendations in order for the Division to prepare final draft for consideration of Science Advisors/Technical Committee/Working Group. Any recommendations on process and schedules for the final draft would be appreciated. Before the new sampling plan can be implemented, the contract for new monitoring wells must be in place. Any delay in the RFP for construction of monitoring wells will delay sampling. After the RFP for new monitoring wells is finalized by Science Advisorsffechnical Committee/Working Group/State, approximately two weeks will be required to advertise and notice potential contractors. This notice period will include a date for pre-bid conference and site visit. After the pre-bid conference and site visit, approximately thirty days will be required for potential contractors to submit final design (any recommendations at this time for response would be appreciated). The contractor design selection by the Science Advisors/Technical Committee/ Working Group/State may require at least two weeks. If this process and schedule is accurate, it will take approximately eight weeks before a contract is implemented. Any suggestions for accelerating this process would be appreciated. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Voice 919-733-4996 l:£M2d•Mmta FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper Oct.14, 1996 RFPs, Schedules, Processes pg. 2 The Division intends to issue a sole source contract to Triangle Labs (RTP) for dioxin analysis. We can defend the basis for a sole source contract: only Dioxin Lab in North Carolina; access if question/problems occur; access for lab certification staff of State to review all processes, equipment and procedures. However, there is some risk involved. Due to the anticipated amount of the contract, competing labs may challenge the sole source award. While this is not anticipated, and we can successfully defend the contract, it will cause a delay if challenged. The option is to advertise up front and select the service from a more competitive process. This will add some time to selecting a contract lab. Any suggestions, comments, or recommendations would be appreciated. BF A Environmental Consultants Barnes, Ferland and Associates, Inc. MEMORANDUM TO: FROM: DATE: SUBJECT: Bill Meyer Pat Barnes, P. G. September 30, 1996 Requested Response to Peer Review Comments Received 9/24/96 BFA#95-017 I was under the impression that the proposed supplemental sampling and testing activities had already been agreed to by both the State (our July 3, 1996 meeting) and the Working Group (our August 27, 1996 meeting). I don't believe the project schedule will be best served by addressing the S&ME peer review ~ comments, in particular, at this stage. Moreover, It is difficult to respond comprehensively to these comments when I don't know the peer review ground rules. For example, I am uncertain which of the three drafts I submitted to the State was peer reviewed and if the individuals performing the peer review were also given all the background data which we have. We (the Science Advisors and the Working Group Technical Committee) are puzzled as to why the State submitted their April 26, 1995 proposal for comparative review, especially when the basis for the current proposal was jointly agreed to. 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I I -IZ..-'ft, 'IS,' 2. 10· "l 7.-t.:f t.. 4~-. l.f 2.- 'l-2,Cf-1~ LfS.o o '£-2-15--qz... 45,o'$ 7, Jb -'1;_ '(3.11- t -2, .qz 'f'2 ,S&./ s-2q_e12 ... 41 '2.5' LI -z.q-'f)~ 'I I, 31 ·--. -. ·-·---· -· ------------.. ------···-.----. -. - 1-2?-'ff1.... 42. tl,. _,, ____ . --. ----~ ~-··--·-. ----~-------- 1..-21-ti'L 4Z, ti 1-'<l-'1'2. t../l/,41 11 l1--1 .. -.:,1 . tl'l.,O I. I" ia -qf w".<,4-'2.. lc.rJ-qi 4.1 '1-o _ti,. 1n -q I 4.~ :n 1-?/_ .,q/ ' 42 2., 7-f-q, lit.I ~q (,-27-91 : '-/P,i5 4_ 2!l--'f t ''" '11 I I /· I . NORTH CAROLINA DIVISION OF SOLID \-V ASTE MANAGEMENT SOLID WASTE SECTION CALCULATION SHEET I ; I I i I i I I ! I i i I i I I I I ! I I I I i ! ; ! I I ! I I I i i i i .: \ I I I I i i i I ! ! ! i I I i ! :, i I I I ! i I I ' ! i :---r-i I ! ! fl l j / I f ,,. I jl I r I i t 11 I I V 7i / I i I : ! ' / ______ , 35ti., ~-: ! ! ! ! L<J.J-~ ~e.; i ! I 1"1 I•! ! i ! 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Number of pages including cover sheet Pnone Fax Phone CC: REMARKS: Barnes, Ferland and Associates, Inc. 3535 Lawton Road Suite 111 Orlando, Florida 32803 Phone (407) 896..8608 Fax Phone (407) 896-1822 D Urgent O For your review O Reply ASAP O Please comment '~ .:-..-~~.,_::, ~~~"-"\\.EAC-f1..Xt$ ~ f -+-I l--=-I -r----·. r I I 1 1 1 --~-~t-=--1------_r_____ ·r--'----~-:.! 1LEACHATElccES~WATlRLEV~L ·---~-,--~--~--------:~---~~ -±¥ + 1 J WIJ!llEN couNn f'Ctl tANDftU l 1 -------------· • ---[= ----,.--i-------------+----__ ,_ -·f-----· ---+---l---1 ------1--~--,-i--1 I I I ~ I ---1-------~-~ ·-----r--. --D,.Ut I -~I F•931 l.lo<-93I "4><-931 1.!ortl Joo.t)j Jul-93 A~ S.,..93I 0<1-YJ Na,-S~j O.C•tl J,._.9.~_,.94 M•-~• Ao•S• u.-,-~• Jun$4I Jul-94 .<~-~ s,..~O<:t·9• ltNATERl..f•·e. 1 13.UJ 13_591 1:usr 13.•fl 11•• 1a.01 tl.sa 1•.23~, •. 561 1•.J2 1•.~e~_ 13.95 ,.·i;'--1Jss 1l.H 13&1 1J.jSI 1•~ i<.BJI I ---1----¼----+--1----+---"'I-----+----+---r-1 •--1----i---='---=cl-__.___,i___~--=---i LEACHATE SYSTEM WATER LEVEL ,.;.; I -----------------. , Ji~ r-·---___.,..,----12.S ~-------------------l---+---+----;---1---/ 1• s .,.., '' "~ 13 S •st 1J ----~----il 5 --~: i, .. :i'" : -~~ t~ , .. "~ .:l"' I -~~~] L==l=--=t=-~I ·--·-·,-----r-----,-----·--.---~ -, U-t:i '-:it ill i.~ c:;l~:;:~ a~ .. ~i;~ ,z ~:::: ---~-!----+----~-I t I I I J_ I I I WARA LtVa :~r~:~:=~?:=~~-~= ,u ~-----------------,t:~Ir-1:ij..: ~~ wt:~t:;:""")t:~1.;._~ ~: ~~:. r~,.r;i,. , ... ..,. ,, • PCB Landfill Measurements The foUov..'ing water level and well depth measurements were taken on October 5, 1995 by Larry Rose, hydrologic technician with the State's Solid Waste Section, and Bob Glaser. Well# :MW-1 MW-2 :MW-3 MW-4 Landfill Well Measuring Point Elevation 343.99 329.98 325.12 322.82 357.67 (ft) Well Depth l below ·.: ·.· ;fMeasutjpg 51.88 46.86 40.80 38.48 Point (ft) Static Water Level below Measuring 45.23 38.25 26.38 23.48 20.43* Point (ft) Water Table 298.76 291.73 298.74 299.34 Elevation (ft) Water Level Elevation in 337.24 Landfill •measurement made on July 21, 1995 The elevation of the bottom of the leachate collection system is approximately 321 feet above mean sea level. H:\BOB-G\G-BAJN2.WPD :! ~-~: \{\: ,-\ ., .. ---·---------------···----------- _____ , _____ •·•·-------·-··------·-····-- ' ., I fl . ,I ' RECOR0 OF COMMUNICATION 0 F'HONe CAll O 0ISCUSSION 0 OTHER (SF'EClfYJ FIELD TRIP D CONFERENCE TO: fROM: CATE 10 -24 ~9 flME $1JMMAlcY OF COMMUNICATION .. Cl ~'v..\ \~~1t:.1J....~ \~ ~'f.\"":;..,...,i..\~ \IC:.l-,..lT ?' pt:: -l:).,;. 1c..!=-l•-l!uS \:iL8-JL"l~oj c~ Vi;z1..n-P\ ~"E C..Q..."P-\~", ,a.µ;n ,o-p o'I=! l-\'-f-J f'\f'E- t ----·· -r -1.1& .,L "'!;\A.\o ... \ 2.\' "3 '<:_ _, c..~\,)h..l..,,.Y 'P(..~ Lc-. .... 1 'OF=\\-!.__. ~-,,.~ l ~~kl2l--l.' ~ p, p.. -~ ~ --·-----~------------------------------~--------; CuNc;ll)StQNS, .4CTIO~I T AKl':N QI, 11eQUIIU:O : • \.\""L.~ I '2.1, ~~i"a.~ ::. \"2.l&-,1'1 :. \J;.:l.,.)"r lc:1,;>fl.-!)J<.._ =-\Z.~,\9 -4 .z. 1 .... 12.1,12. I • r 11 INFOIIMA TION COPtlS TO, ! -•~: i:?~.:,o '-A 1.,~sD'::-~-v _,.,~ ~.101-?1: I<\?.;\.:,_..,. EPA Ferm t:l'.l0-6 (7-72) F"c'l.1:-"f\-,\"'=> .,__;,"'l""l;. . ~.H\.4 RF~ \'2.t.:.,l'i-l\7S -::.12A4l I . \~~"-..:T 4-k\ 1~~ •. ~ . ' ;>·:~!: \'.i),\, ':':',, :.1~t,, •"ti' ·'·. •,, ,,: ;, ·:,if/ ,·~~1.,·, ',, .. ,.I, 0 ~;t :.. !.. µiv ~ ~ ,... f ._,, I • 0 • □ ~ :J-( "' l: i 'ii t !) ! e,I i r f I J C" f -z.. "' I ,.,. :D <n ; ,.., C"'l :< ► r .. ~ -" -c::!:: 'c ~;i;,-S! U:> a: ::r::, -= --lr-r"T'1 n, >,Z ::.c: s c:-, ,, = ~ ;:, ,.. ~~§ ,., ~ <=I r-::z; = C, .-~ 7'i -< ~ ij - ' J 0 'ii :t .1 E. ri:.. -..D -I ~ ~ • 'e-• w Jk ~ , 0 ~;1 :t f. f!!~ " f ... ~ ~ tf 'i! C7 E. 'Tl l f ~ \ • \,N :i ; ,:. 0 (_a~ 11'1.'IO ') . C:J (E.L"' 11D.O-Sl 0 (a .. 1u,o;') 1 I D l!iL" l'ZJ,H) ■(a1o 1-t..t~-;i I 0 (E.!..' 1-zi.sa) 0 0 (a.• J'ZJ.5$) r-1t (~ r~ 0 (EL•l~."I{.) ,, "' f ~ f~ /7< TO: RECORD OF COMMUNICATION 0 PHONe CAlL 0 OTHER (SPECIFY) FROM: 0 01SCUSSION 0 FIHD TRIP 0 CONFERENCE (Recctd of item thecked above) DATE TIME i ----•·-·--·--------------..L------------------'---------I -~l SUIIJ!-:CI I I ·s u_M_M_AR_Y_O_f _C_O_M_M_UN_\_C:A_T_IC-N--------------------------------------1, .... , -1 :rB l Liz-·,! ;. s.c,o -------_fl' 7? v,co ....... ••. I ..L --~---. -·------........... ··-• -··------·---------------------------------------~ CONCLUSIONS, ACTIO~I rAl(fN OR REOUIREO INl'QlltMJI.TION COPUlS TO: EPA Form IJ00-6 (7·7'i) L_ ___ .. \IC ) i \\ i i I ..,._.,. ~:·. '=· ;. \ :--... .::--- I, I _r "" ! ~ G) 8 iii _,:;; Cl ~ .... t--" (!) r-,.. .!!:! 0 z )( . ro u... "-i 0 ~ Q. Scope of Work• Part II Monitorins We11s 2 O Ba~k~ound on Warren County PCB Landfill .. ~ u. .. ~ =-C: £ )( ni l.L 2.0.1 The State ofNonh Carolina (State) own• and maintain11 • clotod (July 1983) polyehlorinated biphenyl (PCB) chemical waste landflll permitted in aC00rdanoe with the Toxic Substance Control Act. (TSCA) and 40 CPR Part 761. 2.0.2 The PCB landfill I• located on the Eut aid• of SR 1604 approximately 1. S to 2.0 mile, ft-om the intenection of SR 1604 and US 401 South, 2·3 miles from Warrenton, North Carolina. 2.0.3 The State ii committed to detoxtflcation of the PCB landflH utilizing appropriate and fea.ible te~hnoloi)'. 2,0.4 The State hu e1tabli1hed a Joint Warren County/State PCB Landfill 2.0,5 2.0.6 2.0.7 WorJdna Group (Working Group) to evaluate ttchnoloaiot and tukt aSIOCiated with the deto,dfication of the tandflll. The Warren County PCB Landfill hu four (4) existing monltorina wells designated aa MW-1. MW•2, MW-3. and MW-4 looated api,ro"imatoly east, north, west and south re1poctively from the fenced ln area orthe landfill. These are 1hown on Pi8Urt 1 ofthia RFP . The purpose ofthe RPP i• to construct addhlonal aroundwatet monitoring wells ln order to detormlne any extent or dfil'et of contamination external to the landfill. Any contaminated soil material and/or aroundwater may require detoxification in addition to the landflll ~~•• which may effect ,, A-D c; '( ~ ~ - tochnoJosy and tcale of deto><iflcation eft'~ ~ ;v -~ ~- Oraanic contamination will be determined by the leytavailable analytical ~ method• for trace orsnaica . Decontamination 0f1l1 equipment and devices utilized in the construction of the well, is enential. 2. 1 Con~ptuaJ dealan oonalderationa for the monltorin, wells. Z.1.1 Tho location and identification of the new monitorina wells required per this m are as described below and aro ahown in Figure 1. Woll m # Dull Losatino MW-JA Shallow Rut of tho landflll ~25' ~om the foncetlne MW-J8 Deep Batt of the landfill ""25' from the fenc.Hno MW-JA Deep Weat of the landtltl -2S1 &om the fenceUne MW-4A Deep South of the landfill ~25' from th& f'encellne -- ~ P. 4 IIDIBIA\~1f MW-5 MW-SA MW-6 'MW•7 MW-7A MW-8 'MW-9 MW•lO Shallow Deep Dffp Shallow Doep Deep Deep Deep Northeast aorner of tho landflll -2S' ft-om the fenoeline Northealt comer of the.Jandfill -25' from the fcncellne In the 80Utheut draw u 1hown in Figure 1 Southwest comer of the landfill -2S' from the fenceline Southweat comer of the landfllt -25' ftom the ftncelinc In the northeast draw u shown in Piprc l In tho northem draw •• ahown in Fiauro l In the wos,ern draw u lhown ln Fisuro 1 2.1.2 The ahallow well• are to be tcreenod in the upper 10 feet of the aquifer . 2.1.3 All deep well, are to be drilJed to augtt refuaal ( 100 blows por foot). The deep wells are to be screened from auaer refusal el8Vation to IO feet above auaer ref\aaal. NOTS: Woll, MW-8, MW-9, and MW-to are to be handled llightly differently a1 desoribed ln Section 2 .1.4 2.1,4 Welti MW-8, MW-9, MW-10 are to be drilled to auaer refu,aJ (sreater than 100 blow, per foot), lf1hero is a greater than lO foot saturated r.one above auaer refu.al then 2 neated wells will be inatalled at that location, All nellted wells will be screened u followa: • The duper well, will be screened from auger refusal elevation to an olcvatlon 10 feet above the auger refusal. ~ The ,hallow well• will be 1creened in the upper 10 roet of the aquifer. 2. I. S The monitoring wells are to be constructed in accordance with the following requirements. The relevant aection1 pertaiftin, to monitoring wells 11 contained in TitlelSA North Carolina Administrative Code Subehapter 2C • "Well Ccmstruetion Standards". The US Environmental Protootion Agency. Region 4, "Environmental lnvo&tigatlon, Standard Operating Procedurea and Quality Assurance Manual" (May 1996) or equivalent, Applicable ASTM 1tandards. 2.1.6 Deai9n or appropriate 1lu1 and/or pumpins teat, on ,elected well,. 2.1.? A!l well, are to be con1tructed with ltalnleaa ateel caaina and 1tainle11 steel ....... ! ~ f''~~ {_1-y;e ,JtLj FAX COVER SHEET PHONE: PHONE: 73,.3-4996 COMMENTS:~ \.D-z___ Y\Q.,Lcj ~ D:\Q~ ~ c::h~.w X)O,,.o..e__C) CiY:c ?~& JU,,'.)2\v,,.F~ ~cl \>0\CA~~r,7:D~ TOTAL NUMBER OF PAGES INCLUDING COVER SHEET:_,_)_,_()~_ DATE SENT: ~ cf-'-I c--..Cf (._p ♦S&ME September 20, 1996 Mr. Patrick Watters State of North Carolina DEHNR -Division of Waste Management P.O. Box 27687 Raleigh, North Carolina 27611-7687 Reference: Peer Review of the Warren County PCB Landfill Materials Dear Mr. Watters: ---,rr-~-.~~· ?.,.,-l'tr" ,'c.k... u.) t&/ I/ f}U,·rv' The CEC/PENC Groundwater Subcommittee has completed our review of the referenced information provided to us. We had two firms of our committee r:nembers respond to our request: S&ME, Inc. and GEi, Inc. Rather than combine the comments by these firms, I have elected to attach their reviews to this letter. We appreciate the opportunity to provide peer review to you on this important project. If we can be of further service, please call us. Sincerely, Groundwater Subcommittee Chair cc: Mr. William Meyer Director, Division of Waste Management Mr. Donald F. Carter, P.E. CEC/PENC Environmental Committee S&ME, Inc. 3100 Spring Forest Road, Raleigh, North Carolina 27604, (919) 872-2660, Fox (919) 790-9827 Mailing address: P.O. 13ox 58069, Raleigh, North Carolina 27658-8069 -·- September 20, 1996 Ms. Ann M. Borden S&ME, Inc. 3100 Spring Forest Road Raleigh, North Carolina 27616 Reference: Review of Warren County PCB Landfill groundwater issues Dear Ann: A review of the information that the State has provided has lead to the following comments and recommendations on the proposals. NOTES FROM REVIEW OF WARREN COUNTY LANDFILL PROPOSALS COMMENTS: 1. Drawings in Packet #2 show monitoring well MW-1 off center of the ridgeline, possibly at the very head of a swale. The BFA figures show the well just about on the ridgeline. The actual location could strongly affect interpretation of existing and future ground-water data and projection of the potentiometric surface. 2. The modelling results in Packet #3 are clearly not representative of the potentiometric surface due to insufficient data points. If monitoring well MW- 1 is indeed off-center of the ridgeline and near the head of a swale, much of the apparent inconsistency of the data could be explained. S&ME. Inc. J100 Spring Forest Rood. Raleigh, North Carolina 27604. (919) 872-2660. Fax (919) 790-9827 Mailing address: P.O. Box 58069, Raleigh. North Carolina 27658-8069 Ms. Ann M. Borden September 20, 1996 3. DSWM's proposal is to install deep wells to pair up with shallow wells MW-2 and MW-3, and to install two other well pairs on the northeast of the landfill, very close to the edge of the landfill. Believe that the deep wells at MW-2 and MW-3 are merited and will be needed but the location of the new well pairs puts too much credence on the existing landfill mapping. Groundwater flow, particularly shallow, around the landfill needs to be better defined. 4. George Bain's comments are that the four existing wells at the site appear to be functioning properly and that groundwater flow needs to be better defined both laterally and vertically. He suggests a new deep well at MW-4 and three upgradient shallow wells upgradient of the site. He refers to a Figure 1 and a Sverdrop and Purcell drawing which are not in the packet so don't know exactly where he has in mind. Bain suggests constructing a new potentiometric map with the new shallow wells first, then installing the two new well pairs. Agree. We disagree on some details of discussion but agree as to scope and approach. Would like to see Bain's proposed well locations. 5. BFA goes into quite a bit of discussion and depth of analysis. However, I believe their plan goes beyond a reasonable extension of the existing data and relies to a great extent on supposition, using generic geologic and topographic data and interpretation to try to cover all contingencies. Overall, their reasoning based on these principles is sound, except that I do not agree with their projection of the water table. BFA's proposal projects that the water table is mounded 2 Ms. Ann M. Borden September 20, 1996 beneath the unit and slopes away radially. However, using the principle that the water table is a subdued reflection of the topographic surface (a principle that they reference and rely on), the projected water table beneath site before construction of the unit would fall off to the north, south and west from the north, since the unit was built on a ridge but not at the crest of the ridge. According to the topographic mapping, the crest of the ridge is located slightly east of the unit. Rather than a mound, there would be a slight gradient originally under the site from east to west. Since the water table is recharged from surface infiltration and the unit prevents infiltration in its footprint, the reduced recharge would result in a slightly lower water table under the unit, increasing the gradient from the east to the unit. This would slightly increase the gradient from the east part of the ridge to the unit and a very slight decrease in gradient from the unit to the west. The :result is a flattening of the water table, not a mound. Some specific comments to the BFA report: Do not see a need at this time for PCB/dioxin analysis of soil samples above the water table. Agree with installation of well pairs 1 (A,8), 5(A), and ?(A). May ultimately need 5(8) and 7(8) but not yet demonstrated, so I list them as "maybe's". Do need a shallow well on the west side as well. 3 Ms. Ann M. Borden September 20, 1996 Rather than put in deep wells at existing wells MW-3 and MW-4 and label them MW-3A and MW-4A, all deep wells should have the same nomenclature system; that is, the deep wells should be "B" wells and the shallow "A" wells, as BFA suggests for new well pairs. Do not believe that new wells MW-8 or MW-6 are justified at this time. If MW-6 were installed, it should be located further up the draw. Do not like background wells on another ridge. Don't see the need for 3 background wells on that ridge. Believe that further analysis will show that upgradient well is possible to the east of the unit on the· same ridge. With the choice, would prefer several slug tests in this regime, rather than one pump test. During drilling of test borings for new wells MW-1, MW-5, and MW-7, soils should be sampled from surface, not wait until get to base elevation of unit. BFA questions function of existing well MW-1, since it seems very stable over time. Yet Bain looked at same data and states that all wells appear to be quite functional. Need more info, such as how does the well recharge when bailed for sampling? 4 Ms. Ann M. Borden September 20, 1996 MY RECOMMENDATIONS: I believe that we have to learn how groundwater is flowing in the immediate vicinity of the unit first, then we can extend the system based on that understanding, historical records from the existing wells, and understanding of the site geology and topography. My recommendation is to install a shallow well at the approximate mid-point of the four sides of the unit. Deep wells should be installed paired with the new shallow well along the eastern side of the unit and at existing wells MW-2, MW-3, and MW-4. This system of new wells will establish three well rows radiating from the pair along the eastern edge of the unit in the direction of the three main swales to the west of the eastern ridge. It will also provide a set of four deep wells covering the same area. Water level readings will have to be modelled to evaluate groundwater flow directions around the unit. This should not be done with a simple contouring program but be modelled in light of existing topographic and geologic conditions. After this modelling is complete, an analysis can be done to evaluate whether additional wells are needed (and where) and which wells should be sampled. If there is any further discussion, I am available at 872-2660. Sincerely, S&ME,l~c. ~- Ernie Parker, P.E., .G. Vice President 5 GE I Consultants, Inc. September 16, 1996 Ms. Ann M. Borden S&ME,Inc. 3100 Spring Forest Road Raleigh, North Carolina 27604 Re: Peer Review of Work Plan Materials Warren County PCB Landfill Dear Ann: 7721 Six Forks Road Suite 1.16 Raleigh, NC 27615,5014 919·676·0665 In reply to your letter to Steve Whiteside dated September 4, 1996, the following are comments on the materials you provided on the Warren County PCB Landfill. I have combined my comments on the State's plan with those on the Barnes, Ferland and Associates plan to facilitate comparisons. Comments of George L. Bain (October 19, 1995 letter) • I agree that the direction of growidwater flow in the area of the landfill cannot be adequately evaluated with the existing well network. Additional monitoring wells are needed for this purpose. Evaluation using groundwater-level data from the existing wells and the new wells may reconcile the apparent contradiction between the State's interpretation of the direction of shallow groundwater flow (to the north and northeast) and the surface topography of the site, which drains generally radially from the landfill. • I have not located "Sheet 3, Sverdrup & Parcel, 8/12/81" cited in item 2 of the Recommended Alternate Plan. Consequently, I am not able to comment on the recommendations. State Draft Workplanfor Upgrading the Ground Water Monitoring System at the PCB Landfill (April 26, 1995) and Barnes, Ferland and Associates, Inc. 's PCB Landfill Supplemental Site Investigation Plan (Summer I 996) • The BF A plan refers to ''the existing Sampling Plan dated July 12, 1994." I believe this plan was not included in the materials provided. Consequently, I may not have the full context of the work proposed by BF A. I am offering comments based on my widerstanding of the situation from the materials provided. C' ... mcmd, NH Winchester, MA Chic:ai,:o. IL Enj!lt:woml. CO C'..arlsbad, CA S:;,.n Fnmdset1, C'..A Ms. Ann M. Borden September 16, 1996 • The basis for the State's plan appears to differ from that of the BFA plan in the interpretation of the probable direction of shallow groundwater flow from the landfill. The BFA plan appears to emphasize the general assumptions that ''the natural water table in this area should be a subdued expression of the surface topography" and "recharge to the mowid, or groundwater reservoir, occurs by downward infiltration through the unsaturated zone to the water table, where the infiltrating fluid becomes groundwater." The State appears to place considerable emphasis on its interpretation of a north/northeast direction of groundwater flow, based on repeated measurement of groundwater levels in the four existing monitoring wells. While it is reasonable for BF A to make its assumptions in the absence of other information, the State has accumulated groundwater monitoring data that appear to contradict the assumptions. While not an objective stated in the BF A plan. the BF A plan would provide data that would enable a more comprehensive evaluation of groundwater flow. The State's plan would not evaluate this apparent contradiction. • In addition to information on groundwater flow, the new monitoring wells will provide additional information on groW1dwater quality. Both the State's plan and BFA's plan appear to locate monitoring wells for both early detection of releases from the landfill and for detection of migration at some distance from the landfill. Again, the well locations per the State's plan appear to be based on the interpretation of a north/northeast direction of groundwater flow, and BF A's well locations are based on the assumption of radial groundwater flow, with emphasis on surface drainage cL.--aws. Because of the larger number of wells in the BF A plan and their strategic placement in the most likely paths of groundwater flow, the BF A plan is more likely to detect releases from the landfill than the State's plan. • Parts of the narrative in the BF A plan are confusing and should be clarified. Certain sentences or phrases may also need to be edited. On page 5-3, the third paragraph begins with a comment about flow in fractured rock (apparently incorporating one of George Bain's comments). But the "deep" wells are to be installed within the weathered rock. While the comment may be valid, it could cause confusion about the distinctions among rock, weathered rock, and saprolite. On page 5-3, third paragraph, two sentences assert knowledge of the site hydro geology; they appear to be statements of general principals of hydrogeology rather than what is known about the site: "The orientation of the draw features which surround the site is directed by fractures. Enhanced directional groundwater flow will occur along these fractures." I doubt that the understanding of the site would support these statements as facts. Ms. Ann M. Borden .. -:,-September 16, 1996 On page 5-3, third and fourth paragraphs, the term "intercept" is used where it appears that the term "intersect" is intended. On page 5-4, first paragraph, reference is made to identifying contaminants in groundwater at background locations. Are contaminants other than PCBs and dioxin a concern for this site? If not, I question whether analysis for a range of parameters is warranted. Because it is more comprehensive, the BFA plan will also be more costly to implement. Given the concern about the accumulation of infiltration water in the landfill cell and the resulting concern about the effect on groundwater quality, the cost of the more comprehensive plan appears to be warranted for the situation. The BF A plan provides a higher probability of early detection of a release from the landfill. Also, I have some concern that the State's plan depends on the interpretation of the direction of groundwater flow based on water levels in only four monitoring wells; if there are components of shallow groundwater flow in directions other than north and northeast, work conducted under BFA's plan is more likely to observe these components than the work under the State's plan. I would be glad to discuss my comments with you or with the State. Sincerely, GEi CONSULT ANTS, INC. ~7t-~ Kevin R. Boyer, P.E. Environmental Division Manager KRB:cf c: Steve Whiteside ACTIUIT Y REPORT(TX) ~)9.24.1996 ?Ci .... -· 9197 153605 SOLID WAST E DIU DATE TI ME DURAT I ON REMO TE ID MOD E PAGES RE SULT 09 .20 13: 4 9 00' 00 " 971501 66 G3 0 I NT ERR UPT 09 .20 13:50 00' 00" 97 1 50 1 66 G3 0 I NTE RRU PT 09 .20 13 :5 2 01 ' 4 4 " 84078961822 G3 3 0 . K . 09 .20 14 : 0 4 00' 28" 9 103424021 ECM 1 0 . K . 0'3 . 20 14 :07 0 1 '33 " 830 1949 1237 ECM 3 0 . K. ~t 9 . 20 1 4 : 1 1 0 1 '04 " 9197 150 166 ECM 1 0 . K . 09.20 14: 23 00 ' 46 " 704 8 68 564 2 ECM 1 0. K . 09 .20 15 :37 0 2 1 16 JJ 7039349740 ECM 3 0 . K , 09 .23 08 :42 00' 00·'' 9469996 7 G3 0 I NT ERRUP T 09 .23 08 :43 00' 00" 94699967 G3 0 I NTE RRUP T 09 .23 08 :43 00' 00" 94699967 G3 0 I NTE RRIJ F'T 09 .23 08 :43 03' 26" 9 4699967 ECM 6 0. K . 09 .23 1 0 : 1 4 0 1 ' 1 3" 704 522 0063 ECM 2 0 . K . 09 .23 10 :50 00 ' 00" 99199549932 G3 0 N.G.25 09 .23 10 : 5 2 00 ' 48" 9 19 95 4 9 932 ECM 1 0 . K. 09 .23 11 : 39 00 ' 00" 98344564 G3 0 fL G. 20 09 .23 1 1 : 4 1 00' 41 " 834 4564 G3 1 0 . K. 09.23 1 2 : 1 4 00' 00" 7332 178 G3 0 IN TE RR UPT 09 .23 1 2 : 1 5 00' 00 " 4892499 G3 0 INTERRUPT 09 .23 12 : 16 01 J 57 11 9194892499 G3 3 0 . K . 09 .23 1 2 : 1 9 00 1 28 11 919 7153060 ECM 1 0 . K . 09 .23 12 : 32 01'58 11 493 5272 ECM 3 0 . K . 09 .23 13 :43 0 1 '03 " 9 19 715 0588 G3 2 0 . K . 09 .23 1 4 : 1 0 00 ' 00 " 8513865 1930 133 0 IN TE RRU PT 09 .24 08:04 07 1 55 11 830 19 491237 ECM 14 0 . K . 0 '3. 2 4 09 :03 03, 55 11 83019491237 EC:-1 7 N.G .39 09.24 0 9 : 15 06 J 15 11 84'0~ _. ------- 09 .24 09 :27 00' 00" 82026247875 G3 0 N. G. 25 09 .24 09 :27 00' 00" 82026247875 133 0 IN TE RRU PT 09 .24 09 :28 00 ' 46 '·' 8202624 7875 ECM 1 0. K . MEMORANDUM: TO: Potential respondents FROM: William L. Meyer, Director Division of Solid Waste Management SUBJECT: Monitoring Wells for the Warren County PCB landfill The Division of Solid Waste Management (Division) has drafted a request for proposals (RFP) for work on the Warren County PCB landfill. The scope of work is generally defined in the enclosed RFP. However, there may be other issues or elements that should be included in the RFP. A pre-bid meetin2 is scheduled for AT 8:30AM AT 401 OBERLIN ROAD, RALEIGH, NORTH CAROLINA 27605 IN CONFERENCE ROOMS fl/VD ~{'7:€: u1s11SC~(,{t£/..J 4T /,' 67:) PM · The Division realizes that this is short notice, however, due to the potential cost and resources needed to provide data on the landfill, the Division has determined that feedback from potential respondents at a pre-bid meeting is the most effective means of addressing questions on the project. The Division is looking forward to working with respondents on the PCB landfill. Participation in the pre-bid conference is a pre-requisite for consideration of bid proposals. I Scope of Work -Part II Monitoring Wells 2.0 Background on Warren County PCB Landfill 2.0.1 The State ofNorth Carolina (State) owns and maintains a closed (July 1983) polychlorinated biphenyl (PCB) chemical waste landfill permitted in accordance with the Toxic Substance Control Act (TSCA) and 40 CFR Part 761. 2.0.2 The PCB landfill is located on the East side of SR 1604 approximately 1.5 to 2. 0 miles from the intersection of SR 1604 and US 401 South, 2-3 miles from Warrenton, North Carolina. 2.0.3 The State is committed to detoxification of the PCB landfill utilizing appropriate and feasible technology. 2.0.4 The State has established a Joint Warren County/State PCB Landfill Working Group (Working Group) to evaluate technologies and tasks associated with the detoxification of the landfill. 2.0.5 The Warren County PCB Landfill has four (4) existing monitoring wells designated as MW-1, MW-2, MW-3, and MW-4 located approximately east, north, west and south respectively from the fenced in area of the landfill. These are shown on Figure 1 of this RFP. 2.0.6 The purpose of the RFP is to construct additional groundwater monitoring wells in order to determine any extent or degree of contamination external to the landfill. Any contaminated soil material and/or groundwater may require detoxification in addition to the landfill contents which may effect technology and scale of detoxification effotts. 2.0. 7 Organic contamination will be determined by the least available analytical methods for trace orgnaics. Decontamination of all equipment and devices utilized in the construction of the wells is essential. 2.1 Conceptual design considerations for the monitoring wells. 2.1.1 The location and identification of the new monitoring wells required per this RFP are as described below and are shown in Figure 1. Well ID # ~ Location MW-IA Shallow East of the landfill ~25' from the fenceline MW-lB MW-3A MW-4A Deep Deep Deep East of the landfill ~25' from the fenceline West of the landfill ~25' from the fenceline South of the landfill ~25' from the fenceline MW-5 Shallow MW-SA Deep Northeast comer of the landfill ~25' from the fenceline Northeast comer of the.landfill ~25' from the fenceline In the southeast draw as shown in Figure 1 MW-6 Deep MW-7 Shallow Southwest comer of the landfill ~25' from the fenceline MW-7A Deep Southwest comer of the landfill ~25' from the fenceline MW-8 Deep MW-9 Deep MW-10 Deep In the northeast draw as shown in Figure 1 In the northern draw as shown in Figure 1 In the western draw as shown in Figure 1 2.1.2 The shallow wells are to be screened in the upper 10 feet of the aquifer. 2.1.3 All deep wells are to be drilled to auger refusal ( 100 blows per foot). The deep wells are to be screened from auger refusal elevation to 10 feet above auger refusal. NOTE: Wells MW-8, MW-9, and MW-10 are to be handled slightly differently as described in Section 2.1.4 2.1.4 Wells MW-8, MW-9, MW-10 are to be drilled to auger refusal (greater than 100 blows per foot). If there is a greater than 30 foot saturated zone above auger refusal then 2 nested wells will be installed at that location. All nested wells will be screened as follows : The deeper wells will be screened from auger refusal elevation to an elevation 10 feet above the auger refusal. The shallow wells will be screened in the upper 10 feet of the aquifer. 2.1.5 The monitoring wells are to be constructed in accordance with the following requirements. The relevant sections pertaining to monitoring wells as contained in Titlel5A North Carolina Administrative Code Subchapter 2C - "Well Construction Standards". The US Environmental Protection Agency -Region 4, "Environmental Investigations Standard Operating Procedures and Quality Assurance Manual" (May 1996) or equivalent. Applicable ASTM standards. 2.1.6 Design of appropriate slug and/or pumping tests on selected wells. 2.1. 7 All wells are to be constructed with stainless steel casing and stainless steel screen. 2.1.8 All drill cuttings are to be containerized in 55 gallon drums. 2.2 Deliverables 2.2.1 Bid options are to be submitted for: -Mobilization -Decontamination -Materials -Drilling -Slug and/or pumping tests -Cost per foot and total cost based on adherence to the EPA Standard Operating Procedures and Quality Assurance Manual noted in 2.2.5 of this RFP. -Cost per foot and total cost with alternatives to the EPA Standard Operating Procedures and Quality Assurance Manual that are equivalent. 2.3 Criteria for selection of respondent 2.3.0 Appropriate design and technology proposed 2.3.1 Demonstrated experience and qualifications for landfill project with emphasis on North Carolina projects. 2.3.2 Cost ofbid option submittals 2.3 .3 Financial capacity for assurance of performance and environmental impairment protection. 2.3.4 Past performance with respect to working relationships with clients and compliance with project cost, schedules and management of change orders resulting from unanticipated activities. 2.3.5 Capability and commitment to work with the Department and citizens working group. 2.6 Process for selection of respondent 2.6.1 RFP sent to approximately 40 companies that have experience in working on landfill projects in North Carolina. 2.6.2 PRE-BID CONFERENCE TO BE HELD AT: 401 OBERLIN ROAD, RALEIGH, NORTH CAROLINA, 27605 IN CONFERENCE ROOMS ON AT 8:30 AM. Technical presentation by DWM staff, respond to questions and provide specific data needed for project. Members of the joint State/Warren County Working Group will be encouraged to participate in the pre-bid conference. (Attending pre-bid conference will be a prerequisite for consideration of bid proposals). 2.6.3 A bid response date will be established at the pre-bid conference. 2.6.4 All respondents subrnittals will be reviewed and a selection of at least 3 proposals will be submitted for review to the Working Group. The Working Group may request a presentation from the 3 selected proposals. 2.6.5 The Working Group will make a recommendation to the Department for final selection of a contractor. 2.6.6 The Division of Solid Waste Management will draft a contract and negotiate with the selected contractor. 2. 7 File information is available for review. Respondents should contact Pat Williamson, at (919) 733-4996, ext. 337 for a schedule of file reviews. 2.8 Attachments 2.8.1 Monitoring well location map -Figure 1 2.8.2 Location/vicinity maps -Figures 2 and 3 2.8.3 Two 3.5" diskettes of the US EPA Region IV "Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (May 1996) I ... ;i-1. 3 ~ 5 n ::r ', , I I ' ,, \ ' I I • • . • ' I I ' , I I I ' I I , I ·,... ,, ---- -.. \,;I u i,., c::r, u n ,, 3 ~ J C/1 I» ?$. ~ n C/1 ~-[ :r s· R R ID 0 ii' OQ I ,. s· §' ~ ! • OQ ,, if if ! a ':2. §. ti' =' tl to ~-,, = -! OQ C/1 ! s· e, ii;'" "- ---\ I I I E. ' ,- \ ' I ' I I I I I I I I , \ ' ', ', ... , ' ... , I --.. ••••• .. , ,..----- \, . ', _,,' ......... , ... ____ ,,,,,, W AIUlEN coumY PCB LANDFI1J. Srt'E -------..... @ . --,· • > z z - ).-· I .~ ,,/ \ ~ ." n 0 C z ~ . , ) ) \\ ' r' J • . 'f- #t ◄ ,1' ' I ~ .. "' Scope of W~k .. Part ll Monhorins Wei, 2.0 B~ound on Warr., County PCB undftll 2.1 2.0.J Tht State of North Carolina (State) own, and maintain• a doMd (July 1983) potychtori111ted biphtnyl (PCB) chemical waett l1ndfill ,,.,-mlttod ln IKIOOrdanct with the ToKic SublWICO ConU'OI Act. (TSCA) and 40 CPR Part 761. l . 0.2 Th• PCB landfill 11 loc1ted on tht But aide of SR 1604 approximately 1. 5 to 2. 0 milel tom the intenection of SR 1604 and US 40 I Sou,h, 2~3 mile, ft'om Warrenton. Nol1h Carolina. 2.0.3 The State It committed to detoxltlcalion ofthtPCB landftl utllldng appropriate and f'Bulbl1 tKhnolo9Y. 2,0.4 The State hu tttabll1hed I Joint Warren County/Sttte PCB Landfill Warldna Group (Worldn1 Oroup) to ,valuate ttchnoloaltt and tuk• moolated Yilth the detol(Jflcatlon of the landftll. 2,0.S The Warren County PC& Landftll hu four (if) e>dttlna monltorln1 well, dellgnated u MW~t, MW•2, MW.3. and MW•41ooated appro"imattly eatt, north, wett and eouth retpectiveJ)' fl'om the fenced in area ortht landflU. Thelt Ill 1hown on Pl,ur, J or tNI RFP. 2.0.6 The purpo" or the JUPP II to conatruot addltlonal aroundwetet monltorinJ wen, In order to dettrmll\e any extent or depN or oontamlnatlon o,cternal to the landDU. Any rontmiriattd 10II material and/or 1roundwattt may require dttoitifieation In addJllon to the landflll ~~ll wheoh may cft'e<,t ,...u,<; r ~ · -< tochnoloaY•nd IClleofdeto><ifteatlonene ~ f'V .~~ ti' 2.0.1 Oraanic contamination wiU be determined 1,y the lout avaUable 1n1lyticaJ ~ method• fbr trace orsnalc1. Deoontaminatlon c,fliiequlpment and device• utilized in the con1trualon of the well• le e,aendal . Co~tual dllip oon,ideratlona for tht monltorina well,. l . l , l The location and Identification of die new monitoring wwl11 required per thl1 k1P are .. de.crtbed btlow and are lhown in Fiaure I . Wal m 4f Dlcldl w.as1on MW-lA Shallow l!ul or the landftll -2,• &orn the ftn~llne MW• I 8 Deep IHt of the landfill ""25' ft'om the fenceline MW•3A Deep Welt of the landfill ... 2,• ftom the fencolfne MW-i4A Deep South of the landfill -2S' &om the hnceUne MW-S MW-SA •MW-6 --'MW-7 MW-7A . MW-I 'MW-9 : MW-10 ~- ShaUow Deep Deep Shallow DNp Deep Dtep DNp Northeall oomcr of the landflll -25' fl-om the f'tnoeline Nonhe11t comer of1h1,1andft11-25' fl-om the r~lne In the 10uth1Ut draw u lhown In Plaure I South""8t corner of the landf\11 ~2S' ftom the f'e11ccllne Southwett comer of the landflll .. 25• f\'om the tencellne In the northeut draw u 1hown In Piprc, I In tho nonhem draw .. ,hown In Pipe 1 In tht Wt1tem draw M lhown in Pil\lrt I 2.1.2 The lh1Uow well• are to ba 1CN1eT1ed In the upper JD fMt of the aq11if'er. 2.1.J AH deep wen, are 10 be drilled to auger rtft&aal ( 100 blow• por foot). The deep w.tl11 aro to be screened ft-om auaer ret\laal eltv,tion to IO feet above auaer rtfulll. NOTB: Well1 MW-I, M\V .. 9, and MW•IO •~ to bo handled .U1htly dln-ently H dnorlbed ln section 2.1.it 2.1.◄ Weft, MW4, MW-9, MW-10.,. to bt drilled to qer refttaal (lrt1ter than 100 blow, Pft foot). lfehere la a 1reat1r than 30 foot 11tul'lted r.one abo\'e ai1or re"1tll then 2 ne,ted welte will be installed at that location. All netted well, wlU be aeened II followa: ~ The deeper well, will be weened from auger ret\lHI elevation to an elevation 10 feet ebovt the aupr ref\a11I. 11111 1h1llow well, wUI be •crooned in the upper JO feet of the aquifer, 2. J .S Tho monitorins well• are to be con,tn,ettd in 1000,dance with the followina requirtmenta. 2. J .6 2. 1.'1 • The relevant NCtion1 perta!nin, to monltorins well• 11 contained i\ Thl,UA North Carolina Admlnl1tratlve Code Subch1pttr 2C • "Well Conltniction Stand&rda". The US Environmental Protection ~ • Region 4. "Environmental lnv11tl911ion, Standard Operatlns Procedurea and Quality Atsuranet Mm11t• (May 1996) or equivalent. Applicablt ASTM 1t1nd1rd1. Detfan of approprlatt alu1 ,~or pumpina teat• on aelected wetl,. AJI well, 11• to bo conatruc1 td with ltllnlNt lteel cutna and ,tainleu steel acreen. / ~ ,f''~~ {_17/e 3l~L-) I .,.. ~;. ~~/-s {!) ~58 c!)/ '-f/e /0-/4AJ~ frr &a.~t/nf<r1-_ ;;:,olald ~lder5 ca-~e --ne ~a,~ fable/ -rztg ~;; lrd-C.-frr 7hz. I ( r::uJ c/;,,-Ma/ 1)' 11, e /dcl 6-f!d41~s~ a~~ f -1-o h «d //llA-f te-~-/ ro/(! ye/ btJ_Y I u y a I-~ /' ' -/!1r.ee (3) d;1evlJ d,:j•acVtf-/a:,,..;{,"'5. {P ~Y b;cfdf;,iy /v>po5~s ~{!_ ~=-4v- -5/u.l( as>vfife ~ ~ve,rc,.,J,e de~ °{{' ~<pf~ c;;d..all~ wel/2a,,4' 9v~f /H ~/7 ?U3/ls. " FROM HC DEHNR SOLID ~ASTE SECTION 733-4810 Scope ofW~k .. Part II Monitorina Wells 2.0 BM::k ... ound on Warren County PCB Landfill 2.0.1 Tho State of North C!arollna (State) own• and maintain• • cloled (July 1983) polychlorinatod biphonyl (PCB) chemi"' watte landfill i,ermitted in accordance with the Toxic Subttance Control Act. (TSCA) and 40 CPR Part 761. 2. 0.2 The PCB landfill i1 located on the East aide of SR 1604 approximttely 1. 5 to 2.0 miJea ft-om tho intersection of SR 1604 and US 401 South, 2-3 miles from Warronton. North Carolina. 2.0J The State is committed to deioxitloadon of the PCB landfill utilizing appropriate and feuible technoloi)'. 2,0.4 The State hu c1tabli1hed a Joint Warren County/State PCB Landfill Working Oroup (Workina Group) to evaluate technoloaie1 and tuka as,ociated with the deto>tifleatlon of the landfill. 2.0.s Th11 Wan-en County PCB Landft11 hu four (4') exl1ting monltorina well• de1ignatod as MW•l, MW•2, MW-3. and MW•4 looated appro"imatoly east, nonh, west and 110uth respectively &om the fenced in area of the landflll. Thieu are ,hown on Fiaure 1 of thia RFP. P . 3 2.0.6 Tho purpose of the llFP is to con,ttu,;:t additional around water monitorins well, in order to dettrmlne any extent or de,rte or contamination external to the landftU. Any contaminated 1011 material and/or aroundwater may require 2.0.7 dotoxiflcation in addition to the landflll ~~ta which may effect ,. .w<; '( ~ ~ teehnoloSY and ~1• of deto,dfiQatiort eff'e ~ ,v ,~ s--<-' Oraanic contamination will be determined by tho lean,1vailable analytical ~ method• for trace orgnaica, Decontamination ofiii equipmentind device, utilized in the oonstru~ion of tho wens is enential. 2. I Con~ptuaJ do1ia,, oon1ider&tion1 for the monltorina wells. 2, l. J Tho location and identification of the ntw monltorlna wells requlred per this R1'P are •• described below and are 1hown in Figure I . w•m• Dl&2'11 ~loo MW-lA Shallow BNt of the landtlll -25' ft-om tho f'oncollne MW-JB Deep Batt of'tho landfill "'25' &om the fencelinc MW-lA Deep Weat ofthe landftll-15' ftom the fenceline MW•4A Deep South of the landfill ~25' ft-om the feneeUne ,, F~OM NC DEHH R SOLI D WASTE SE CTION 73!-•aie • MW .. S MW-SA • MW-6 ---'MW-7 Shatlow Deep Deep Shallow Deep °"P Deep Doep Northeaat oomor of the landflll '""251 ft'OM tho tenoc,Une Northtalt corner ofthe.Jandflll •2!' from the foncellne In the eoutheut draw u ahown in Plgure l Southwest comer of the landfill ~251 ftom the tenceline Southwest comer of the landflll ~1S' from ,he f'enceHnc ln the notthealt draw u shown in Pipro l In the northern draw u 1hown in Fiauro l In the western draw II ahown in Fiaure 1 2.1.2 The shallow well• are to be screened in the upper IO feet of the aquifer. 2.1.3 All deep well, are to be drilled to auser rttl&aal ( JOO blows per foot). The deep wells are to be screened from auaer refuaal elevation to l 0 teot above auacr refbaaJ. NOTB: Wel11 MW-8. MWP9, and MW•tO are to be handled lllghtly dlft«ently aa described in Section 2.1.4 2.1,4 Woll, MW-8, MW .. 9, MW•IO are to be drilled to auser refuaal (sreater than JOO blow• per foot), If there l1 a greater than lO foot saturatod zone above auaor refi.aaat then 2 noatod wells will be installed at that location . All nested well, wlll be acroened u follows: ~ The deeper well• will be screened ft-om auger refusal elevation to an elevation 10 feot abovo tho aupr retinal. The ,hallow welt, will be acreened in the upper l O feet of the aquifer. 2 .1. S The monitoring wen, are to be constructed in accordance with the tollowina requirtment1. .. Th, rele,,oant sections pertainlnJ to monitoring wells II contained in Title 15A North Carolina Admlni1tratlve Code Subchaptcr 2C .. "Woll Cr::mstruction Standarda". The US Environmental Protection Apncy. Region 4, ''Bnvironmontal Invoatisations Standard Operating Procedures and Quality Alsuranc:e Manual• (May 1996) or equivalent. Applicable ASTM standards. 2. 1.6 Dealan or appropriate 1lu1 and/or pumpina t01t1 on eelected well,. 2.1.7 AU wolls ere to be con1tructed with stainless stool casina and stainle,s steel ocr .. n. / ~ f ,r~~ ( T"!f7e .3-!'2 __ ,__LJ_.__._ -..... ----·· ---·---- -/) 11 # {!) ~5{: i>/ '-fl e /d~A /iaf' ft> y cfMU/ v-., -, . ;:;,ola W jM-v/ c/er; c1::,, ~e, --/1 e t,{la,/4,,---fabk -/'11e t:£'11/yd<--fay 7)a.l ~ t7A df,,e.Jtt¢ ~ --n /'&(cl G-&/o7rsf-a~r7 f 1-o I u € T?t / . /-v tf(c/vd,,t,(te,_ btd. /T~Ycl ~Ytuf a 1--~/7 -/Zlr~ (3) c/;i&:,,IJ df/acMf-/~J"i,,5. {P ~r b;cldlt'tf fvr7{)5,,a_-s --Me ~~~ -5 k I I a >> v ftf e avi c>. ve,,, <A-J-f! de ,,vft, °((" -f< pf~ ,;;d.a//4.-.r w-el/2~ 90 {fe-e f / M l}e.e,/ µei/s FROM NC DEMNR 50LID WRSTE SECTION 733-4810 --- -~ MW•S MW•SA . MW--6 'MW-7 MW-7A MW-8 1 MW•9 MW-JO Shatlow Deep Offp Shallow Deep Dup Deep Deep Northeaat. oomer of the landflll ""2S' fl'om the fonoeli"-· Northealt corner of the.Jandf111 .. 25' from the fertoeline In the aoutheut draw u 1hown in Ftaure l Southwest corner of the landftll .... 2s1 from the fenceHne Southwest comer of the landflll ~251 from the feneeline In tho northealt draw u 1hown in Fipro l ln the northern draw u ahown in Piauro 1 In the wost.em draw u lhown in Figure I 2.1.2 The shallow wella ire to he acreoned in the upper 1 O f'etl of the aquifer. 2.1.3 All deep wells are to be drUled to auger rtf\aaal ( 100 blows per foot). The deep well, arc to be screened from auacr refusal elevation to l 0 feet above auacr refuaal. NOTB: WollsMW-8, MW~9, and MW•lO are to be handled slightly differently 11 desoribod in Section 2.1 .4 2.1.4 Wells MW-8, MW-9, MW-10 are to bo drilled to augcrreftaaat (greater than JOO blow• per foot). If there ia a greater than 30 foot 1aturatod ione above auaer rtfus&l then 2 neated wens will be installed at that location. All nested well, will be acreened aa follows: The deeper wella will be &oreened from auger refusal elevation to an elevation 10 ft!ot above the auger refusal. ~ The shallow wells will be aorccned in the upper 10 feet of the aquifer. 2.1.S The monitoring wells are to be constructed in aceordanoe with the fotlowina roquirtments. Tho role\Jant NOtiona pertalnin1, to monitoring well1 11 contained in Title15A North Carolina Admlnl1tr1tlve Code Subchapter 2C • "Well Construction Standard111 , The US Envin,nmental Protection Aacncy • Region 4, ''Environmental Inve1tl9ation1 Standard Operating Procedures and Quality Assurance Manu1l 11 (May 1996) or equivalent, Applicable ASTM standards. 2.1.6 Deaian or appropriate ,lu1 and/or pumpina teat• on ,elected Well,. 2.1.7 AH wolla are to be con1tructed with stainless steel easina and stainless steel O<teOn. I ~ f 1 '~~ (17/e !,l6t-) I . 1vrP-h (!) ~5c? 0/ '-/I e. /d-/41iJ;; t,,. 8«Ct?VJ/Jf,(,y/;_ ;70£-/ed ~lclers .a-~e -tie wa~ -0rbk ./ The u' n fr~ PY '5Aa-l ( t7--r:J c:/;,,-~a/~ t1, € /de! G-&4;,S~ a~r; -1-o «clt/(//,,fte ~-//~~,/ bc,Yi~f a I-~/7 lo ftuee (3) c;/11t:0IJ ctcj'acbtf-/~;{"115. {P ;t,-, 6;ddtMy /vff7()5e-s: --/4e a¼k,:Xc,_k-v .-s Ju,./ I a S<;u ftf e ~ c>i ve-ru-)-f! de/ft-, r 1"< pf~ c;;MII~ w-e!/4~ 9J cf-a f / M ,!Je.e./ aei/s . DIVISION OF · · . WASTE MANAGEMENT FAX COVER SHEET FAX NUMBER: lf D ]-35 ~-/ 8 &°'-. PHONE: FAX NUMBER: 715-3605 PHONE: 733-4996 ~.~, COMMENTS ';-f b ~ ~ S 4 , OJ d) 2-0 pan d .e .oJ:o "d ~-~-\l -Sl.i:lliJV ti@. . TOTAL NUMBER OF PAGES INCLUDING COVER SHEET:--=-3"""'----- DATE SENT: 9-dD ~7 (_p Lf 0TOTe ur 1\Jorrn L-urouna Department of Environment, Health and Natural Resources Division of Waste Management ,-Ai-,~ a sn ,.----• James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director DEHNR · VV<:::: ~ 'S\.\)1\-~e..D I,).;) L~ ff'~~ ~ 't)~fL~ F~ FMk)) 5 3 ~u.t,:ffl~ OEcl.~~ °\=)\~~ ~'5 ~~~ D.2.12. srlfrE= G\i\6<C,,~\J oi ~~ A.)Sc ~~ P\ u ~c:iT ~l..)n ~ ~ \)OL,\J.,W'c,, ~ ~~ (~'h-! "t{lf:£,5 ~ ~C..l'l"l'DN)jLtJJ7'1L 1 1-tE:. "\:)\:SPf:.ie.R \le:.00C::12..y ?h ~cs \S ~~ 'ti~ D1u&-o~ Y..l{(L -Cc: ~6hNc/01rc:;;cTJ>i~ SoL\D W~lG:= ~~ s-~Tt • Vvlc: rt~ p~~'fcS:b f2 RJ ~ .... ~~C'trt),-)J\-'--rna.o tl'Vl1-\ ~ ()..X::LLS ( E~co;~) --s:Cf)~ d w~) -1 f-~ rwu.-e.& ~ ~"' MODI~~ ·tl"\--.S / / f-1}/\-f f.JtLG-~ I ·:~ (!l) .~ ~ Cl lo~"' w~ ~ /Tc:ct4 (J)n\m1/j!:t ~ · 'lii6tl.E:. ww.lJ fuc ~IV\<=-E:f,;e61.C'f' : "" et)m6, ,D, v<-, ~ ut t}l.}1Vh ~ ~ M l\'.W/1, uW &-6 Q ,d._ s~ 0-> 1 ,I,._ {JJ ..S11" b:.. tJ ~ \ 1:i /\J r\-0\\--"'-.. lJ.JCU S, -if>t1ti <S ~ ~ ~~ · Wt: Atlt Jn!YjtFY/Nv--<9~ S/rrrjJ½ jJ~ l'f1t.1J /fa,pe fe h~ 4 H/(,M, DIM/-f ~fov 'fM., f/~ 1//eeh:., / J/)(,S~ }t;JC' -Jo fL~ ~ f,n A--~b h ~ r~ JJ/<=c-~ P.O. Box 27687, Raleigh, North Carolina 27 611-7 687 Voice 919-733-4996 • Vl/tct., v~ T/ll~UUs -i s-h!/4:--~s · • Wtll u5f-tll-l~~ ~ /.UAS-lJM1d czJ 'fv p*"'1f'U~1 ll£C,U~ 'S,lh,,~UJ 2>"'-$Ju. ~ j:JMUI.IJ ef S~ (1)/4ilt1 f ~ -1i}v & C, ~ rJ / _RAN • wlt<.i L,(S€-6'7/f s;,pJ?o,_, Lt;~;f/4,.J { h #~ pM,i1UA~ ~v Yi-ht CfM j1t,u/.aj ~~w~.., s: ~ ~ FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/1 O"/o post-consumer paper 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 September 18, 1996 MEMORANDUM: TO: Respondents to February 16, 1996 RFP FROM: William L Meyer, Director Division of Waste Management SUBJECT: Excavation, handling, storage of PCB contaminated soils from Warren County PCB Landfill Each of you participated in a pre-bid meeting and site visit on Friday, February 16, 1996 concerning a proposal for excavation, handling, and storage of PCB contaminated soils from the Warren County Landfill. Since the February 16, 1996 meeting, the Working Group has hired new science advisors. The science advisors have developed a new Master Plan for selection of detoxification technologies. One major change is for bench-scale treatability studies rather than pilot scale field studies. This requires a modification in scale and processes for excavation, handling, and storage of contaminated soils. The maximum volume needed for bench-scale will be four 55 gallon drums. This volume would provide for both immediate treatability studies and for contingency for any future additional studies. The following are specific modifications to the request for proposals: Sub-section 2.2.1 Excavation This section heading is modified to read: Design for multiple six inch to 12 inch cased extraction bore holes (wells). The minimum number of wells shall be two with a maximum number of four. The amount of excavated materials shall be 24 to 28 cubic feet or four 55 gallon containers with at least one half cubic foot of head space. Sub-section elements A through K are retained and not modified. Sub-section 2.2.2 Handling of Excavated Materials P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper September 18, 1996 Excavation, Handling, Storage of PCB Contaminated Soils from Warren County Landfill Page 2 This section is not modified; however, it should be noted that the design should be based on placement of excavated materials into four 55 gallon containers. Sub-Section 2.2.2 Storage of Excavated Materials This section is delected. The state will provide all containers, devices or structures for storage of PCB contaminated soils. Sub-section 2.3 Deliverables Sub-section 2.3.3 Storage design and implementation process is deleted. Deliverables 2.3.2, 2.2.2 and 2.3.4 are retained and not modified. All remaining sections are not modified. The division is requesting that all respondents submit a response:by October 11, 1996. If any additional information or clarification is required, please contact Pat Williamson or Bill Meyer at 919/733-4996. c:\wpfdes\pcblf\rfpmodif.mem BF A Environmental Consultants . .z..:._;... ====~=~=~ Barnes, Ferland and Associa·tes, Inc. MEMO.RANDUM TO: FROM: DATE : BillMeyer & Pat Barnes 'ff September 13, 1996 Post-it• Fax Note BFA #95-017 7671 Oat Phone ii SUBJECT: Performance ofLandrdl Inspection and Collection of Water Levels It is recommended that the State (if they have not already done so) quickly perform an inspection of the PCB landfill facility and collect a round of water levels from the existing monitoring wells as well as inside the landfill. This inspection is critical and necessary to address community concerns relative to possible detrimental effects from the recent hurricane (Fran). Please repon the result5 of this inspection within the next week. Also, please pro\iide the elevation (reference to MSL) for the access pon used in measuring the landfill water level. ?-~1-1~ jtJL/7 The Hollister Building· 3535 Lawton Road• Suite 111 • Orlando. Florida 32803 Office (407) 896-8608 • Fax (407) 896-1822 08/19/1996 15:18 4078%1822 BARt'-lES FERLAHD ASSOC PAGE 01 ..... :;. -.BFA-~~v~~~rn:~n.~t-~I d~n-sultants Barnes, Ferland an_d ,ll_ssoc_iates, . . MEMORANOlJJ\i'r :_ FROM: •, .:.·· --· ....... , .. -:. '"' , ... :_, - ·-·DA'fE:· :~ August] tl996 -·=---- «"" ,-sun.JEC:T! -~·-st~t~~-of -Re~isj~~s to ~uppleme·ntal Sampl~ng -Plan-and . Related M au~rs ___ ·.' ----. . " --,. ...... . --".:!!:.-=- ···, -'. ~ Since 'fie last spoke,) h~~e pe-l6rmed t.he following : _-----_. . ' --.-;..,_-_ .... -----·-. · .. ,.,- ··,~-dded Reginnal Ffydrogeol◊gf Section t~ Plan and .tied ·it·t;o_th toJh~Wcal hydrogeofr~gy a))d ,.: the j)roposed wellJoc;iti Q!fs·.· -_ -__ -. _ -: . -. . ···~-...... --· " .. • "' -~ ··-- '2 .. Ad(i~(i-tfiiie'.(3) g'~ologic i.:r9~sjections through the landfill area terfuinating at the J)roposed_:-·-·.:: welt locations .. Because -·of-the lack of subsutface data (e.g:, · strike ·and dip of the sapr6lite -':: -. -" . -zone), s~v-eral _as~tlmpficnis. a1i made. However) the water le\/el gradierit infonnaiton~ inake.s-· =----. ii . ... the crnss--s~ctfon~till yery u_~efuL ... ... . . • ---· . --- '3 Obtained"ii fuJ(cop/ofthep 1?-w EPA, May, 1996 SOPs.-1·--~m tising th~m -_ex!ens"jv.~ly tcY--~ _ tnodify the drilling pro~edures and well design sections_ I don't think procedures afr Q<::0e"ded _:. - fr)r areas which: ~wetlap with the July, 1994 Sampling Plan: For example, in describing t.he .. · ~- --•. protocol for surface water-sampling l reference both the July Plan an't:1 the EPA ·soPs.-Piease---· ~--- _ let _ine-kncrw if ytju sugge~t otherwise. ---.. . .. ----········· . Federal_ Express~ci_ copies (hartl copy and on disk) of site map with s~tnp(c iocatioQi as we-ll the drafl cross-sect.io,is. -to Hol:>-Glaser' s attention . These items ire .draft and I am lo()King fr'ir.::. .. yourjnput a_s"s~o!'! as pos~ible. --s: . I l,av~ i~:11 friessages :r6{Bob:Glaser, his yoicc mail indicates he is either Qfl vacation or in tlf('': " field _ P_lease httvfhiin call lTie _When he gets back i_n. J want to m~ke su~e--·~e ag1'ee on what--:-: -airecti_on to Jake the· Pia~ iti and .that we are not duplicating efforts.--- •·.· Also, please t'et r11e know tl1e $tat(!~ of our July 15th :i~voice . As you kn9,;v, cash-flow is criti~al t() ... -~:c a srna..11 fli'mi . ····. -.:- -. .. P)case give me a ~~Jrfodf!_y,'.ifJ~osl ib]e_ --~-" --.. :: ... --·· ---:-..: .;_- . T~e Hoilist~/su;tldi~g -/J$35 Lawton Road. suite 111 • o~i and6, Flqrida:32803 Offfc_e (~0_7) 896-8608 • Fax (407) 896-1-8~2" -.. -- I To: The ~_,.~ Adv4sors ; From: cal Com~ ittee Oats: A 1956 i S!Jbjeet: ! Commitee Meeting 2) The re eomm· report h the state' beappt nd the Technical Commntee had a confat"ence call on Au~ 7th and s 118C8S~ry to focus your attention on the following: I I . work appr~v&d by the Technical Committee and the Working Group. I . technotogles and vendors that was due on June :14th. T1'e Teehnfcal not yet r~ this report nor an explanation concerning why tne ... -~n submi~ed. Other due dates have not been met as w.ff. lf"dudlng tcry testl~ and the fietd sampling and testing draft which needs to the Workiry9 Group. I 3) VJae!dy pt · ess repo~ based on the scope of work . You agreed to prov!de these reperts. TI'\ls eement 0¢Urred two months ago, yet the Techn!Cal Committee has yet to recaive prcg,~ report based on the entire scope and 'scheduie of work. 4) The nv .which co decisk,n i tha !andf!I lar.drffl ls an on--slt 17, 1993 framework which has informed the Workfng Group sir.cs 1SS3. and to intorm tie Working Group, makes it dear that 'the det~xtficatlOn based on' technical feasibility. risk as~ent, and on the f8d 1t1at Ing. Detoll'.Jficatlon is net connngent upon proving'. or disproving that the . Toe flve-boint framework also makes it c,ear that the goat Is to find n to the ctisis (Enciosures: Memorar.dum to Jonathan 8. Howes. Mav from Jonathan B. Howes. May 21. 1993). , i 5) Th9 Wooc,1 Group will beet on August V . The Techn!cal Committee needs to meat with yo ore the ~eeHng bocausa the Technical Committee needs to make rscom~n-rmtions to:tt,e full committee. The Technical Committee would triarafora Ike have a conf4)(8ncs call with you the week before 1tie August 27th meeting, prgf ly on Wednesday, August 21 ; Thursday, August .22: or Friday. August 23. YO\Jr pre e at the ~ust 27th meeting would be appreciated. Enc!esura: Of Work, Memorancum. Letter I I I -PCB LANDFILL SUPPLEMENTAL SITE INVESTIGATION PLAN TABLE OF CONTENTS l.O BACKGROUND 2.0 PURPOSE 3.0 SITE SETTING AND HYDROGEOLOGY 4.0 SITE LOGISTICS 4.1 4.2 4.3 4.4 4.5 Site Access Work Zones Site Control Der.ontamination Facilities Field Decontamination Procedures 5 0 SUPPLEMENT AL INVESTIGATIONS 5 1 Landfill System 5 2 Groundwater/Soils 5.2.1 Locations 5.2.2 Drilling Procedures 5.2.3 Monitoring Well Design/Testing Procedures 5.3 Surface Water 5.4 Stream Sediments 5. 5 Surface Geophysics 6.0 ANALYTICAL TESTING 6.1 Matrices and Analy1es 6.2 QA/QC 7.0 REPORTING 95-017 00 SIPTOC.DOC ' \ 1 ' \ I,' ·~ .• I " : .\ \ ~ u " ' -L~ j I ; l ;; : L:J UJ WARREN COUNTY PCB LANDFILL SUPPLEMENTAL SITE INVESTIGA TJON PLAN 1.0 Background D S? ! ) j; ;, !.I The State of North Carolina owns and maintains a closed landfill containing PCB-contaminated soils. This landfill is permitted under the Toxics Substances Control Act (TSCA). This landfill is "inyl and clay lined and contains approximately 40,000 cubic yards of soi.ls (24 feet thick) contaminated with polychlorinated biphenyls (PCBs). The landfill is located on a 142-acre tract ofland located just off State Road 1604 in Warren County. the containment area or landfill cell is enclosed by a fence occupying approximately 3. 8 acres (Figure 1 ). 2.0 Purpose Barnes. Ferland and Associates, Inc. (BFA) has developed the foliowing "Supplemental Site Investigation Plan'' ("Plan) to acquire more detailed information fOi detennining the environmental impact associated with the landfill and for planning the scope of the remedial design program The objectives of this Plan are to determine the: c Geological setting including definition of soil and rock types, permeable and confining layers, fractures and faults. hydraulic properties and potential contamination pathways; o Direction and rate of groundwater and surface water flows and seasonal water table variations; • Location and extent (both vertical and horizontal) of soil and groundwater contamination at discrete intervals; • Quality of surtace water where it first appears from the ground water system in each of the major draws surrounding the site; and, • Quality of stream ;sediment in areas \Vherc sedimentation is most likely to occur. These objectives can be achieved through a phased data collection program involving upgrading the monitoring network, additional sampling and testing, and surficial geophysics if required. In February, 1995 the State developed a proposal to update the existing groundwater monitoring netv,.-ork by installing three deep monitoring wells and one additional shallow monitoring well. In October of 1995 the plan was reviewed by George Bain, P.G., who also recommended additional spatial coverage both in shallow and deep zones. Mr. Bain's review also emphasized the difficulty of developing a groundwater monitoring system to detect the migration of contaminants 111 fractured rock. 95.0[7,0() n-.--saip.doc -1- '. ' ti \ ' ... We agree with the recommendations of both the State and Mc Bain, and have incorporated their c()ncerns into the scope of this investigation. 3.0 Site Setting and Hydrogcology The l 42 acre site is near the nose of a NE trending ridge, whose general elevations are greater than 3.30 feet (NGVD). Part of the approximately 4-acre fill area are within the 340 feet (NGVD) contour ,vhich forms a small local closed high on the nose of the ridge. Su1face drainage to Richneck Creek to the N"\V/NINE and E and to an unnamed tributary to the S/SE. The site is underlain by a related sequence of mica schists, according to the North Carolina Geological Survey and the lJSGS report "Geology and Ground-Water Resources in the Raleigh .¾ea, NC''. Rocks that compose th.is complex of mica schists exhibit layering, but attitude and composition of individual zones cannot be observed in the site area because of deep weathering Data from auger hoies at the site indicate the following general sequence of weathered strata: Land surface to 10-20 feet -Red-brown micaccous fine sandy clay; 10-20 feet to bottom of hole (max depth about 40 feet) -Brown rnicaceous sandy clay to sandy silt to clayey. The above materials are thoroughly decomposed native rock; formed in place by chemical weathering and characterized by preservarion of structures that were present in the unweathered rock . These materials are also referred to as "residual soils". The exact depth to partialiy weathered rock or to fresh bedrock is not known at the site. Partially weathered rock, as used herein, refers to the zone between thoroughly weathered residual soiis above to fresh bedrock below. The term saprolite is often applied to this zone. For the sake of consistency with other documents prepared for this landfill, we have also used the tem1 saprolitc to refer to that zone . Permeability in saprolite zone has been enhanced by fracture/weathering processes, and it is commonJy the most permeable zone in the vertical section. This enhanced penneability is oft.en e:xploited by seating well casing within or immediately below the partially weathered zone. The water table com..monly occurs in the overlying residual soils but may occur or fluctuate within the saprolite. Because of its higher transmissivity, this zone should be considered an avenue to transmit contaminants. The natural water table in this area should be a subdued expression of the surface topography: that is, mounded under the ridge with highest gradients toward the topographically iow areas in gf:neral K and S directions and lower gradients to the E/NE. Height of this mound, which represents the water table, would depend on such factors as vertical and lateral permeability of the residual soils/saprolitic materials; distance to points of natural discharge; and duration and magnitude of recharge events. A smaller mound related to the closed 340 feet contour may occur under part of the site area. Recharge to the mound, or groundwater reservoir, occurs by downward infiltration through the unsaturated zone to the water table, where the infiltrating fluid becomes groundwater. General circulation of groundwater in this environment is downward from the water table to the zone of partially weathered bedrock, then laterally to points of areas of eventual discharge (usually 9~-0!7.00 nt:,s.:iip.do~ -2- 7/18/96 streams or springs under natural conditions). Deeper circulation belo\v the partially we.athered zone is usually limited by rapidly decreasing occurrence of interconnected fractures ~~th depth in underlying fresh bedrock. Thus the most commonly expected groundwater flow path is predominately downward from the water table to the sapmlite .zone, then predominantly in the lateral direction to discharge areas. Discharge has been observed as would be expected emerging from the walls of the major draws in the saprolite zone. Deviations in this idealized flow path may occur related to inhomogeneities in the residual soils. In layered strata, as an example, differences in permeability may result in lateral flow components beginning to predominate above the saprolirc zone, thus resulting in shortening the groundwater flow path and discharge to contact springs on the adjacent valley wall above the panially weathered rock. Thus, in summation. this is a very localized groundwater flow system in that all recharge to the mound underlying the ridge occurs from infiltration from the ridge. and most discharge occurs to adjacent valleys of Richneck Creek and its unnamed tributary. Deep circulation within the bedrock to eventual discharge in more distant areas is not expected. The most probable fiow path for ground\vater is downward to the partially weathered zone, then predominantly in lateral direction to the nearby discharge areas. This idealized flow path may be. in part short circuited by inhomogeneities in the materials above the panially weathered zone, in which case discharge would occur at higher elevations in the adjacent valleys. 4.0 Site Logistics 4. 1 Site Access 4.2 J-Jlork Zones 4.3 Site Control 4.4 Decontamination Facilities 4. 5 Field Decontamination Procedures 5.0 Supplemental In:vestigations Additi0nal sample collection is needed to comply with the regulatory requirements and to obtain current data for planning remedial activities. The supplemental sampling generally involves sarnpling and analyses of groundwater. surface water and sediment from existing stations and several additional locations (Figure l ). All sampling and testing procedures should be conducted in accordance with the existing Sampling Plan (Appendix 1). Table 1 is a summary of all proposed sampling points by matrix. It also includes the type of analysis proposed. · 93-017.00 OC!l-qip.doc -3- 7118:% I I '"" .. r , r.,"\ {M ~ I :• ! '; , l.J I : ;: I : ., ~ L.'.:'.J !_i u Lnl .r lJ 5.1 Landfill System It is important that some continuity with the pre"ious analysis be maintained to establish trends whenever possible, The establishment of trends is critical to our ability to determine the real potential threat associated vvith mi,gration of contaminants. lt is particularly important that locations which tested above detection .levels be reanalyzed. Repeat the first round (July, J 994) for all locations and corresponding rnatrices (see Table l) excluding so il samples collected on the landfill cap, which correspond to the landfill system These locations include the leachate inlet and outlet, the settling pond overflow pipe base, soil at the center of the pond and the discharge pipe outlet. A sample of the landfill contents will also be collected from the central gas vent . It is particularly imponant to continue to regularly analyze the landfill contents, which will enable continued evaluation of natural biodcgradation. Procedures to be followed in the collection of those samples outlined are in Appendix A. Further analysis of landfill cap materials is not warranted because it was properly addressed pre\~Ously and there is no mechanism for it to be contaminated. Reanalysis of J\lf\.V-1 is not recommended because the well screens appear to be plugged , This is discussed in more detail lateL 5.2 Groundwater/Soils 95-017.00 n~;sip.doc 5.2, 1 Locations Two additional deep groundwater samples from wells adjacent to MW-3 and l\fW-4 . These wells will yield samples from the weathered rock (saprolite) zone , These wells which will be designated MW-3A and 3B are important to establish the vertical flow component at key existing locations. The new hydraulic and groundwater quality data will be compared to that of the existing wel.ls at those locations Comparison of these data will give us an indication of the relative transmissivity of each zone and how much of the recent recharge reaches the saprolite zone. Water table and ~aprolite zone groundwater samples will also be obtained at locations directly northwest, south and east of the landfill within 25 feet of the landfill footprint, These three clusters of wells which will be designated MW-1A,B> MW-SA,B and l\1\V-7, 7 A are critical to the establishment of a proper flow net for the immediate vicinity of the landfi!L They \Vill also yield key water quality data from areas directly adjacent to the landfill in the currently anticipated flow paths. Groundwater samples will also be collect~d in the three major draws located to the north, northeast and northwest of the landfill and in the one major draw located to the southeast -4- 1118196 c:-:, i I ·~ \I.S-017.00 o=ip.(IQ.; I , As discussed in Site Hydrogeology, it is very difficult, if not impossible, to develop a monitoring nenvork which will capture l 00~,.o of the flow in a fractured rock system These four wells are positioned to minimize the guess work. The orientation of the draw features which surround the site is dictated by fractures (see Figure _). Enhanced directional groundwater flow will occur along these fractures. By locating monitoring wells within these features we have an extremely high probability of detecting groundwater flow as it leaves the landfill site. Of the seven draw features identified on Figure __j it appears that five intersect the filled area. Because of the uncenainty of flow patterns leading to these draws, it is important that they be monitored with wells located at approximately the 3 00 ft. to 31 O ft. elevation. Proposed monitoring wells M\V-6, J\.ffi'-8, MW-9 and MW-10 are positioned to intercept groundwater flow along these features. With the exception of VOCs, surface water collected v.rithin these draw features should have the same quality characteristics as that of the groundwater; however, the monitoring wells are needed so that samples may still be collected during low flow periods. Background groundwater samples from three wells located outside of the landfill groundwater and surface water flow system are also proposed. At least one of these \veils will be screened at the \vater table. The other two will be screened within the saorolite zone. The wells will be designated BG-1, 2 and 3. Tnese background 1.vells will l -' '- enable proper technical review of data collected at the remaining locations. by allowing us to filter oui the contaminants which might exist within the groundwater outside of the influences of the landfill . Monitoring well sample collection procedures are outlined in Appendix A. 5.2.2 Dri])jng .Procedures The environmental drilling will be accomplished by the Hollow Stem Auger drilling method. Soil samples ·will be collected using split spoon samplers. All samples will be handled in accordance with Appendix A. It is anticipated that nine (9) borings will be performed; one at each proposed well location. At least four of the borings will be used as a lithology test boring, complete ·with continuous sampling to competent rock. The soil will be closely classified to identify geologic, not engineering, properties. The soil samples from the test boring at locations l, 5 and 7 (Figure 3) will be collected from below the base of the landfill and above the water table in the silty clay strata (about 30 feet deep), within the sandy silt strata (about 50 feet deep) and within the saprolite zone (about 60-90 feet deep). Soil will be collected in the remaining five borings at five-feet intervals or change in lithology. It is recommended one soil sample from each test boring will be analyzed . All auger flights and split spoons will be thoroughly decontaminated before use and between borings. -5-'. ' 7/18/96 ; : I '. 87/18/1996 14:22 ~;-:;GE 95-017.00 m,-ssi ;,. ,.kx, '' : --, L~ R : i : ~· ' ' ( L.'.:'.) j :! i II '--'W 5.2.3 Morutoring Well Design/Testing Prncedures Currently only four monitor wells exist at this site. Figure 4 shows that the water level in MW-2 is consistently lower than the other wells and that the highest water level varies seasonally in M\V-1, 3 and 4. However, review of the data provided indicates the MW-1 has failed to respond to changes in water levels since approximately December, 1994 and prior to that consistently lagged the other wells. This may be the result of a plugged well screen, but underscores the importance of having a proper weU design in order to collect representative environmental data . Since the landfill lies on a ridge crest, f,rround water is expected to flow radially outward from the site . All of the proposed wells will assist better defining the direction of ground water flow. They will be surveyed and static water levels measured in addition to existing well measurements. This informati on will be used to better define the water table contours, tlow direction and gradient at the site. Each of the proposed well clusters would include two wells installed adjacent to one another and screened at different intervals. Within each cluster one well should be screened at the water table but to capture the seasonally !cw water elevation and the other should be screened \Vithin the saprolite zone irnmediately above the bedrock surface. A11 new permanent monitor wells should then be sampled and tested in accordance \¥ith the attached Sampling Plan. A.II field work shall be conducted in conformance with accepted engineering and geologic practices as well as the Groundwater Section 's Guidelines for the Investigation and Remediation of Soils and Groundwater and the Hazardous Waste Section's Sample Collection Guidance Document. Well installation shall be in conformance with the North Carolina Well Construction Standards. A site safety plan shall be developed and followed by all field personnel. All appropriate decontamination procedures documented in the references above shall be followed . During the installation of each boring/well. a qualified hydrogeologist shall be present and a boring log coru.pieted for each well . Split spoon samples shall be collected at each change in lithology and where there has been a significant change in the penetration/drilling resistance. Soil cuttings shall be containerized until the analyses of ground water samples have been received from the laboratory. At such time, the appropriate disposal option shall be selected. Each well shall be constructed: a) in accordance \.'vith the attached diagram ; b) in conformance with the State's well construction standards; and c) to be capable of yielding a ground water sample representative of the ground water quality at that location. The well casing and screen shall be constructed of 2 inch diameter PVC The manufactured well screen shall be sized appropriately, according to the soil type. Each well shall be completed with a 10 foot well screen. The annular space from the bottom of ·, -6- 71)8/96 o::: u 5. 4 Stream Sediment Four stream sediment samples are proposed along Richneck Creek and the unnamed tributary. The locations were selected to detem1ine what impact to stream sediments may originate from the upstream areas of Rkhneck Creek, both above and belO\v SR-1604, therefore allowing the road's effects to be filtered out, as well as to determine the quality of ')5-017 ii!) n;:ssip.<lc,c -7- 07/18/1996 07 :55 4078%1822 BARNES FERLAND ASSOC PCB LANDFILL SUPPLEMENTAL SITE INVESTIGATION PLAN TABLE OF CON'l'ENTS 1.0 BACKGROUND 2.0 PURPOSE 3.0 SITE SETTING Ai'lD HYDROGEOLOGY 4.0 SITE LOGISTICS 4.1 Site Access 4.2 Work Zones 4.3 Site Control 4.4 Decontamination Facilities ~ 4.5 Field .Decontamination Procedures SUPPLEI'vfENTAL INVESTIGATIONS 5.1 Landfill System <5 ;z. l.l0ce£:N 5.2 Groundwater/Soils <-1 .., (:1(:;c/J ;) 1 'Z,.. I • (..,o 5 .2 1 Drilling Procedures --s:y 5.0 5.22 Monjtoring Well Design 5.2.3 Testing Procedures 5. 3 Surface Water 5.4 Sediments 5. 5 Surface Geophysics 6.0 ANALYTICAL TESTING 6, l Matrices and Analytes 6.2 QA/QC 7.0 REPORTING BFA~Dune BFA))one BF.AJ)one BFA,170% Cornplete DWA1 or Joel H. ? BF4,,,Done PAGE 01 .BF A Environmental Consultants Barnes, Ferland and Associates, Inc. MEMORANDUM TO: PCB Landfill Working Group (Technology Group) FROM: Patrick A. Barnes, P.G. Science Advisor COPIES: Joel Hirschhorn DATE: July 9, 1996 SUBJECT: Project Status Report BFA#95-017 On July l st I had a detailed conversation with Senator Frank Ballance about the status of the PCB Landfill. The Senator was very appreciative of the update and indicated that the situation was still on his radar screen. We set a tentative meeting date for the fourth week in July to discuss specifics. I recommend that key members of the Working Group be present. Related to the Supplemental Field Sampling and Testing Plan I have performed the following: • Coordinated sample locations with the State. • Obtained and reviewed cost information from analytical laboratories. • Analyzed information on the site's hydrogeology. • Developed a conceptual model of the groundwater flow system in preparation for July 3rd meeting with the State. Both Joel Hirschhorn and I attended the July 3rd meeting with State technical staff personnel to discuss the proposed Supplemental Field Sampling and Testing Plan. In general, discussions centered around the following topics: • Inadequacy of the prevous work performed: • Number and location of monitoring wells near the landfill and in the draws. • The need for and proposed locations of additional surface water and sediment samples. • Number and location of background monitoring wells. • Criteria for determining clustered locations. • Type of analysis for the different matrices to be tested. • Pros and Cons of split sampling. • The need to justify all testing efforts and costs. • Responsibility and lime table for plan development. Formal meeting minutes will be prepared by the State. P AB/psg/7-9PCB.doc The Hollister Building• 3535 Lawton Road• Suite 111 • Orlando, Florida 32803 Office ( 407) 896~8608 • Fax ( 407) 896-1822 07/03/1995 14:41 ,. fax Date i 40781351B22 Nurnber of pages including cover sheet To: -----------------. Ptwne Fax Phone CC: REMARKS: Barnes, Ferland and Associates. Inc. 3535 Lawton Road Suite 111 Orlando, Florida 32803 Phone Fax Phone _(407) 896-8608 (407) 896-1822 0 Urgent O For your review O Reply ASAP O P!ease comment / -f· 07/09/1995 14:41 ' 407:3'::H:,1822 MEMORANDUM TO: FROM: PCB Landfill Vil or king Group (Teclmology Group) Patrick A Barnes, P.G. Science Advisor COPIES: Joel Hirschhorn DATE: July 9, 1996 SlJBJECT: Project Status Repo11 BAFNES FERLAND ASSOC F'AGE 02 BFA #95-017 Since our June 26 conference, I have performed va1ious activities related to the Supplemental Field Sampling and Testing Plan . l. Coordinate sample locations with the State. 2. Obt.ain and review cost information from analytical laboratories. 3. Analyze infonnation on the site's hydrogeology. 4 Develop conceptual model of the groundwater flow system m preparation for July 3rd meeting with the State. Both Joel Hirschhorn and I attended the July 3rd meeting with State t.echnical staff personnel to discuss the proposed Supplemental Field Sampling and Testing Plan. The following is a general summary of the major points discussed and decisions reached, as I understand them. • Afonitoring vVells lt was agreed that four monitoring locations in the draws (gorge features) would be sufficient t.o assess what impact the landfill might have on the quality of groundwater leaving the area. Each location may contain two wells if greater than 30 feet of saturated strata exists above bedrock. Three clusters of two monitoring wells each were proposed for the northeast corner, southvJest corner and the east side of the landfill . The wells will monitor groundwater near the water table and in the weathered rock .zone immediately above bedrock. lt was agreed that deep wells should be added to current monitoring locations MW-3 and MW-4. .... MEMORANDUM July 9, 1996 Page 2 • Swface iVater Samples .. It \Vas agreed that the surface water analysis in the gorge features would duplicate those of the proposed monitoring wells for the parameters of concern, and thus would be largely redundant. Surface water locations were added south of the site and upstream from the current Richneck Creek upstream location. Additionally, the unnarned tributary downstream sample was :relocated to a position closer to the landfill. • Ad.di1ional Stream Sediment Samples It was agreed that stream sediment samples should be collected at two locations; where the two no11h-south trending gorges meet Richneck Creek and the unnamed tributary. respectively. It was agreed that the monitoring well network should include three background locations ouiside of the site's drainage system. It was proposed that these wells be located northeast, northwest and southwest of the site. ,,, Parameters lt was agreed that the suite of analysis pe,fonned previously is sufficient; however, detection limits would be increased for cenain analytes. It was also agreed that not all locations would require the full suite of parameters. A table will be developed by Joel identifying what analysis will be performed where. Because the sampling event would invo.lve several different matrices and be performed over several days, numerous sarnple blanks would be required. An approach to combine and thus rninimize these blanks was discussed. The State will prepare a sumrnary table with that information. It was generally agreed that the quality assurance and data confidence achieved by split samples may be also achieved by allowing the Science Advisors to select laboratories, retrieve data directly and independently determine sample designation . Finally, it was agreed that the final product should be for joint State/Science Advisor s1gnat.ure . A final draft will be submitted by July 17, 1996.