NCD980602163_19800125_Warren County PCB Landfill_SERB C_Appendix D - Comments on Draft Environmental Statemment-OCR

APPENDIX D
Comments Received on the
Draft Environmental Statement
"
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COUNT IE~
Franklin
Gr111ville
Per■on
Venc;e
·,wauen
MuNICIP.t.1..1 TIES
Sunn
Cre«imoor
l'ran•I1n1on
Henclerson
l<ill,.11
l.oui111u,9
i.tacon
M1ddlallutQ
Norlina
021ord
Rozoaro
Siem
Stowell .... ,,."'°"
Yo..i191v,11a
KERR -TAR REGIONAL COUNCIL OF GOVERNMENTS
P.O. Boa 709 13~ OR4HCE STREET JffNOER.SOH . H C. ,7SH
Pl>ICIHE 19191 ~?1 ,,\o/
J.D. E••••tt, E,..cu1;.,., Otr..cto,
Ms. Chrys Baggett
N. C. Department of AdministrJtion
State Clearinghouse
Room 504, Administration Building
116 W. Jones Street
Raleigh, NC 27603
Dear Ms. Baggett:
Jdnuary 25. 1980
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RE: Draft Environmental Impact
Statement for the Removal
and Disposal of Sotls
Contaminated with PCBs
Along Highway Shoulders in
Warren County
The Kerr-Tar Areawide Clearinghouse Review Convnittee has
completed its review of the above referenced draft EIS.
The A-95 Review Coll1Tlittee does not concur with the draft
Environmental Impact Statement per ttie"following statements:
1. Additional emphasis needs to be placed on the integrity of the
plastic liner.
A. There is no proposal to maintain the surface free of trees whose
roots could penetrate the plastic top liner and create a
connection to surface water. Annual mowing should be a minimum
requirement.
B. The plastic liners along the side walls of the proposed site offer
the only barrier between the disposed PCB waste and the surround-
ing soil. What other measures does the State propose in order
to mitigate any damage of or decomposition of the plastic liner.
{root intrusion, damage by equipment, etc.)?
2. Half the waste is to be buried above current ground level and thus
be subject to eventual erosion or slump. The Statement mentions
flood diversion structures but does not describe them or indicate
how long they might be expected to last.
3. The proximity of the water table and the bottom of the sump is too
close. This is of utmost concern since the exact elevation of the
water table has not been determined, only estimated.
The EIS states ths~ excavation will not come closer than seven
feet from the water tabl •! (pp. 12, 17), but it is unclear as to
whether this includes ~he new lower sump. It's also unclear as to
,,_
-.-:: 1. ______ . _ _,.
Ms, Chrys Baggett
January 25, 1980
Page 2
how the high water table elevation -,.,.1s predicted. rt appears :hat ~h~ hi;hes:
actual measurement taken from several Feb . 1, 1979 bor in ·1s at t~e site
(306') was added to one-half of the maxir.ium normal c,round·,•;ater fluctuation
in Warren -Co. (11') which gave a high water l evel of 312' (311 1:i' rounded off ).
Evidently this figure (312') was then subtracted from the maximu~ surface
elevation at the dumpsite (343') resu1tin~ in a 31' difference between the
ground level and the high water 1 eve 1. Si nee the study ·.;as conducted
"during the middle portion of maximum seasonal fl uct!.Jatio•1", the water was
presumed to have already risen half as far as it was predicted to go which
resulted in adding half of the fluctuation. If this methodology or a similar
one was utilized in determining the high water level, it wouldn't seem to be
too reliable. In addition, the lowest point on the dump surface, not the
highest point, should probably have been utilized in determining how much
working room would be available in relation to the groundwater table. The
exact calculation utilized in determining the high groundwater level should
be clarified.
4. The plan allows numerous opportunities for human errors in construction:
installing plastic liners and pipes, compacting the clay liner, driving
trucks on top of buried pipes and close to plastic side liners, and close
tolerance surface .grading.
5. The site must not be subject to flooding or have a hydrologic connection
with the groundwater according top. 16 of the Draft EIS "Surface water
discharge is to Richneck Creek ... 40 miles separate the site .discharge
area and the closest raw water intake." If a disruption were to occur,
the PCB material would easily run off into Richneck Creek, and subsequently
to the raw water intake located 40 miles downstream. How will the State
prevent this from ever occurring?
6. This is not an adequate environmental impact >tatement. More emphasis has
been placed on the chronology of events which have occurred and little
or no mention has been made concerning the possible effects which the
proposed PCB landfill could have on the natural environment. Also, by not
exploring all possible environmental effects. the means to mitigate or
eliminate factors which could do harm to the environment have been omitted.
7. Humans should also be considered in ascertaining possible environmental
effects posed by the PCB disposal activity. Will PCB disposal affect
the economy of Warren County through adverse connotations?
8. Reputable sources have disputed the State findings on the availability
of clayey material, further investigation should be made.
9. The express will of the local government concerning PCS disposal should be
given more consideration by the State government.
10. Warren County hired a geologist, Or. Charles L. Mulchi, who took his own
soil samples at the site and reviewed the State's plan. The En vironmental
Impact Statement does not mention him or the questions he raised about clay
type, depth of clay, and groundwater uncertainties. The addition of the 30 mil
plastic liner may have been in part a respo,se to his criticism about lack
of groundwater protection from leachate. ~!e recommended that the State's
proposal be turned down and his paper, A Review of the_Proposal tu Use S~ils
in the Afton Comnunity of Warren County,_~"-l. C. as a Disposal Site for Soils
Ms. Chrys Baggett
January 25, 1980
Page 3
Contaminated with PCB, still remains v.:1;~d for the most ;:-1 rt.
To stop PCB, you must keep it dry. 7nis for-mation becau.5e of the type of
clay and the low proportion of cl 1y :~ other types of soil, especially at
the lower levels, is not naturally waterproof. James Scarboro·Jgh of the
EPA admits (Appendix C) that it ''is not in a 'thick, relatively impermeable
formation such as lara'=-area ciav c~rns' '. t_iners must be formed from earth
dug from the surface. -')f ei9ht s:i~ipl<?s t ,:;:2n from the top layers by th~
ij. C. Dept. of Transportation, only three showed 50 percent or more clay
(Appendix B}. The percent went down as they went deeper. To quote Dr.
Mulchi, (pp. 4-5 Mulchi), "There are very small amounts of clay present
deep within the soils at the site which would serve to trap escapirg
materials in future years. The r-elativel .·1 high sand content in these
lower regions _suggest that moisture '10vement below the burial layer ·.~ould be
very rapid and that there could be a risk of groundwater contaminations
resulting from leakage from the burial site." •
"A dependence on such means as artificial plastic liners and barriers of
soil less than 50 percent clay may not give the safeguards necessary for
storage of large quantities of PCB material. Plastic liners may ultimately
deteriorate due ta actions of natural forces op~rating within the soil.
This may result in moisture movement through the disposal site which in
turn will move toxic materials. The low absorptive capacity of the kaolenite
clay combined with the low moisture retention properties of the clays may
not prevent the system from leakage of chemical waste at some future date."
~:sp
Sincerely,
Roy M. Willi ford
Planning Director
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SIERRA CLUB~ Joseph LeConte Chapter
... To r.rflorr, ,.,.io1 ,nw -,rrt"11t' t/11' ,w,ti<,,.' 1 f orefts, w•tn-1, wiuuif I ....i wiJ,,,i,,._,, · · •
Burley Mitchell, Secretary
Department of Crime Control
& Public Safety
Raleigh, NC 27611
l.5 FabruarJ 1980
Subject, Removal and DisPOsal of Soils Cont&lllinated With PCB's Along
Highway Shoulders In North Carolina -Draft E)avirorunental
!~pact Statement
!')ear Secretary Mitchell 1
Thank you for allowing us to submit our comments for your consideration
even thou~ it is past. your deadline. As ve stated in our January letter,
we needed this extra tillle to compile our statement.
We previously commented on the Draft Negative Declaration in January 1979,
Altho~h many of the isaues ve raised have been addressed., 111.&ny subject.s remain
that must be evaluated. before the Sierra Club can assess the proposed action.
Sierra Club policy disapproves of landfilling of toxic or hazardous
materials in most cases. In this case, we agree vith the detennination o! the
Administrator of the ~vironmental Protection Agency, Douglas Costle, 1n his
letter of 4 June 1979 to Gowrnor Hunt, •Any huzu.n exposure to PCB's is of
oonoem because ot what is known about thia chemical." Disposal ot the
contudn&ted soil 1n a chemical vaate l.Andfill that c0111pl1es with the following
recomendations vill provide an interim method tor protecting public s~ety
and health and tor preserrtng our natural environment. w'e expect the state
to remove the soil from the landfill and destroy the PCB's vhen an alternative
technology is developed.
Recommendations required for the construction and operation and tor the
long tena management ot the proposed chemical vaste land!llls
1. Citizens Monitoring Committee
A cCllllittee of local citizens JIUSt be fonned to monitor the construction,
operation and long term management ot the facility. Members ot the committee
11ust include local otticials, adjacent land owners, and leaders ot the ooZllllluni ty
including those vho NY' be opposed to the proposed action. This "111 allov
the affected eonmrunit7 to keep close vatch on all activities concerning this
project. It lllU3t be 1n attendance during all actiVitiu, especially the
monito~ after closure ot the landfill •
.. 2. Disclosure
All operations and monitoring cuta must be announced to the local and
statewide news l!l«ii• on a regular and continuing basis. This will keep the
public infonned ot the our?'9nt status whether good or bad and will provide
aceoUl'ltabllity ot the responsible state officials.
J. Leach~te T:--:,o.t::ient
T:""8at~nt of leachate has been discussed in the D~IS. However, no
method or dispos&l. of the treatment residue of leachate after landfill
olosure has been ciiscribed. An appoved EPA method ot disposal must be
provided for this residue.
fh" deoontaminat.ed 9.ffluent of' the leachate must be tastG<l before
it ia d~harged. This efnuent mu1t not be released until laboratory
:analysis has con!i.med that the PCB's have been ?"l'!moverl. The DEIS must
describe the m&Mer in which the effluent \/ill be discharged.
~. Restriction For Use or Site
All possible legal and adminiatrative aotions au.st be taken to
insure the one time use ot this site for the di.tpoaal of the PCB oont&minated
soil as desori.bed in the DEIS. The at'feoted c0B11Unit7 needs every
guarrantee that the proposed action u the onl.7 use enr tor the site.
Th• deed for the larx:! must contain a covenant prohibiting the use
or t.~e entire parcel for any other storage, treatment or disposal facility
tor hau.rdous,. ndioaoti .... , or tox:io materials. Arty lease !or other
aoti'rl.ties suoh as taniling must contain these reet.rictions.
The gonmor of the state muat issue an executive order speci!,-ing
the restriotions for this site. Additionally, the &d.adnistration .mu.at
seek special leg13lation from the 1980 session of the General Assensbly
to restrict the use ot the site to the prop:md action.
The state lllUst include these restrictions in its permit application
request to the Regional Administrator of the EnviroMental Protection .Agency.
The state must assuN the citizens that all the loopholes tor other uses or this sits are eliminated.
5. Groun:ivater Separation
The proposed five (5) foot groundwater separation is insu!'!'icient.
In!o?"!IIAtion in the DEIS shows that a 111u0h greater separation is possible.
Pa11;e 17, paragraph 1 gives the aximum axcavation depth as 24 feet. Thus, by
removing the thiclcness of the liner and leachate collection systems, the
larwdfill vill have a useable depth ot U feet. Allovi.ng for topographic
variation, a useable depth of 15 feet would mean that the entire 401>000
cubio yards ot oont&minated ... teri&l could be stored 1n an area o! 1, 7 acres.
By increasing the land!lll surface area to 2.9 acres (aa is shown in
the N.C. Department o! Tra.nspCl'tation boring (soils) stud;y 1n the DEIS), the
IIMLXim~xcavation depth would only be 14 feet -10 fNt shallover than
proposed 1n th• DEIS. This increase in al"'9a vill inoreaH the groU1'¥iwater
separation to 15 feet -more than double the proposed separation.
In the interest o! maintaining environmental protection, the final design
for the larx:!!1.ll must provide greater groundwater separation than proposed.
This oan be achieved at little or no increased cost add.will provide a
greater measure ot security.
2
6. Lam fill Sidewalls
According to F1guN 5, Section I. D., the landfill will not have &
contiguous clay liners the design fails to provide & unifo?'!II container
of equal specifications for the bottOffl, sidea and top, The DEIS pro·.rirles no
infol"Tll&tion to show that latterally moving KroW'lCiwater or that anir..ala vill
not be a problem. In addition, there is no Wol"'!ll,il.ticn •bout t~~ long tem
integrity of the artificial liner.
The entire landfill must be encased in a clay liner that is conti?~O~~
from the cap to the bottom including the sidewalls. This cor.ti;:.:o:.:s liner
must be constructed to the specifications that are pror:,osed f .-:ir t::e '!::lottc,i
in the DEIS.
?. Landfill Cap
'T'he proposed cap design is insui'ficient to provide for 'l'egetal erosion
control and to prevent future penetration by surface water. Th• specifications
on page 12 (10 lllil artUicial liner, 1.5 foot clay liner and 6 1..~ches of topsoil
,:raded to a ~ slope) fail to provide an adequate root zone fr,r m&intaining
V9P,etat1on without an irri~ation s~stem. Any vegetation established in such
a thin zone for roots will be very susoeptable to drought, Site mainten&nce
must include fertilization &nd Nseeding of the vegetal cover.
Moreover, the cap is not thick enough to allow for pedogenetic (soil
forming) processes. The design provides for an al.most inpenetrable bottoms
it must provide a no less penetrable cap. The chemical and physical forces that
could penetrate the la.nd!'ill are !llost intense at the ground sur!ace. It is
concievable that normal climatic events could easily penetrate the 2 !'eet of
topsoil and olay liner within a century. This scenario is ».de 111ore probable
if a S111All area of vagetat1on dies and ero•ion occurs.
The cap design m~t specify 2 feet of root zone consistant with agronomic
concepts and the same clay liner plus artificial liner requirements as proposed
for the bottOlll in t!'lt DEIS. An agronomist-soil scientist must supervise all
surficial earth disturbances, rewgetation and cap construction.
9, Revised Draft Envira.nental !Mp&ct Statement
We request that a revised DJcrS be prepared which incorporates our
rt1tcol'lll!lendati0ns. This revised document will allov all agencies and the public
to assess submitted comments on th• proposed action.
Adoption ot our recommendations will assist in providing greater protection
· of the public and the environment from the har.ards ot PCB cont&ndn&tion. Thank
you for considering these coDlftent••
Sincerely,
\JJ~4vr'-k .~:fit-) n
Wil.l1ul H. Doucette, Jr. \J
Hazardous Waste Committee
~'t_ vi;; 'lt .(/4_/"
David w. Levy J
Conservation Chail'5n
1428 Sedwick a:i.
Durham, NC 2771J
( 919) _544-1187
J