NCD980602163_19800129_Warren County PCB Landfill_SERB C_Comment of Warren County on Draft Environmental Impact Statement-OCR

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COMMENTS OF \lARREN COUNTY ON
DR.J\FT ENVIRONME'l':TAL H lPP,C':2 STATErffNT
OF THE STATE OF NORTH CAROLI NA
OF REMOVAL AND DISPOSAL OF SOILS
CONTNHNATF.D ~H'l'P PCI3 ' f
ALONG HIGHWJ\.Y SHOULDERS n: :'.('J P.TE CA POLI:~l~
DATE: 1/29/80
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Warren County offers the followin<1 conrnents o n the flra f t
Environmental Impact Statement prepared by the State of r:orth
Carolina in compliance with the North Carolina Environ~ental
Policy Act on removal and disposal of soils contaminated ~ith
PCB's along highway shoulders in North Carolina:
1. SITE SFLFrTION
The technical requirements for n che~ical waste land~ill
to be used for the storage of PCD's according to EP A regul2tio ns
stated in 40 C.F.R. Sec. 761.4l(b ) are as follo~s: (1) ~o ils.
'I'he lanc1f ill site shall be loca tec'l i!: t r.i cJ:, relc1tive J y iP':,e r-
rreable forriations such as large-area cl a.y pans. \•'here U :i s i s
not possible, the soil shall have a hi g h clRy an~ silt conten t
and the following parameters:
(i) In-place soil thicl:ness, .1 f"eet or c o~p acterl s o il
liner thickness, 3 feet;
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(ii) Perr,eability (cr.1/sec), ( OJ. ,, 10 ;
(iii) Percent soil passing no. 200 sieve,) 10;
(iv) Liquid limit,~ 3 □;
(v) Plasticity index,') 15;
(v i) !'>rtificic1l liner thid:ne s s, ') :.') nil.
a. Laboratorv Procedures a~ll r:esults .
The laboratory test results pre s e nted in t h(-~ r·nvi r onn r-.:ntal
Impact StateJT1ent, l\ppendix B , fai1 to satisfy the re<1 uir0nc nt s
statea in paragraph 716.'11 (1:,). ':r'he t est r e snl ts ,.1 e re too fc':.'
in n ur.1ber for the critic a J soj 1 c hi:: r.3ct<•r ist i c s o f p e rrre2r·-i 1 i ty ,
liquid limit a n d plasticity index. Specifically , there Hf:•rc
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inadequate sample numbers anc replic2tions of s an,p les t o d eter-
mine the mean and standard deviations f o r these Y.ey soil para -
meters both with depth and across the site in genera l. Anyone
familiar with the field of soil science is fully a~are that
soils are highly variable in their c hemical and physical p r c -
perties and there is likewise varia tion ass ocia t ed with t he
procedures selected to estimate the riagnitud e o f t h e v a r i o11s scil
parameters, even among "standard meth o ds ''. ~her e a r e t wo p r o -
cedures listed to measure soil permeability in t he 197 4 e~ition
of Earth Manua l -A Water Resources Technica l Publica tio n , 2nd
Edition, U. S. Department of Interio r. One p rocedur e outli nes a
"constant head " approach to measure perf.'1eabili t y in a c oripactec~
soil; ano ther procedure outline s a "f a lling head '' appr oach to
e stima te the p err.ieabili t y of a cor1p a c ted s o il. ':'"'he "co!lstant
h ead 11 appr oach is b y f a r the nor e a ccu r c1 te o f t he t wo . Th e "f,1 l J -
ing he ad 11 appr oach requires one t o '' i nte r pol ab)" va 1 ues ~re,· 2
g r aph in o r d e r t o comple t e t he ca l cul~ti o n s .
e x pe rience that s uch "interpo]_ations " oft en l ead t o lars;E:!1-f:n-c,)-
c ompon ents . The State unfo.:i::-tuna tely has c hosen to use tLf_,
"falling head" JT1ethod for this project. Anoth e r najor f~ctur
concerning the test methods used to d e terDine t he pe r me~hilit}'
results was the f a c t that 11 remol de<l" s amples were usec1 in t he
"falling head" method. Such "r emol ding" a ssured a b r eakdo\,·n i n
native soil structure, and insured uniformity o f ~oisture t hroush -
out the sample and the general creation of arti f icial c ond itions
within the sample prior to measurement of the per ~eability .
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. :
Had the sample been compacted as re~oved from the field, i.e.,
just as will be the case during actual soil line r construction,
there is no doubt but what a different and probably far less
acceptable set of values for permeability would have been
obtained. There was no report of permeability values for undis-
turbed samples. It is important to reco9nize and appreciate the
wide variability that is faun~ in soils for these important
paran:eters and to likewise unclerstand that one c A.n often b ias
the results by the creation of artificial cond itions within the
samples -even using "standard methods". In c onclusion, the per-
meability clr1ta presented in the iITpact stc:ter•pnt g ives no evidence>
of the "true" permeability of the soil under a ct ua ] f i elrl cor:--
pacted conditions or the variation which nost l i!:e ly exists vith
depth or across the site in this critical par a~eter .
b. Soils Map of Site.
\'ilith the lir.1i ted soils information providcc in the irrpc:.c t
report, it would be a physical irnpossihility to c onstruct a Per
waste chemical landfill at the Warren County site anrl be 100 ~
certain that the soil liner meets the requirenents statcc1 j~
paragraph 761.4l(b). In addition to the lack of definitive
test results regarding permeability, no detaile~ sub surface rap
of the various soil layers found at the site has been prepar~~-
This would have involved a systematic physical identification
and characterization of the various subsurface horizons t o cleter-
mine which layers meet or exceed the stateo reguireJT\ents 'Y the
EPA for liner construction. The limited nurrber of test t.orinss
at the site were "bulk sampled" with depth rathe r tha n a t (-inch
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intervals. Mechanical analysis of the sa~ples vith aepth i nto
sand, silt and clay fractions would allow t he construction of
a detailed subsurface map indentifying those layers meeting
the minimum requirements. Since the soil liner will be con-
structed from materials existing at the site , the present i~p act
statements fail to identify the exact soil layers which rlo
meet the requirements. 'l'he impact stater-.1ent suggests that
the construction engineer will "stocLpilc " lc1yers of soils
which visually appear to neet the nece ssary requirements anrl tha t
these materials will be blended in a nanner to assure the r e -
quiremen ts are met . No feasible metl:ocl is a vu i l abl c for (let er-
mining the adequacy of the blend in9 operation . It cannot be
accepted that the hlende:n product \,'i ll J-,e of st:ch a r.ualir:y ,.,s
to satisfy t he ~inimurn liquid linit 2nrl plasticity in~~x speci-
f i e d by the f P ]\ re CJ u 1 a ti on s , \•: h (~ n t he' he ,; t s CJ i J s i' t t )w :: i t c
are only rr,ar<J ina l ly within these 1 ini ts. -:•his rrocec':urc · -'l:· h :
adequate for building a road or dam, hut is ~uch t0O uns2f0 or
risky for the building of a chcnical waste lan2f ill on ~a r 9 inal
soils.
c. Clay Content and Definition~.
The critical features for retainin<J che~icc1ls in rlace v,uul c1
be the clay con tent in the soi ls usec1 in the soi 1 1 iner. Clays
are defined by both the International Society of Soil Ecience
and U.S.D.A. classifications as solid particles of soil less
than or equal to 0.002 r..l:'. in size (Soil ~urvev 1\2nuc1l, r·.s.-l .J\ ..
Eandbook, No . 1 8 , August 1951, p . 208). '.T'hr~ in-pact stc1tc ·'.e r t.
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does not identify the quantities of solids below O.O C5 ~Din
size, which are fine silts. Since 761.4l(b) states that "the
landfill site shall be located in thick, relatively imperP.'eable
formations such as large-area clay pans [and] [w] here this i s
not possible, the soil shall have hi9h clay and silt con-
tents .•. ", it is paramount that these zones of clay enr i ch-
ment be identified prior to construction.
The cl~y content is the controJlins factor 1n scver2J
critical soil parameters includ i ng liquid l i ~it , p l asticity
index, chemical exchange ca pactiy (CFC) 2nd surf~ce area .
Accordinq to Baver (S oil Physics, ':'hinl r.cli tion, ,Tohn
h'iley and Son), "~he Atterberg constants are ,,,.,,irlely l~scr1 in
highway construction. The plasticity nur'Ler or incex in . n~;in ei:~r-
ing terms, is e mp loyed as an "emp irical measur e" of the suita-
bility of the clay binder ~aterial in stabilized soil ni~ture ''.
The P.N. (plasticity nu~ber ) = n.6C (cl ay content) -12 for
0.005 rnm particles and P.!,:. = 0.G6C -10 for o.noJ 1:..rn pacicles .
Thus, with these relationships, thi s illustrates t hat the suil
liner has to be constructed ~ith soil which always exceeds AS~
content of 0.005 rr.r.1 material or 3 8Z, of 0.001 P.'n material. Frcm
material supplied by the Soil & l laterial Engineers, Inc., M~rch
5, 1979, report, the soils in the O' -2' ~arginally meet the
0.001 and 0.005 mm soil requirements for plasticity index , but
a sizable portion of the O' -4' and O' -6 ' would not neet
the requirements. However, soils, such as that a t the 1'larr~n
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County site, which contain a ppreciahle quantities of mica
may cause the plasticity index values to be higher than would
be expected fro~ the clay contents. These differences are
attributed to a greater surface and increased c on tact in the
case of plate-shaped particles. The r efore , the presence of
mica in the Warren County s oiJs nay have r csul tec2 in the hic;J-:er
plasticity index values than shoulrl ~ctua lly have teen ~c•asurc~
based on the clay s content at the site. !\gain , the lirriit, d
nul"1ber of samp les fro~ the various s o il horizons prevent any
intelligent assessment of the nean plasti city index va lues
or the variation in plasticity index values at the site .
results would strongly suggest that t he aGount of soil which
would likely meet the requireme nts for a soil liner v:ould be
limited to the upper two feet of the soil. Therefore , the calcu-
lations in the amount of soils a t the site v.'hich v1ould be~ r,uitnl ,lc~
for liner construction l"1ay be grossly ove r estir~a ted. P i tr.out
more detailed snbsurface rrapping anc~ IT'echanical 2.nalysis d~,·-rac-
terization, it is d ifficult t o esti~ate the volume of soi~
material which would safely rect the soil Jiner speci ficatio~s .
It is of paramount ir.portance t hat t he n. C1n2 r.~P' size for
c]uys be the nccc•ptec'l st.7nc'L,rrl for 7uclc-;in~1 the ;icn~r•tuhiJ it 'i
of soils for establishment of PCB waste chen i cal lun~fills .
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Soil 0. 005 nun in size would hc1.ve a s u r f ace area for 1 en of
2
soil equal to 6,283.2 cm
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whereas a soil 0.002 ~~ in size would
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have 15,708 cm surface area within a l er~ sample or over t\-.·ic0c
the surface area for retaining the PCB chemica l. Likewise, the
chemical exchange capacity (C EC ) for 0.005 rn~ soil would h e
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about 11 milliequivalents (~1.F.) per 100 gn of soil. The c heni-
cal exchange capacity (CEC) for 0.002 rr.rn soil wculd be about
19 M.E. per 100 gr. or over 1.5 X hi gher than the 0.005 rnn
soil (Baver, Soil Physics, cited above). These two important
parameters, related to clay content, affect the retention of
chemical substances in soils. It is vital that the soil liner
be constructed of soils "high in clay" to r educe the risk of
chemical migration fro~ the site. The very thin lay er of
clay enriched soil at the ~arren County site ~oulrl appeRr in-
adequate in quantity to safely construct the s oi l liner. 'T he
reference of "nixing of s o ils" within t h e initial n ' -S '~. in
the narch 15, 19 79, letter f :r o r1 Soi 1 & I'.a ter i2 l f nc; ineed nr,,
Inc., to 11r . ._ierr:-/ Perkins appec"lrs n n oversir0plific.:it i c,n in
their estir.,ate of the volune of "hiqh cl2y" soil 2va ilal>J e for
soil liner construction.
d. Clay Tyne vs. Plasticity Inc3ex and Li0uid Lini t.
One of the r,ost disturbing and trouh ling aspects of trie
site selection process was the lacr:. of interest and reg arc: by
both the State of North Carolina and FPA a dninistrators in
information concerning the lack of chenical activity an d sur-
face area of the type of clay foun d at the TTarren County site.
The limited quantities of clay found at the t 7arren County site
appear to be predominately kaolinite clay. As shown in Figure
10, p. 28, Earth Manual (attached), soils with sandy clay, s~a ll
amounts of clay, and kaolin clay have very low p lasticity index
and liquid li~its, both key para~eters as noted by EP~
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regulations 761. 41 (b) (1). Kuolin clay is 1:1 type crystal
lattice material with very low che~ica l exchange capacity
(CEC) and low surface areas for chemical adsorption of
toxic substances. On the other hand, clays with 2:1 typE
crystal lattice have much larger s urface areas , higher
chemical exchange capacities, and much higher plasticity index
and liquid limits. These clays are conronly referred to as
"Montmorillonite" clay or "Dentonite" c lay . Fron Figure 10,
"I-1ontmorillonite" clay, identified by nul""ber 10, had plasti -
city indexes which varied fron 55 to 140 and liquid limits
which varied fron 80 to 165. The "!;e nton ite", icJ e ntifiecl by
number 13, had plasticity indexes which varied from 250 t o 560
and liquid limits which varied fron about 300 to 600. On page
35, the impact statement lists the average plasticity in~ex
as 9-21 and the liquid limit a s 36-71 for the ~arren County
site, which is identical to line nunber 4 on Figure 10 listed
for ":kaolin clay formed from. cJecoJT1posed 9 ran i te."
Fro'f:1. Figure 10, it is very evident that th e FP,-, minir:ur: r e -
quirements of plasticity inc'!ex) 15 or liquio liI':',its) 30 , anc1
the position of the Warren County soil --i.e ., s i milar to
nur.1.ber 4 --should be considered as much too weak for the r•ro-
tection of health from PCB. This is especial l y true for t he
soils at the Warren County site since there are a number of
soils in other areas of the state where 2:1 type clays 2re
predominant. From the publication "'!'he Soils of north Carolina ",
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Tech. Bul. No. 155, by w. D. Lee (attached), the key soils
which contain 2:1 type clays are Iredell (II.C.1), White Stor e
(V.C.l), and Creedmoor (V.C.3). These soils are located across
the Piedmont region of North Carolina and can be found in the
areas identi f ied by I M and ~Con the attached rap obtained
from the above listed publication. :L ee estinatcc: these tF0
soil associations --i.e., IM and ,~c --covered soGe 790 ,noo
acres. It would seem logical that t he State of ::orth rarolina
could have located the 10-15 acres needed for 2 rcn lanar 11
somewhere in this 790,000 acres.
published regarding the sites exarninea h y the State prior l o
selecting the Warren County site, it is d ifficult to detvr-
n~ine how TI'.any, i f any, of the a 1 ternc1t i vc s ites wero J oc,t<:c1
within the areas shown on t he attached soils n ap for tlor th
Carolina. Due to the high plasticity ind exes ana high liq ui~
limits for the 2:1 type cl ays , the areas des ignated on the
map are where the State shoula have concentrate~ its initi 2l
efforts for locating a landfill site. ~he site chosen by
the State would qualify as one of the least aesirable sites
from the type and quantity of clay present at th~t location.
From a transportation perspective , spill sites nos . l, 2 ,
3, 4, and 5 are near rec;ions desisn c:te( by t he r,: and \:'C soil3 .
From a health safety perspective, it would be far more ~esira b le
to locate one or more lanc'lf ills for P e n on thf~ 111 or 1•7(' soi] s
than to select the Warren County site ,-:ith soils which ha ve
clays wit~ narginal plasticity index anci liquid limit value s .
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2. GROutm 'i·i'l'-,'l'ER
The impact statement indicates that the base of the
leachate collection system will be a mini~um of 7' above
the water table for the site. The EPA regulations state
that there must be a 50' separa tion; however, this regulation
was waived for the Warren County site. Basea on the previous
discussions regarding the soils at the site, the EPA should
not have been allowed to waive this very iDportant regt1lation.
This is especially true since there appears to be a great
deal of uncertainty just where the "rean hig h water ta:b l e "
for the aren should be placed . l\s sta t ecl in the iTT'pc1ct st.:itc-
ment, the U. S. Geology and Groundwate r Resources s how tl1is
ta.ble to be 4 7' below the s urf 2ce , whereas the ~o i 1 & !'a t er ic: J
Engineers, Inc., suggest the sta tic wa t er t ab l e is 32 ' to 3 7'
below the surface , but is estir.a tec t o vary 5 ' t o 11'. '2'h 0
Soil & naterial Engineers, Inc., assur·.e c: their Fe l...,ruary, }()7?,
samples were at the top of the range because there haa been
a 5 percent above normal rain fal l for soroe time prec ed ing the
sampling. The initial samp les f o r the site taken in Septerl:cr ,
1978, normally the lowest period in the hydrology cycle for
North Carolina, show moist soils at some 20' nnd wet soils at
25'. Thus, the report fails to identify the actual high
groundwater limit therefore, and this determination would be
made after construction begins. Since the plasticity index
and liquid limit of the soil is marginal at best, it is
totally unsound to have such great uncertainty a s to the
location of the wate~ t~ble. Also, the ~PA r egula tions ~irect
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that there must not be a hydrologica l conne ction between
the landfill and the grounclwater . This report fa ils to "prow~"
that no such connection exists at the site. Therefore, to
allow the landfill to be constructed 7' ~ore or less above
a _water table, about which there is great uncertainty as to
its actual location, is greatly to exacerbate an already
risky operation.
3. PCB LANDFILL ~ESIG~
The conceptual plan, Figure 5, f o r the land f ill has several
severe limitations. Perhaps the rr.ost criticul f2 ults i n the
design are the absence of a cl'"y liner alons t he uoper sic:c
walls and t he outsloping of the sifewa lls at a n an9le r ati o
of 3: 1.
the constructio n of a liner b c-:ne ;:,t h the systcr-to r c~o ve t he
water before a hydraulic head is a llowea t o ~evclop wo u ld nro~uce
a site which would retain waste ch0.r icals". This assur:-:p ~ ion
is demonstrably false with respect t o the unlinE.~(1 , o ut sloi c:cJ
upper sidewalls, since at thes e locations the downward n0v0 -
rnent of water would leach PCB's airectly out of tl1e JancJfill .
The other problems with this assu~ption are that chemical s
may escape from the site through the lateral flow of moistJre
and by diffusion both laterally and downward. A clay line r
along the sidewalls of the landfill would reduce the rate of
lateral flow of moisture and waste chemical, but this will not
stop the escape of chemicals from the l andfill site by cli::fusi on
processes, especially if the clay is kaolinite.
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The diffusion process is governed by the laws of therDo-
dynarnics; chemicals will move fron a zone of high chemical
potential to a zone of low chemical potential. The high con-
centration of PCB chemicals inside the landfill would be a
major factor associated with a high cherical potential zo~e
inside the landfill. The absence of PCn outside the landfill
likewise would cause a zone of low chemical potential . Th0
chemicals will move fron the inside to the outsiae of t~e
landfi ll walls even with zero ~oisture fJow . nncc outsi ~e ,
the rate of PC B movement will sreatly increase ~ue to rapi~
moisture flow through the sandy s,1bsoil. nther rajor routes
by which the PCB's can be expecte d to rig rate out of the
landfill include volatilization, uptake by soil microorganisr s ,
transport with water, and possibly plant upta~e. Conta~ination
of the groundw ater will soon f o llow if the landfill is only
7' above the water table (Marshall, The Physical Che~istry and
Mineralogy of Soils, John Piley ana Son, 1964).
The primary method for reducing the rate of cheFical rliffu-
sion will be to provide a thick barrier of clay enriched soil.
The type o f clay is also of critical importance since the
surface areas ?nd chemical exchange capacity (ere) of the cl2y
determines the adsorptive capacity of the clay. Pen noleculcs
adsorbed on the clay particles will tend to diffuse a t a ruch
slower rate, and 2:1 type clay would be far superior to 1 :1
type clay in retaining the PCD molecules.
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The conceptual plan, noted in Figure 5 of the i~pact report,
shows no means for moisture to flow f ror:1 the sand to the lower
leachate collection system. hs shown in Appencix B of the
report, the native soils at the botton of the landfill are
extremely sandy with less tha n 20 ~ clays . Paver (Soil
Physics, p. 111) states that s o ils t hat contain l es s th~n 20~
0 • 0 0 5 mm s i z e cl p art i c 1 es c1 o not ex h i b i t p 12 s t i c i t y . 'Thus ,
these soils below the lanrlf il] would he h iqhly perreal1l e ~n~
move cm,1nw a r c1 rathe r th2.n l aterally ir: t1-:c~ sa.no J 2yc~r .
should be c1 clay soil liner be J rn·.' t h~ l m·.·er ccllccticn ~'./Ste r
to assure collection of the J.e 2 ch~t e .
substantially imp rove the safet y of t l1e lanffill ~es i gn .
4. t~O ISTURE conTROL DU RiiiC-: C0 71S TRUC';'I());.
The Environme ntal Ir.ipa ct St<1tPn1cnt i s very r.on-:-:pccif j c on
how the construction engineers plan to c ontrol rair.fal l a nc 1
excess moisture within the site <1t tte time thR s oi l liner is
being constructed. The Soi 1 end r~a ter i a 1 I.nq ineers , Inc. ,
were very specific that the samples o f soil t hey teste~ for
permeability had to exhibit about 29.G to 3O.7~ mo isture
(optir:i.um moisture contents) in orc3e r to cor-1:-..a ct t o 0 S, of
maximum dry density of 90.2 to 92.0 poun~s per cub ic foot to
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meet the (1.0 X 10 cm/sec perroeability re g ulation. ~hese
consultants mace the further point t h2 t even 95", cor.,pacti on
will not meet the regulatory r cquirerent; the suggest i on is
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~-------~---------------. ------
made that 100% compaction will have to be achieved in order
to assure that the permeability standard will be attained .
Since soils are typically 50% solids and 50% air and water,
and water does not compact, a very low noisture content would
be necessary to maintain the JOO % co~pa ction. ~s a practica l
matter, it will be nearly i ~possibl e to achie ve 1nn 9 c orpacticn
under the fie ld conditions t ha t wi ll be present cu rir.g con -
struction. ~i th an open pit of soGe fiv e acre s in si ze , r ain -
fa 11 on the soi 1 1 i n er rr c1. y l ca c1 t o i n c: c,c c; u;:: t e co!""[-'? c t ion t bi::-t
will cause t ~e liner not t o ~ee t t he r e c u l a tions. Ir. othc 1
words, how d o you "dry out" seve r a l feet of clay enr ich E::,1 s ci]
following s everal days of r~infall, especially in such 2
large area? It would appear that such problem s as IToisture
control should be addressed more specifically in the imp2ct
statement.
5. AL'J'ERNATIVF OF TRJ\NSPORTA'I'ION TO EXI S'I'II-:G
CHEMICAL LnmrILL.
The Draft Environmental Impa ct Statement only me ntions
in passing the alternative of tran~portation to an existinc,
chemical waste landfill. This alternative is dismissccl on t he
basis of "excessive cost" with the e stiMate that the c ost
would be $12,000,000. (pp. 25-26).
Unfortunately, the State does not disclose its basis for
estimating the high cost of disposal at an existing landfi ll.
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From materials prepared by the Environmental Protection ~ge ncy
and filed with the United States District Cou rt for t h e Easte rn
District of North Carolina, it a ppears that the c o st f or tran s-
porting PCB contaminated materi als to a chemical waste landfi ll
site (400 mile average trip) would a~ount to t wo c e n t s p er p o und .
(Support Docume nt for Propo sed Regu latio ns , p . 20 ). Ee c aus e
40,000 cubic yards or approx imately 86 ,40 0,000 pounds r f c on-
taminated material are involved here , the e stima t ed tru 1.s porta -
tion cost would be $1,728,000. The close st adequa te e x i s t-
ing chemical landfill site is near Eme ile , Al abama . This l a n d -
fill has been in operation for some t ime , s o ro unique s i te
expenditures would be involved with oisp osal o f the PC B ~a t e rial
from North Carolina. Accord ing t o information obtained from
the landf ill operator, charges for disposing of the 40,00 0 cubic
yards of PCB materials from ~orth Caro lina woul d he a bout
$5,184,000. Hence, the total cost of transporting t h e ma teria l
to and disposing of it at an existing l a ndfill, apparen tly wou l d
amoun t to $6,912,000, substantially l e ss t han the $12 ,1 00 ,00 0
estimated by the State.
Considering the extre mel y serious safe t y p r obl ems i nvo l v e d
in use of the proposed Warr e n Coun t y s i t e for PCB d ispos a l,
as discussed in this comment, the sign ificant, tut not e x t ra-
ordinarily, greater expense for transporting the PCB materi als
to an existing landfill site outside North Carolina, is e asil y
justified hy the additional protection a f forded to the p ub l ic
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health of our citizens. ~he State has estimated that dispos a l
at the Warren County site would cost $1 ,5 80 ,000. Of thi s
amount, $615,000 represents costs incurred in removal of
the material from road shoulders, and would be incurred re-
gardless of the disposal method chosen. The remaining
$965,000 is specifically related to use of the ~arren County
landfill site. (Draft EnvironMental I~pact Statemen t, p. 9).
Thus, additional costs of $5,947,000 wo uld he incurred if
the material were transported to the disposal site in Al abama .
6. SOC'IJH, A!?D ECONOl·'Ir: r-il'.'1":'EPS .
Section s IV through VI I o f t he i npac t s t a t e n•en t f 2,.i l to
a ddress the major i~pact th i s landfi ll will have on the
coMmun ity in ~hich it wil l be locat~~, the v~Ju~ o f the prnpc!rty
adjacent to the land fill, a nd the extent of t he injury fro~
groundwate r contamination, if and when it occurs .
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