NCD980602163_19810701_Warren County PCB Landfill_SERB C_Exhibit C - Affidavit of William Meyer in Support of State Defendants' Motion for Summary Judgment-OCR

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
RALEIGH DIVISION
CIVIL ACTION NO. 79-560-CIV-5
':•J,T-1..REN COUNTY r
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EXHIBIT C
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AF?IDA.VIT Or, WILLIAM MEYFR IN SUPPORT
OF STATE DEFENDANTS MOTION FOR
SU:V1MARY JUDGMENT ON SIXTH CAUSE OF'
ACTION ---------------------ct al.
I, WILLF1I-l HEYER, b2ing first duly sworn depose and say:
l. In~ employed by the North Carolina Department of
Human Resources, Solid and Hazardous Waste Management Branch ,
as an environmen~al engineer. I have been in this position
s:;.nce M.a.y, 197C. Tam the person responsible for technical
assistance fo~ ~he State 's Solid and Hazardous Waste Manage-
;oent Program .
2 . I r2~eived a request from W. A . Raney, Jr., in
late Septembe~ =~ early October, 1980 to address the feasibility,
cost, and desi:c~biiity of treating the soil liner with
tetrasodium pyr0phosphate (TSP?) to be applied at a rate of
. ? five (5) pounds ?er foot-. I was also asked to dete~mine
the feasibilit~, cost and desirability of constructing a twelve
inch soil lin2:c .,)::: one part blended montn1::xillinite clay to
3. As a ~ssult of that request I contacted a supplier
of TSPP to determi~e cost and feasibility of treating the soil
liner ~ith TSP?. i also discussed the costs, feasibility and
practicability ~t such treatment with two soil engineering
I est.irn:'. ::ec"i :::1e cost and desirability of treating the
soil liner with ~SP2 and provided the estimate to W. A . Raney,
Jr ., jn a memo 6~ted October 8, 1980. The portion of that
memo which cc~ta~~ the estimate is attached hereto as Attach-
The s~:~;cs~ion of TSPP treatment was discussed by the
co:n.mittec::: prepc,: .. :·:_," :.:.ii2 ~•'EIS '::i_·i::.h the Secretary of Crime Control
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and Public Safety and was rejected as being unnecessary in
view of the adequacy of the existing design and the considerable
additional expense involved with TSPP treatment .
4 . As a result of the request from W. A. Raney , Jr.,
I also calculated the volume of nontrrorillinite clay needed
for construct{on of the suggested blended 12 inch montmorillinite/
B-hor izon liner and obtained estimates of the cost of the
necessary clay. I calculated the cost of construction of the
12 inch liner and supplied that to W. A. Raney , Jr . in a memo
dated October 8 , 1980 . The portion of that memo which con-
tains the estimate is attached hereto as Attachment I. The
suggestion of the 12 inch montrrorillinite /B-horizon liner
was discussed by the committee preparing the FEIS with the
Secretary of Crime Control and Public Safety and was rejected
as being an unnecessary expense in view of the adequacy of the
proposed soil liner and plastic liner .
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----if / l l . -//7 J_ / (/ V.1{,(/ . .ttV1 /// ,l,{/ /C/
William Meyer
Sworn and subscribed to before me
pr C\_l._,_ this the _1 __ day of ~, 1981 .
l_-/1 Lt e d ~
\~-. Notary Public
My Commission Expj_res :~
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