NCD980602163_19811110_Warren County PCB Landfill_SERB C_Re comments on the landfill preliminary plans and specifications-OCR

... ,,_,1EO·H4,..<".r '\:, ft ~ "' z ~s~ ii " % ,~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV ~ e,'-1-,.. ◄t PROI~ NOV 1 0 1981 REF: 4AH-RM 34!5 COURTLAND STREET ATLANTA, GEORGIA 30365 Mr. o. w. Strickland, Director Solid & Hazardous Waste Management Branch Department of Human Resources P.O. Box 2091 Raleigh, North Carolina 27602 Dear Mr. Strickland: ~Jc:Eivta. f~ " rff ~. ,\ i NOV 12 1981 ~ 1. ,1 i-' .... ~ ~ ~a ~ U'J' ~~ ~AsTE ~~~. On March 31, 1981, EPA responded to your request for connnents on the preliminary plans and specifications for the proi:osed chemical waste landfill in Warren County. Several weeks ago we received the consulting firm's responses to our comments. We wish to summarize the adequacy of these responses: (a) Placement of sump; adequate. (b) Penneability of liner; adequate. (c) Slope of pit; adequate. (d) Vandal protection; adequate, provided the area is routinely patrolled ( this should be docwnented in the post closure plan) • (e) Silt pond contingency; inadequate. Region IV believes that if PCB is found at all, it will be found in the sediment rather than in the water layer. Consequently, the sediment should be sanpled prior to close out in a manner which will provide a representative sample; the sediment should be analyzed and ham.led in accordance with 40 CFR 761. If the sediment shows contamination, the water layer and liner should be handled in accordance with 40 CFR 761, unless it can be denonstrated that the material is not subject to regulation um.er 40 CFR 761. ( f) Lining of holding pond area; adequate, provided the consultant furnishes the following information with regard to the construction of the liner: (1) Assurance that no heavy equipment will enter the silt pond area during the operating life of the unit. (2) Assurance that the operating life of the unit will not exceed the capacity of the one foot liner to prevent leakage.
___,.,, . ,,, . .... -2-(3) Quality control during construction will be excercised such that the liner minimtnn thickness will be one foot, and rnaximtnn permeability will be 1 X 10-7 cm/sec. (g) location of additional monitoring well; adequate, provided it is designed and located in a manner which will intercept southward groundwater movement. Boring data should be provided in the final report to verify the location of this well. (h) Grouting of annular space: adequate in part. The connnent regarding seasonal fluctuation of groundwater elevation has not been adquately addressed. In the latest transmittal, we did not receive a copy of the post closure care program, which we requested in our March 31, 1981 letter. Therefore, we are assuming that this plan will be suhnitted with the final plans and specifications at some point in the future. If we can be of further assistance to you, do not hesitate to contact me at [phone]. Sincerely yours, l, James H. Scarbrough, Chief Residuals Management Branch -;/