NCD980602163_19820401_Warren County PCB Landfill_SERB C_Cooperative Agreement Between US-EPA and the State of NC for Construction of PCB Landfill and Cleanup of Contaminated Soil-OCR

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COOPERATIVE AGREEMENT BETWEEN
THE U.S. ENVIRONMENTAL PROTECTION AGE NCY
AND THE STATE Of NORTH CAROttNA
FOR
THE CONSTRUCTION OF PCB LANI)fILL
& THE CLEAN 1l?JP OF PCB CONTAM INATED SOIL _.,. . l • ~ ;
ALONG N. C. ROADWAYS
Ap r il 1982
:· i
SECRETARY N. C. DEPARTMENT
OF CRIME CONTROL &
PUBLIC SAFETY
Hernan Clark
ASSISTANT SECRETARY
David Kelly
Table of Contents
Part I• GENERAL ADMINISTRATIVE INFORMATION
A. Purpose of Project 1
B. Lead Agency 2
c. Summary of Budget Information 3
D. State Assurances 4
E. Contract Services 5
F. EPA Forms & Project Approval Information 8
G. Special Conditions 15
H. Signatures 17
Part II. STATEMENT OF WORK PROGRAM
A. Project Description 19
B. Background Information 29
c. Remedial Response Plan 34
D. Remedial Response Alternatives 48
E. Preferred Alternative 50
F. Project Management System 54
G. Project Safety Plan 55
H. Work Plan 56
Part I. GENERAL ADMINISTRATIVE INFORMATION
A. Purpose of Project
The State of North Carolina proposes to remove and dispose
of approximately 40,000 cubic yards of PCB (polychlorinated bipheny l )
contaminated soil. The PCB contaminated soil is the result of deliberate
discharges from a passing truck of approximately 30,000-35,000 gallons of
liquid waste material on to the roadway shoulders of North Carolina's
highways. The discharge of this industrial waste material containing
PCBs have been identified along approximately 210 shoulder miles of
roadways located in fourteen central and eastern piedmont counties of
the State.
The proposed action involves the mechanical removal of the PCB
contaminated soil from the roadway shoulders and transporting of the
PCB contaminated soil to a disposal site for permanent storage. The
disposal site for containment of the PCB contaminated soil will be
constructed according to Environmental Protection Agency rules and
regulations governing the removal and disposal of PCBs. The disposal
site is located in Warren County approximately four miles south of
Warrenton.
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B. Lead Agency
The State has requested and EPA has agreed that the lead
project role should be taken by the State.
By the transmittal letter Governor James B. Hunt has designated
the N.C. Department of Crime Control and Public Safety as lead
agency for this project.
The Department of Crime Control has authority to enter into
agreements with federal agencies.
The project officer for N.C. is:
Special Assistant to the Secretary
N.C. Department of Crime Control & Public Safety
In accordance with PL 96-510 and by Executive order No. 12316,
dated August 16, 1981, the project officer for the U.S. Environmental
Agency is:
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c. Summary of Budget Information
The estimated costs for the total remedial project is estimated to be:
1.
2.
3.
4.
5.
6.
7.
Community Relations
Landfill Construction & Engineering
Sampling and Analysis
(Pre and Post)
Landfi 11 Road Construction,
Removal, Transportation, and
Depostion of Soil
Shoulder Reconstruction
Landfil 1 Monitoring
State Project Cost incurred
between January 1, 1978 and
December 11, 1980
EPA SHARE (90%)
STATE SHARE (10%)
TOTAL COST
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$ 20,700
450,000
37,355
1,240,000
800,000
20,000
285,339
2,568,055
285,339
$2,853,394
D. State Assurance
1. Cost Sharing -Governor James B. Hunt has expressed his
interest to enter into a cooperative agreement with EPA in a letter
dated December 30, 1981 to the Regional Administrator of EPA, Region
IV -Mr. Charles R. Jeter. Governor Hunt's letter follows: North
Carolina will share 10% of project costs through project expenses
incurred during period January 1, 1978 and December 11, 1980.
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STATE OF NORTH CA.ROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27611
JAMES 8 . HUNT, JR.
GOVERNOR January 15, 1981
Dear Mr. Cook:
It is my information that you will be in charge of the Superfund Office,
and I am writing to inform you and your Agency of North Carolina's top
priority for consideration under the recently pas ~ed Hazardous Spills
Cleanup Legislation (P.L. 96-510}. ·
North Carolina has approximately 210 miles of highway shoulder which
has been used as an illegal dump site for transfO!rmer oil containing
high concentrations of PCBs. The cleanup of this hazardous spill .is with-
out doubt our number ·one priority and I would appreciate your adding
this to your list and·indicating to the appropriate officials at EPA
my personal concern in this matter.
I am enclosing a copy of our Environmental Impact Statement addressing
the problem in more detail. Any additional information you may need
can be obtained from Burley B. Mitchell, Jr., Secretary of the Depart-
ment of Crime Control and Public Safety, Post Office Box 27687, Raleigh,
North Carolina 27611.
f1>' wannest personal regards.
Mr. Mike Cook
Acting Deputy Assistant Administrator
Office of Hazardous Emergency Response
United States Environmental Protection Agency
WH 546, 201 M Street, Southwest
Washington, D.C. 20460
cc: Burley B. Mitchell, Jr., Secretary
Enclosure
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JAMES 8 . HUNT, .JR.
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27611
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GO·✓ERNOR Dece mber 30, 1981
Dear Ms. Gorsuch:
Your agency has been involved with the State of North
Carolina in addressing the problem of the PCB Roadside
Waste Sit~s. These sites have been ra~ked as North
Carolina's highest priority for funding under the Com-
prehensive Environmental Response Compe nsation and
Liability Act of 1980 (CERCLA).
Personnel from the involved State agencies and the EPA
regional office in Atlanta have been wortinq together t o
develop a sampling program that, wh0n combined with in-
formation previously generated by the State agencies,
will provide the information necessary to cnQblc funding
of the cleanup of these sites under CERCLA.
Please be advised that the State of North Carolina is
committed to such a sampling program and is prepared to
negotiate a cooperative agreement providing the assurances
required in Section 104 (c) (3) of CERCLA. I understand
that the State would have to assure payment of ten percent
of the cost of the remedial action in accordance with
Section 104 (c) (3) (C) (i) of CERCLA and that this could mean
as much as $250,000 -$300,000 in in-kind services and
cash outlays. Consequently, I am prepared to enter into
a cooperative agreement with the U.S. Environmental Pro-
tection Agency to implement any remedial actions that
may be necessary to complete the clean-up of these sites.
I will appreciate your giving this matter your immediate
attention.
My best personal regards.
Ms. Anne Gorsuch, Administrat9r
U.S. Environmental Protection Ag0ncy
Washington, D.· C. 20460
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ASSURANCES
The Applicant hereby agrees and certifies that he will comply with the regulations, policies, guidelines, and requirements
including 0MB Circular No. A-95, A-102 and FMC 74•4, as they relate to the application, acceptance and use of Federal
funds for this Federally assisted project Also the Applicant agrees and certifies with respect to the gra,:it that:
1. II possesses legal authority to apply for the grant; that
a resolution, motion or similar action has been duly
adopted or passed as an official act of lhe applicanr s
governing body, authorizing the filing of the applica-
tion, including ·au understandings and assurances
contaiMd thet~n. and directing and authorizing the
person identified as !hit official reprss~nlati-,e of the
applicant to act in connection with :he application and
to provide such additional information as may be
required.
2. It will comply with Title VI of the Civil Rights Act of 1964
(P.L 88-352) and In accordance with Title VI of that
· Act, no person In the United States shall, on the ground
of race, color. or nation origin. be exduded from
participation in, be denied the benefits of, or be
otherwise subjected to discrimination under any pro-
gram or activity for which the applicant receives
Federal financial assistance and will immediately take
any measures necessary lo effectuate this agreement.
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It will comply with Tille VI of the Civil Rights Act of 1964
(42 USC 2000d) prohibiting employment discrimina-
tion where (1) the primary source of a grant is to
~-• provide employment or (2) discriminatory employment
practices will result in unequal treatment of persons
_-; who are or should be benefiting from the grant-aided
activity.
4. It will comply with requirements of the provisions of the
Uniform Relocation Assistance and Real Property
Acquisitions Act of 1970 (P .L 91-646) which provides
for fair and equitable treatment of persons displaced
as a result of Federal and federally assisted programs.
5. It will comply with the provisions of the Hatch Act which
limit the political activity of employees.
6. It will comply with the minimum wage and maximum
hours provisions of the Federal Fair Labor !;tandards
Act. as they apply to employees of institutions of higher
education, hospitals. other non-profit organizations,
and to employees of State and local governments who
are not employed in integral operations In areas of
traditional governmental functions.
7. It wiU establish safeguards to prohibit employees from
using their positions for a purpose that is or gives the
appearance of being motivated by a desire for private
gain for themselves or others. particularly those with
whom they have family. busine». or other ties.
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8. It will give t'1e grantor agency and the Comptroller
General through any authorized representative the
access lo and the right to examine all records, books,
papers. or documents related to the granL
9. It will comply with all requirements imposed by the ,
Federal sra:itor agency concerning s~ecial require-
ments of law, program requirements, and other ad-
ministrative requirements. .,
10. It will insure that the facilities under its ownership.
lease or supervision which shall be utilized in the
accomplishment of the project are not listed on the
Environmental Protection Agency's (EPA) list of Violat-
ing Facilities and that it will notify the Federal grantor
agency of the receipt of any communication from the
Director of tli\e EPA Olfice of Federal Activities indicat-
ing that a facility to be used in the project is under
consideration for listing by the EPA.
11. It will comply with the flood insurance purchase .•.•
requirements of Section 102(a) of the Flood Disaster
Protection Act of 1973, Public Law 93·234, 87 S!aL
975, approved December 31, 1976. Section 102(a)
requires, on and after March 2, 1975, the purchase of
flood insurance in communities where such insurance
is available as a condition for the receipt of any Federal
financial assistance for construction or acquisition
purposes for use in any area that has been identified
by the Secretary of the Department of Housing and
Urban Development as an area having special flood
,hazards. •
12. It will comply with all applicable requiremenls of
Section 13 of the Clean Water Act Amendments of
1972 (P.L. 92·500). if the grant is awarded under any
grant authority of that Act, which provides that no
person in the United States shall, on the ground of sex
be excluded from participation in, be denied the
benefits of. or '>e otherwis'! subject to discrimina!ion
under any p~ogram or ai::'.;vJty under the . "lid Claan
Water Act Amendments lor which the applicant re-
ceives financial assistance and will take all necessary
measures to effectuate this agreement.
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PACE 12 01' 12
2. Off-Site Treatment, Storage or Disposal Facility -During
the fall of 1978, the State investigated ninety (90 ) locations for a
possible disposal site to accept the PCB contaminated soil. A site
in Warren County, North Carolina, was chosen by the State as the bes t
location for the PCB disposal. This site was ,urchased in December
1978. North Carolina submitted an application t o the Regional
Administrator for approval of the landfill under the Toxic Substances
Control Act (TSCA), 15 U.s.c. 2601, ~ ~-on June 4, 1979, EPA
approved the design of the Warren County site.
The consultant engineering firm of SVERDRUP & PARCEL has designed the
PCB landfill and will supervise construction. The Department of Human
Resources, Solid & Hazardous Waste Management Branch will ir.sure
compliance with EPA permit conditions.
All PCB contaminated soil will be placed in compliance with the EPA
permit. Bids for construction of the landfill have been received
and a contract will be signed with the low bidder following the
signing of the State/EPA Cooperative Agreement and receipt of a letter
of credit from EPA.
3. Operation and Maintenance
Contaminated PCB soil will be removed from the 210 miles of
roadway and hauled to the PCB landfill disposal site. Pre-sampling
will be done to determine the beginning and end of roadway excavation
strips and post-sampling will be done in the outs to insure that all
PCB has been removed down to 49 parts per million. No further
monitoring activities are proposed on these roadway cuts other than
restoration of grades and an erosion control program.
The PCB landfill will be monitored by the Department of Human
Resources, Solid & Hazardous Waste Management Branch to insure
compliance with EPA permit conditions. Monitoring activities will
be covered by existing state appropriations made to the Solid &
Hazardous Waste Management Branch. Site maintenance problems will
be corrected by using state funds.
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E. Contract Services
The State plans to use the EPA contractor to do laboratory anal ysis
of samples and to prepare the community relations plan. The State wi ll
let contracts for the construction of the landf ill, and technical
assistance which may be required.
State personnel will manage the project, collect pre and post
samples from contaminated PCB strips, construct the landfill access
road, remove contaminated soil, do community relations a c tivities,
transport and dispose of the contaminated soil.
The State assures EPA that contracts will contain the necessary
safety plan to protect the health and safety of personnel involved as
well as the public. In addition, the state of North Carolina will
conduct quality assurance evaluations to insure compliance with the
safety procedures provisions of the contract and carry out similar
safety requirements for all state personnel.
Contract Reporting Requirements
The actual amount of the contaminated soil is expected to be completed
within six weeks of landfill excavation. Because of the short time
involved, a report will be submitted by the State Project Officer to
the EPA Project Officer at the close of the f i rst quarter. A final
report will be submitted within sixty days aft er close out of the
landfill.
The initial progress report will contain as a minimum, the following:
Maps and drawings showing areas picked up
Sampling results
Work remaining to be accomplished
The final report will summarize the significant facets of the work
activity and, as a minimum, will address:
Amount of material removal from roadways (cubic yds.)
Results of monitoring
Final sampling results
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F. EPA Forms & Project Approval Information
The N. C. State Clearinghouse is located in the Department of
Administration. Project reviews are conducted by the Clearinghouse in
accordance with 0MB Circular A-95. The Clearinghouse review follows:
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STATE AND LOCAL NONCONSTRUCTION PROGRAMS
FEDERAL ASSISTANCE •· HU.uta 2. ,.,,u.
CANT'S
1. TYP'I: 0 Pl£AP'P'LICATION ,.,,1,1. •· DATI Ytor fflOIII~ d11y Of CATION
ACTI0!-4 III AP'P'LICATI01! 1'82 4 16
(Nori op-0 NOTIFICATION Of INTENT (Opt.) LH., "°'""" bo:r) 0 R£l'OIIT OF FEDERAL ACTION Blad
4. U!OAL AmJCAHT/RfCll'lfNT
--~N.-•North Carolina
Ill. 0,p,,I ....... U..it 'Department of Crime Control & Public
L ...... IP.O.h1 I Safety -512 N. Salisbury Street ... o., 'Raleigh •. C-,Rtr I Wake
I.I-. 'North Carolina 1· ZIP Co-d.o 27602
h. C-,_ (Nomt :Dav.id Kelly [phone] • 1,/,pAo,,t No. J
7. TITLE AND DHCRl'110N Of A"LICANT'S ,.OJKT
Cooperative Agreement Between EPA & N.C. for PCB
Project using CERCLA Funds
See Remarks, Section IV
10. AlfA OF ,a()JKT IM,ACT (Namn of citit1. cou111it1. 11. fSTIMATED HUM• s,.,,,. "'·' lflt 0,' P'ERSOHS
IEHEflTIHG Entire State ,:; nnn nnn
13. P'ROl'OSfD fUHDIHG 14. COHGltcSSIOHAl DISTRICTS Of:
•· PIDfllAL t? 'l6R 0'l5 .00 e.APPUCAHT 4th Ii. "OJKT
Statewide •· A""-ICANT 285.339 .00
c. ITATf 16. ,110JKT STAIIT 17. P'IIOJECT .oo OATE y,., MO~l/t ~ay OUIIATIOHl ? Mo,.,Ju ,I, LOCAL .oo II~?
•· OTHta .00 11. ESTIMATED DATE TO y,.,, MO"l/t day
I. TOTAi. •2.853.394 Ii: SUlMITTED ·ro ,.82 4 16 .00 fEDfllAl Ar..CNCY ..
20. flDEIIAl AGEHCY TO •ECEIVE HQUEST (N11m,. C11y. Slott, ZIP cod,)
3. Sr1.n •· HUMNa Am.I-
CATION
t:>ENTI-•· DATt y,., ,,11,111A ""' flEII ASMGNID 1,82 4 16
,. fEDfMl EM'lOYf• IDIHTIPIC'ATION HO.
6. l·I ft I ,iio. •· NUMIII I I GIAM •· TITLI Comprehensive En
(Fr,.,, onmental Respons1, Co Fdno/ satiijn a?d L1ab~ 1ty Cotolo,J of 1 80 CERCLA
I. TYN Of A'1UCAHT /UOl'IEHT ·--_c.-,_._,. ..__ .... ..,._, __
c..L .,.._ ........ ,_
Oi,trict ll-°"'"' (Spttit,#: D-'-,_ °"
vir-mpen Act
·---0-lpoolol...._ £111,r .,,.riott lmtr ,XJ -.....
9. TY,t Of ASSISTANCE ,._ ..... o.. ... o-i,,--
I-lv,.I•-••• o,..,. 1-Otho, £111tr Of¥rr>-CI.i]
C+t.-,n,,u lm,,(1)
12\ TY,t ()f AmJCATIOH
Af( New C-1..-iltH 1-A 1 1 t•tieilo ...... _ .. o-Ceftti~ E_11,,ro,ri111t i,,,.,(Al
15. TYP'f Of CHANGE (For 11 c or /1 t)
,._ ........ Del..., •-°"'" (s,«ify) --o.c,-o.ii... N/A c..--.... o.,,.,;.,, o-o.c,-o.........
t-c-..lloli.rt £",,,.,,_ I . p,vw l,11,,(1) : I I I
, •• EXISTING fEDEIIAL IDEHTl,.ICATIOl'I HUMIU
21. •EIAAUS ADO!D
U.S. EPA, 345 Courtland St., Atlanta, GA 30308 m ..... 0 Ho
7'2. •· To tl,o i..,1 el ,., kft.-t_... •"" Ii.lie/, Ii. If •~~••911 1,, Ololl Orc..ier A-95 thi, o.,p1,..,,;.., ••• ,~~. ,...,. .. .,. le i'illlY• R,,,_,, .,,,,,,.,,, THE ... "' ""' ,...,.,iwtle,,/.~atie,, iol,ll'Y<ti_ ....,.;., .. -.,..;.,. cleeri"f•-.... "" -... ••· .,,,.,,
AmlCAHT ... .._ ..... _, .... ...._ ... , ...i...l, D D a1T1f1ES ...... ....,, ·"""'"•911 .., .... -""""I (IJ N.C • Clearinghouse .....,. ......• ,...i..-, -.... .,., ...... D D THAT ► will c-ply willi the .......... ._.._ (21
Hthee,titteM•it-....i. (31 . D D
23. •. TYPID H_AMf AHO TIT~ ua V 1 a --ice 11 y ' I,. SIGNATURI c.OATISIGHID
atTll'YIHO Assistant ecretary y,.., "'°"'" d11y
IIE,ttf. for Public Safety, NC Dept. 1982 4 16 S!HTATIVE
24. AGENCY NAME or 1.;r1me c..;ontro1 6 Public :sarety 2,. A""-JCA.
TION
Ytor mo"tlt ""' aECEIVEO 1'
26. OIIGANIZATIOHAL UNIT 27. ADMIHISTIIATIVE OfflCI 21. FEDEU\ A""-JCATIOM
IDEHTIHCA TIOH
29. ADDRESS 30. fEDEW GllAHT
IOINTlflCA TIOH
31. ACTION TAKEN 32. NNOIMG y..,, "'°"'" do1y )4. y,., IJtOlfllt do1y
STAITIMG
Oe. AWAaOED •· ffDHAI. • .00 3l. ACTION DATE ► " DATE " 0 II. lllltCTED I,. A'1\ICANT .00 3'. COHTACT fO• ADDITIONAL IHfOitMA-36. y,., ,,.,,,.,,, do1y
0 c. fflUIIHl!D FO• TIOH (N•-•"" ~~ 11vmNr) ENDING
c. STATf .oo DATE " AMINDMEHT ,I, lOCAl .00 37. IIEMAllS ADDED
0 4. DffEl!ll!D •· OTNH .00 o., .. 0Ne 0 •· WITHOllAWM ,. TOTAL • .00 -31. •· ., ._..,. ...... .....,_..., _,. -.i.e4 .,_ c1eer1,..,_v,.. _. I,. ff DUAL AGINC'I' A•ts 0fflCIA1
~-H..-,, -••lt4vo ...,,..,,....__,,_. l,OMI ,...,.,,,, olld ,,.,.._ u)
Pl!DfllAI. AGENCY Cirwle, A-ts. If._ ...... e, it ............
A-95 ACTION
ITANDMIO fOIIIII IN 'AGI IC ..... •-7~/
,._,,..., t10.WII c ..... , ,4./nJ
EPA Fo,,,. S700-Zl /Rn. 10-79) ,:>/\GE I OF 12
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Section IV -Remarks
Re: Section 7.
The Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA or "Superfund") (P.L. 96-510)
provides monies for remedial action to clean up PCB contamination.
The State proposes to enter into a cooperative agreement with EPA
to clean up the PCB contamination soil along 210 miles of N. C.
roadways and dispose of it in a PCB landfill as approved by EPA.
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PART II
Form· Approv«J
0MB No. 158-R0110
PROJECT APPROVAL INFORMATION
Item 1.
Does this assistance· request State, local, regional, or other priority
rating?
____ Yes _Y ___ No
Item 2.
Does this assistance r~quest require State, or local advisory, educa-
tional or health clearances?
____ Yes X ____ No
lt•m 3.
Does this assistance request require clearinghouse review in accord-
ance with OMS Circular A-957
X ____ Yes ____ No
Item 4.
Does this assistance request require State, local, regional or other
planning approval?
____ Yes _ .. X..__No
Item 5.
Is the proposed project covered by an approved comprehensive
plan?
X ____ Yes ____ No
Item 6.
Will the assistance requested serve I Federal installation?
____ Yes _ X __ No
Item 7.
Will the assistance requested be on Federal land or installation?
____ Yes _ _..X....__No
Item 8.
Will the assistance requested have an impact or effect on the
environment?
X ____ Yes ____ No
Item 9.
Has the project for which assistance is requested caused, since
J11nuary 1, 1971, or will it cause, the displacement of any individual,
family, business, or term?
X ____ Yes ____ No
Item 10.
Is there other related assistance on this project previous, pending,
or anticipated?
____ ve, __ Y __ No
Item 11.
Is project in a Designated Flood Henrd Ar•?
EPA. Form ~700-33 (Rn.10-791
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Name of Governing Body----------------Priority Rating ___________________ _
Name of Agency or Board _________ ...,...,_ ___________ _
(Attach Documentation/
Name of Approving Agency __ N_/_A ___________ _
Date ____ .._ ___________________ _
Cheek one: State
Local
D
D
Regional O N/ A
Location of Plan __________________ _
Name of Federal lnstallation_N__./_A ____________ _
Federal Population benefiting from Project ________ _
Name of Feder,1 Installation _N_/_A __________ _
Location of Fede!el Land _______________ _
Percent of Project __________________ _
SH instructions! for additional information to be provided.
Beneficial impact due,to removal of
contaminated soil.
Number of: N / A Individuals ____________________ _
Families----------------------Businesses_ ..... __________________ _
Farms _____________________ _
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See instructions for additional information to be provided.
N/A
PAGE!i0Fl2
I .... N I GRANT PROGRAM, FUNCTION OR ACTIVITY (1) t. CERCLA 2. 3. 4. 5. TOTALS B. Object Class C1tegories 1. Personnel b. Fringe Benefits c. Travel d. Equipment e. Supplies f. Contrectual g. Construction h. Other i. Total Direct Charges j. Indirect Charges k. TOTALS 7. Program Income E PA Form 5700-33 (Rn. 10-79) PART Ill-BUDGET INFORMATION SECTION A-BUDGET SUMMARY FEDERAL ESTIMATED UNOBLIGATED FUNDS CATALOG NO. FEDERAL NON-FEDERAL FEDERAL (b) (cl (di (el s s S 2,568,055 . $ ~ S 2,568.055 SECTION 8-SCHEDULE A BUDGET CATEGORIES GRANT PROGRAM, FUNCTION OR' ACTIVITY Previous 121 Remed ia 1 (11 es~u froject (3) lmnlementati Dn $ s1,015,460 $ 139.000 782.290 114,205 501.600 15,500 s 285,339 $2,568,055 $ S 285,339 $2,568.055 $ rorm Approved 0MB No. 158-R0110 NEW OR REVISED BUDGET NON-FEDERAL TOTAL (f) (gl S 285,339 S 2,853,394 S 285.319 $ 2.R',1_ 'lQl. TOTAL (41 (51 $ s 1.015.460 139.000 782,290 114,205 501. 600 15,500 $ s2.ss3.1<M $ $2.853.394 PAGE 7 OF 12
6. Program Elements
;
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b.
c.
d .
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f.
g.
h.
i. Total Program Elemvnts
j. STATE TOTAL
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SECTION B -SCHEDULE B -BUDGET CATEGOfUES
. FUNDING
(1) FEDERAL (21 NON-FEDERAL
$ 2,568,055 $285,339
. .
I
s2,s6a,oss $285,339
$ $285,339
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Form Approved
()MB No. 158-R0T 10
(4)
MAN•
(3) TOTAL YEARS
s 2,853,394
$2,853,394
$
.... ~ \ SECTION C-NON-FEDERAL RESOURCES -\ \lal GRANT PROGR~M {I:>) APPLICANT (c) STATE (di OTHER SOURCES 8. $ $ $ 9. 10. 11. 12. TOTALS $ s s SECTION D-FORECASTED CASH NEEDS TOTAL FOR 1st VEAR 1st QUARTER 2nd QUARTER 3rd QUARTER 13. Federal s 2,5~8~!)_5~-s--i, 284,028 $ 1,284,027 $ 14. Non-Federal *285,339 15. TOTALS s 2,853,394 $ 1,284,028 $ l,284,UZ7 $ SECTION E-BUDGET ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT FUTURE FUNDING PERIODS (YEAflSI (a) GRANT PROGRAM (bl FIRST (c) SECOND 16. $ $ 17. 18. 19. . 20. TOTALS $ s SECTION F-OTHER BUDGET INFORMATION (Attach Additional Sheets If Necessary} • 21. Direct Charges: 22. I nclirect Charges: 23. Remarks: EPA Form 5700,33 (Rn, 10-79) PART IV-PROGRAM NARRATIVE (Attach per instruction) *Expended between Jan. 1, 1978 and Dec. 11, 1980 (d) THIRD $ $ Form Approved 0MB No. 158-R0t 10 (e) TOTALS $ $ 4th QUARTER s $ ·-(e) FOURTH $ $ AGE30Fl2
G. Special Conditions
1. The Govenor's certification in Part ID is intended to meet CERCLA sections
104(c) (3) and 104 (d) (1) that the state assure payment of ten percent
of the costs of the remedial actions undertaken related to this agreement.
2. As requ1red by CERCLA 104 (c) (3) (A), the state will assume all future
maintenance and operating costs (0&~) for the expected life of the PCB
landfill as determined by EPA.
3. The state assures EPA it does have available the PCB disposal site which
is large enough to receive the 210 miles of soil for disposal as required
by CERCLA sections 104 (c) (3) (B).
4. All activities conducted under this cooperative agreement will be consistent
with the National Contingency Plan.
5. Safety plans prepared for activities required by this cooperative agreement
shall be consistent with the requirement of CERCLA Section 104 (f), EPA's
Occupational Health and Safety ~1anual and other applicable EPA Safety
guidance. In awarding contracts to any person engaged in remedial actions,
the State. shall require compliance with Federal Health and Safety standards
by contractors and subcontractors as a condition of such contracts.
6. In accordance with 0MB circular A-102, the state will utilize small, minority
and womens' businesses as sources of supplies and services whenever pract-
icable,
7. The state shall adequately document the costs incurred in undertaking the
activities described in this agreement. Legal chain of custody for the
samples and materials taken from the site shall be insured.
·8, The State shall assure that quality assurance procedures are adhered
to throughout all activities.
9. The State will cooperate with EPA and the U.S. ~epartment of Justice so that
legal actions against responsible parties are cdordinated in a manner that
will result in the greatest recovery of the costs of the remedial measures by
both the U.S. and the State.
10. The State shall establish a community relations program plan within
thirty (30) days of the award that is consistent with current EPA
guidance. All press releases, media presentations, etc. shall be
issued in accordance with the EPA-approved Community Relations Plan.
11. The State agrees to submit quarterly progress reports to the EPA
Project Officer. These reports shall cover expenditures to date and
expenditures since the previous report; estimates of work completed
(as a percentage of the total work to be done on that activity), with
a description of the basis for the estimates; estimated variance (cost
and time) expected at project completion, based on current project
status; as well as an itemization of expenditures by cost category.
12. The State shall assure that all federal, state and local permits
necessary for implementing the activities addressed in this
Cooperative Agreement are obtained.
15
13. The State will provide access to the site, as well as all rights-of-way
and easements necessary to satisfactorily complete the planned response
actions.
16
H. Signatures
The following persons hereby declare that they have been authorized
by their respective governments to enter into the Cooperative Agreement
and do hereby sign ~t accordingly.
For the U.S. Environmental
Protection Agency
Mr. Charles Jeter
Regional Administrator
Region IV
Date
Witnessed:
17
For the State of North Carolina
James B. Hunt
Governor
State of North Carolina
Date ---------
Witnessed:
..
PART II
STATEMENT OF
WORK PROGR.M1
18
A. Project Description
Roadway Spills
During the months of June, July, and August of 1978, approximately
35,000 gallons of oily liquids were intentionally di scharged along the
shoulders of 210 miles of North Carolina roadways. (See location map and
table). Subsequent chemical analyses conducted by the state indicated that
the oily liquids contained polychlorinated biphenyls, PCBs. Further
investigation showed soils, in very narrow and shallow bands roughly 24 inches
from the road edge, to be contaminated with PCBs at concentrations as high
as 4,000 ppm.
Temporary remedial measures were taken to contain the PCB compound along
the roadway shoulders. An application of a 10% solution of activated carbon
applied at the rate of approximately one gallon per square yard, then
followed by an application of liquid asphalt at the rate of approximately
one-tenth of a gallon per square yard were placed on the contaminated soils.
The activated carbon solution was utilized to bind the surface concen-
tration of PCB by absorption of the PCB's into the pores of the activated
carbon and retard dissipation into the surrounding environment. The liquid
asphalt was applied to eliminate dusting of the activated carbon and to reduce
run-off of the activated carbon caused by storm drainage. These applications
also served to delineate the contaminated areas.
19
.
. '" . .
20
0
LOCATION MAP
11111111 PC B SPILLS
,0
zzaza~ £S!4ifflY
TABLE
1. SR 1004, Alamance County -From Bethel Church north of Snow Camp
to the Chatham County Line.
Length: 5.00 shoulder miles
2. SR 1004, Chatham County -From Alamance County Line to SR 1346.
Length: 2.22 shoulder miles
3. SR 1346, Chatham County -From intersection with SR 1004 to NC 87.
Length: 11.16 shoulder miles
4. NC 87, Chatham County -From intersection with SR 1346 southerly.
Length: approximately 1.42 shoulder miles
5. US 421, Chatham County -SR 2120 to Lee County Line.
Length: 9.59 shoulder miles
6. SR 1006, Chatham County -Between NC 902 and NC 42.
Length: 3.46 shoulder miles
7. NC 42, Chatham County -From Deep River (Lee County Line) to
intersection with SR 1006.
Length: 4.56 shoulder miles
8. NC 902, Chatham County -From SR 1006 to Rocky River.
Length: 9.68 shoulder miles
9. SR 1146, Edgecombe County -From US 301 to SR 1135.
Length: 2.40 shoulder miles
10. SR 1135, Edgecombe County -From SR 1146 to SR 1143.
Length: 2.43 shoulder miles
11. SR 1143, Edgecombe County -From SR 1135 to SR 1141.
Length: 0.51 shoulder miles
12. SR 1130, Edgecombe County -From SR 1003 to NC 43.
Length: 1.33 shoulder miles
13. SR 1141, Edgecombe County -From SR 1143 to NC 43.
Length: 1.43 shoulder miles
14. NC 44, Edgecombe County -From SR 1409 east 0.2 miles.
Length: 0.23 shoulder miles
15. NC 43, Edgecombe County -From SR 1130 to SR 1131.
Length: 0.87 shoulder miles
16. SR 1003, Edgecombe County -From NC 43 to Wilson County Line.
Length: 3.38 shoulder miles
21
TABLE (Cont'd)
17. SR 1432 and SR 1436, Franklin County -From 1/2 mile east of
Moulton to a point beyond Gupton, then traces to Centerville.
Length: 5.10 shoulder miles
18. NC 561, Franklin County -From Nash County Line to Centerville.
Length: 4.80 shoulder miles
19. NC 58, Franklin County -From Warren County Line to Nash County
Line.
Length: 5.10 shoulder miles
20. NC 98, Franklin County -From Nash County Line to Bunn and
approximately 5 miles west of Bunn.
Length: 4.70 shoulder miles
21. NC 97, Franklin County -From Wake County Line to Nash County Line.
Length: 0.90 shoulder miles
22. NC 96, Granville County -From just north of Oxford to NC 49.
Length: 15.2 shoulder miles
23. NC 49, Granville County -From NC 96 to Person County Line.
Length: 1.80 shoulder miles
24. SR 1315, Halifax County -0.2 miles from NC 4 to 0.1 mile east
of bridge.
Length: 1.03 shoulder miles
25. SR 1308, Halifax County -From 0.1 mile north of SR 1309 to 1.2
miles north.
Length: 1.18 shoulder miles
26. NC 4, Halifax County -From SR 1314 to SR 1308.
Length: 3.13 shoulder miles
27. NC 43, Halifax County -From Warren County Line to NC 561.
Length: 0.65 shoulder miles
28. NC 561, Halifax County -From SR 1317 to Nash County Line.
Length: 3.58 shoulder miles
29. NC 87, Harnett County -From Lee County Line to NC 27.
Length: 5.30 shoulder miles
30. NC 27, Harnett County -From NC 87 to SR 1252.
Length: 12.00 shoulder miles
31. NC 210, Harnett County -From Johnston County Line to city limits
of Angier.
Length: 1.82 shoulder miles
22
TABLE (Cont'd)
32. NC 210, Johnston County -From intersection with US 70 southerly
to Harnett, County Line. North side only.
Length: 17.00 shoulder miles
33. NC 42, Lee County -From intersection with SR 1322 to Deep River
(Chatham County Line).
Length: 4.52 shoulder miles
34. NC 87, Lee County -From Harnett County Line to US 421.
Length: 2.14 shoulder miles
35. NC 98, Nash County -From Franklin County Line to NC 231.
Length: 1.41 shoulder miles
36. NC 231, Nash County -From NC 98 to SR 1137.
Length: 0.94 shoulder miles
37. SR 1137, Nash County -From NC 231 to NC 97.
Length: 3.48 shoulder miles
38. NC 97, Nash County -From SR 1137 to Franklin County Line.
Length: 4.39 shoulder miles
39. NC 58, Nash County -From Nashville to Wils0n County Line.
Length: 4.12 shoulder miles
40. NC 561, Nash County -From Franklin County Line to Halifax County
Line.
Length: 0.7 shoulder miles
41. NC 97, Nash County -From NC 58 west 1 mile.
Length: 0.35 shoulder miles
42. NC 58, Nash County -From Franklin County Line to 3 miles north of
Nashville.
Length: 4.11 shoulder miles
43. NC 49, Person County -From Granville Coun~y Line to SR 1515.
Length: 4.24 shoulder miles ·
44. NC 96, Wake County -From 98 to Franklin County Line, to traces
only.
Length: 0.30 shoulder miles
45. NC 97, Wake County -From Zebulon to Frankl in County Line and
from US 64 Bus. to Zebulon.
Length: 4.50 shoulder miles
46. NC 43, Warren County -From Liberia to Halifax County Line.
Length: 6.40 shoulder miles
23
TABLE (Cont'd)
47. NC 58, Warren County -From intersection with NC 43 southerly
to Franklin County -both sides.
Length: 19.25 shoulder miles
48. us 158, Warren County -Between Macon and Vaughan.
Length: 0.60 shoulder miles
49. SR 1407, Wilson County -From SR 1003 to SR 1002.
Length: 1.06 shoulder miles
50. SR 1419, Wilson County -From US 301 to SR 1003.
Length: 0.87 shoulder miles
51. SR 1003, Wilson County -From Edgecombe County Line to US 301
Bypass.
Length: 4.76 shoulder miles
Total Length: 210.97 shoulder miles.
24
Disposal Site
The proposed disposal site is located in the northeastern North Carolina
Piedmont Plateau of Warren County, approximately four miles south of
Warrenton. (See Maps).
The proposed disposal site consists of approximately 142 acres of which
about five acres will be used for the actual disposal of the soil contaminated
with PCBs. The remaining acreage will serve as a buffer zone for the disposal
area.
Surface water discharges are controlled by the topographic position of
the land. The proposed disposal area occupies the c~est of a gently sloping
upland ridge which has 70 to 80 feet of relief. Surface water discharge from
the site is toward seven draws located in a radial pattern around the site.
Two large draws immediately Northeast, and West of the site receive the major
portion of surface run-off. Exposed clayey subsoils, topographic position and
side slopes tend to minimize surface water infiltration and maximize surface
water run-off.
Surface water discharge is to Richneck Creek and an unnamed tributary
to Richneck Creek via draws around the site. Richn~ck Creek discharges to
Fishing Creek. The confluence of Richneck and Fishing Creek is approximately
3 miles downstream and Southeast of the Warrenton ra~ water intake. Stream
classifications for Richneck Creek and Fishing Creek in the discharge area
is class C. Approximately 40 miles separate the site discharge area and the
closest raw water intake.
U.S. Geological Survey Flood Records of N. C. streams indicate that the
100-year flood elevation is not more than 8 feet above average water levels
in Richneck Creek and its tributaries. The site is 70 to 80 feet above these
streams and not subject to flooding.
Recharge of ground-water resulting from surface water infiltration and
percolation is estimated to be low. There should be no signficant fluctuation
in water table elevations beneath the ridge occupied by the disposal site.
All features on the site which enhance surface run-off reduce ground-water
recharge. Rapid run-off and the relatively small area of gently sloping ridge
crest minimizes the volume of precipitation available for infiltration and
recharge. The close proximity of 2 deep draws for ground-water discharge and
the relative low retention and water storage capaciiy of deep subsurface
weathered rock (silty sand and sandy silt) indicates a low potential for build-
up of any significant hydraulic head or water table below the ridge. The net
effect of constructing impermeable barriers on the ridge crest and diverting
any off-site surface water will be to further reduce the potential for mounding
of ground-water below the site.
Subsurface borings performed during February 1, 1979 by the consulting
firm of Soil & Material Engineers, Inc. indicated a static water level of
approximately 303' to 306' in elevation or 37 to 32 feet below land surface.
The study conducted by the firm Soils & Materials Epgineers, Inc. was carried
out during the middle portion of maximum seasonal fluctuation of ground-water.
The measured elevation of ground-water in February, 1979, was 303 to 306 feet.
25
Ground-water elevations could be predicted to rise an additional 5 to 6 feet.
The predicted highest ground-water elevation would be 309 to 312 feet.
Maximum surface elevation in the disposal area is 343 feet. The highest
predicted water table elevation is 31 feet below land surface which would
allow a maximum excavation depth of 24' to remain 7' from the high water table
elevations. Construction of a clay liner would affor d a 14 foot separation
from the high water elevation.
Surficial soils on the site consists of red-brown silty clays. The top
soil on the site is significantly eroded but where pr esent extends to a depth
of 3 to 6 inches. Subsoils are clayey and silty and extend to depths of 38 to
45 feet. In general, a gradual transition exist between upper silty clays and
deeper clayey silts. Observations of soil borings on site indicate that the
clayey silts which grade to fine sands is typical of the Piedmont province.
Detailed analyses of the soil materials were performed by the N.C. Department
of Transportation laboratory and Soil & Material En~ineers, Inc. The two
laboratory analyses indicated an upper layer of clayey soils ranging in depth
from Oto 38 feet below land surface. Soils at the 45' maximum drilling depth
were classified as silty sands and sandy silts.
Standard Engineering laboratory tests for maximum density at optimum
moisture and permeability at 95 and 100 percent maximum density were performed
on the soils. At 95% maximum density the permeabili ty of 1.9 x 10-7 cm/sec
and minimum permeability of 1.8 x 10-8 cm/sec. At 100% maximum density no
permeability was greater than 1.0 x 10-7 cm/sec. The 8 acres encompassed by
detailed soil borings and analysis demonstrates that 50,000 to 75,000 cubic
yards of clayey materials are available to construct highly impermeable soil
liners.
26
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27
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B. Background Information
The first deliberate discharge of what was later identified as PCB liquid .
materials took place the last week of June, 1978, on remote roads of the Fort
Bragg Military Reservation. The discharge was investigated by Fort Bragg
personnel who secured liquid samples of the material. The next discharge
occurred on July 27 and July 29 on the roadway shoul ders on NC 58, north of
Centerville in Warren County. This discharge was reported by pqvate citizens
to the N. C. Highway Patrol, who alerted the Divisi~n of Health Services, Water
Supply Branch. Water Supply Branch personnel notifi ed Division of Environmenta l
Management, Water Quality Program personnel in the Raleigh Field Office of the
spills. Raleigh Field Office personnel investigated the spill on July 31 as
an oil spill and on finding no oil ponded or evidence in surface waters, returned
to their office without taking further action.
On August 2, the Water Quality Operations Brauch, Division of Environmental
Management, received a call from a Johnston County f armer concerning a spill on
NC 210 in front of his farm. Because of the description of the odor and the
effects on field workers being reported, a staff chemist was immediately dispatched
to investigate the spill and to take appropriate samples. Grass, soil, and water
samples were hand delivered to the Division of Environmental Management Laboratory
for analysis later that afternoon, August 2. The same chemist who investigated
the Johnston County spill encountered a similar spill near Snow Camp, North
Carolina on SR 1004, Alamance County, while returning to his home. A sample was
taken from the spill area and hand delivered to the laboratory the foll-.wing
morning for analysis.
On August 4, the Laboratory's Analytical Section Chief notified the Water
Quality Operations Branch that the material spilled in Johnston County api.ared
to be Aroclor-1260, a Polychlorin~ted Biphenyl (PCB) substance. The Water Quality
Operations Branch immediately notified the Chief of the Environmental Protection
Agency, Region IV, Emergency Response Branch, of the Laboratory's findings. After
briefing the Director, Division of Environmental Management, a meeting was called
with representatives of the Attorney General's Office, the Department of Crime
Control and Public Safety, and Public Information representatives of the Secretary
of the Dep~rtment of Natural Resources and Community Development. A notification
to all al1 enforcement officials was prepared and sent over the Police Information
Network system during the late evening hours of August 4. A news release was
prepared and sent to local newspapers for publication in the Saturday morning
newspaper. The same day, the laboratory confirmed material discharged in
Alamance and Chatham Counties was Aroclor-1260, the same form of PCB material
found in Johnston and Harnett Counties. Also on ~ugust 4, the~. C. Highway
Patrol delivered soil samples obtained from Chatham County to EPA. The results
of the EPA laboratory analysis were reported to SBI on August 8.
On August 5, Water Quality Operations Branch met with concerned citizens
in Johnston County, investigated the spill areas in Johnston and Harnett Counties,
and conqcted a •idoor-to-door contact with people resUia5 alqng NC 210. !ecause
of concern by some residents along NC 210, the Division or Sighway, Department
of Transportation was requested to cover the spill with a layer of sand in order
to suppress the noxious odors present. This was completed in late afternoon
August 5 and continued on August 6.
29
On August 6, the Raleigh Regional Office was directed to secure samples
of the spill area in Warren County to determine if similar material had been
deposited along NC 58. Because of the publicity being given by the newspaper
and TV to the spills, the Fort Bragg Environmental Coordinator requested the
Water Quality Operations Branch to analyze material secured from the spill at
Fort Bragg to determine if simil~~ material was spilled on the military reser-
vation. Because of the publicity, reports of spills began coming in from many
different sources such as Highway Patrol, Department of Transportation Division
Engineers, private citizens, and others in nine additional counties. It appeared
that most of the spills took place in the evenings of August 1, 2, and 3. While
it has not been conclusively determined, spills may have occured in Wilson County
the evenings of August 5 and August 8. The Division of Environmental Management
Laboratory continued to work around the clock to verify the material in the
spills in the other counties,
On August 7, a preliminary conference was held with representatives of the
Division of Highways, Division of Health Services, Attorney General's Office,
and Public Information personnel, Specific information gathering activities
were spelled out and assigned to specific people. A coordination conference
wss t•.eld with-representatives of tu Depai:tment 1,f Human Reso-.,.rces, DepartMtent
of Agriculture, Attorney General's Office, the Department of Transportation,
Environmental Protection Agency, and the news media, on August 10. A working
session was held following the briefing to news media to provide direction,
identify responsibilities and initiate specific actions concerning the spilled
material. Advice was solicited from the Environmen~al Protection Agency Office
of Toxic Substances, the National Centerior Disease Control, Hevi Duty Electric
Company, the EPA Health Effects Research Laboratory, and various academic and
private sector personalities known as having expertise in handling this type
of material. On August 11, the EPA Health Effects Research Laboratory began
ambient air sampling at spill sites.
North Carolina State University was identified as having expertise in
detoxifying pesticides. The University was contacted to provide expert advice
and assistance. A proposal was submitted to the Governor for temporarily
deactivating the PCB materials to prevent its migration and to neutralize any
hazard to people coming into contact with the material on the shoulder of the
highway, The Governor provided directive authority to proceed on August 15,
1978. An activated charcoal solution was applied to the PCB contaminated
roadway shoulders during the latter part of August, On August 15, the Governor
requested assistance from the President of United States. On August 17, a
special EPA coordinator was assigned to the problem,
Because the initial sampling procedures only gave gross approximation
to tile concentration-.c,f PCB. material on the grass .and in the s.oil column,
several cross sectional samples were taken at one-inch intervals to determine
the magnitude of the penetration into the soil column and the strength of the
material at various depths. These samples were taken during the period of
August 21-28.
On August 28 and 29th, the Epidemiology Section of the North Carolina
Division of Health Services convened a meeting of national experts on PCBs,
Those in attendance included scientists from the Environmental Protection
~gency, National Institute of Occupational Safety and Health, National
Institute of Environmental Health Sciences, and th~ Center for Disease Control.
30
State personnel in attendance were from the Division of Health Services,
Natural Resources and Community Development, Department of Agriculture, and
the Department of Transportation. Industrial users 0f PCBs were represented
by a person from Carolina Power and Light. The purp0se of this meeting was
to assess the immediate risks to the persons who live along the spill routes
and to discuss the safety of those persons who would be participating in the
removal and storage of the PCB contaminated soil.
On September 6, 13, and 19 alternative methods of removing soil from the
roadway shoulders were conducted on noncontaminated sections of roadway shoulders.
~'hen the soil removal procedure had been formulated a test removal operation
was conducted. The test removal operation was performed on October 5, 1978 on
a one mile PCB contaminated section of NC 58 near Inez on Warren County. The
PCB contaminated soil obtained during the test removal operation has been
temporarily stored at a disposal site in Warren County. The purpose of the
test was to examine the practicality of picking up the contaminated material
as well as any possible health or environmental effects. On November 6, test
results indicated that the pick up of contaminated shoulder material was not
harmful to the environment or personnel.
On September 29, 1978, Governor James B. Hunt's request for assistance
from the Federal District Assistance Administration, Department of Housing
and Urban Development was denied. On October 4, North Carolina officials
were notified by the Federal Highway Administration, U. S. Department of
Transportation, that the request for emergency relief funds was denied.
During the month of December a Draft Negative Declaration was prepared
pursuant to the North Carolina Environmental Poli cy Act. The statement was
sent to State Clearinghouse on December 21, 1978 for circulation. Comments
received on the Draft Negative Declaration requested an EIS be prepared.
Therefore, a Final Negative Declaration was not prepared.
On December 12, an application was filed with EFA for approval of the
Warren County site for placement of contaminated PCB material. On January 4,
1979 a hearing was held on the Warren County site a t the National Guard Armory.
During the period January 25-31, 1979 additional soil ~amples were taken
by the Division of Environmental Management to substantiate the location of the
contaminated material and determine if any migration had occurred. Test
results indicated that the material was present and had not migrated. On
January 29, 1979, a meeting was held in Washington, D. C. between representa-
tives of the State of North Carolina and EPA officials to discuss the current
PCB regulations and to discuss alternative solutions. On February 6, the state
of North Carolina filed petition with EPA to amend the rules under the Toxic
Substances Control Act to allow consideration of alternate methods of
treatment,
On February 15, 1979, a test was run on a contaminated section of NC 210
in Johnston County and on March 22, on a contaminat1ed section of SR 1004 in
Alamance County to determine the feasibility of utilizing the theory of rcB
fixation with activated carbon.
31
On June 4, 1979, the EPA Administrator, Douglas Costle, ruled against
the petition of February 6 to change the regulations to allow consideration
of alternate methods of treatment. The Region IV EPA Administrator, John
White, on June 4, 1979 approved the State's application to construct a land-
fill in Warren County for disposal of the PCB contaminated soil.
Definition of PCBs 1
PCBs (polychlorinated biphenyls) are a class of chlorinated, aromatic
compounds which have found widespread application because of their general
stabilities and dielectric properties. PCBs have been prepared industrially
since 1929 and are now produced in many foreign industrial countries. The
Monsanto Company's preparations of PCBs were termed "the Aroclors". Produc-
tion of PCBs ceased in the United States in mid 1971.
The outstanding physical and chemical characteristics of PCBs are their
thermal stabilities, resistance to oxidation, acid, bases, and other chemical
agents as well as their excellent dielectric (electrically insulating) proper-
ties. These ~nd other properties have led to numerous uses of PCB such as
dielectric fluids (in capacitors and transformers), industrial fluids (use in
hydraulic systems, gas turbines, and vacuum pumps), and plasticizers (adhesives,
textiles, surface coating, sealants, printing, and copy paper).
PCBs were prepared industrially by the chlorination of biphenyls with
anhydrous chlorine, using iron filing or ferric chloride as catalysts. The
crude product was generally purified to remove color, traces of hydrogen
chloride, and catalyst which was usually achieved by treatment with alkali
and distillation. The resulting product was a complicated mixture of chloro-
phenyls with different numbers of chlorine atoms per molecule. (This fact
is responsible for the physical state of PCB preparations). Most individual
chlorophenyls are solid at room temperature whereas commercial mixtures
are mobile oils.
The most important physical properties of PCBs from an envoronmental
point-of-view are solubility and vapor pressure. The solubility of PCBs in
water is low and decreases with increasing chlorine content. Values given by
Monsanto are 200 ppb (parts per billion) for Aroclor 1242, 100 ppb for
Aroclor 1248, 40 ppb for Aroclor 1254, and 25 ppb for Aroclor 1260. Studies
on the solubility of PCB in water are complicated by the fact that these
compounds are strongly sorbed onto various surfaces. PCB has been shown to
sorb relatively rapidly onto charcoal, plastic, glass, and silt or soil
particles.
PCBs have a high specific gravity (Aroclor 1260/1.500~ and
high density (Aroclor 1260 weighs 13.50 lbs./gallon at 25 C).
by evaporation is extremely slow, i.e. Aroclor 1260 exposed to
1 Hutzinger O. et. al., Chemistry of PCBs, enc Pres
Cleveland, Ohio, 1974.
32
a relatively
Loss of PCB
0 100 C for six
hours would have an evaporation loss of Oto 0,1%. FCBs are very stable at
high temperatures. A temperature of 2000°c or greater is necessary before
these chemicals are destroyed.
In summary, PCB compounds have been manufactured and used in this country
since 1929. Their uses have varied from the manufact ure of many household
products to industrial uses. PCBs are very stable heat resistant compounds
that are fat soluble and some are known to build up i n biological food chains.
PCBs are relatively insoluble in water but have strong absorption properties
onto such materials as clay, soot, charcoal, and grease. PCBs are found in a
wide variety of substrates throughout our environment .
P.egulations Pertaining to PCB Spills
The Environmental Protection Agency has promulgated rules and regulations
pursuant to the Toxic Substance Control Act to protect the environment from
further contamination by PCBs resulting from improper handling and disposal
of PCBs. Title 40 Part 761.10 (b) (3) of the Toxic Substances Control Act
spells out disposal requirements of PCB mixtures in soil. The regulation
initially defined PCBs to mean any mixture with 500 parts per million (PPM)
of PCB. This regulation was amended effective July 2, 1979. The amendment
in 40 C.F.R. 761.1 (b) lowered the concentration of PCBs which are covered by
the regulation from 500 ppm to 50 ppm (Federal Register, Vol. 44, No. 106,
May 31, 1979). The regulation requires that soil and debris contaminated
with PCBs must be disposed of either through incineration or in a chemical
waste landfill.
Criterion for any such landfill is contained in Annex II to the referenced
regulation. Specific wording in C.F.R. 40, Part 76 ].10 (b) (3) is as follows:
"Soil and debris which have been contaminated wi th PCB as a
result of a spill or as a result of placement of PCBs in a
disposal site prior to the publication date of t hese regula-
tions shall be disposed of
(i) In an incinerator which complies with Annex I, or
(ii) In a chemical waste landfill."
The State of North Carolina petitioned the USEPA for a change in the
disposal requirements for PCB mixtures in 40 C.F.R. 761.10 (h) (3). North
Carolina requested that the regional administrator be allowed to approve
methods of disposal other than incineration or landf illing. The petition
for rule change was denied by EPA on June 4, 1979.
33
C. Remedial Response Plan
Remedial response activities for the PCB contami nated soil clean up will
consist of eight main components. These components deal with the aspects of
actual contaminated material pick up and subsequent road restoration, landfill
deeign, construction, and monitoring, laboratory analysis and sampling and
community relations during t~e response. A more detailed description of these
components follows.
34
1. Community Relations Plan
The state will work closely with representatives of the EPA's Region IV
and ICF, an EPA contractor, in developing a comprehensive community relations
plan for the PCB cleanup. The large area involved in the PCB dumping (210 miles
in 14 counties), and the emotionalism and publicity that has since surrounded
the issue, will dictate the development of an extensive and well-thought-out plan
for informing the public about cleanup efforts that will take place.
The state, the EPA and representatives of ICF presently are drafting a
community relations plan that will be included in the state's cooperative
agreement application. The general components of the community relations
plan are as follows:
a) a press announcement of the approval and implementation of the PCB
cleanup by appropriate state and federal officials.
b) press briefings and news releases as necessary to insure that the correct
information is getting out to all interested media representatives.
c) prior notification of the steps involved, and the timetable of the cleanup
to all state, county and local officials in the cleanup area.
d) notification by mail to those persons in the affected communities who
have indicated a continuing interest in the PCB issue.
e) a toll free number to be provided so that the general public can call
in any questions or concerns that they might have about the cleanup.
f) public service announcements that will be provided to the electronic
media for use during cleanup operations.
g) the preparation of an informational packet on the PCB dumping and cleanup
for distribution to the press and to county, state and local officials
and interested citizens.
35
2. Project Scheduling .and Design
The State will select a qualified project contractcr to prepare
the landfill site, co~struct the landfill, coordin3te with the
N.C. Department of Transportation (DOT) to receive, place, and
compact the contaminated soil and close the landfill site properly.
The contractor will be responsible to state engineers for this
activity. The State will a1sc monitor ground and surface water
on 30-d3y intervals during project construction. The N.C. OOT
will be responsibie for pick up and transportation of the con-
taminated soil to the site and maintenance of the access road.
The State will notify EPA two weeks prior to starting and con-
struction on the project. All landfill construction necessary
to provide for receiving contaminated soil will require 50 days.
Concurrent with initial landfill construction, 4 groundwater
monitorinq wells and 4 surface water monitoring stations will
be established, ~ampled, and analyzed for 44 FR 161.41(6) para-
meters. Prior to receiving contami~ated soil, the state will
sample and analyze all groundwater monitoring we l ls and surface
water stations, and submit the base line data to EPA. Three
samples, at one week intervals, will be utilized to establish
base line data. Additional mo,itoring samples wi ll be taken
at 30-day intervals during construction and submi tted to EPA.
Two weeks prior to receiving contaminated soil, the state will
notify EPA of the datP. for starting pick up and delivery to
the landfill site. The contractor and N.C. DOT will coordinate
to schedule receiving the contaminated soil during a six week
time frame.
Within 10 days after the contaminated soil is placed and com-
pacted in the landfill, final cover including an artificial
liner and soil materials will be applied.
Completion of site construction will consist of erecting security
fencing, seeding for erosion control and general 1 clean-up and
will be accomplished within 20 days after application of final
cover.
Immediately following site closure, the state wi il l sample
monitoring wells and surface water for submissio,n to EPA.
The project will be completed in 144 days from initial site
preparation to closure and final water quality monitoring.
36
N.C. PCB PROJECT SCHEDULE ACTIVITY 0 20 40 PROJECT 01gs 80 100 120 State notifies EPA of intent I I 14 to construct State notifies contractor to ~ begin construction Landfill construction I 50 I State notifies EPA of intent I 14 to dispose Pick up and disposal I I 42 ' \ Dispose of on-site residue I P-i Construct final cover ~ I Complete site closure I 20 Pre-pick up monitoring ' 50 I Post pick up monitoring 42 Ground and surface water 50 ~ I* I* monitoring * Ground and surface water monitoring schedule
3. Landfill Construction
The disposal site for the PCB contaminated soil is located on approximately
142 acres of land in Warren County. The State of ~orth Carolina proposes to
to construct the PCB landfill in accordance with plahs approved by EPA. (See
letter dated ). A general, sequential description of how the landfill
will be constructed follows:
1) An all weather access road will be built to allow necessary equipment and
and transport vehicles for landfill construction and PCB contaminated
material ..
2) Soil erosion control devices will be installed/constructed to prevent
offsite sedimentation during entire construction phase.
3) Cleaning and grubbing procedures will be initi~ted to prepare areas for
excavation.
4) Ground water monitoring wells will be installed so that background data
can be accumulated while the rest of construction phase continues.
5) Major excavation of pit area and subsequent stdck piling of soils will
commence.
6) Preparation of pit area to receive contaminated soil will begin.
a) Installation of lower leachate collection system.
b) Installation of 30 mil. PVC bottom liner.
c) Installation of 12 inch thick soil layer for PVC liner protection.
d) Installation and construction of 5 foot thick clay liner.
e) Installation of upper leachate collection tystem.
f) Installation of filter fabric to protect upper leachate collection
system.
g) Installation of carbon filter system.
7) PCB contaminated soil will be placed and compacted within the landfill.
8) All contaminated materials from erosion control devices and purgings from
carbon filter system will be placed in the lan~fill.
9) The final cover will be constructed and the upper PVC liner and gas vent
will be installed.
10) Final soil erosion control procedures, including seeding, will be performed.
11) The chain link fence will be installed to prevent access to the landfill site.
12) General clean up operations will conunence.
37
4. Roadside Sampling
The roadside sampling activity will accomplish two objectives:
(1) verify that the State has adequately identified the beginning and
ending points of each contaminated road segment by sampling at the be-
ginning and end of each segment; and (2) confirm that PCB's have not
migrated from the 30-inch strip to be picked up by sampling each area
where significant erosion has occurred. Eight tasks will be undertaken
to accomplish this activity. These tasks are described below along with
the sampling methodology to oe utilized.
Develop Monitoring Strategy
This activity will be carried out by two two-man teams and an
activity supervisor. One week is allocated to developing a work plan
of the work to be accomplished. Maps will have to be assembled and
logistics of the project l aid out.
1
Acquire Supplies
Acquisition of supplies is identified as a separate task since it is
a critical path element in the timely completion of the project. Enough
supplies to take 200 samples will be acquired. Each sample will be
placed in an individual jar and labeled. All samples will be taken with
six-inch circular metal cores or pipes. For composite samples, individual
cores and disposable gloves will be used for each part of the composite.
Enough cores and gloves will be acquired for 800 individual cores. Maps
38
will be acquired to plot sampling locations and identify road segment
boundaries. All supplies will be acquired withi n 14 days or project
start-up.
Sample End Points
A log book wil l be developed containing maps of each contaminated
road segment and a preci se descripti on of each starting and ending point.
This l og book will contain all of the data available to t he St ate on
starting and ending points.
The work plan will divide the contaminated segments into two groups
and each group will be assigned to a two-man sampling team. At each
starting an.d ending point the team will take a oomposite sample five feet
beyond the end point. Where the contamination begins at an intersection,
each corner along a possible direction of the spill will be sampled to
assure that the PCB di scharge did indeed terminate at the intersection.
At each sample site a composi t e sample wi l l be taken consisting of
thr ee cores. The cores will be within the 30-inch strip perpendicular to
the road and equally spaced. Each core will be to a depth of 3 inches ,
and the three cores will be composited . A clean core and clean gloves
will be used to extract each co re. Each sample site will be marked by
a small wooden stake sunk level wi th the ground with survey tape nailed
to the top. Each sample will be sent to EPA for analysis. The sample
location will be described in the log book.
Erosion Site Survey
During the identificat1on of the beginning and ending points of each
segment, each t ea m will slowly drive the full extent of each segment
noting on maps areas of erosion. Each erosion area will then be classified
either sheet or channel erosion. An area of sheet erosion would indicate
erosion along a section of roadway bank. Channel erosion would be analo-
gous to a point source or single erosion gully.
The State has already surveyed roughly ten percent of the contaminated
highways for erosion. Based on this survey it has been estimated that
approximately 20 areas of channel erosion will be found and ten areas of
sheet erosion.
Erosion Area Sample
For channel erosion sites two samples would be taken. The first
sample would be a composite of three cores from observable deposition fans
at the bottom of the channel. The second would be a composite of three
cores of the area immediately downslope of the deposition where no PCB 1s
would be expected.
For sheet erosion, the extent of the deposition fan will first be
identified, then a representative composite sample of three cores from the
fan will be taken. Three additional composite samples will also be taken,
the first in an area downslope of the fan, and the second and third at
either end of the sheet. These perimeter samples would also be taken
beyond the zone of expected migration in order tb delineate the migration
area.
All laboratory analyses for both erosion and end point determination
will determine whether or not the concentration of PCB is greater than
49 mg/kg.
Page 4
6. Evaluate Laboratory Results
All sample results of beginning and end points, as well as all
erosion sample results, will be reported whether or not the concentration
of total PCB 1 s is above 49 ppm PCB. If one or more of the erosion areas
show a PCB concentration above 49 ppm, each positive erosion area will
be further sampled to determine the extent of the contamination. All
contaminated soil so identified in the erosion a1rea will be removed to
the landfill.
7. Additional Sampling
The sampling activity tasks and budget include the potential for
taking an additional 39 composite samples. These samples may include
additional erosion samples, if the estimates of number of significant
erosion sites prove to be low.
8. Conclude Activity
A final report will be prepared presenting all sample data and a
description of the project and areas sampled.
41/42
. 5. Lab Analysis
This proposal is based on the assumption that all laboratory analysis
and required quality assurances will be provided by the Environmental
Protection Agency and its contractors. The State's sole role in sampling
will be to ship properly prepared samples to a predesignated location for
analysis. At this point the State does not have adequate information to
provide a reliable estimate of lab costs, but has assumed each sample analysis
would cost $175.00, for a total for 200 samples of $35,000.00. EPA is in
a better position to determine its contractor's costs, and if the $175.00
figure is incorrect, this budget should be appropriately modified.
All analyses would be con cerned only with total PCB's. The erosion
and begining and end point sample results will be reported as only whether or
not the total PCB concentration of the sample exceeds 49 ppm.
43
6. Removal and Transportation of Contaminated So i l to nisposal Area
The proposed method of removing the PCB contaminated soil from
• the roadway shoulders will consist of the followi hg sequential
steps:
a. The contaminated area will be thoroughly wetted
down with water, if necessary, in order to con-
trol dust during the removal and disposal oper-
ations. This may not be required during wet
seasons, but on the other hand, may be required
as much as 24 hours in advance during extremely
dry conditions. This operation is recognized as
extremely critical in the total removal operation
and will be stringently controlled.
b. The contaminated should area will be trenched
out to a width of approximately 30" from the
edge of pavement, and approximately 3" deep by
means of a motor grader equipped with a specially
designed blade to allow for the cutting of a
reasonable neat line trench, working wi t h all
motor grader wheels on the paveme~t. The trer.ched
out materail will be fed along the motor grader
blade to form a windrow of material located inside
the edge of pavement.
c. The windrow of contaminated material will be
mechanically picked up and fed into trailing
dump trucks by means of an Athey force-feed
loader. This loader operation forces the
contaminated material onto a self-contained
belt conveyor by means of rotating paddles.
The material is conveyed up the belt and dropped
into dump trucks. A specially designed canvas
shield will extend from the top of the belt down
into the dump truck bodies to prevent wind drift
of the contaminated material.
d. The Athey loader is designed to scrape the road
surface; however, very thin amounts of residue
will be left on the road surface following the
loader operation.
Depending on soil moisture conditions, this re-
sidue will be either water sprayed back into the
excavated trench or broomed, by means of a tractor
mounted rotary broom or a combination 0f both
spraying and brooming. Spraying will ~e performed .
by a Hydroseeder with especially designed adjustable
outlet nozzles and the broom will be covered with a
specially designed canvas cover to minimize dusting
and wind drift.
44
Once the contaminated material is deposited in dump trucks, the
dump bodies will be tightly covered with tarpaul i ns using elastic
tie-downs. Insofar as possible and practical, contaminated
material will be hauled to the disposal area along rural routes,
avoiding highly congested areas. Hauling of con !aminated material
will take place only during daylight hours .
Vehicles equipped with mobile radio units will r outinely survey
the haul routes for trucks with mechanical diffi t u1ty . In the
event of mechanical trouble, mechanics will be radio dispatched .
45
1. S~oulder ·Reconstruction
Reshaping of the disturbed shoulder area will immediately follow the
removal operation. Depending on the width and cross slope of the existing
shoulder, reshaping of the shoulder by a motor grader, or filling in the
excavated area with borrow soil material and shaping with a motor grader.
The shoulder reshaping operation will be followed by erosion control
operations consisting of seed bed preparation, seeding, fertilizing and
mulching of all disturbed areas.
46
8. Landfill Monitoring
Four groundwater monitoring wells will be constnucted and located
North, South, East, and West of the landfill. The gr oundwater wells will be
monitored in accordance with 44 FR 761.41(6) standar~s. Base line groundwater
quality will be established by sampling the groundwater wells on one week
intervals for 3 weeks . Groundwater Base line groundwater quality will be
determined during construction and prior to receiving contaminated soil.
Four permanent surface water monitoring stations will be located to
determine water quality. Two receiving streams will be monitored, Richard
Creek on the northern site perimeter and anunamed ttibutary to Richard Creek
on the southern perimeter. Two stations, one on each stream, will be located
up gradient from any site surface run-off event. Two stations, one on each
stream, will be located immediately down gradient fr ~m the site and through
which all flow from surface runoff events will pass. Representative surface
water and sediment samples will be monitored at each station in accordance
with 44 FR 761.41 (6) parameters. Excluded from anal yses are chlorinated
organics as indicated in a letter to Governor Hunt from John White (EPA
Regional Administrator) dated 4, June, 1979.
Twelve groundwater, 12 surface water, and 12 secliment samples will be
monitored for base line data.
Three sets of samples will be obtained from each ground and surface
water monitoring point on 30-day intervals during con struction. Each set
will consist of 1 sample from each groundwater well and 2 (water and sediment)
from each surface water station.
47
D. Remedial Response Alternatives
1. Alternative Method of Treatment In-Place
Tests were conducted to determine the feasibility of applying activated
charcoal as a means of achieving long term fixation and containment of the
PCB material within the highway shoulders. The in place treatment consisted
of applying activated charcoal on the contaminated soil and then blending
the activated charcoal material into the soil column of the highway shoulder.
The disturbed areas would then be packed, seeded and reshaped. A continuous
maintenance and inspection program would be performed to insure that erosion
and soil migration did not occur.
A test was run on February 15, 1979 on a section of NC 210 in Johnston
County and on March 22, on a section of SR 1004 in Alamance Ctunty. The test
results indicated that vertical and horizontal mixing was accomplished with
the average concentration being below the regulating requirement at that time
of 500 ppm. The average concentration along the test section is above the
current requirement of 50 ppm (amendment to 40 C.F.R, 761.l(b)).
During the test runs representative soil samples were taken by EPA at the
Research Triangle Park to conduct studies of possible health effects. The EPA
study which utilized rats for test purposes provided evidence that the carbon
fixation process was not adequate and would not be an acceptable means of
disposal.
Because EPA regulations prohibited in place treatment the State of North
Carolina applied for a rule change to allow the regi onal administrator to
approve in place treatment. The EPA administrator on June 4, 1979 denied the
petition submitted by the State of North Carolina.
2. Alternative of Transportation to a PCB Material Incinerator
Three incinerators have been identified as having the capability to
destroy the PCB material through incineration. These incinerators are located
in New Jersey, Arkansas, and Texas. At the present time, these incinerators
have not been issued permits by EPA which would authorized them to accept and
dispose of PCB materials. Additionally, transportation and handling logistics
would make this alternate cost prohibitive,
3. Alternative of Transportation To An Existing Chemical Waste Landfill
Consideration was given to transportating the PtB contaminated soil to an
existing chemical landfill located in Alabama, This alternative was considered
not feasible, because of limited transportation respurces, manpower requirements,
and excessive cost of disposal estimated at $12, million, as well as the increased
logistic problems.
4. Goodyear PCB Detoxification Process
Dr. R.H. Kline, scientist from the Research Division of the Goodyear Tire
and Ruhber Company, was contacted to determine the feasibility of applying the
recently developed Goodyear PCB detoxification process to the soil-PCB spill
mixture in North Carolina. Dr. Kline stated that the process was designed for
PCB fluids not absorbed PCB and solid mixtures. The dnly way the Goodyear process
could be applied was to first extract the PCB from the soil mixture, and while
extraction and detoxification was possible that it is not practical nor econo-
mical.
5. No Action (Do-Nothing Alternative)
The no action or ''Do-Nothing" alternative was not considered to be a
viable alternative because current EPA regulations require disposal of PCB
contaminated soil which has concentrations greater than 50 parts per million.
The rights of way of N. C. highways are generally use~ to provide driveway
access to adjacent properties and to provide for placement of utility
distribution systems. In addition, highway shoulders require periodic mainten-
ance, enlargement and improvement to meet the transportation needs of the public.
None of these right of way activities can be undertaken without substantially
increasing the risk of further distribution of PCBs in the environment by
disturbing the contaminated soil. Even without such use of the rights of way,
the normal usage of the highways will result in some PCBs being distributed in ·
the environment due to vehicles intentionally or unintentionally being operated
on the shoulders. It is felt to be in the public interest to remove the PCB
contaminated soil from the highway shoulders so that the EPA regulations will
be honored and so that the highways can be put to full public use without
further distributing PCBs in the environment.
49
E. Preferred Alternative
1. Summary of Alternatives
One alternative considered for the proposed action consisted of
treatment in-place by applying activated charcoal on the contaminated
soil. Treatment in-place of the PCB contaminated soil is prohibited
by EPA regulations. Therefore, this alternative was considered not
feasible.
Another alternative considered was transporting the PCB contaminated
soil to a PCB material incinerator located out of State. This alternative
was rejected because there is no approved incinerator capable of handling
soil contaminated with PCBs.
The alternative of transporting the PCB contaminated soil to an
existing chemical landfill was considered. This alternative was determined
to be not feasible because of limited transportation resources, manpower
requirements and excessive cost of disposal estimated at $12 million.
The no action or "Do-Nothing Alternative11was not considered a viable
alternative because EPA has determined in the course of extensive rule-
making proceedings that PCB contaminated soil in concentrations of 50
parts per million or greater should be disposed of in landfills. For
these reasons its removal and safe disposal is in the public interest.
The State of North Carolina proposes to remove and dispose of the
PCB contaminated soil in a specially constructed disposal landfill that
is located on approximately 142 acres of land in Warren County.
Approximately 90 sites located in twenty counties of the State were
evaluated as potential disposal sites for the PCB contaminated soil. A
set of general guidelines and EPA technical requirements were utilized
in the evaluation and selection of disposal sites.
2. Sunnnary of Environmental Impact and Adverse
Environmental Effects
The proposed action to remove and dispose of approximately 40,000
cubic yards of PCB contaminated soil will result in some adverse environ-
mental effects. Approximately five acres of agricultural land utilized
for the disposal pit will be taken out of production for an indefinite
period. No significant environmental effects a~e anticipated to result
from the removal and disposal operations. Test results during trial
removal operations show no levels of airborne PCB vapor or dust that
exceeded the NIOSH proposed criterion of 1 microgram/m3 or added signifi-
cant quantities of PCBs to the total atmosphere levels. Dust control
measures will be utilized during the removal of the soil to help reduce
the PCB laden dust particles.
The disposal pit will be constructed to completely contain the PCB
contaminated soil. There will be no hydraulic connection between the PCB
contaminated soil and surface water or groundwater. Installations of
wells and leachate collection systems will allow monitoring of the disposal
site.
50
The removal of the PCB contaminated soil fr0m the roadsides will
have a positive effect on the environment by substantially diminishing
the availability of the PCB substance to people as well as plant and
non-human animal life. The roadway shoulder and surrounding environment
will be restored to normal usage.
See the Environmental Impact Statement for a more detailed discussion.
3. Description of Removal and Disposal Action
Soil Removal
Shortly after the PCB spills occurred, measures were taken to contain
the PCB compound spilled along the roadway shoul~ers. An application of
a 10% solution of activated carbon applied at the rate of approximately
one gallon per square yard then followed by an application of liquid
asphalt at the rate of approximately one-tenth of a gallon per square
yard were applied to the roadway shoulders where the PCB spills have occurred.
The activated carbon solution was utilized to bind the surface concen-
tration of PCB by absorption of the PCBs into the pores of the activated
carbon and retard dissipation into the surrounding environment. The liquid
asphalt was applied-to eliminate dusting of the activated carbon and to
reduce run-off of the activated carbon caused by storm drainage. These
applications also served to delineate the contaminated areas.
The proposed method of removing the PCB contaminated soil from the
roadway shoulders will consist of the following sequential steps:
a. The contaminated area will be thoroughly wetted down with water,
if necessary, in order to control dust during the removal and
disposal operations. This may not be required during wet seasons,
but on the other hand, may be required as much as 24 hours in
advance during extremely dry conditions. This operation is
recognized as extremely critical in the total removal operation
and will be stringently controlled.
b. The contaminated shoulder area will be trenched out to a width
of approximately 30" from the edge of pavement, and approximately
3" deep by means of a motor grader equipped with a specially
designed blade to allow for the cutting of a reasonable neat
line trench, working with all motor grader wheels on the pavement.
The trenched out material will be fed along the motor grader
blade to form a windrow of material located inside the edge
of pavement.
c. The windrow of contaminated material will be mechanically picked
up and fed into trailing dump trucks by means of an Athey force-
feed loader. This loader operation forces the contaminated
material onto a self-contained belt conveyor by means of rotating
paddles. The material is conveyed up the belt and dropped into
dump trucks. A specially designed canvas shield will extend from
the top of the belt down into the dump truck bodies to prevent
wind drift of the contaminated material.
51
d. The Athey loader is designed to scrape the road surface;
however, very thin amounts of residue will be left on the
road surface following the loader operation.
Depending on soil moisture conditions, this residue will
be either water sprayed back into the excavated trench or
broomed, by means of a tractor mounted rotary broom or a
combination of both spraying and broomihg. Spraying will be
performed by a Hydroseeder with especially designed adjustable
outlet nozzles and the broom will be covered with a specially
designed canvas cover to minimize dt~ting and wind drift.
e. Reshaping of the disturbed shoulder area will immediately
follow the removal operation. Depending on the width and
cross slope of the existing shoulder, reshaping will consist
of either scarifying and reshaping of the shoulder by a motor
grader, or filling in the excavated area with borrow soil
material and shaping with a motor grader.
f. The shoulder reshaping operation will b~ followed by erosion
control operations consisting of seed b'ed preparation, seeding,
fertilizing and mulching of all disturbed areas.
4. Transport
Once the contaminated material is deposited in dump trucks, the
dump bodies will be tightly covered with tarpaulins using elastic tie-
downs. Insofar as possible and practical, contaminated material will
be hauled to the disposal areas along rural routies, avoiding highly
congested areas. Hauling of contaminated materi al will take place only
during daylight hours.
Vehicles equipped with mobile radio units will routinely survey the
haul routes for trucks with mechanical difficulty. In the event of
mechanical trouble, mechanics will be radio dispatched.
5. Disposal Method
a. Construction Procedure
The disposal site for the PCB contaminated soil is located on
approximately 142 acres of land in Warren County.
The State of North Carolina proposes to construct the PCB landfill
in accordance with plans approved by EPA.
52
Need for the Proposed Action
Polychlorinated biphenyls are highly stable compounds that will remain
unchanged in the environment for a very long time. PCB will biologically
magnify in food chains and accumulate in the fatty tissue of both humans and
animals. The long term effects of human and animal exposure to low levels of
PCBs are not clearly documented; however, studies using laboratory animals
have shown potential chronic effects such as cancer induction, pigmentation,
and behavioral changes. The Pen contaminated soil may become translocated
into adjacent agricultural crop lands and may have an impact on agricultural
cash crops such as tobacco, feed and forage, and cr~ps for human consumption.
The State of North Carolina considers the removal of the PCB contaminated
soil a necessary action to insure the protection of the natural and human
environment.
In addition to the above reasons for removal of the PCB contaminated
soil, the North Carolina Department of Transportation must periodically reshape
shoulders and ditches adjacent to state highway system travelways in order to
maintain safe egress for the traveling public and to maintain proper cross
slopes for storm drainage. While these operations are closely followed by
necessary erosion control measures to stabilize the loosened soil, there
nevertheless follows a period of time during which the shoulders and ditches
are susceptible to erosion. In addition normal deterioration of the highways
caused by traffic, climate and age will require future modifications to the
contaminated areas including resurfacing and possible widening and realignment
of the highway facilities. All of these operations would tend to redistribute
the contaminated soil in a manner which would be very difficult if not impossible
to control.
The presence of PCB contaminated material along, state highway system
routes has caused the Dc,artment of Transportation to disallow all encroachment
requests along those roadway shoulders which involve activities requiring
excavation or redistribution of the soil structure. This has included place-
ment of utilities and commercial and private driveway pipes. These activities
involving the roadway shoulders are necessary in order to provide needed
services to property owners located adjacent to PCB spill areas.
53
F. PROJECT MANAGEMENT PLAN
The overall coordination/management of all the remedial projects relative
to the cleanup of PCB's dumped along North Carolina highway shoulder shall be
the responsibility of the designee of the Secretary of thie N. C. Department of
Crime Control and Public Safety. (see I-B Lead Agency) Said designee shall
serve as State Project Officer (SPO) and will utilize an inter-disciplinary
team with representatives from the Governor's Office, At~orney General's Office,
Department of Human Resources, Division of Health Services, Department of
i~atural Resources and Community Development, Division of Environmental Management
and the Department of Transportation, Division of Highwa~s.
The general areas of responsibility of the other state agencies shown on
the "Management Plan" are as fol lows:
1. Governor's Representative -to keep the Governor and the appropriate
members of the Governor's Office updated on the project and to relay
guidance from the Governor to the State Project Officer.
2. Attorney General's Representative -to serve as legal advisor to the
State Project Officer.
3. Controller's Office, CC&PS -to receive and disperse all funds (state
or federal) allocated to the project and prepare fiscal reports as re-
quired, as well as serve as fiscal advisor.
4. Department of Transportation -to remove, haul and deposit in the land-
fill the PCB contaminated soil from the highway shoulder, and to recon-
struct said shoulders.
5. Department of Human Resources -to oversee the construction and operation
of the landfill, and to develop and carry out a Public Information/
Community Relations Plan.
6. Department of Natural Resources and Co1T111unity Development -to coordi-
nate all sampling along the spill sites,including the actual pick-up of
samples and delivery to vendor for analysis.
-54-
I I U'I ~ )::o I Pick-Up ---DOT Governor's Representative Attorney Gen. Renresentative Landfi 11 ---OHR Inspections Construction Vendor Vendor MANAGEMENT PLAN Overal 1 Coordination CC&PS Sampling Pick-Up NRCD ---NRCD Analysis Vendor CC&PS -Department of Crime Control and Public Safety DOT -Deoartment of Transoortation OHR -Department of Human Resources NRCD -Department of Natural Resources and Community Develooment Budqet Controller Public InforMation/ Community Relation Community Relations Vendor ---OHR Public lnformati on OHR
G-Safety Plans
The state will prepare safety plans for each work activity
and contract to protect the health and safety of personnel
involved in on-scene response actions, as we l l as the public.
The state safety plan will comply with section lll(c)(6) of
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, EPA order 1440.2 Healt h and Safety
Requirements for Employees Engaged in Field Activities,
EPA Order 1440.1 Respiratory Protection, EPA Occupational
Health and Safety Manual and EPA Interim Standard Operating
Safety Procedures.
55
H. Work Plan
56
WORK PLAN Activity: Community Relations Name of Project: fASK NO. DESCRIPTION OF PLANNED TASKS A. l Prior notification of PCB cleanup and timetable to all state, county and local officials in the cleanup area. A.2 Notification by mail to those persons in the affected communities who have indicated a continuing interest in the PCB issue. A.3 Press announcement of the approval and implementation of the PCB cleanup A.4 Preparation and release of informational packet ,1 on PCB dumping and cleanup • A.5 Press releases and briefings as necessary A.6 Announcement of completion of PCB pi-ckup and closeout of landfill. N.C. PCB Clean Up Work Yrs: OUTPUT Letter Letter Press release, possibl◄ media briefing Press release Briefing Release Activity: Funds: ($000) 20. 7 SCHEDULE START COMPLETE
Task No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. WORK PLAN Activity: Project Scheduling N3me of Project: Description of Planned Tasks State notifies EPA two weeks prior to initiation of project construction State notifies contractor to initiate project construction (minimum 5-day notification) State implements pre-pickup monitoring Contractor initiates site construction Contractor installs groundwater monitoring wells State establishes surface water monitoring stations State samples ground and surface water State submits ground and surface water monitoring data to EPA State notifies EPA of intent to initiate pick up and disposal phase Contractor completes construction of landfill State starts pick up and disposal phase State implements post pick-up monitoring State monitors ground and surface water N. C. PCB Clean-U£ Work Yrs: Output EPA Notification Contractor Notification Pre-Sampling Construction of Site Installs Wells Identified Sampling Data Submitted EPA Notification Landfill ready Pick-up Post Sampling Sampling Start -14 -5 0 0 0 7 35 36 50 50 50 58 Activity: Funds:· SCHEDULE B 0 Complete 0 0 64 124 7 14, 21, 28 35 92 92 58
V, \0 Task No. 19. 20. 21. 22. 23. 24. 25. 26. PROJECT SCHEDULING (continued) Description of Planned Tasks I Output State submits ground and surface monitoring data to EPA I Data Submitted Final cover construction completed Site closure initiated Site closure completed State monitors groundwater and surface water Landfill project completed State submits ground and surface water monitoring data to EPA Project completed Site Closed Sampling End Data Submitted ACTIVITY B Start 95 103 104 124 124 124 130 130 SCHEDJ.JLE Complete 95 124
WORK PLAN Landfill Construction Activity: & Eng. Supervision Name of Project: trASK NO. DESCRIPTION OF PLANNED TASKS N.C. PCB Clean Up --------------Work Yrs: -----OUTPUT Activity: C Funds: ( $000) 450 SCHEDULE START COMPLETE l 2 3 4 5 6 6a 6b 6c 6d 6e (J [ 6g 7 8 9 10 11 12 Access road construction Soil Erosion Control devices installed/constructed Clearing and grubbing procedures Groundwater monitoring wells constructed Excavation and stock piling Landfill construction to receive contaminated soil Install lower leachate collection system Install 30 mil. PVC bottom liner Install 12 inch soil layer for PVC liner protection Construct 5 foot thick clay liner Install upper leachate collection system Install filter fabric for leachate system protection Install carbon filter system Placement and compaction of PCB contaminated soil Place carbon filter system and contaminated sediment from erosion control devices in landfill I Construct final cover and install upper PVC liner and gas VP.nt I Perform final soil erosion control procedures in-eluding seeding I Install chain link fence General clean-up Access site Prevent erosion Site cleared Sampling capability Pit construction Ready to receive contaminated materials PCB material landfillei I Finish construction I Close site I Prevent access Final activities I I I 0 0 0 0 0 • 0 51 86 93 104 104 104 I I I 50 50 50 7 50 50 92 92 103 124 124 124
0-, I ..... WORK PLAN Activity: Samili.!J..g Name of Project: N.C. PCB Problem Activity: D Work Years: l.O • Task No. I Description of Planned Tasks l I Develop monitoring strategy and procedures. 2 I Acquire necessary supplies. 3 4 5 6 7 8 I Identify and sample beginning and ending points of all contaminated road segments. Survey all significant erosion sites. Sample all erosion areas. Evaluate laboratory results. If necessary conduct additional sampling. Conclude activity. Funds ($1,000): --~_..:l __ _ Out Put -Work Plan Supplies Map 81 Samples Map \fork Pl an I 80 Samples Report and Recommenda-tion 39 Samples Final Report I Start 0 0 8 8 28 44 56 56 ---Schedule (Day~J I Com leted 7 14 21 21 42 55 106 l 09 ._ _____ _.J.__________________ -------------------'----------------'----------~-J
0-, N ~~ORK PLAN Activity: Lab Analysis Name of Project: N.C. PCB Problem Activity: 35 E --~-Work Hours : Contract .. Task No. I Description of Planned Tasks 1 I Submittal of roadside monitoring samples to EPA for analysis by EPA contractors. Funds ($1,000): Out Put 200 Samples Results Start 8 Schedule (Days) Completed 106 L ____ ___JL_______________ ·-·--------------··------L---··--------1------------~-----------
WORK PLAN Name of Project: N.C. PCB Clean up Activity: F Activity: Removal, Transportation & Disposal Work Yrs: ____ _ Funds: ( $000) $1,240 !TASK NO. F .1 F.a F.j F.li F.5 F'-6 F.7 F.9 F,9 F .10 r.11 DESCRIPTION OF PLANNED TASKS Const. Landfill Access Rd. Pre Sample-Test to determine beginning and ends of strips (210 miles) (By environmental management division) Wet down contaminated soil in test strip ( _ mile) Remove contaminated soil from test strip (3"x30") / feed to inside edge of pavement OUTPUT Road Acess Identify beginning and ends of strips Dust control Remove test strip soi]i Mechanically pick up '4ndrow of contaminated material I Load from pavement Load on trucks -Broom or spray pavement residual in cut Transport contaminated test strip soils to landfill Test bottom of excavation strip to determine down to 49 parts per million or less Remove additional material from bottom of excavation if necessary Clean up pavement Transportation of contaminated soils to landfi 11 test to insure con-taminated soils remove! Check Wet down contaminated soil from remainder of 210 I Oust control miles Remove contaminated soil from remainder of 210 mile11 Remove test strip soil feed to edge of pavement SCHEDULE START COMPLETE
~ -WORK PLAN Activity: Removal, Transportation & Disposal (continued) Name of Project: :TASK NO. DESCRIPTION OF PLANNED TASKS F 12· Mechanically pick up windrow of contaminated material from pavement/ load on trucks Fl3 Broom or spray pavement residual in cut F14 Transport contaminated test strip soil to landfill I N.C. PCB Clean Up ActivHy: F Work Yrs: -----Funds: ($000) $1,:::40 OUTPUT SCHEDULE START COMPLETE Load Clean up pavement Transportation of soil to landfill ' I I
~ ~ 1 1 Shoulder Reconstruction Act V ty: WORK PLAN Name of Project: N.C. PCB Clean up Work Yrs: rASK NO. DESCRIPTION OF PLANNED TASKS OUTPUT G .1 Reshape shoulder or fill in excavated area and re-Filled in excavation shape (210 miles) area G.2 Seed,fertilize and mulch disturbed area for erosion Erosion control control (210 miles) . Activity: G -----Funds: ($000) $800 SCHEDULE START COMPLETE .
Activity: Task No. -1. 2. 3. 4. J 5. 6. 7. 8. WORK PLAN Landfill Monitoring N:lme of Project: N. C. PCB Cleanu£ Activity: H Work Yrs: Description of Planned Tasks Contractor installs groundwater monitoring wells State establishes surface water monitoring stations State samples ground and surface water State submits ground and surface water monitoring data to EPA State monitors ground and surface water during placement of materials in landfill Data submitted to EPA Submission of records to EPA as per 43 FR 761,45(b)(3) State samples surface and ground water twice a year Funds: SCHEDULE (Day) -. Output IS tart Wells Installed I 0 Station Locations I 0 Identified Samples collected I 7 for baseline data Submission of Baseline I 35 Data to EPA 58, 88 65, 95 Data submission to EPAI 95 Perpetual sampling Complete 7 7 14, 21, 28 35 58, 88 65, 95 185