NCD980602163_19820819_Warren County PCB Landfill_SERB C_Re June 4 1979 and December 14 1981 letters-OCR

North Carolina Department of
Crime Control ~
. . & Public Safety·'
512 N. Sahsbury Street P. 0 Box 27687 Raleigh 27611 -7687 (9 J 9) 73:i ? ; '!t'i
James B, Hunt, Jr., Governor · rk, .S1:c:•2tary
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Mr. Charles R. Jeter
Regional Administrator
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
Attn: James H. Scarbrough
August 19, 1982
Re: N.C. Superfund Project -PCB Landfill
Dear Mr. Jeter:
AUG 20 1982
~
TT~~ -=
As part of the Environmental Protection Agency's approval for
North Carolina to construct and utilize a landfill to dispose of PCB
contaminated soils, two letters dated June 4, 1979 and December 14,
1981 were issued from the regional administrators outlining specific
approval conditions. The following addresses North Carolina's current
status in complying with the conditions summarized in the December 14 ·
letter;
I. Reference June 4, 1979 approval letter signed by John C. White
A. General Requirements
1. Notification was issued concerni ng intent to begin land-
fill construction by letter dated June 4, 1982 from
0. W. Strickland to J. H. Scarbrough and by letter dated
June 7, 1982 from W.W. Phillips to A. R. Hanke. Landfill
construction started June 21, 1982.
2. Notification was issued concerning intent to begin dis-
posal of waste at landfill on August 16, 1982 by letter
dated August 2, 1982 from 0. W. Strickland to J. H.
Scarbrough and by letter dated August 9, 1982 from W. W.
Phillips to A. R. Hanke. Date of beginning waste dis-
posal has been postponed until after August 23, 1932.
Mr. Jeter
Page 2
August 19, 1982
5. EPA will be notified immediately of any deviations from
any approved conditions or procedures.
Conditions numbered 3, 4, and 6 were waived in the December 14, 1981
approval letter.
B. Technical Conditions of Approval
1. The condition to control water runoff totally inside the
landfill appears to be more appropriate for the original
conceptual landfill design that did not utili ze sidewa l l
lining. We are requesting a clarificati on i n writing
as to how North Carolina should comply with this condition.
2. Soil and Material Engineers, Inc. has been employed to
provide quality control for the clay liner construction.
3. North Carolina has employed Sverdrup & Parcel to assure
that the landfill construction proceeds according t o the
EPA approved specifications.
4. Efforts are being made to place a record in the property
deed identifying the waste disposal area.
6. The EPA approved construction documents speci fy the use
of rubber tired vehicles as the means to compact waste
materials (section 2.7.4). The referenced approval letter
specifies the use of tracked equipment. North Carolina
would like to have the option of choosing the method(s)
of waste compaction as its engineers deem best. We would
appreciate your concurrence in writing or clarification
of these contradicting approval conditions .
7. Approval was given to the conceptualized erosion control
plan by John Holley(Land Quality Section, N.C. Department
of Natural Resources and Community Development)on December
9, 1981. Mr. Holley made a site visit on Aug us t 3, 1982
and felt that there was no infraction of the N.C. Sedimen-
tation Control Act.
8. It is the intention of the N.C. Department of Transportation
to have all trucks carrying waste materials to be covered .
9. The December 14, 1981 letter indicates this condi ti on has
been satisfied.
10. The December 14, 1981 letter indicates this condition has
been satisfied.
Mr. Jeter
Page 3
August 19, 1982
II. Additional Conditions of Approval
A. North Carolina will monitor leachate collection systems monthly
and dispose of any collected leachate as per 761.4l(b)(71).
All records will be maintained by 0. W. Strickland(Solid and
Hazardous Waste Management Branch, N. C. Department of Human
Resources).
B. North Carolina through on-site representatives and t he firm
Sverdrup and Parcel, will assume compliance with the approved
plan.
C. North Carolina feels that waste concentrations and volumes are
adequately reported in the Environmental Impact Statement.
Should you not concur with this opinion, please advise in writ-
ing.
D. The all weather access road has been constructed . The fence
and gate have not been constructed yet. These will be
adequately maintained to insure their functions .
E. North Carolina will notify EPA immediately of any de t ection
of PCBs in the monitoring program.
F. 0. W. Strickland will be responsible for post closure monitor-
ing.
G. North Carolina will notify EPA of any intent to change owner-
ship of the site.
H. All monitoring activities are being conducted in accordance
with EPA approved procedures. Replacement monitoring wells
will be sampled as indicated in the July 2, 1982 letter.
Stream samples are collected at locations indicated in John
E. Dickinson's letter of April 21, 1982 to 0. W. Strickland.
Conductivity and pH measurements at the existing monitoring
wells and the stream sampling locations were not taken at the
same time as samples for PCBs. This deviation was approved
by Don Hunter to Tom Karnoski via telephone on July 28, 1982,
and by Jim Scarbrough at a meeting with 0. W. Strickland on
August 5, 1932.
I. Saturated hydraulic conductivity measurements of the clay
liner (1 per 25,000 ft.2 of liner) will be sent as they be-
come available.
Mr. Jeter
Page 4
August 19, 1982
If you have any questions or if I can clarify any issues con-
tained in this letter, please contact me .
WWPjr:jj
cc: Bill Raney ✓
0. W. Strickland
Tom Karnoski
Bob Adams
Frank B. Rainey
Al Hanke
Jack Reavis
Sincerely,
wf6.l{~fa,
Assistant to the Secretary