NCD980602163_19820929_Warren County PCB Landfill_SERB C_Herman R. Clark letter to Rep. Walter Fauntroy - Site Selection Summary-OCR

North Carolina Department of
Crime Control~
512 N. -bury SI}} I;p~!L cR§~[';JY~19/ 1m126
James 8. Hunt, Jr., Governor
September 29, 1982
Delegate Walter Fauntroy
U. S. House of Representatives
2350 Rayburn House Office Building
Washington, D. C. 20515
Dear Delegate Fauntroy:
.,.
Heman R. Clark, Secretary ' •
Governor Hunt has asked me to respond to your inquiries about the Warren County
PC~ landfill near Afton. This Department is responsible for the coordination of
this highway clean-up project. I welcome this opportunity to give you this overview
of the problem and its solution.
First, please understand the origin and scope of the problem. In the summer
of 1978, over 200 miles of public road shoulders were contaminated with 35-40,000
gallons of PCB-laced transformer oil by criminals who have since been prosecuted in
Federal and State courts. These highways were situated in fourteen counties, in-
cluding .Warren County.
The State moved i:nme rl iately to remove the public health and environmental threat
posed by the exposure to ~~is uncontrolled and unmonitored roadside PCB contamination.
Our technical and professional people, in consultation with officials of the
U.S. Environmental Protection Agency, reviewed all options available at that time.
Under E.P.A. regulations promulgated pursuant to the Toxic Substance Control Act for
the proper handling of such contamination, there were only two options. One was to
do nothing and leave the public, including school children, and homes up and down
the highways exposed. The other was to place the contaminated soil in a secure
well-designed landfill removed from all access. Governor Hunt applied to E.P.A. at
that time for a variance from their regulations to allow the State to treat the
PCB-laced soil in place. This petition was denied by E.P.A. on June 4, 1979.
At that juncture, Uorth Carolina asked for citizens in the affected fourteen
counties to offer sites to be considered for construction of a landfill for the
contaminated soil. More than 100 sites were suggested and they were evaluated on
a stringent set of criteria for suitability for such a landfill. The Warren County
site proved to be the best site based on evaluation of all the criteria. It has ·
soil more than adequate with which to construct the landfill, the lay of the land
is good, i.e •• the landfill is built on a ridge where water naturally runs offi
Delegate Fauntroy
September 29, 1982
Page 2
the separation of the water table from the landfill was good; the site was large
enough for the actual landfill and a good buffer zone and it was isolated.
The actual design bf this landfill is the new and improved state of the art.
It has a multiple defense system to preclude PCB from leaching out of the fill
area--a five-foot thick, compacted clay liner which allows water through it only
at a rate of one one-hundredth of a foot per year and a plastic liner as a second
layer of defense under that. All this will be-.capped with a plastic liner and
clay liner to keep water out. The material going into the landfill is going into
it in a dry state. It is PCB mixed with 40,000 cubic yards of soil, not liquid
PCB. Nothing is being put into the landfill to make it become liquid and all
liquids will be precluded from getting into the landfill once it is capped.
We also have installed methods of detecting if anything goes wrong with the
landfill. There are two leachate collection systems in the landfill itself; one
under the contaminated material, the other below the plastic liner. The landfill
bottom is sloped toward these collection systems, and we will be able to detect,
and remove, an accumulation of moisture if it does occur. Also, four monitoring
wells have been stationed around the landfill. They will be checked periodically
to see if anything is escaping from the landfill.
The likelihood of this happening is nonexistent. This landfill is safe and
will protect the environment and citizens in the area. I believe even the Warren
County Citizens Against PCB will agree this is the best landfill that can be built.
While we were in Federal court testing every aspect of this project, numerous
proposals to treat PCB by incineration or biological detoxification were studied.
Incineration is prohibitively expensive and not really suited to dealing with PCB
mixed with soil. Not one proposal for biological treatment of PCB mixed with soil
has proven acceptable to E.P.A., and none received sanction from that organization
for use in our situation. Truly, the only option we have is to landfill the PCB
contaminated soil.
The issue here is not civil rights, nor is it a race issue. It is a public
health issue. PCB left on more than 200 miles of our roadside in an uncontrolled,
unmonitorable condition threatens hundreds of thousands of our citizens who live
along those roads or travel upon them. North Carolina has taken the only responsible
course left open to deal with this health threat. It is removing the health threat
from our highways and securing it in a well-designed, secure landfill which will
keep the PCB away from our people and environr.1ent.
All aspects of this project are explained in detail in our Application for
the Cooperative Agreement with the U.S. Environmental Protection Agency. We will
be glad to send you a copy of the environmental statement and any other data upon
request.
I sincerely believe that once the high emotions, fear, and misunderstanding
abates in Warren County, the people of that county will understand that the State
. •
.
I
... ,J)elt:'gate Fauntroy
September 29, 1982
,Page 3
acted responsibly and did what it• had to do to protect the people in Warren County
as well as other areas of the state.
Please call if I can be of further assista t·. ~
i ce ely your,,
--
HRC/rab
SITE SELECTION SUMMARY
Approximately 90 sites were evaluated under these standards. Sites
on state property and private property with a relatively high probability
of meeting the standards were evaluated by boring for water table and soils
information. Eleven sites were initially tested. Six of these sites were
further evaluated and technically ranked in approximate relative priority.
The state ranked Person and Warren sites as approximately equal with respect
to soil standards and above all other sites. EPA concurred with this
technical ranking.
At this time, the state evaluated 11 county sanitary landfills for
potential utilization for a potential site and found that the soils were
too permeable or water table too high relative to the other sites under
evaluation. The state further evaluated the Chatham and Warren sites for
technical suitability. In the final ranking with EPA and consideration
of all criteria, Warren County met more conditions than any other site
and was selected by the state (or presentation to· EPA as · the most. suitable
for permitting.
Final site selection was made by evaluation of all site criteria and
selection of the best available site. Some sites had one site criteria
that may have been technically superior to a site ranked higher in priority,
but in reviewing all criteria, Warren County was the most ideal site.
The Warren County site offered the best protection of public health and
the environment.
SITE SELECTION FOR PCB LANDFILL
The Department of Human Resources' Solid and Hazardous Waste
Management Branch had considerable field expertise in evaluating
potential landfill sites. The Branch was directed by the Department
of Crime Control and Public Safety to locate potential PCB landfill
sites. A procedure was established to locate and evaluate potential
sites. The procedure establishedincludedPCB landfill regulations
for site criteria and knowledge gained from past experience with
locating landfills. These procedures included:
ELEMENT
1. Size
2. Isolation (human population)
3. Relief (scope of land)
4. Soils
Type
Amount
STANDARDS
Large enough to construct and protect
disposal area.
Minimum -16-20 acres.
Maximum -dependent upon land available and
layout of land, need for extended buffers.
Number of homes within one mile.
Transportation routes with respect to population
density.
Low to moderate.
5 to 20% slope, avoid areas that can cause
slumping or sliding and increase erosion.
High silt and clay content.
Maximum rate of water infiltration less than
0.1 inch per year.
More than 30% silt and clay (fine soil particles).
The silt a~d clay must hold at least 30% moisture
without flowing in order to meet liner
construction standards.
The silt and clay must have a 15% moisture range
or flexibility to meet liner construction
standards.
Sufficient soils on site to construct all required
protection structures (liners, berms, dikes,
and topsoil).
. '
ELEMENT
Surface Water Protection
Groundwater Protection
Topographic Position
STANDARDS
No direct connection to streams or springs above
100-yr. floodplain.
No direct runoff to surface drinking
water supply.
Minimum of½ mile from All stream (stream that
may be future surface water supply).
Not located in public water supply watershed.
Maximum practical separation, 10' minimum
(from waste).
No private well within 500'.
Location in area of minimum potential rainfall
infiltration and movement to groundwater.
Isolation of recharge area -location such that
rainwater and groundwater that occurs off-site
does not pass through site for groundwater
fluctuation control.
Isolation of direction of discharge of groundwater
so that it cannot impact water supplies.
Predict maximum upward fluctuation to give minimurr
of 10' separation.
Priority: Flat -lowest
Side slopes -better
Hill or ridge -best
• A
Access Nearest paved road.
Existing road to disposal area.
Ease of constructing road to disposal area.
Ownership of access property to disposal site.