NCD980602163_19821210_Warren County PCB Landfill_SERB C_EPA Region IV Response to 16 Oct 1982 letter re PCB Landfill-OCR

,ftO S7-4,-->"" ~,S' ~ ft ~ ~ ~Ttt w UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \ ~ <",i, ,, ,.◄l Pf!01tC, RE G ION I V
DEC 1 o 1982
REF: 4RC
Mr. James M. Johnson
Chairperson
34!5 COURTLAND STREET
ATLANTA. GEORGIA 3036!5
Residents Engaged in Action
for a Cooperative Hollister
Littleton Road, Box 45-C
Littleton: North Carolina 27850
Dear Mr. Johnson:
This letter responds to your letter of October 16, 1982, to
Ms. Anne Gorsuch, Administrator of the u. s. Environmental
Protection Agency, in which you voiced concern about the Warren
County, North Carolina, PCB landfill. I appreciate your
concern and would like to address your comments.
In June 1978 liquid materials containing PCBs were
discharged onto roadsides of the military reservation at Fort
Bragg, in Cumberland County, near Fayettevil le, North
Carolina. Shortly thereafter, complaints were received from
various areas of eastern and Piedmont North Carolina of like
occurrences. From Warren, Johnston and Harnett counties in the
east and from Lee, Chatham and Person counties in the Piedmont
area, reports came into Raleigh of roadside areas saturated
with an oily substance later identified as containing PCBs. In
all, fifty one separate sites in fourteen counties were sprayed
with the contaminant. A thorough investigation by State and
Federal officials determined that the substance was used oil
removed from transformers at Ward Transformer Company in
Raleigh and disposed of by a private contractor. Federal
indictments arising out of the incidents resulted in guilty
pleas or verdicts of guilty against all of those allegedly
involved.
As soon as the substance was identified as PCB, studies and
tests were begun to determine the safest, most feasible, and
economical way of dealing with the 210 miles of contaminated
roadside. Knowledgeable experts in the field were either
brought in or contacted in an effort to determine whether it
would be best to treat the soil in place or remove it for
burial or incineration.
It was subsequently determined that alternatives to a
landfill would not be effective or feasible. The tc:.sk thus
began of selecting a suitable landfill site. The State of
North Carolina began the site screening process with some
ninety potential sites. The State eliminated the great
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majority of these sites from consideration on the first
screening because they failed to meet the requirements for a
PCB landfill. As a result of further screening, the State
narrowed the original list to only a few possible sites that
were suitable (i.e., had adequate soils for liner construction
and were large enough to accommodate the landfill and
surrounding buffer zone).
After the State of North Carolina sele~ted the Warren
County, North Carolina, site, the State prepared an application
for the site and submitted it to EPA, Regi0n IV, in December
1978. The application was subsequently apwroved after
extensive review in accordance with existing regulations
promulgated by EPA under the authority of the Toxic Substances
Control Act (TSCA). A Federal district court upheld EPA's
approval in Twitt , et al., v. State of North Carolina, et al.,
527 F.Supp. 77 (E.D. N.C. Warren oun y v. tate of
North Carolina, et al., 528 F.Supp. 276 (E.D. N.C. 1981). In
August 1982, the same court reaffirmed its decision in a
separate suit brought by the Warren County Chapter of the
National Association for the Advancement of Colored People.
The Warren County landfill was designed for one time use
only to contain the PCB contaminated soil from the contaminated
North Carolina roadsides. The landfill as designed and
constructed is safe and environmentally sound and presents no
threat to the local ecology or water supply.
The landfill was constructed with major emphasis on the
protection of surface water and groundwater from potential
contamination from the material buried at the site. The design
incorporates an artificial liner and five foot compacted clay
liner below the landfill to prevent hydraulic connection with
groundwater and an artificial liner and two foot compacted clay
liner on top of the landfill to prevent infiltration of rain
and surface water.
There are also leachate collection systems installed above
and below the bottom liners to remove any leachate. This
system will be monitored monthly. In addition, there are
groundwater monitoring wells installed around the site which
will be sampled on a monthly basis during operation or for a
period of one year, whichever is shorter, and semi-annually
after closure. Surface streams located downgrade from the site
will be monitored monthly during operation of the site and
semi-annually during the post-closure period. The disposal
site design, therefore, provides for stringent environmental
isolation of the PCB contaminated soil.
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I trust this information is useful to you. If I can be of
further assistance, please let me know.
n~~~
nal Ad~-=or
cc: North Carolina Department of Human Resources
North Carolina Department of Crime Control
and Public Safety