NCD980602163_19830112_Warren County PCB Landfill_SERB C_Correspondence with Rev. J. Clinton McCann-OCR

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~'-~} UN fTED STATES ENVIRONMENTAL PROT ECTION AG ENC
'°1,, (,,,--REG I ON I V 4l PRO'\.
JAN 1 2 1983
R8F: 4RC
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
Rev. J. Clinton Mccann, Jr.
Pastor
Warrenton Presbyterian C~urcn
Wctrrenton , North Carolina 27589
Dear Rev. Mccann:
Thank you for your letter of November 29, 1982, L1 whic i1 you
respond to my letter of November 3, 1982, regarding th e Warren
County PCB l a ndfill. I appreciate receiving the benefit of
your v~ and opinions .
As I indicateJ in my prior lette r, however, I beli eve tne
Warren County landfill as designed and constructed is aafe and
environmentally sound and presents no threat to the local
ecology or ~ater supply.
Once again, I wa nt to t~ank you for your continuing inte rest in
this matter and your thoughtfulness in provijing me with your
comments.
Sincerely ,ours,
c11ar esd✓
Reg·onal Aaministrator
cc: North Carolina Department of Crime Control
ana Public Safety
North Carolina Departme,1t of Humaa Resources f=-
/
/
~arrenton ~resbptertan Qtburcb
WARRENTON, NORTH CAROLINA 27589
[phone]
~ovenber 29 , ~982
Mr . Charles R, Jeter, Regional Adrn lnis~ra tor
U. s. Environmental Protection Agenc y, rte~ion I V
J45 Courtland Street
Atlanta, Ga. 30J65
Dear Mr . Jeter:
Thank you for your letter of Novembe r 3, '.i..982 in response to the
Littleton Ministerial Fellowship's resolution ln opposition to the
disposal of PCB-contaminated soil in tr.e Afton cor:ununity of ·•,!a :r:ren
County.
The "Environmental Assessment" which Y'"'U enclosed was very helpful;
howeve r, it did not serve to allay my fears completely. I a~ still
quite concerned about th e following two po ints:
1) The docunent falls to define what precisely is meant ~Y the
stater.ient that the dump in Afton "does not present an unreaso~able
risk of injury to public health a!1d the enviro!"'.:r:ent."(p. 7) ·rhis
stateme nt implicitly admits that some risk to public health is posed
by the landfill. Since t~is is the case, it would seem tone that
the local residents should have the right to decide what is a
"reasonable" or 11 unreasonqble11 risk to their own health, safety ,
and environment.
2) On p. 14 of the document, there ls the follo;.ring staterient:
"The requireJ:1ent that the bottom of the waste cell nust be located a t
least 50 ft. from g round1:Ja ter was waived . 11 The r ationale given for
this waiver is that sufficient protection is provided by the clay
liner, the p lastic liner, the leacr.ate collection system, and the
~onitorlng wells; the docume nt s pec ifies tha t this waiver has been
"reasonably deterr1lned. 11 The matter, however, is not so simple nor
clear-cut. Clay liners and pl astic liners have not proven to be
sufficient protection i~ other l andfills. Leachate c ollection
systems have become clogged and ineffective, and mon itori~g wells
often do not detect what ~i~ht be significant leaching . Given the
current state of the a rt in landfill t e c~nology , and given the
poor record of landfills to this po int, the only reasonable
conclusion is that one shoul d be as caut ious as possible . The
decision to waive the 50 -ft . requirenent does not disp l ay the kind
of caut ion which I would prefer to see, and hence the decision does
not s eem to be one that was 11 re·:1sor.ahly deternined ."
I realize that t he illegal dunp ing of the .2CB arid th ,·ct existing
regula tions ha ve severely li~ited the options which were available
to the State of N. C. and the EPA, and I appr e cia te the care ful
attention which EPA hqs ~lven to t~is ~qtter. I urs e y ou , howeve r,
2
to c o nsider the possibiJity of 4ttempting t o detoxify ~~e Afton site.
I realize that t he ap uro p-i:-i -,,te technology does no t no·.1 e x i st . hut
I also understand th3t Steve Osborne of the Fr qnklin Je sea r ch Center
is still working o n ~)e rfect i ng t r,e Na.?::.:G r1ethod f or use ,.,,1th
PCB-contare inated soil. a rd thRt l~~Y Na ssaf of ~olybac Corp . is
experimenting with a ba cte rial ~et hod for detox ifying FCB -
contam lnated soil. When and if the se technolog ies be come feasibl e ,
I hope that the EPA will approve them, and I urg e the EPA t o apply
them to the Afton site, e ven if only on an expe rime ntal basis.
Detoxifica tion of t he Afton site wou ld appare r1tly rec_uire a wa iver
of the existing r egul at ion th ~t a capped site cannot be uncapped;
howe ve r, if wa ive rs could -be granted i n order to create the Afton
site. then it seems re"<sonable that waivers should be g ra!'l t ed in
order to detoxify tr.e Afton site.
In his October 20, 1982 Open Le tte r to the Citizens of Warren County ,
Governor J ane s :a . Hunt JT:.8.de t he f ollowing pro1:1ise : "The state will
pus h as hard as it ca n for detoxification o f t he l andf ill when and if
tr.e ap~Jr opri ate 8.!1d f easible t e c h!1ology is deve l oped ." I hope tha t
t he E?A wi ll work with t he State of N. C. and othe r i nte r ested partie s
to promote rese arch toward t h is end, and I hope :hat t he EPA will
t ake whatever actions rnight be necessary to move t owar d de toxifica tion
of the Afton site.
Again. thanks for your response. and for your continue d a ttention
t o th i s , mat t er •
Si ncerely .
'" 'i {; / ? ?if' / ,_ (,,,-,
. ~ -{i:,C,7--'i-1 / ' ( {>vc~,__"----h r/v. J. Clinton Hc Cann , J_p: 1
Secretary. Littlet on Min1steri a l
Fellowship
Pastor, Wa rrenton Presbyt e rian
Church