NCD980602163_19931210_Warren County PCB Landfill_SERB C_Correspondence, 1978 - 1993-OCR

10 December 1993
Ms. Vivian Jones, Director
Office of Environmental Justice
Region IV, US EPA
345 Courtland Street, NE
Atlanta, GA 30365
Subject: Warren County Community Assistance Project
Dear Ms. Jones:
During our discussion two weeks ago concerning the Warren
County PCB Landfill, you asked that I send you some additional
information about the situation. I don't yet have all the
information that you requested, but I want to send you that which
I do have in order for you to begin your process of deciding if an
environmental equity issue is at stake here.
First, let me briefly restate the situation. In the summer of
1978, PCB-contaminated oil was discharged from a truck along 270
miles of NC roadside. Using the State's prerogative of selecting
one site to be automatically included on the National Priorities
List (NPL), North Carolina chose this 270 miles of contaminated
roadside soil. The "site" was remediated in that the soil was
removed from the roadside and placed in a single-purpose, lined and
capped landfill in Warren County that was completed in 1983. At
the time, there was significant community opposition to siting the
landfill in Warren County, including nonviolent acts of civil
disobedience by citizens and some vandalism of the landfill liner
and access roads. In fact, more than 500 people were arrested
while protesting the decision to put the landfill in Warren County.
As a result, although the State believed that the landfill was
well-sited and capable of containing the wastes for a very long
time, Governor James Hunt promised the citizens of the county that
the waste in the landfill would be detoxified whenever the
appropriate technology became available.
The population of Warren County is approximately 38% white,
57% black, and 5% Indian and other. Many of the people in the
community protested the siting of the landfill not only because of
health and environmental fears, but also because apparently they
felt that the community was chosen as the site of the landfill
primarily because it was predominantly black and lacked political
power. In fact, as Rachel D. Gods*** notes in the November 1991
issue of the Michigan Law Review,
"In 1982, protesters applied the techniques of nonviolent
civil disobedience to a newly recognized form of racial
discrimination. The protesters, both black and white,
attempted to prevent the siting of a polychlorinated biphenyl
(PCB) landfill in predominantly black Warren County, North
Carolina. In the end, the campaign failed. Nonetheless, it
focused national attention on the relationship between
pollution and minority communities and prompted the U. S.
General Accounting Office (GAO) to study the racial
demographics of hazardous waste sites.
The GAO report found that three out of the four
commercial hazardous waste landfills in the Southeast United
States were located in majority black communities. Following
the GAO report, in 1987, the United Church of Christ
Commission for Racial Justice published a comprehensive
national study analyzing the relationship between race and the
location of hazardous waste sites. The Commission found that
race is the predominant factor related to the presence of
hazardous wastes in residential communities throughout the
United States a more significant factor than even
socioeconomic status. Responding to this finding, Reverend
Benjamin Chavis, Jr. coined the term "environmental racism,"
referring to both the intentional and unintentional
disproportionate imposition of environmental hazards on
minorities."
The citizens of Warren County continue to call for the
detoxification of the wastes in the landfill. They believe that
the time has come to review appropriate technologies and decide on
a course of action. The State of North Carolina is extremely
sensitive to this case of real or perceived environmental inequity
and is prepared to revisit the issue. In fact, Governor James
Hunt, now governor again, stands by his 1984 promise that the
wastes would be detoxified when appropriate technology became
available. To that end, the governor has appointed a commission to
decide how to detoxify the landfill. The community is represented
on this commission and will have a major voice in the decision.
Right now, we are searching for a way that the citizens of the
community can educate themselves about the different options
available to detoxify the landfill and be able to contribute
knowlegeably to the decision.
The project that we are trying to establish consists of
funding the community to hire an environmental consultant. This
consultant will represent the community's interest when reviewing
detoxification alternatives and will present and explain the
technical aspects, risks, and costs of each of the alternatives to
the community. In this manner the citizens can feel comfortable
that they are being represented and can make well-reasoned
contributions to the commission's decision making process.
Although the State will fund the project, if the resources can come
from a source outside the influence of the State, the credibility
of the consultant's advice will be greatly strengthened. Our
intent is to fund the project with monies not from State sources.
Other information that you requested is as follows.
1. The facility name is Warren County PCB Landfill.
2. The landfill does not have an address but is
located about 2 miles southeast of the intersection
of us 401 and SR 1604. The latitude is 36d 20m 13s
and the longitude is 78d 09m 58s. A map is
attached.
3. The detoxification of the landfill will cost an
estimated $7 to $15 million.
4. The community assistance project will cost an
estimated $50,000 to $100,000.
For more information on citizen concerns about the landfill
and the community assistance project, you can contact Mr. John
Humphrey, Director of Policy Development, NC Department of
Environment, Health, and Natural Resources, at [phone].
I am in the process of getting some demographic information
about the area around the landfill. I will send that data to you
as soon as it is available. If you have any questions, please call
me at [phone].
Attachmen,t
Sincerely,
Grover Nicholson
Environmental Engineer
NC Superfund Section
EXPANSION BUDGET 1993-94
DIVISION OF SOLID WASTE
The Division of Solid Waste Management requests appropriations
for equipment, installation and maintenance of this equipment, and
one (1) technician position as a Waste Water Treatment Plant
Operator II, for the PCB landfill in Warren County.
This landfill was established in the 1980's as a result of the
cleanup of PCB's which had been illegally disposed along over 200
miles of highways in the state.
The equipment costs for the first year are estimated to be
$160,000, and $60,000 the second year. This equipment will be for
the removal and treatment of potentially contaminated water which
is currently in the landfill. The operator costs are estimated to
be $35,000 per year, and would be terminated once the water is
removed and it is demonstrated that no further water is leaking
into the landfill.
It should be noted that without removal of this liquid,
further decaying of mRterial will occur in the landfill, and
potentially contaminated water may leak from the site and
contaminate area groundwater, resulting in a much more expensive
cleanup in the future.
..
DEPARTMENT EHNR PRIORITY PROGRAM NUMBER <FUNPl CODE 4 1760-7621 PRELIMINARY SUMMARY LIST OF EXPANSION BUDGET REQUESTS SOLID WASTE MGMT DMSION AGENCY OR INSTITCITION SOLID WASTE SECTION PROGRAM DESCRIPTION CCONCISE SENTENCES) Funding is requested to provide equipment (including installation and maintenance), and one technician position for a two year time period for the PCB landfill in Warren County. This will allow for removal and treatment of potentially contaminated water currently in the landfill. Clean up is necessary at this time to prevent groundwater contamination. Total Requirements Receipts Appropriations No. of Positions Capital Equipment Personnel ,./ ATIACHMENT13 BUDGEr O)DE ~ 1993-94 195,000 0 195,000 (1) 0 160,000 35,000 1994:95 95,000 0 95,000 (1) 0 60,000 35,000
I)fcAfT ,
----------
29 November 1993
Ms. Vivian Jones, Director
Off ice· of Environmental Justice
Region IV, US EPA
345 Courtland Street, NE
Atlanta, GA 30365
'·,.'
Subject: Warren County Community Assistance Project
Dear Ms. Jones:
During our discussion last week concerning the Warren County
PCB Landfill, you asked that I send you some additional information
about the situation. I don't yet have all the information that you
requested, but I want to send you that which I do have in order for
you to begin your process of deciding if an environmental equity
issue is at stake here.
First, let me briefly restate the situation. In the early
1980s, PCB-contaminated oil was sprayed from a truck along 210
miles of NC roadside. Using the State's prerogative of selecting
one site to be automatically included on the National Priorities
List (NPL), North Carolina chose this 210 miles of contaminated
roadside soil as its first NPL site. The "site" was remediated in
that the soil was removed from the roadside and placed in a single-
purpose, lined and capped landfill in Warren County. At the time,
there was significant community opposition to siting the landfill
in Warren County. As a result, although the State believed that
the landfill was well-sited and capable of containing the wastes
for a very long time, the governor at that time, Governor James
Hunt, promised the citizens of the county that the waste in the
landfill would be detoxified whenever the appropriate technology
became available.
r -~ -...... ~ \.' •~ .. <:••-i .... ~"-J, .. ;--. . • , : , • I • . . -.
About two years ago, the State discovered a significant amount
of water inside and at the bottom of the landfill. In effect,
water is trapped inside the landfill by the surrounding impermeable
liners. Although the State is confident that this water is the
result of the downward percolation of water from the heavy rains
that saturated the wastes during filling of the landfill, opponents
of the landfill interpret this data as showing that the landfill is
leaking. Even though the State and the county health department
completed an extensive sampling of water wells around the landfill
and found no PCB contamination, the community is distrustful of the
State and is convinced that the landfill is leaking and
contaminating local wells, and is calling anew for the State to
precede with its original plan to detoxify the wastes. Their
position is supported by Governor James Hunt, now governor again,
who stands by his promise that the wastes would be detoxified when
appropriate technology became available.
At this point, the governor has appointed a panel to decide
how to detoxify the landfill. The community is represented on this
panel, and will have &voice in the decision. Right~' we are
searching for a way~ the citizens of the community educate
themselves about the different options available to detoxify the
landfill and be able to contribute knowlegeably to the decision.
One of the community's complaints is that Warren County was picked
for the site of the landfill because its citizens are poor,
predominantly black, and don't possess much political power. Local
distrust of the State's decisions with respect to the landfill is
high. The project that we are trying to put in place consists of
funding the community to hire an environmental consultant. This
consultant will represent the community's interest when reviewing
5~ 1-detoxification alternatives and will educate the community about
the alternatives. In this manner the citizens can feel comfortable
that they are being represented, can develop a mutual trust and
understanding with the State, and can make well-reasoned
contributions to the panel's decision-making process.
Other information that you requested is as follows.
1. The facility name is Warren County PCB Landfill.
2. The landfill does not have an address but is
located about 2 miles southeast of the intersection
of us 401 and SR 1604. The latitude is 36d 20m 13s
and the longitude is 78d 09m 58s. A map is
attached.
3. The detoxification of the landfill will cost an
estimated $7 to $15 million.
4. The community assistance project will cost an
estimated $50,000 to $100,000.
For more information on citizen concerns about the landfill
and the community assistance project, you can contact Mr. John
Humphrey, Director of Policy Development, NC Department of
Environment, Health, and Natural Resources, at [phone].
I am in the process of getting some demographic information
about the area around the landfill. I will send that data to you
as soon as it is available. If you have any questions, please call
me at [phone].
Attachment
Sincerely,
Grover Nicholson
Environmental Engineer
NC Superfund Section
18 November 1993
To: Bill M I/
From:
Subject:
Grovere:::holsona4
Warren county co~nity assistance project
I talked with Rosemary Patton, Region IV, US EPA, on 17
November 1993. A TAG is not appropriate for this project
because:
a) the site is not an NPL site,
b) there is no EPA involvement in a clean-up at the
site, and
c) this is a new course of action, not application of
a ROD.
Rosemary suggested that I call Diana Hammer, National TAG
Coordinator, US EPA in Washington, DC. Diana confirmed that
this action would not be appropriate for a TA~. There may be
an alternative, however.
There is a new EPA program beginning called Applied Community
Technical Assistance (ACTA). It is designed to fund
universities to conduct "outreach" and "technical data
transfer" to communities. What this really means is still
being discussed, but the intent is apparently for universities
to provide education and technical training to communities
about cornmuni ty environmental problems. Diana thinks that the
Warren County project is a very good match for an ACTA program
project.
As I understand it, the program works by funding the five
national Hazardous Substance Research Centers (HSRC). These
HSRCs work with selected universities. The three in our area
are Georgia-Tech, LSU, and Rice. These universities in turn
provide outreach services to a community with an environmental
problem. It is unclear if the selected universities can
subcontract with local universities to provide services.
Right now, US EPA has committed $200,000 to the Sot'.lth and
Southwest Hazardous Substance Resource Center, a 13-state
region, for ACTA grants. The rules for providing these grants
are not yet written.
..
Diana thought that the Warren County project was a good
candidate for an ACTA grant. She suggested that someone from
here attend the next ACTA meeting and present the project in
detail. She thought that such a concrete example of how to
use the funds would help the ACTA committee write the rules
and may help us get a grant. The meeting will be held in
Washington DC on 6-7 December 1993.
\ OCT 071993 J
STATE O F N ORTH C ARO LIN A , /,
DEPARTMENT OF TRANSPORTATION '·~ ___ ,,_,.,,. .
jAM ES B. H UNT. j R. DIVISION Or HIGHWAYS
October 5, 1993
TO:.
FROM:
GOVERNOR
SUBJECT:
Mr. Steve Metcalf, Deputy Secretary De partment of Administration
G. B. Rose, County Maintenance Engineer Warren/Vance Counties
PCB Landfield Groundhog problem, upd at e
Traps have been set for catching groundhogs at the Land field.
Five groundhogs have been caught from September 4, 1993 through Octobe r 1, 1993.
We will conti nue to monitor and remove them fr om the area if possi ble .
GBR/lbr
cc : D. L. Wall, Di strict Engineer
C. E. Thompson, Road Maintenance Supe rvisor
L. E. Stegall, Di vision Engineer, 'p . E.
y'Larry Rose, Hydrogeolog ical Technician Solid Waste Sect·on
State of North Carolina
Department of Environment, Health, and Natural Resources
51 2 North Salisbury Street • Raleigh, North Carolina 27604
Division of Solid Waste Management
James B. Hunt, Jr., Governor [phone] Jonathan B. Howes, Secretary
July 21, 1993
MEMORANDUM
TO: Dennis Retzlaff, Health Director
Warren County .
FROM: William L. Meyer, Directoili j)., Mv1,QJ\/
Division of Solid Waste Management
3UBJECT: Procedure for notifying residents of results of analysis of drinking water wells;
information on constituents identified in two wells
The procedure for notifying residents by the Environmental Science Laboratory is as follows:
• original is mailed by lab to resident
• copy to Warren County Health Director
• copy to Environmental Epidemiology
• copy to Division of Solid Waste Management
• copy to Environmental Science Laboratory file
To the best of my knowledge, all residents should receive a copy within three to five days
of analysis by lab.
• Benzene hexachloride (BHC) is a commercial mixture of isomers of 1,2,3,4,5,6
-hexachlorocyclohexane insecticide
• "gamma-BHC is the chemical name for the insecticide Lindane. Lindane is
the common name or label name. Lindane is a restricted use insecticide
and toxic.
• "alpha BHC is an isomer that is typically or normally contained in Lindane as
part of the commercial mixture during the pesticide manufacturing process.
• Dieldrin: Label name of chlorinated insecticidal product, it is a restricted use
pesticide and can not be used for agricultural application.
PO Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax# [phone]
An Equal Opporrunity Affirmative Action Employer
Post-it" brand
Dennis Retzlaff
July 21, 1993
Page 2
• Unidentified peaks -
The Environmental Science Laboratory has
suggested resampling and investigation into
possible causes of contamination.
Environmental Epidemiology has considerable
expertise in investigating similar circumstances
and could be of assistance if you think they are
needed.
H you need any assistance from the Division of Solid Waste Management, please
let me know.
cc: John Humphrey, Policy Director
Department of Environment, Health and Natural Resources
Dr. John Freeman, Director
Environmental Epidemiology Section
John Neal, Branch Head
Environmental Sciences Lab
Fax ·rransrnittal Memo 1s12 No. of Pages ~ Today's Date ?-;;)./
To ~ U~:J.kd;d~
Compan/l{,)~
Location
From ~ /4~.n,Vv
Company • ;'
Location Dept. Charge
Fax# (119) ~S-1-~'!97 Telephone r91V :;s7-11F.5 Fax# 133-~j/0 Telephone#733-5LS7Y~
Comments .Al _ · Original. 0 Destroy O Return O Call for pickup ~ -D1spos1t1on:
a llcud~~/4~/or~~.
&,a
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh , North Carolina 27604
Division of Solid Waste Management
James B. Hunt, Jr., Governor [phone] Jonathan B. Howes, Secretary
July 21, 1993
MEMORANDUM
TO: Dennis Retzlaff, Health Director
Warr en County
FROM: William L. Meyer, Directotb JJ tv\V1,QJ\/
Division of Solid Waste Management
SUBJECT: Procedure for notifying residents of results of analysis of drinking water wells;
information on constituents identified in two wells
The procedure for notifying residents by the Environmental Science Laboratory is as follows:
• original is mailed by lab to resident
• copy to Warren County Health Director
• copy to Environmental Epidemiology
• copy to Division of Solid Waste Management
• copy to Environmental Science Laboratory file
To the best of my knowledge, all residents should receive a copy within three to five days
of analysis by lab.
• Benzene hexachloride (BHC) is a commercial mixture of isomers of 1,2,3,4,5,6
-hexachlorocyclohexane insecticide
• "gamma-BHC is the chemical name for the insecticide Lindane. Lindane is
the common name or label name. Lindane is a restricted use insecticide
and toxic.
• "alpha BHC is an isomer that is typically or normally contained in Lindane as
part of the commercial mixture during the pesticide manufacturing process.
• Dieldrin: Label name of chlorinated insecticidal product, it is a restricted use
pesticide and can not be used for agricultural application.
PO. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax # [phone]
An Equal O pportunity Affirmative Action Employer
Dennis Retzlaff
July 21, 1993
Page 2
• Unidentified peaks -
The Environmental Science Laboratory has
suggested resampling and investigation into
possible causes of contamination.
Environmental Epidemiology has considerable
expertise in investigating similar circumstances
and could be of assistance if you think they are
needed.
JUL 2 1 1~'.,
If you need any assistance from the Division of Solid Waste Management, please
let me know.
cc: John Humphrey, Policy Director
Department of Environment, Health and Natural Resources
Dr. John Freeman, Director
Environmental Epidemiology Section
John Neal, Branch Head
Environmental Sciences Lab
. ;
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. D~b~rah1 an~ ·K~n 1
Ferru~cio ha~e· fo~gh't the PCB landfill in Afton for 14 ye~rs. The coble· and sign bar access to the site.
' ' . . . J ; ' . ' ' , . ·, · · . 1' . ' · , ·, · STAFF PHOTO BY ROBERT MILLER , ' . · . ·
··•.:··.Old· tandfill .f ears .. f ar ····.f roBiburied
. -· ·• : ; :_ ~ 'i · :· .-... : • ., •• ...-··<: --·:?··.·:?<·l~'/:W~~;?:-,·. __ :_ · · .
: _/Warren County residents .fear. th~t watef;.,insi_d~ __ pg~.:i~4JllP •,Re~es oan~er
' ' ' . . . ;. , . , .' .:· .. _, :. Jr ,T. ;·.r• ·.:.·.,. ~-~· • -. , .. •/''-•.' , , '
BY BEN STOCKING , T · · tr"cks h~tdipg toxic" ~<>i-1' tQ. the site. '
, . , \ ' srAFF WRITER ~ ·he· belief that man c~n .. . . . •.;1._•w~r~n..C,oµnty w.~~ tne birthplace of the AFTOtf ;... .When officials announced 'plans environmental ,civil rights JllQVement," says for Warr~n'County's toxic waste dump, they ' -~ construct a container that ·' Ken F,erruccio, who pas been ~rrested nine
called it th!!."Cadillac of. landfills." Ten ... ,.tf". __ ill_last_fo,.reverreq_uiresa times·for protestirig}ttw ~um~. ".It began years :'after•its completion; 13 feet of water , here." . . . .
has poQled _ipside the underground landfill, · ,. s(rftcli of.the imagjqati01J. '. The dump ·w&s a political nightmare for threatening to preak its clay and plastic · · · · , ·· .·. · ,1. Gov. Jim Hunt.during his first term. Now it liners .. -· · Ken Ferruccio , · ·. ·, :. · · •. · has come back to haunt him. Warren County
Some residents fear the limo is a lemon. 10nd1i11 opponent • · : , )_ • ' activists.plan to make him keep promises he
"We say it may be the Ford Pinto," says · , • ·:·, ' !i!!!!!i!!!!!!!!!!!l!!!!i!!!!l! . mad.e about the landfill back in 1982. ·
Deborah. Ferruccio, who with her husband, . . : . , · t_ • ··' • • , • • •. The (lump was built to pold chemicals that
, J(en, has waged a 14-year fight against the At'the time, the state said it ~elected µie .: · .. a tr.ansforvier company· illegaUy sprayed
dump, r.'. ·, . · · ,. • · . . .site'. for: scientific reasons, bµt protesters . along'road~ in ~ North Carolina counties in
In May, state offjcials disclosed that they be,ieved the choice was poli~ical: Warren. _:,th~ lab;"'.1970s. TQday, the lan!lfill sits
had discovered as .many as a million gallons· • -· County • was · poor, 64 percent · black : and · beneatn a pretty country, field, covered with
of water inside the landfill. Their announce-lacked clout. · ' · · ~rass aJ)d surrounded by tree~. It lools,s like
·.ment threatened to re-ignite a controversy National civil rights leaders joined hun-. <\. nice·~pot (pr a picnic.
· ' that drew , national attentioq to the P~B ~reds. of loc~l residents in ~he s~reets . as . . .. :. But. ~~~e If:lSide~~~; especially ttiose who . · dump in 1982, when·1 more than 500·.people :,lines of helmeted state troopers_ watched · ·· ''i · · · ·, · · ·
were arrested during six weeks of protests. · them. Protesters lay in front of yellow state SEE DI.IMP, PAGE BA
•. ,,lr.¥JII.
~ t DlJM·. p , . .: ·-"~cc~~t~roµ~ O:e· Ji~ers, ~ut has
l been, trapped . inside since the
-' . CONTINUED FROM PAGE 1 A landfill was sealed. He say,s it . · -j' comes from rainwater that col•
tve near it, fear the dump might lected in the.soil before construe-,, ~ e leaking aqd threateqing the. lion worke\°S finished capping the ·.
-roundwater below it. They won-landfill. · · ·· ·
: p,er whether• their wells have been The soil, acting like a giant
• tainted. . . . sponge, ret.ained the water for
,. "To tell· _x9u -._the truth, J ~on't years, but it gradually trickled tu
arink water ~t all," says Ricky, the bQltom, Meyer says. There, it
O'Ncal; who· lives about three '•.formed a pool as deep as i3 feet.
• ~ilc.s· from the landfill. "I drink' State tests of groundwater .and
ostly Pepsi." nearby streams show that no
Other residents, including some contaminants have leaked from
tounty officiulo, don't worry about the hmdfill, Meyer says. And u~
\he dump. . · far_ as h~'s .concerned, t_he wa_te1:
· , "Jn the context of the many 111s1dc.p10ves that the-lmers a1c
lealth challenges that our popula-holding. . '. } '., . ..
· ion .faces, the landfill is -a rela-. In Ute unlikely· event tllat . the . -
. tvcly small concer. n," ~a.ys. De11-hners were to bri:ak, M. cye;s s:y~,
is Retzlaff the county health the PCBs probably wouldn t reach
· irector. ' " • . i . the groundwater. He says they
.. ,.. clmg to dirt and would attach
j Giant Baggi,. ·. • . ,· · themselves to the sojl and clay in
· j When state officials announced' I,}h~ landfill.-. . ' '. :
111 _May that water was tr_apped ·. ~ ~hmk the_ risk to t~?sc c1t1-
.. 111s1de the dump they •said the , zcns ts essentially zero; Meyer
~itualion pooed n~ imminent dan; :;ays. "From an engineeri11g a11d
!er. But. they 'prpposed spending .... sc_ientific ~erspective, I don't
200 000 to remove the water and tl11nk there ts a reason to fear for
ep~ir the site as soon as possible. their l)ealth." , , l_,
· The water is placing pressure
911 the landfill's clay and plastic Quilt to last?
Floating d,~nrip . ·. · · .. · ; < .-.
The stote plans to. spend $200,000 to remove water from
a Warren County lanafill containing PCB-tointed soil.
Here.'s why : · '. . . · .
· 1 .. In 1983, the stole .-' ':'2. U~;~q on~· ~illion;goll~ns of
.placed PCB•taintflr;I ', 'roinwdtEir t~ot so'o~!3d Into the
soil in a specially·,'' · · ·.soil during disposal have settled
. lined landfill if'). _, on the. bottom .. of the landfiU,
Warre.n Coynty. placing pre~sGre on the liner.
3 .. Pumps i~t~nd~p
lo remove water Goivenl •
malfunctioned. . . ~;
• f~ ,.;.:.•~> I • •
. , :i,.f!'>_';·FI >•
liners, and officials fear the liners • -· Ken. and Deborah Ferruccio
might eventually leak, tainting don't belij:ve Meyer's rainwater Vie groundwater H feet below. · the()ry. They fear the water may
I Ttie dump's monitoring system · have leaked into the landfill from · '
f:1ilcrl lo detect the water, and a outside the liners_ which would . · f(~:_P,Q.lychl~rl,nqf~~~li»h.MIJYI••·
P11 1i1P intended to keep thp landfill, mean PClis could be seeping out 0111A syi:,th~,i~ ~~n'ipi0h\J~~fi"t;4t'"1•
jl !')· malfunctioned. 1'he ·state ' of it. , . . widely used in the United Stoles in-~ '
' · t·ilusc the · pump because it was While the landfill was under manufactured products, including , ·. ~
11cxpensive, says Hill Meyer, di-· construction. vandals slashed the points, adhesives and lubricating
rector of . ihe state Division of plastic. Rather than replace il, the ~-fluids. Also ·us~d in transformers,
$olid Waste Management. stale mended the liner: If the 1cqpocitors qnd other el(li;;tricol_·
.. I "It was \he cheapest _thing ,WC! ., liners haven't already begun leak-· · ·_equ1p1J1enl.J · · .. , {
•· tould put our hands on that would in,::. Ken fi'crruccio says, sooner or ■ Prod,;ction was banned in _;,,: .
: pump·waler~••·Mcyer says. · · · later. they will. · 1977 becouse•of health • · ··'
· ' The landfill contains 40,000 cu-"Eventually,. that landfill will . concerns. High concenlrotions
. bic yards of soil tainted with 'contaminate the groundwater of moy cause birth d9fects, cancer,
t' olychlorinated biphenyl, or PCB, Warren County," he says. ':The -liver domoge 011d nerve disorders.
chemical once us!)d to insulate .. belief that · man can eonstruct ·'a ■ Common waste treatment
lectrical transformers .. PCBs are · container th.at will last roiever ' , . ",rnetl,ods do r.,ot i;jestroy PCBs.' B1Jt .
~-b1gh.ly toxic and a possible cause requires .a stretch of the imagina-/ : --~~i(lntists hove developed
utlawed their production Ill 1077 ... • . have dedicated more tha11 a de, chlorine oloms, converting them ently 111 · th_e, ground: .,G?ngres~: .. three miles f~om the landfil.l,'·Thoy process _strips PCBs of their ·
_Tl)c 2',i•acre _landfill is _like a ..... 'cadc to .in almost obsessive cam, int~ horr,1.ess i:ornpounds.
, .,, r ~:,· );"'., J WARREN CO. f,_;
\:.· ' .. "• ... ®.)->
•. )Warrenton ·
<A~'t 11L "'t ~-.· . ~-' 1, .•.
..
,i
: ~f cancer.· Once burie~, they du 'lion.'~. The ,lfc1-ruccios,. 'both Et1'· 1/ -hhe'th'ods :<>f'destr'oying them in ·
.:; !ot dec~mpose, remammg perm a-· ·_glish '.,teachers, · Jive in a· c,il;ii)l. . · .;,WQSte 'r(1oteriols. One such
1ant undergr!)und Bag~~e. · II~ .. , paign against the dump. · Sou«•: World Book
clay and plastic lmer~ ar~ 1_ntend-. They atte.nd virtually every · ._,-------------~-----------'
(!d to seal the chemicals Ill and · state meeting on waste disposal,
~cep the water uul. · tape record officials' statements . IIW dump. His 'mother, 58, was
, When the landfill was built, its and painstakingly tratlSl:ribc dia~nosed with c_ancer about five
pesign was considered · state-of-them. Ken churns out landfill \,, years ·!!go.' 9'Neal says he doesn't ·
Jhe-art, says Dr._ c;. f'red Lee, a memos on his home computer. · krlow whether her illness Is som()•
~acrnmento _ envtrnnmental con-whkh is filled with point-by-point how conn~ctcd l? the PCB ~_µmp,
i_ulta1_1t ,~ho 1s considered a land-scenarios_ and theoretical and bu.~ he'd hk~ to f111d out. '' · ·.
111 expe1 t. ph1lusopl11cal treatises on waste It theres any problc111 ',\'Ith
: But a toxic waste dump built · ·· ·management. that dump down there, go ahead
\oda>' would have two layers of During one of his trips t.o jail. he and fix it now,'' he says. "Don't
. ~lay· and two layers of p.lastic, he spent 18 days fasting to protest the play with it..,
· ~ays; "Today, I would think the:;.· dump. . If till! la11dfill lincrs arc leaking,
fUUld put the double system in." h f O'Ncal fi gures. lhc. JJClls cuuld
Lee says. "That's Lill' sland;ml T e ears hal'e uuwd intu th,! groundwat1·r.
f
' pµroach fur hazardyus wasl".I° . •'·· lt1· ck v. ll;Jll=I is a. tuba. cco fan1i· · T,-11, /~ ~ '.Jiitw< ,,',; _,,. ,., · · , ,. ~••
L lyl:yer,.,~,i~t~•lw~~~;'.,?i•t , ~-~•~ t~:~~1!~ \~ilff}f8''P:l.
water from a well.
1'l'd like to know if there's
a·nythlng at all in our water," says
O'Neal, whose family has lived in
the are11 for generations.
Ever since 'Alvin Green, 20, was
diagno~l)d witl1 ·cancer in 1985, his
'ramily has wondered whether the
dump caused his illness. The
family has stopped drinking the
waler from its well , whid1 is
located about :l 111iles tru111 the _-
l;1 11dlill. 1-:Vl'l'.Y week. f;1111ily
' •' • l i I
' '
It Comes WrthAn Owner's Manual,
Tou'?-DJ? ~t,~d~Eqr~s
and haul then
.. My parcn1
about it, .. Sil
Alvin's sister.
Retzlaff, tll
rector, says I
to suggest th
linked to the
neighbors, h1
health depar
water from 5!
state will test
"With the
state has b
groundwater
there just clue
a luw likclihu
coming fron
1 says_.·
•. Critics of t
compounded 1
lung-slandin
tarnished it;
whole state
us," Debora
, "We're the ,
ly."
Since the ,
say, the COUI
come level ha
100th ..
"We're on
says Belle Bri
Warrenton sir
poorest count:
of North Caro
Industry, m
Warren Count
more difficult
"We've ha1
looking, but 1
wanting to set
ty." says llut
commissioner
man of the
. development (
Food comp;
hesitant lo cor
doesn't belie,
any serious lu
pie who sell
want their na
the problem ti
Hoy Hober
real elilate a
1;alesman, sa;
have exagger;
its impact. "
w;1s made of :
state and e,
says.
Detoxh
· The Ferruc,
intend to kee1
to fulfill its l
citizens of w~
In l!JIJ2. aft
the sclcdio11 u
site. he issu,
citizens th1·rc
state would de
...
. ,
. t'.,,.,•~it~·-:-:·-r. ,, ... 11,·· ... ·:>:t-•.ii~ ,t· -~(:,,. , .... ~i:~ ·-.~: .... ·,,'"· :· f~-:r ·1.',: , :,t ;'r ··,_pi,;,·"' .. ~ .. .-• 1 ",-(,~,tr·-
THE .CoN~rANfiNATED CouNrry •·. r "wili.
::-i i I
I
rs, bul has
since the
I-le says it ·
r that col-
e construe-, .
:apping lhe
:e a giant
water for
trickled to
,. There, it
as 13 feet.
lwater and
v thal no :
akcd l'rom
~s. And as
the water
liners arc
1l that'thc , ..
~ycrs says.
ldn't reach
says lht•y
uld attach
md clay in
those citi-
o."' Meyer
)Cring and
:, I don'(
to fear for
I?
Ferruccio
rainwater
.11ater mav
nclfill frorn
hich would
eeping out
l'as under
lashed lhc
ilacc il. thl·
er. If the
1('gun leak-
,, sooner or
ndfill will
1dwatcr of
ays. '·Thi.,
oi1strud a
sl forever
~ imagina-;
both Erl-
1 a cahih
dfill. They
han a dc-
;sive cam-
• ',' 1• • ~,._ I~ ,• 1 •~ I , •,,, • ,-,, i
Flodtihtf H~)fl-~-,. <' .
The state plans to ip~nd $200,000 to remove water from
a Warren County lan~Hill containing PCB-tainted soil.
Here's why: .. -,, . .• .,, , _ . ,.
' • 1 ~ I I I • ' •, ·• C I ' 1. In 1983, the stat~ · :2. Up1td o'n_e· ml!lion·.gollons of
placed PCB-tainted ·. '.• 'rdlnwdtlir thot soaked Into the
soil in o specially· ·soil durirlg disposal hove settled
lined landfill in _,on the. bott6n, of the londfil1,
. 'Warren County. pl_acing pressCre on the liner.
. 3. Pumps intended .
to remove water ; , Gmvent •
-malfunctioned. ,.; '-~
. -~---·.
PCB: p(\lyt
! ' ; ;, ~). 'f\' ·0; .. • ,,,~ );. • ■ A synthetic compound 6nc:Ei .
widely used in the United Stoles in
manufactured products, including
points, adhesives ond lubricating
-, fluids. Also used in transformers,.
-copocilors and other electricdl ·
equipment. : .. ·., .• .,,, . ·
.• Prod1Jction was banned in :; • ,(
1977 becciustf of health
concerns. High concentrations·
may cause birth defects, cancer,
liver damage and nerve disorders.
rl Common waste treatment
methods do not destroy PCBs. But.
sciet1tists hove developed , ·
·methods of destroying them in
waste rnoteriols. One such
process strips PCBs of their
chlorine· atoms, converting them
into harmless compounds.
~ourto: Wodd Boo~
T111: \ur~ & 01N:11ni: 1
SUNDAY, JULY 11, 1993:.
I I I
and haul them· home. became available. . . !
"My patents arc really scared Two years later. a stale com-•
about it." says Yolanda Green, mittce concluded that it wasn't I
Alvin's sister. l'easible yel to detoxify the dump. ,
Retzlaff, the county health di-The Fcrruccios say it's time. to '!
rector, says there is no evidence revisit thal question. " ,
to suggest the cancer cases are "We're going to redeem Warren :
lhlked to the dump. To reassure County's . reputation," Deboroh :
neighbors, however, the county says. "We're going to detoxify this :
health department is sampling landflll. ·• · · -· , · ,I ·• , ' ·: ; water ftom 55 area wells. and lhe , state will test them for PCBs. ·The state has agreed to SI!~ up a : committee of government ufli-, "With the monitoring' that lhe dais and local i-eslderits lo coiisid-l
state has been doing of the er questions about the dump. They :
groundwalC'r and surface waler. will confer with outside sclcnlisl8, l
there just doesn"t seem to be even decide whether detoxification is l a low likelihood of contamination feasible, and consider how 'to :
c·oming from PCBs, ·· · Rctzfaff dispose of the water that has ;
'· says. ' pooled inside the liners. . . ·: . I
, ·•. Critics of the dump say it has . , The· Ferrucclos will qppose a~y •l
·' compountlcd many.of the county's . · solution that requires 111ovf11g the ;
long-standing problems and PCBs from the site nnd· dumpi11g·•1
tai-nished its reputation. "The , ._ them In an~t.h~r. neighborh~od . .' . ; I
whole state makes jokes about :. . "We had a movement In' 1982 to I
us." Deborah Ferruccio says. : slop· the stuff from .cornirlg iii."'
"We're lhe contaminated coun-K~n Ferruccio says. •'Nqw we'd ;
ty ·" . have the mobilization to stop the ) Since the dump opened. they stuff from leavi1,1g." i' ' _'. I say, the county's per capita in-,
come level has fallen from 97th lo · Meyer ag1·e'es that lhe'tei:hnolo-,
100th. . gy exists lo detoxify the dump. l
· , llul it is possible. he says, lhat : "We··re on rock bottom now•" detoxifying the landfill ·could pose.;
says Belle Bright. who has lived in more dangers than leaving the :
' Warreriton since 1933. "We're the PCBs inside it. "And of course, :
poorest county in the entire state · costs will be considered." he says. :
of North Carolina." . The committee demonstrates:
Industry, never easy to lure to Hunt"s willingness to work with.I
Warren County. has become even·.,· the, citizens of Warren County, ,
more difficult to recruit. · · says Rachel Perry, tile gover1lor·s .:
"We've had a lol of ·people press secretary, -. · I looking. bul not a lol of people , 1 . ,
wanting to settle in Warren Coun-"Instead of ,:oiling over folks I
ly."' says Butch Meck, a county and saying, 'This is how wc'.,rc:
commissioner and former chair-going to do it,· the state is saying. :
man of I.he county's ccono,nic , 'What _do you think? How do,yi>u :
development commission. believe w~ sliciuld proceed?'" · l
When Hunt rhose the site baek •
in the early J!l80s, Warren County i
residents felt as if they were :
. steamrolled. "Dump Hunt in the j
dump!" went a familiar chant. . :
Food companies arc especially
hesitant lo come, says Meck, who
doesn't believe the dump poses
any serious health dangers. "Peo-
ple who sell food· products don·t
wanl their name associated wilh
the problem that we've got."
Roy Robertson, a Warrenton
real estate agent and insurance
salesman. says the dump's critics
have exaggerated its dangers and
its impact. "l think a big thing
,, j
. Some of the bitter feelings lin-I
gcr. "I'm a registered Democrat, :
and I voted for him before.'' (
Bright says of Hunt "But I'd ;
never vote for him ·again. I ,
wouldn't have ·voted for · him for:
dog catcher." . :
llv e,·erv
: disposal.
tatcments . , the dtlmp .. His ·inolher. 58, was
was made of it for nothing by the These days, the ~'erruccios and
state and everybody else.·•. he state officials are speaking the water from a well. says. langua·gc of conciliation. But if the i "I'd like to know if there's government and dump opponents i ranscribc diagnosed with cancer about five
1l landfill ye:irs ago. O'Neal says he doesn't
computer.
it-by-point.
tk:al and
on w..istc
wc:o f:1rm-
1il,, .... from
know whether her illness is some-
how eonncclcd lo the PCB dump.
but he"d like lo find out.
"If tlH'rc's any problem with
thal clump clown there. go ahead
and fix il now." h<' savs. "Don't
play with il." · ::::& 1 . thc.laridfi
,\ncf lik1• l'ir'tuallv nil fnmili<'s in
lh<' an.•a, lhc O'Ncals draw their
anything at all in our water." says Detoxing the dump can't come to terms on the defoxi, :
O'Neal, whose family has lived in · The ·Ferruccios and their allies· fication question. the J<'erruccios ;
the area for generations. intend to keep pressing the stale say they may be forced to leave 1
Ever since Alvin Green. 20. was lo fulfill its commitments to the tho negotiating table and take to l
diag_noscd with cancer in J!J85, his citizens or Warren County. the streets again. , • • family has wondered whether lhc . : , . , ,, . , -~ ,_.. . , ; .:
dump caused his Illness. The .; In 1982,. after Hunt ahnounccd. Rallying.the troops may not lle.:J
family lias ·slopped~.drinking,,thc f ,the selection ofthe Warrell County . as easy now as it was before lHc' }~·
1v · ."~lrpn1 · • · ,ve!J.~ ."cwnjclf is l.·,· sit~ ... 1)9," i~Su~~ J,. l~ttci~;.t.o.i:tht!·;··~,e,umP,· w1111 N place. But f?~b.orah ! 1J'tls, _6n\ ~ho:1:~t:lijzeri~ tMrc f)¥orriislrig~uitt1tj,lh A r·erl'ut:clo Insists the· protesters ,
. ~--ta'M,1:y ··1'' fate 1vol1ld detoxify the tlump --"-··,:\viii return. \ . : -.
· ·members drive to a rclatil"l•s rcndl't" the l'Cl3s harmless --as "Wl• will ·activate them." she \
house. fill up 40 plastic. gallon jugs soon as the necessary technology says. "They will come... i
--------------------------•: '
July 2, 1993
FUNDING $20,000 -$30,000 PCB LANDFILL PROJECT FROM 93/94 BUDGET:
1. Solid Waste Section has 10 positions in expansion budget. The
first year these are budgeted 10/1/93. The difference in salary for
full year and this first year is approximately $80,000. Typically
these funds are used to buy computers and for other one-time
operating costs for new staff. Approximately $35,000 of this money
will be used to renovate space for these ten people. With careful
planning, the PCB project could be funded from this first year
budget. However, this is one time, not continuing money. If this
is needed for more than one year, we would need to look for another
source.
2. Funding could be provided by splitting cost equally among
Superfund, Solid Waste, and Hazardous Waste state dollars.
However, this would be a problem for both Superfund (because of
limited state money) and Hazardous Waste (because they contributed
$109,000 budget cut).
3. Inactive Hazardous Sites Fund. We would have a problem
justifying use of these funds for this purpose.
,.
Facsimile Cover Sheet
To: MR. JOHN HUMPHREY,
POLICY DIRECTOR ~-..
Company: DEPT. OF ENVIRONMENT,
HEALTH AND NATURAL
RESOURCES
Phone:
Fax: [phone]
From: PAULINE EWALD .
Company: ECO
Phone: [phone] ~---
Fax: [phone]J5 OR 358-7291
Date: 06/15/93
Pages including this
cover page: 9
Comments: MR. KEN FARRUCCIO, OF THE ECUMENICAL
ENVIRONMENTAL LEADERSHIP COALITION ASKED ME TO
COPY YOU WITH THIS PROPOSAL FOR CITIZEN TECHNICAL
ASSISTANCE AT THE PCB CRISIS SITE. PLEASE NOTE THAT
THE SUGGESTED TASKS FOLLOW THE CERCLA TAG
PROGRAM, AND REPRESENT COMPARABLE COST OF TAG,
WHICH WE BELIEVE IS AN EXTRAORDINARILY SUCCESSFUL
PROGRAM, ESPECIALLY AS IMPLEMENTED IN NORTH
CAROLINA. WE APPLAUD YOUR EFFORTS TO HAVE
MEANINGFUL PUBLIC PARTICIPATION ON THIS PROJECT, AND
LOOK FORWARD TO WORKING WITH YOU TOWARDS A
SUCCESSFUL RESOLUTION OF THE SITUATION. PLEASE
FEEL FREE TO CONTACT ME FOR FURTHER INFORMATION IN
THIS REGARD.
ECO is pleased to offer our services, which are uniquely suited to the
successful completion of the North Carolina PCB Site Technical Assistance project.
Th e ECO advantage includes:
* ./\,Ju/ii-Disciplinary Staff with nm/ii-media capability
* EJZdorsed by major EJZviroJZmeJZtal aJZd Citir,eJZs Advocacy
groups
* Past rexulatory /teclmical experiell£:ed with Alajur Project
Oversixht· ..
:;,.
* Specialists ill actillK llS citizen advocates, so llt?l'er a possibility
of conjlicl of interest
* All senior employees hal•e adl·anced degrees and experience in
both privqte and public sector
* 100''.o of~taffhave receil•ed EPA training
" JOO% of staff are current on OSHA safely certifications
* l 00°-o of staff trained in EPA data reduction 111.etlwd,;
" Staff includes Engineers. Chemists, Toxicologists
* 1 OO ~o suc;cess rate of compl.eting projects on, or under budxet.
and on tiiue
NC PCR Proposal
June 14 , 1993
page 2
MANAGEMENT SUMMARY
The Environmental Compliance Organization (ECO) was founded in 1988. by
a group of experienced individuals dedicated to providing cost effective, competent
compliance and engineering services to community groups, small businesses and
governmental clients. ECO is devoted to bringing quality. value. integrity and
customer service to the field of environmental consultinQ. -. -
The principles of ECO offer advanced educations, enhanced by professional
experience in the public and private sectors. ECO staff members have extensive
experience and contacts with numerous regulatory agencies nationwide. Our
managerial staff alone has accumulated over 50 years of comprehensive experience in
the field of environmental sciences. This allows ECO to address a wider range of
compliance challenges expeditiously. at minimum cost to our clients.
E NVIROl\MENTAL
C 0)'.1PLIANCE
0 RG;;.NIZATION
NC PCB Proposal
June 14, 1993
page 3
ECO is committed to a multi-disciplinary approach to compliance and site
management, and is unique in utilizing both technical and legal professionals to:,;; .,
provide clients with the most comprehensive assistance available. This unique
advantage allows ECO to effectively reduce liability, as well as the direct costs of
environmental management for our clients. Additionally our staff is focused on, and
specifically trained in waste minimization theory and technology. and has been able on
virtually every consultation to suggest designs and practices that have resulted in
significant reductions in hazardous wastes, as well as remedial costs. Our multi-
disciplinary approach, and our highly qualified staff allm-'vs ECO to provide a full
range of environmental, hc<dth and safety services to meet all the needs of our clients.
regardless of the challenges involved.
ECO's commitment to environmental protection, extends beyond compensated
projects. Through the non-profit ECO Foundation, we donate approximately ten
percent of our net profits. as well as personal time and energy to various
em·ironmental education and protection projects. Wherever possible, we utilize
recycled and environmentally friendly office products, and practice recycling of our in-
house \Vaste . ECO personnel proudly serve pro bono on numerous local, and national
committees for development of sound \Vaste management and environmental policies.
anJ participate in a number trials for the Jevelopmenl and testing of alternate waste
destruction technologies.
E NVJRONMENT AT,
C OlVIPLIANCE
0 RGANIZATION
NC PCR Proposal
June 14, 1993
page 4
ECO currently has three offices, a headquarters located in Ashland, Virginia,
_...,.
an engineering and research facility located in Bloomington, Indiana and a public · ...
assistance office located in Apollo, Pennsylvania. Staff from all technical disciplines,
and from all ECO offices will be available in assisting in the successful completion of
the North Carolina PCB Site Technical Assistance project.
ECO believes that solutions to the particular challenges presented by projects
such as the North Carolina PCB site Technical Assistance project can best be met
through our unique multi-disciplinary approach .
In keeping ,vith this philosophy. ECO has assembled a team of hi ghl:',·
qualified professionals in the fields of engineering, toxicology. chemistry, biology.
economics, education, planning and la,v, in order to fulfill and exceed the primary
requirements of the Technical Assistance program, and any other ancillary needs that
may arise in successfully completing this project.
ECO proposes to utilize this unique combination of technical and regulatory
compliance talent in a balanced "team" approach to this project. thereby providing
the highest standard of competence. in conjunction with service that is time and cost
effective.
E NYIRONMENTAL
C 01\IPLIANCE
0 RGANIZATIC 1N
NC PCB Proposal
June 14 , 1993
page 5
All staff memhers designated for v.·ork under this proposal have direct ·,, ~
experience in Federal, State or Local government, and have had extensive involvement
in the development and implementation of all relevant environmental regulations and
standards.
ECO conducts all work according to an EP-1 approved Oualitr Assurance
Project Plan , and EP4 approved methodology for sample and risk assessment
n:\·iew. All ECO staff have re<.:eiveu relevant training uirectly from EPA, anu
undertake yearly update training. This rigorous attention to approved protocol and
dctaiL provides assurance for our <.:lients that all work performed by ECO will meet
\Vith regulatory approval on first revic\V, and is defensible as evidence in court if
necessary. or requested.
E NYJRONl\1ENTAL
C Ol\·1PLIANCE
0 RGANIZATION
NC PCR Proposal
June 14 , 1993
page 6
PROJECT PROPOSAL
.
I. SITE INVESTIGATION -to mclude 15 split samples to be
.analyzed for full CERCLA scan, including PCDD/PCDF. All lab work
to be perfonned as per EPA protocol at an EPA CLP laboratory. Lab
results will undergo data reduction and analysis as per EPA functional
guidelines. Preparation of written sununary report to be included.
COST • 15 samples (a/$ 2,000/samplc = $ 30,000.00
(competitive bids will be solicited and documented from at
least three ~LP labora ~~
180 Man hours (a) $ 6.5 00/ nan hour = $ 11 ,700 00 ~ /
~--/
Travel to include (2) t\YO round trips for (2) two people (CD
$ .25/ mile X approxuuately 1,000 mile round-trip=
$ 250.00
Cooler purchase and shipping @_.; $125. OU/cooler X 2
coolers=$ 250.00
TOTAL COST THIS TASK= $52,000.00
E NVIRONMENT AI ,
C O~IPLIANCE
0 RGANIZATION
NC PCR Proposal
June 14, 199 3
page 7
II. RISK ASSESSMENT -to include EPA protocol and fonnat ,.,
analysis of potential impact on hmnan and wildlife receptors of ;. "
conditions documented during site investigation
COST: 450 man ho~rs aO/man hour= $ 29,250.00
TOT AL COST THIS TASK -$ 29,250.00
-> III. FEASIBILITY STUDY -to include analysis and weighting of
all applicable remedial technologies as per EPA protocol and fonnat, or
other formal and criteria to be developed in conJunction with State
agencies. Ultimate goal is to choose remedial teclmology representing
greatest possible short and long tenn protection of human health and the
environment, while being reasonably cost efficient. To mclude
providing technical assistance and publtc education rcgardmg
unplemcntation of chosen alternative.
COST: 525 man Ii.ours ~/man hour= $34,125.00
TOT AL COST THIS TASK : $ 3-t,125.00
F NVIRONMENTAL
C 01'1PLIANCE
0 RGANIZATION
..
NC PCR Proposal
June 14, 1993
page 8
IV. REMEDIAL DESIGN AND IMPLEMENTATION -to
include review and conunenting on proposed plans, and provision o(
citizen infonnation assistance and education during remedial activ1~ --....... , ... ·-
\ I
COST 100 man hour (g;~OO/n~_an hour=$ 6,500.00
TOT AL COST THIS TASK: $ 6,500.00
V. POST CLOSURE MONITORJNG -to include preparation of
final site disposition re))ort, and review and monitoring of proposed
long tenn monitoring plans for the areas potentially impacted by the
site
COST 50 man hollrs (a!&n hour=$ 3,250.00
TOTAL COST THIS_ TASK:$ 3,250.00
ECO estimates that the technical assistance pro_1cct will ha,1e an
effective duration of behveen hvo (2) to four (4) years.
TOTAL ESTIMATED COST THIS PROJECT: $154,125.00
E NVIRONMENTAL
C Q;\fPLIANCE
0 RGAJ\IZATIOl\
4221 Farboo Blvd., Ste. 240 • Lanham, MD 20706
[phone] • FAX: [phone]
June 15, 1993
TO: John Humphrey
Ken Ferruccio
FROM: Joe) S. Hirschhorn
Hirschhorn & Associates, Inc.
A subsidiary of
Post-ft"' brand f · t . To ax ransmttta! memo 7671 rfl-o-, pe-g.-s-.. ----
::.:rdV\ .._ u .. r .. "' Co. . t/
Dept.
Fax(I
Co.
Phone If ) / i _., 0 I
Hix# Ji·r
St'.ibject: Proposal to serve as Science Advisor for PCB Landfil~ Warren County
As a result of phone conversations with Billie Elmore and Ken Ferruccio, I am
submitting this letter proposal, because I am eager to serve as the independent Science Advisor
for the community, which the North Carolina Department of Environment, Health and Natm:al
Resources is to fund.
It is my understanding that the principal activity will be to provide analysis and
recommendations regarding the current and future potential for using some form of
detoxification technology for the landfilled materials, as long as it can be done without posing a
greater risk to citizens than the landfill its.elf. AJso, I presume that all the complex factors of
technical effectiveness, reliability, safety and cost-effectiveness must be integrated into a sound
technology ~ment Through details to be worked out later, we would provide a
professional report that assessed the potential for using detoxification technology for the
Warren County landfill material within the constraints established by what l understand to be a
five point agreement between the State and concerned citizens. Moreover, I also understand
that the Science Advisor may also have to address other technical issues regarding the current
landfill, it.& effectiveness, and its management, and that this would be done under explicit
direction from the State and/or the citizens.
Attached is my extended resume which pwvides. considerable detail about my capabilities
and experience. To sum up, my 12 years at the Congressional Office of Technology Assessment
and my three years of experience as head of Hirschhorn & Associates, an environmental
consulting firm, provide absolutely unique technical credentials for this important work. In
particular, I have used my engineering background and OT A experiences to seive several
communities as an independent technical expert.
For three Superfund sites, I have served as an advisor under Technical Assistance
Grants obtained by community groups. Also, for Citizens for a Healthy Fairfax, I have served
as their independent advisor regarding assessment and cleanup of a major contaminated site,
through funding they obtained from a company. Additionally, I have worked as an expert
witness for a Maryland citizens group and successfully stopped the permitting of a new but
1
unsafe 1andfi11, and I recently was involved in a South Carolina permit hearing1 working on the
side of environmental groups to stop the permitting of a hazardoll5 waste landfill because of the
technical flaws in the de.sign and location of the landfill. However, I have publicly stated that a
ne.cessary and properly sited, designed, operated, and regulated landfill can be acceptable, but
unfortunately most landfills do not meet all of these needs and technical criteria.
Because of 15 years of solid experience in hazardous waste technology and management
• I have extensive materials and contacts necessary to comprehensively evaluate your PCB
situation and the potential for using; detoxification technology. For example, we have the latest
electronic EPA cleanup technology database which we can use to access technology ~ and
vendors specificaUy applicable to PCBs, and extensive contacts in government agencie&-'3Il~.
private sector companies.
, I also want to emphasize that although I feel proud to have worked for citizen groups
nationwide, I have enormous professional credibility and integrity, because I also work for
industrial corporations, trade associations, and government agencies. A full analysis of my
professional background shows that· I honestly address the issues and needs of all my clients and
remain faithful to serving the public's interest in protecting health and environment
As to the costs of serving as the Advisor, there are of course many unavoidable
uncertainties at this time regarding the level of effort necessary. Nevertheless, based on my
experiences and current information provided to me, I make the following estimates, using
hourly rates of $100 for myself and $35 for my support staff.
Technology assessment for PCB detoxification:
80 hours for JSH/100 hours for support staff
Meetings with citizens, state officials
and others to discuss and address_ other
technical issues, needs, and prese~ assessment
results (probably three trips from Wash.,DC to
North Carolina plus phone conference calls)
50 hours for JSH
Reimbursement of direct expenses for travel,
long distance phone/fax, etc.
TOTAL ESTIMATED COST
$11,500
5,000
2,000
$18,500
I believe this is a valid, good faith estimate; however, as you probably understand, there
are unpredictable circumstances which can add significantly to tirne, effort, and costs ia this kind
2
•
interview many managers. The goal of the project was to prepare a manual for use at all IBM
facilities so that consistent, company-wide data could be obtained on facility waste minimization
and toxics use reduction to facilitate internal company management and compliance with state
and Federal reporting requirements. IBM has begun company-wide implementation of the
method developed The project has also included developing educational materials on the
is1mes related to waste reduction measurement for use both within the company and outside.
Dr. Hirschhorn is also a consulfa~t to IBM's environmentally conscious products pwgram, and
he has also assisted IBM with regulatory compliance. h-~ :41 -··
For Warner-Lambert, Dr. Hirschh;orn has provided technical advice and analysis on solid waste
management and other issues to support the company's development and marketing of its
N(j)von brand of agriculturally derived specialty polymers, which are being marketed because of
their biodegradability and environmental advantages. Df. Hirschhorn has worked for senior
corporate executives and for the company's Washington, DC government relations office, and
has assisted with legislative activi~ies and establishing new working relationships wjth national
environmental groups. Hirschhorn & Associates has also performed a lifecycle analysis of
Novon and competing plastics and paper, and prepared a white paper on the economic benefits
of solid waste composting.
For Texas Instruments, he has ~mined the market for pollution prevention technologies and
products in the U.S. and globatly; and how TI can exploit its core competencies for this market.
2
For Chevron, Union Carbide, Q,rning, Texas Instruments, DOE's Pacific Northwest
Laboratories, and Lawrence-Livermore National Laboratory, Dr. Hirschhorn has provided
reviews of ongoing waste reduction and environmental management programs. For Phillips
Petroleum, Texas Instruments, and 3M, Dr. Hirschhorn has presented specially designed lectures
on pollution prevention for company employees. Dr. Hirschhorn has also presented programs
to foster development of pollution prevention education for Stark County (Ohio) and the state
of Washington.
For the Food Marketing Instiiute, Dr. Hirschhorn directed a project on developing a waste
reduction manual for operators {Ind managers at supermarkets. For the Hazardous Waste
Treatment Council, Dr. Hirschhorn directed a project on correlating RCRA hazardous waste
regulations with increases in ind~trial hazardous waste reduction.
Dr. Hirschhorn directed a project on the lifecycle analysis of various paper products for the
Green Seal organization, which evaluates environmentally responsible products. The two major
reports formed the basis for Green Seal's standards for various consumer paper products.
For Baroid Drilling Fluids, Dr._.Hirschhorn has identified Jifecycle environmental benefits and
provided advice on how to mafk~t the company's new types of environmentally preferred
products, which are non-toxic a.nd biodegradable and make petroleum drHling safe to the
environment.
For the U.S. Agency for International Development, Dr. Hirschhorn has directed a study
leading to a guidance manual on implementing pollution prevention in developing countries,
contributed to a Near East water resources strategy, and served as chief-0£-party for a project
I-' -"':::,
3
examining the feasibility of a new Near East trade and environment initiative to foster
sustainable development through expediting the adoption of proven U.S. clean tc:chnologie.s and
products. He also presented pollution prevention seminars in Egypt and Morocoo, where be
also assessed many industrial facilities, which he has also done in Jordan and Tunisia.
For the U.S. Office of Technology Assessment, Dr. Hirschhorn has directed a study on U.S.
environmentally responsible products, including the problems they face in the matk:etplace and
their potential for export. The study included detailed case examples, a market assessment;-and
policy recommendations. · '·~ ·•
Dr. Hirschhorn has also served as an Adjunct Professor at the University of South Carolina,
assisting in the development of pollution prevention programs. ,. .
Experience in Superfund, Waste Site Cleanup. Waste Management. Litii:;ation Support. Expert
Witness Testimony:
While at Hirschhorn & Associates (a subsidiary of H+GCL), Dr. Hirschhorn has been a senior
consultant to Southern Pacific Transportation for one of its CERCLA sites in Texas. His
mission was to change the remedial technology already selected by EPA He performed many
technical analyses, provided strategic advice, and worked in organizing support within the site's
business community, in Congress, and the news media. Toe project was successful. EPA is
allowing the PRPs to use a safer, more proven, and lower cost remedy. The PRPs will save
well over $25 million on this site alone.
For another PRP, the Malone Company, Dr. Hirschhorn has provided technical analysis to
support a position on its share of cleanup costs at a large Superfund site and has served as an
expert witness on a number of technical and Superfund program issues for a suit brought by the
company.
He has seived as a technical expert for the Ciba-Geigy Corp. to assist the defense of employees
in a RCRA criminal prosecution.·.
He has seived as a consultant to Hunter Industrial Facilities, Inc., to provide technical
88Sistance and expert testimony f9r their hazardous waste disposal facility project making use of
a &alt dome in Texas.
For Santee Cooper, a South Carolina utility, he has se1Ved as an expert witness in a state
hearing, providing testimony on landfill technology, leakage and contamination, and cleanup
issues and costs.
He bas been a technical consultant to assist two companies (SDTX Technologies and TerraVac)
offering advanced cleanup technologies .
.
He has served as technical consultant for two Municipal Utility Districts in Texas because of
their interest in a Superfund site. He also has served as a technicaf consultant to the Colorado
Center for Environmental Management's program on alternative approaches to cleanup
decisions, and has also directed a case study on a Supcrfuod site for the program.
Dr. Hirschhorn has served as a technical advisor for several Superfund EPA Technical
Assistance Grants for community organizations in New York, Maryland, and Texas. He
provided expert testimony for a community group in Maryland opposing the siting of a new
rubble landfill. He was also selected as the independent technical advisor for the citizens'
group ooncemed with the Fairfax, Virgjnia oil spill.
Other clients in the areas of environmental technologies and Superfund include D0:8"'~•
Lawrence-Livermore National ~boratory, Clean Sites, Inc., and several law firms.
Siqce leaving OTA, he was invi~ to present testimony at a June 1990 Senate hearing, a
September 1990 House hearing, and an October 1991 House hearing, all on Superfund.
Experience at the Con2ressional. Office of Technoloio: Assessment:
4
During his 12 years at the Congressional Office of Technology Assessment from 1978 to 1990,
Dr. Hirschhorn distinguished himself as an environmental authority. His studies of hazardous
waste management under RCRA, Superfund and cleanup technology, pollution prevention and
waste reduction, among others, helped steer federal laws and policies in new directions and
impacted virtually all state and industry toxic waste policies and activities. Results of these
OTA studies have been published and include: Technologies and Management Strategies for
Hazardous Waste Control; Superfund Strategy; Are We Cleaning Up? -10 Superfund Case
Studies; Assessing Contractor l,.Jse in Superfund; Coming Clean ... Superfund Problems Can Be
Solved; Technology and Steel Industry Competitiveness; Serious Reduction of Hazardous Waste;
and From Pollution to Prevention.
While at OT A, Dr. Hirschhorn provided responses to special Congfessional requests, particularly
examining major Superfund sites, including Love Canal, Times Beach, StringfeJlow Acid Pits,
Crystal City Airport, Brio Refining, Carson River Mercury, and the Rocky Mountain Arsenal
sites. He testified over 60 times on behalf of OT A at Senate and House hearings on
Superfund, cleanup, waste management and technology, and pollution prevention subjects.
Additionally, Dr. Hirschhorn maintained liaison with Congressional staff, Federal agencies,
states, technology developers, industry and trade association leaders, interest groups, news
organizations, and universities throughout his OTA careef. Few professionals have the
credibility with the general public as well as people in industry, environmental organizations,
government and the news media· that Dr. Hirschhorn .earned because of his work at OTA
Experience Before OTA:
Dr. Hirschhorn provided management consulting to many small and large domestic and foreign
companies (e.g., IBM, Rayovac, Quebec Iron and Steel, Cabot, Bethlehem Steel) from 1965
until 1978 in strategic planning,.R&D planning, manufacturing technologies, acquisitions and
diversifications. He was also in.valved with product failure pfoblems and provided expert
testimony in legal cases, including directing a large project for Covington and Burljng,
Washington, DC.
A5 a full professor of Metallurgical Engjneering at the University of Wisconsin, Madison from
1965 to 1978, Dr. Hirschhorn initiated and directed an internationally recognized and industry
supported teaching and research program on powder metallurgy manufacturing, a waste-saving
technique_ He is the inventor of porous surgical implants and new engineering alloys) and has
two U.S. patents.
Dr. Hirschhorn was the Director. of Research for Friction Products Company of M~i~a, Ohio
for a period of 4 years while still maintaining his faculty position with the University of
Wisconsin. He was responsible for strategic planning, designing and establishing the R&D
laboratory and program, new products, consulting to the production department, and assisting
the president in marketing new _products.
EDUCATION
Dr. Hirschhorn earned his PhD. in materials engineering at Rensselaer Polytechnic Institute in
1965, with a minor in physics. He earned his M.S. and B.S. degrees in metallurgical
engineering from the Polytechnic Institute of Brooklyn in 1962 and 1961, respectively.
AWARDS AND HONORS
Engineering News-Record 1990 Award for Superfund accomplishments;
aean Water Fund 1988 award and award from the Citizen's Clearinghouse on Hazardous
Waste in 1989;
United States paper of excellence for the 1987 International Congress on Hazardous Materials
Management;
SerioU6 Reduction of Hazardous_ Waste chosen Notable Document of 1987 by the American
Library ~ociation;
Invited member of 1989 European Hazardous Waste Study Tour (New Jersey Institute of
Technology, and Ciba-Geigy Corporation);
Invited speaker on waste minimization at Special Wastes Symposium of International
Environmental Bureau and Ciba-Gejgy, Geneva, Switzerland, 1989;
s
Invited Special Report on Pollution Prevention for 1989 Pacific Basin Conference on Hazardous
Waste, Singapore; ·
Washington. DC.
AJ a full professor of Metallurgical Engjneering at the University of Wisconsin, Madison from
1965 to 1978, Dr. Hirschhorn initiated and directed an internationally recognized and industry
supported teaching and research program on powder metallurgy manufacturing, a waste-saving
technique. He is the inventor of porous surgical implants and new engineering alloys, and has
two U.S. patents.
Dr. Hirschhorn was the Director. of Research for Friction Products Company of M~ja, Ohio
for a period of 4 years while still maintaining his faculty position with the University of
Wisconsin. He was responsible for strategic planning, designing and establishing the R&D
laboratory and program, new products, consulting to the production department, and a.uisting
the president in marketing new _products .
..
EDUCATION
Dr. Hirschhorn earned his PhD. in materials engineering at Rensselaer Polytechnic Institute in
1965, with a minor in physics. He earned his M.S. and B.S. degrees in metallurgical
engineering from the Polytechnic Institute of Brooklyn in 1962 and 1961, respectively.
AWARDS AND HONORS
Engineering News-Record 1990 Award for Superfund accomplishments;
aean Water Fund 1988 award and award from the Citizen's aearinghouse on Hazardous
Waste in 1989;
United States paper of excellence for the 1987 International Congress on Hazardous Materials
Management;
SerioU5 Reduction of Hazardous_ Waste chosen Notable Document of 1987 by the American
La"brary Association;
Invited member of 1989 European Hazardous Waste Study Tour (New Jersey Institute of
Technology, and Ciba-Geigy Corporation);
Invited speaker on waste minimization at Special Wastes Symposium of International
Environmental Bureau and Ciba~Geigy, Geneva, Switzedand, 1989;
s
Invited Special Report on Pollution Prevention for 1989 Pacific Basin Conference on Hazardous
Waste, Singapore; ·
Outstanding Young Faculty Award from the American Society for Engineering Education;
ALCOA Foundation and INCO Corporation research awards;
NASA fellowships;
NSF and German Marshall Fund U.S. travel awards;
Brierly Alumni Achievement Award from Polytechnic Instjtute of Brooklyn;
OTA nominee for 1988 Federal Environmental Engineer Award.
MAJOR TELEVISION APPEARANCES, PUBLIC TALKS, AND PUBLICATIONS
Featured on major television:
MacNeil-1.ehrer
Nightly Business Report PBS
CBS Evening News
NBC White Paper
CNN News
700 Club
Adam Smith's Moneyworld .
Bill Moyers Frontline Special PBS
Bill Moyen Listening To America Special PBS
Monitor 1V
Race to the Save the Planet, PBS
Slow Death in the Cities Special.
On National Public Radio and local 1V news shows numerous times;
Op-ed articles in the New York Times, Washington Post, Los Angeles Times, Chicago Tribwie
and Baltimore Sun on technology-policy issues;
Over 150 papers, articles, guest editorials, and chapters in books; some of the prestigiomt
professional periodicals that have published Dr. Hirschhorn's work include: MITs Technology
Review, Chemical Engineering .Progress, EPA Journal, Environmental Science & Technology,
Civil Engineering, Institutional Investor, and Harvard Business Review;
Hundreds of invited and keynote presentations at U.S. and foreign conferences and meetings;
for example, keynote talks on pollution prevention at the Air Force's Process Technology 88
conference, the 1989 Australian Conference on Management of Hazardous Waste, and the
EnSol '90 conference in California;
Author of several engineering and science text books, including Introduction to Powder •
6
Metallurgy and Prosperity Without Pollution -The Prevention Strategy For Industry and
Consumers.
PresentatiQns Related to Pollution Prevention:
Presentation on "Waste Reduction Measurement Project at IBM,~ Tufts Univ. and EPA
conference on Measuring Progress jn Pollution Prevention. Mass., March 1993; ~.;,-,.,
Pollution prevention talk at 1993 Update on RCRA Regulations and Legislation course,
Government Institutes, Arlington, Virginia, March 1993;
Pollution prevention workshop, 2nd South Carolina Environmental Symposium, March 19'J3;
Plenary talk on pollution preventjon, The Georgia Conservancy annual conference, February
1993;
' Panel member for plenary session "Are the New Environmental Challenges Obstacles or
Opportunities?, The Chemical Management & Resources Assodation meeting, January 1993;
Invited talk on pollution prevention, Columbus Area Chamber of Commerce, Columbus,
Indiana, November 1992;
Invited talk on clean technology ~nd AID program, American Chamber of Commerce in Egypt,
Cairo, November 1992;
Invited paper on Cleaner Production in U.S. Industry, United Nations Environment Programme
Ministerial Meeting and Second Senior Level Oeaner Production Seminar, Paris, France,
October 1992;
Workxhop Leader, Pollution Prevention Technology and Policy, ChemicalWeek Conference An
Environment of Change, Houston, October 1992;
Keynote talk, Rhode Island Pollution Prevention Conference, Providence, September 1992;
Guest Lecturer on pollution prevention, Management Program, George Washington University,
September 1992;
Invited Lecture on pollution prevention, Jordanian Society for the Control of Environmental
Pollution, Amman, Jordan, August 1992;
Invited talk on pollution prevention at Indiana Governor's Conference on Environment, June
1992;
Product Lifecyde Analysis Promotes Multimedia Pollution Prevention, Air & Waste
Management Annual Meeting, Ka~sas City, June 1992;
7
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Plenary talk on pollution prevention, Princeton University Symposium on State Leaden.hip in
Industrial Pollution Prevention Policy, April 1992;
Waste minimization talk, Yale University International Conference on Industry and the
Environment, March 1992;
The Bottom Line: How to Satisfy All Compliance Needs: Pollution Prevention; Surviving _
Multimedia Environmental Ins~tions Conference; Washington, DC, March 1992; ._.::-,.,
8
Prosperity Without Pollution Requires Education & Training, 18th Environmental Symposium of
American Defense Preparedness Association, Washington DC, February 1992;
Cbair and speaker, Toxics Use and Source Reduction Conference; San Francisco, February
1992;
Keynote talk on RCRNHSW A: Where Do Reauthorization and Program Implementation Need
to Go?, RCRA Reauthorization and Implementation: Preparing for the 1992 Debate
Conference, Washington, DC, rebruary 19<J2;
Prosperity Without Pollution lecture, Agency for International Development Environmental
Speaker Series, Washington, DC, December 1991;
Chairman and speaker for Design For Environmentally Responsible Products Conference,
Washington, DC, December 1991;
Chairman and speaker for Toxics Use & Source Reduction --Compliance and Beyond
Conference, Washington, DC, ~ovember 19<Jl;
Invited presentation on pollution prevention for the President's Commission on Environmental
Quality, Subcommittee on Pollution Prevention and Quality Management, Washington, DC,
October 1991;
Keynote presentation at Phillips ·petroleum Company's conference on waste mjnimization and
pollution prevention, Bartlesville, Oklahoma, September 1991;
Keynote speaker at the South Carolina Hazardous Waste Reduction Conference, Columbia, SC,
September 1991;
Invited presentation on the role of government in lifecycle analysis for green products; Green
Cross symposium on Eco-Labeling, New York City, September 1991;
Invited keynote speaker, 3M company symposium on Environmentally Compatible Products &
Processes, St. Paul, May 1991;
Invited paper on pollution prevention; Stockholm Envirnnment Institute confetence on clear
production; Prague, September ~9<J1;
Invited talk on environmental technology, Armed Forces Communications and Electronics
Association International Convention, Washington, DC, June 1991;
9
Lecturer on pollution prevention, conference on Incorporating Pollution Prevention Concepts in
Higher E.ducation Curricula, Seattle, June 1991;
Speaker on pollution prevention laws, Government Institutes conference on RCRA, M~y 1991;
,_~: ... ,
Invited speaker on pollution prevention, conference on cleaner production technologies,
Stockholm Environment Institute, Stockholm, April 1991;
• lq_vited talk on preparation of :,,.,aste reduction handbook, Food Marketing Institute
environmental conference, Washington, DC, February 1991;
Speaker on "Helping Marketing People Understand Technically Complex Environmental
Subject&," The Power of Green conference, New York, January 1991;
Keynote speaker, "Pollution Prevention, Waste Minimization, Recycling and Reuse," Air and
Waste Management Association, Dallas, February 1991;
Chairperson and speaker, Pollution Prevention 1991: Understanding Regulations and
Implementing Your In-House Program, Executive Enterprises conference, San Francisco,
February 1991;
Invited talk on manufacturing ~t the Business Week/World Resources Institute conference: "The
Environment -Corporate Stewardship and Business Opportunity in the Decade of Global
Awakening," New York, December 1990;
Keynote speaker on pollution prevention at Polawid Corporation's Earth Day conference,
Cambridge, September 1990;
Invited talk on pollution prevention at the International Society of African Scientists conference
.. Waste Management in Developing Countries," Washington, DC, September 1990;
Invited talk on waste minimization at the Rhode Island conference "Managing the Environment
in the '90s," Providence, September 1990; . .
Commissioned paper "The Tech_nological Potential: Pollution Prevention," for World Resources
Institute/ Organisation for Economic Co-operation & Development Symposium: Toward 2000;
Environment, Technology and the New Century, June 1990;
Invited presentation "Teaching ~ollution Prevention" at the International Conference on
Pollution Prevention: Clean Technologies and Clean Products, Washington, DC, June 1990;
Invited contributor to U.S. EPA•s Pollution Prevention Focus Group, Environmental Education
and Training Committee, National Advisory Council for Environmental Policy and Technology,
1990;
.
I •
Invited luncheon speaker at State Congress on Pollution Prevention, Association of State and
Interstate Water Pollution Control Administrators, New Orleans, May 1990;
Special lecture on waste minimization for the 1989 Whitney Symposium on Science and
Technology at the General Electric Research Laboratory;
Speaker on environmental technology for the Brookings Institution Executive Leadership
Seminaf8; '--~:.:.,-
Lecturer for American Bar Association and Georgetown University Law Center courses;
Fr;equently invited to speak at corporate environmental meetings ( e.g. General Electric, IBM,
Union Carbide, Allied-Signal, Rayovac, Hewlett-Packard, Ciba-Geigy, Dow Chemical, Polaroid,
3M, and Texas Instruments), anq trade associations.
Recent Pollution Prevention and Related Publications:
"Privatization in Developing Countries and Pollution Prevention," Pollution Prevention, 1993;
"A Model for Improved Community Relations," J. of Environmental Regulation, 1993.
10
Chapter in "Clean Production Strategies: Developing Preventive Environmental Management in
the Industrial Economy," CRC Press, 1993;
"Solving the Georgia Waste Issue," Atlanta Constitution, July 19, 1992;
"Environmental Quality Is In Tiie Doing, Not The Words/ Total Quality Environmental
Management, Summer 1992;
"Business and the Environment," chapter in Environmental Strategies Handbook," in press.
"Prosperity Without Pollution Requires Education and Training," Proceedings 18th
Environmental Symposium & Exhibition, 1992;
"Corporate Culture For Total Environmental Opportunities," Our California Environment,
Winter 1992;
"Green Products and the Future of Pollution Prevention," Pollution Prevention Review, Autumn
19'Jl; .
"Economics of Waste Reduction, Resource Recovery, and Recycling," chapter in The Greening
of American Business, Government Institutes, 1992;
"The Technological Potential: Industrial Pollution Prevention," three part series, Pollution
Prevention, February, April, June 1991 ;
.. .
"Reducing Risk," Forum contribution, Hazmat World, April 1991;
"Technology and the Four Stages of Hazardous Waste Reduction,'' Iron and Steel Engineer,
November 1988;
"Cutting Production of Hazardous Waste," Technology Review, April 1988;
.
"Regulations Create New Business Niches," In Business, November 1990;
"Preventing Industry Waste," EPA Journal, Jan./Feb. 1990;
"The Case for Pollution Prevention," EPA Journal, April 1989;
I •
"The Obstacles to Waste Reduction," Chemical Engineering Progress, June 1989;
"Waste Reduction Audits: Matching Types to Strategies," ASTM Waste Minimization Practice,
1989;
"Rethinlcing Environmental Protection," Hazmat World, October 1988;
"Roadblocks to Waste Reduction," The Environmental Forum, July/August 1988;
"Sell Pollution? Why Not Stop It Instead/ The Washington Post, August 1987;
"Preventing Pollution Is No End-Of-Pipe Dream/ Across the Board, June 1987;
"Waste Reduction," Environment, March 1987;
"Waste Reduction: From Policy to Commitment," Hazardous Waste & Hazardous Materials,
November 1987;
"Congre.ssional Opportunities to Support Waste Reduction," Fourth Annual Mas.s. Hazardous
Waste Source Reduction Conference, October 1987;
"From Facility Siting to Waste Reduction,'' Forum for Applied Research and Public Policy,"
1987;
11
"Hazardous Waste Reduction," chapter in Management of Hazardous Materials & Waste, Penn.
Academy of Science, 1986;
"New Environmental Protection," Pollution Engineering, November 1987;
"Pollution Prevention," Hazmat World, July 1989;
"Recycling Isn't Source Reduction," Waste Age, August 1989;
"The Hazardous Waste Issue," Chemistry for Protection of the Environment 1985, Elsevier,
.
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1986.
Pre,sentations Related to Superfund and Waste Site Oeanup:
Invited talk on environmental technology, Armed Forces Communications and Electron!cs
Association International Convention, Wash., DC, June 1991; """,
Invited talk on Soil Cleanup> ENPROTECH '91 -International Environmental Control &
Protection Technology Exhibiti6n & Conference, Taipei, Taiwan, January 1991;
In'.vited luncheon speaker on Superfund at Air & Waste Management Association conference
"How Clean is Clean? aeanup Criteria for Contaminated Soil and Grnundwater," Boston,
November 1990;
Keynote talk on reuse of contaminated land at Haztech International conference, Pjttsbm;-gh;
September 1990;
12
Invited overview speaker on appropriate role of incineration at conference on health effects of
combustion by-products, National Inst. of Environmental Health Sciences, Superfund Basic
Research Program, and National Science Foundation, Bethesda, October 1990;
Invited talk on National Perspective on State Hazardous Waste Cleanup Programs, Association
of State and Territorial Solid Waste Management Officials conference on State Superfund
programs> Denver, July 1990;
Invited talk on Superfund at Spl'ing Meeting of the Information Network for Superfund
Settlements, Atlanta, April 1990;
Speaker on environmental techoology for the Brookings Institution Executive Leadership
Seminars;
Lecturer on Superfund issues for American Bar Association and Georgetown University Law
Center courses;
Chairman and speaker for the ~azMat International 1990 session "Learning How to Use Pump
and Treat for Groundwater Cl~nup;"
Recent Superfund and Cleanup . Publications:
"What Will It Cost?'' Institutional Investor, July 1990;
"Qeaning Up: The Second Decade," Civil Engineering, October 1990;
"Selecting Better Cleanup Tecbnology for Superfund Sites: Where EPA Goes Wrong,"
Environmental Hazards, August 1990;
"Toxic Contamination and Industrial Re-Development," Haztech International News, October
1990;
"Superfuod Strategie.s and Technologies: A Role for Biotechnology," Environmental
Biotechnology, ed. by G. S. Omenn, Plenum, 1988;
"Comments on Establishing and Meeting Ground Water Protection Goals in the Su~~und
Program," Hazardous Waste Site Management: Water Quality Issues, National Academy of
Science.s, 1988;
"Are We Cleaning Up? An ~essment of Superfund," Chemical Engineering, December 1988;
"Save Superfund; Issues in Scien~ and Technology, Fall 1988;
"Investments in Environmental Technology Jeopardized by Regulatory Process," Environmental
Business Journal, November 1988;
"Using Risk Concepts in Superfund," Superfund '87;
"Superfund: A Scientifically Sound Strategy Needed," Ground Water, Jan./Feb. 1987; _
"Entropy Races Superfund," 8th' National Ground Water Quality Symposium, September 1986;
"Superfund: What's New," Environmental Science & Technology, March 1987;
13
"Biotechnology in Hazar:dous Waste Management: Major Issues," in Impact of Applied Genetics
in Pollution Control," Univ. Notre Daine, 1982.
PROFESSIONAL ACTIVITIES
Member of the editorial boards of several publications, including: Green MarketAlert,
Hazardous Waste and Hazardous Materials, Hazmat World, Pollution Prevention Review,
Pollution Prevention -The Journal for the Protection of the Eur:opean Environment,
International Journal of Environmentally Conscious Manufacturing, Environmental Waste
Management;
Member of Task Force on Environmental Waste, Arner:ican Institute of Architects;
Member of the Board of Directors, National Association of Professional Environmental
Communicators;
Member of Keystone Superfund Implementation Dialogue Group;
Member of Oean Sites, Inc. Supetfund remedy selection project;
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Member of the Keystone Hazardous Waste Management Policy and Materials Use Reduction
Projects;
Member of advisory board Stockholm Environment Institute Low Waste Project;
Technical peer reviewer for Clean Water Action, INFORM, and Council on Economic
Priorities;
fi:··
Member of the Advisocy Committee for the Source Reduction Research Partnership (los
Angeles);
A World Book contributor; ,.
Member of the National Governors' Association Biennial Report Advisory Board and Waste
Minimization and Source Reduction Work Group;
Member of Advisory Group, Institute for Local Self-Reliance German Marshall Fund Sol.id
Waste Project;
Member of the Keystone National Environmental Decisionmaking Forum;
Invited participant at the Conservation Foundation's 1989 conference for 100 environmental
leaders on setting envjronmental priorities .
4/15/93
..
14
4221 FortxM; Blvd., Ste. 240 • Lanham, MD 20706
[phone] • FAX; [phone]
JOEL S. HIRSCHHORN, Ph.D.
Prlacipal
Hirschhorn & Associates, Inc.
A subsidiary of
Dr. l,lirschhorn has an exceptional background in science, technology, and environment
combined with extensive work in government programs, industrial practices1 and public policy.
He conceived and directed many influential environmental studies at the U.S. Congressional
Office of Technology Assessment (OTA), helping to define key environmental issues, policies,
and solutions for government and industry nationwide, especially in pollution prevention and
industrial waste reduction, clean technologies and products, Superfund cleanups, waste
management technologies, and environmental management and policy. He has worked closely
with every sector of society, from small and large companies and trade associations to local and
national environmental organizations. Internationally, he has worked extensively on developjng
pollution prevention and clean technology transfer programs in developing countries.
Experience in Pollutjou Prevention, Waste Minimization, Green Products and related areas:
Since forming Hirschhorn & Associates (a subsidiary of H+GCL), Dr. Hirschhorn has applied
his pioneering work in pollution prevention and the marketing of "green" or environmentally
friendly products to solving practical problems. Pollution prevention is now coming of age, and
his work is frequently referred to internationally. It is this type of vision that results in
cost-effective management advice and research studies for industrial and public sector clients.
His book PROSPERITY WITIIOUT POLLUTION: The Prevention Strategy For Industry and
Consumers (Van Nostrand Reinhold) is already a classic.
Dr. Hirschhorn directed a comprehensive study for the Polaroid Corp. of the potential to design
and market green products. The project included inspections of key manufacturing facilities, a
review of the company's ongoing waste reduction and R&D programs, and extensive interviews
with many company managers in technical and marketing areas. Several dozen strategic and
specific options were presented to the company's senior marketing executives on how to move
forward for its instant photography and electronic imaging products with a green marketing
strategy.
For IBM, Dr. Hirschhorn has directed a multiphase project focused on developing a
measurement system for the compa·f?y to use at all its facilities. The goal was to develop a
system that could accurately couelate waste reduction or chemical usage with production
output, while addressing the many complexities at IBM facilities, especially with regard to
production output. Dr. Hirschhorn visited several of IBM's largest manufacturing facilities to
review manufacturing operations, nianagement systems, and waste reduction programs, and to
of activity. We would bill monthly for actual labor and expenses. I note that funding for a
technical advisor under EPA Superfund TAG grants typically amounts to $25,000 to SS0,000,
and that other work I have done usually falls within this range. However, I have prepared the
above estimate with the belief that your requirements are much more focused than a typical
cleanup site and that most of the work can be performed within the next several months.
As to some references for my work as a technical advisor for citizen groups, I suggest:
Marie Flickenger [phone]; Kathy Sheridan [phone]; and Steve Lester (703)
237-2249. All three have worked with me extensively.
I look forward to having the opportunity to serve the needs of North Carolina ;~-~ its
citizens. If you have any questions:or requests for additional information, please do not
hesitate to call me.
3
Facsimile Cover Sheet
To: MR. JOHN HUMPHREY,
POLICY DIRECTOR
Company: DEPT_ OF ENVIRONMENT,
HEALTH AND NATURAL
RESOURCES
Phone:
Fax: [phone]
From: PAULINE EWALD ..
Company: ECO
Phone: [phone]
Fax: [phone] OR 358-7291
Date: 06/15/93
Pages including this
cover page: 9
Comments: MR. KEN FARRUCCIO, OF THE ECUMENICAL
ENVIRONMENTAL LEADERSHIP COALITION ASKED ME TO
COPY YOU WITH THIS PROPOSAL FOR CITIZEN TECHNICAL
ASSISTANCE AT THE PCB CRISIS SITE. PLEASE NOTE THAT
THE SUGGESTED TASKS FOLLOW THE CERCLA TAG
PROGRAM, AND REPRESENT COMPARABLE COST OF TAG,
WHICH WE BELIEVE IS AN EXTRAORDINARILY SUCCESSFUL
PROGRAM, ESPECIALLY AS IMPLEMENTED IN NORTH
CAROLINA. WE APPLAUD YOUR EFFORTS TO HAVE
MEANINGFUL PUBLIC PARTICIPATION ON THIS PROJECT, AND
LOOK FORWARD T·o WORKING WITH YOU TOWARDS A
SUCCESSFUL RESOLUTION OF THE SITUATION. PLEASE
FEEL FREE TO CONTACT ME FOR FURTHER INFORMATION IN
THIS REGARD. .
ECO is pleased to offer our services, which are uniquely suited to the
successful completion of the North Carolina PCB Site Technical Assistance proieet .
The ECO advantage includes:
* A;Julti-Discipli,wry Staff with multi-media capability
* Endorsed by major Environmental and Citizens Advocacy
groups
* Past regulatory /technical experienced with A1ajor Project
Oversight.-..
. ,,..
* Specialists in acting as citi;.en advocates, so never a possibility
of conflict of interest
* All senior employees have ad~•anced degrees and experience in
both privqte and public sector
* 100% of~taff have received EPA training
* 100% of staff are current on OSHA safety certifications
* 100% ofstafftrained in EPA data reduction metlwd<t
* Staff includes Engineers, Chemists, Toxicologists
* 100% suc;cess rate of completing projects on, or under budget,
and on tiine
NC PCR Proposal
June 14, 1993
page 2
MANAGEMENT SUMMARY
The Environmental Compliance Organization (ECO) was founded in 1988, by
a group of experienced individuals dedicated to providing cost effective, competent
compliance and engineering services to community groups, small businesses and
governmental dients. ECO is devoted to bringing quality, value, integrity and
customer service to the ficli of environmental consulting.
The principles of ECO offer advanced educations, enhanced by professional
experience in the public and private sectors. ECO staff members have extensive
experience and contacts with numerous regulatory agencies nationwide. Our
managerial staff alone has accumulated over 50 years of comprehensive experience in
the field of environmental sciences. This allows ECO to address a wider range of
compliance challenges expeditiously, at minimum cost to our clients.
E NVIRONMENT AL
COMPLIANCE
0 RGANIZATION
NC PCR Proposal
June 14, 1993
page 3
ECO is committed to a multi-disciplinary approach to compliance and site
management, and is unique in utilizing hoth technical and legal professionals to ',; .._
provide clients with the most comprehensive assistance available. This unique
advantage allows ECO to effectively reduce liability, as well as the direct costs of
environmental management for our clients. Additionally our staff is focused on, and
specifically trained in waste minimization theory and technology, and has been able on
virtually every consultation to suggest designs and practices that have resulted in
significant reductions in hazardous wastes, as well as remedial costs. Our multi-
disciplinary approach, and our highly qualified staff allows ECO to provide a full
range of environmental, bel';lth and safety services to meet all the needs of our clients,
regardless of the challenges involved.
ECO's commitment to environmental protection, extends heyond compensated
projects. Through the non-profit ECO Foundation, we donate approximately ten
percent of our net profits, as well as personal time and energy to various
environmental education and protection projects. Wherever possible, we utilize
recycled and environmentally friendly office products, and practice recycling of our in-
house waste. ECO personnel proudly serve pro bono on numerous local, and national
committees for development of sound waste management and environmental policies,
and participate in a number"trials for the development and testing of alternate waste
destruction technologies.
F, NVIRONMENTAL
COMPLIANCE
0 RGANIZATION
,, ....
• ....
NC PCB Proposal
June 14 , 1993
page 4
ECO currently has three offices, a headquarters located in Ashland, Virginia,
an engineering and research facility located in Bloomington, Indiana and a publttt::
assistance office located in Apollo, Pennsylvania. Staff from all technical disciplines,
and from all ECO offices will be available in assisting in the successful completion of
the North Carolina PCB Site Technical Assistance project.
ECO believes that solutions to the particular challenges presented by projects
such as the North Carolina PCB site Technical Assistance project can best be met
through our unique multi-disciplinary approach.
In keeping with this philosophy, ECO has assembled a team of highly
qualified professionals in the fields of engineering, toxicology, chemistry, biology,
economics, education, planning and law, in order to fulfill and exceed the primary
requirements of the Technical Assistance program, and any other ancillary needs that
may arise in successfully completing this project.
ECO proposes to utilize this unique combination of technical and regulatory
compliance talent in a balanced "team" approach to this project, thereby providing
the highest standard of competence, in conjunction with service that is time and cost
effective.
E NVIRONMENT Al,
C Ol\1PLIANCE
0 RGANIZATION
NC PCR Proposal
June 14, 1993
page 5
All staff members designated for work under this proposal have direct
experience in Federal, State or Local government, and have had extensive involvement
in the development and implementation of all relevant environmental regulations and
standards.
ECO conducts all work according to an EPA approved Oualitv Assurance
Proiect Plan, and EPA approved methodology for sample and risk assessment
review. All ECO staff have received relevanl training direclly from EPA, and
unde1take yearly update training. This rigorous attention to approved protocol and
detail, provides assurance for our clients that all work performed by ECO will meet
with regulatory approval on first review, and is defensible as evidence in court if
necessary, or requested.
E NVIRONMENTAL
COMPLIANCE
0 RGANIZATION
r •
. ... ....
NC PCB Proposal
June 14, 1993
page 6
PROJECT PROPOSAL
.
s -.
I. SITE INVESTIGATION -to include 15 split sainples to be
...
.analyzed for full CERCLA scan, including PCDD/PCDF. All lab work
to be perfonned as per EPA protocol at an EPA CLP laboratory. Lab
results will undergo data reduction and analysis as per EPA functional
guidelines. Preparation of written sununary report to be included.
COST : 15 samples @ $ 2,000/sample = $ 30,000.00
(cmnpetitive bids will be solicited and docun1ented from al
least three GLP labora UeMc=
Travel to include (2) two round trips for (2) two people @
$ .25/ 111ilc X approxin1ately 1,000 111ile round-trip=
$ 250.00
Cooler purchase and shipping @ $125.00/cooler X 2
coolers = $ 25 0 _ 00
TOTAL COST THIS TASK= $ 52,000.00
E NVIRONMENT AL
COMPLIANCE
0 RGANIZATION
NC PCR Proposal
June 14 , 1993
page 7
II. RISK ASSESSMENT -to include EPA protocol and format,.,
analysis of potential iinpact on hmnan and wildlife receptors of ~-;..
conditions documented during site investigation.
COST: 450 man ho~s ~JO/man hour=$ 29,250.00
TOTAL COST THIS TASK-$ 29,250.00
-> III. FEASIBILITY STUDY -to include analysis and weightiI1g of
all applicable remedial technologies as per EPA protocol and format, or
other formal and criteria to be developed in conjunction with State
agencies. Ultiinate goal is to choose re1nedial technology representing
greatest possible short and long tenn protection of hmnan health and the
environment, while bei~g reasonably cost efficient. To include
providiI1g teclu1ical assistance and public education regarding
iinplementation of chosen alternative_
COST: 525 man hours ~/man hour= $34,125 .00
TOTAL COST THIS TASK:$ 34,125.00
E NVIRONMENT Al,
COMPLIANCE
0 RGANIZATION
.r ... .
L. .... .J ...
NC PCR Proposal
June 14 , 1993
page 8
IV. REMEDIAL DESIGN AND IMPLEMENTATION -to
include review and commenting on proposed plans, and provision <1(
citizen infonuation assistance and education during re111edial activ.1~
COST: 100 1nan hour 0/inan hour=$ 6,500.00
/
TOTAL COST THIS TASK: $6,500.00
V. POST CLOSURE MONITORING -to include preparation of
final site disposition report, and review and 1nonitoring of proposed
long tem1 monitoring plans for the areas potentially impacted by the
site.
COST 50 man hoills @~1 hour=$ 3,250.00
TOTAL COST THI~ TASK: $ 3,250.00
ECO estin1ates that the teclu1ical assistance project will have an
effective duration of between two (2) to four (4) years.
TOTAL ESTIMATED COST THIS PROJECT: $154,125.00
E NVIRONMENT AL
C Ol\1PLIANCE
0 RGANIZATION
To: Martha Waggoner, Associated Press }~
From: Ken Ferruccio, Ecumenical Environmental Leadership Coalition [phone]
Subject: PCB Crisis
Date: 6/15/93
In our conversation on Monday, 6/14, you asked why the PCB crisis has not been more
embarrassing for Governor Hunt. Presently, the only thing standing in the way of a
civil rights movement is a mutually agreed upon 5-point framework (informed by a
rationale consistent with principles of waste reduction and equity) to resolve the PCB
crisis. If the state abandons its commitment to working within this framework, a civil
rights movement is inevitable ( For the 5-point framework see Enclosure A, pp 3+4).
The 5-point framework and the rationale that informs it was completed and dated May
17 and faxed to Secretary Jonathan Howes on Tuesday morning, May 18. as a
memorandum. Immediately after faxing, we released it to the news media of North
Carolina. I read the memorandum to Secretary Howes at the meeting here in Warren
County on May 24th and added to the memorandum the civil rights implications
concerning not only the PCB crisis, but also concerning the intention to site massive
solid waste landfills of the same design as the PCB landfill throughout the state and
nation under Sub-D regulations. (For the civil rights implications concerning the PCB
crisis and concerning siting solid waste landfills under Sub-D regulations, see
Enclosure A, pp 4 and 5).
Martha, the following is the chronological sequence of events that led to
the five-point framework. If you review the chronology of events and
relate them as indicated to Enclosures A, B, and C, you'll understand
why Governor Hunt has not yet been more embarrassed by the PCB
crisis and what is needed to preclude his further embarrassment by yet
another civil rights movement.
May 14, Friday
Radio news stated that the North Carolina Department of Natural Resources had
announced that there were 500,000 to 1 million gallons of water trapped in the
Warren County PCB landfill. water that required pumping. Debbie Crane of the
Department of Natural Resources called .me late afternoon about the PCB crisis.
I told Debbie to make it clear to Secretary Howes that the state do nothing until after a
meeting with us here in Warren County to explain the plan. Debbie said a meeting
was being planned for Wednesday (May 19). I said that we were having a solid waste
meeting on that date and that another date would be preferable. My understanding
was that the date would be changed and that the implication was that we would be
informed of the change.
May 15, Saturday
The News and Observer covered the PCB crisis, explaining the state's plan.
The Herald Sun also covered the story.
May 16, Sunday
I began drafting my response to the state's plan to Secretary Howes. My focus :
Incompatibility of the plan with principles of waste reduction and equity.
May 17, Monday
On Monday late afternoon I was informed that a meeting had been held here
in Warren County involving Secretary Howes, Debbie Crane, our local health
director, and others. I had received no notice about this meeting. I completed revisions
of my statement to Secretary Howes and decided to fax it to him on Tuesday morning
as a memorandum and to release it to the news media immediately after faxing.
May 18, Tuesday
My memorandum was faxed to Secretary Howes in the morning and immediately
after faxing, released to the news media.
Late afternoon, Debbie Crane called informing me that another meeting
was scheduled for May 24th. She said my faxed statement hadn't been received.
A few minutes later John Humphrey called, policy director for Secretary Howes.
He said the fax had been received and that he wished to discuss the 5-point
framework. John wanted to know if we could consider the 5 conditions in terms of a
priority sequence. I said they should not be understood sequentially or hierarchically
but as interrelated facets of a complex situation. We talked for what seemed to be well
over an hour. I mentioned the sacrificial implications of the PCB siting, what it had
meant in human terms, and what it had meant to Warren County. I told him I'd go all the
way on this. I said, "You're not talking to someone who has to pay the mortgage every
month or somebody worried about a job." I said I'd wait for my contract at Halifax
Community College to expire (May 29th) before going active, but that doesn't mean
the state should rush into things as they did in 1982. We 're going to be around a long
time. We live here. I said, "We're in a mine field here, John, you and I and Secretary
Howes, and all of us, and we 've got to walk hand-in-hand very cautiously so that
nobody trips a wire.'' I said I'd stick to my conditions. I said I didn't care if the whole
county, if everyone went the other way. I found out in 1978 that if one person believes
something is important, then it's important. I referred to the fragile strip of land along
the Warren/ Franklin border, the area of the PCB landfill, and expressed concerns
about waste expansion and inequity. I told John that I felt no ill will toward Hunt, but I
did stress that Hunt is a waste expansionist, that he wrote the legislative framework
to establish the infrastructure for waste expansion and inequity in North Carolina in
order to solicit waste from other states and from overseas and referred to Hunt's Waste
Management Act of 1981. I said we'd never accept the preemptive powers of that
Act. I discussed them and referred to the Act as the Waste Expansion Inequity Act.
I said it was based on a rationale for selective human sacrifice. I said what is needed
is a Waste Reduction Equity Act. John said that efforts are underway to repeal some
aspects of the Waste Management Act. I said the Waste Management Act represents a
tyranny of executive power concerning the siting issue and asked, "What's the use
of a siting model when you've got to obliterate the folks to site?" John asked if I'd
read United Church of Christ's history about Warren County and the PCB problem.
I said I'd written the rationale and objectives for the United Church of Christ grant
that helped fund the environmental justice movement at the suggestion of Reverend
Bill Land and others, but that I had not read the history. I said that United Church
should be commended for writing the history, but that we would no doubt write the
definitive history because we have all the inside stuff. Finally, I stressed the need
to keep communication channels open. I said if we had had open communications
with the state, I probably would not have had to send my memorandum to
Secretary Howes to the media and that I wouldn't have to be talking with the state
through the media, but that the media would be essential to keeping things open
anyway. I asked John if he understood our conversations to be confidential. He said,
"no."
May 19, Wednesday
John called me at my office (Halifax Community College) about 11 :20 a.m. We
discussed what the nature of the May 24th meeting should be. We decided
it should be an informational meeting involving public comments and moving
toward some kind of committee through which things could be worked out
within the 5-point framework. John assured me that there would be no sudden activity
at the site, that the attempt would be to reach a resolution within the 5-point framework
by working through a committee. I said my wife Deborah and I would have to be
involved in everything. John agreed. John called again at 2: p.m. He said Bill Meyer
at the meeting would explain the situation concerning the PCB landfill and what
options were available, followed by public comments. John also listed the officials
who would be attending the meeting and noted that Secretary Howes would attend
but would not run the meeting. John said that Secretary Howes would fax a letter
to me tomorrow, Thursday, May 20th, stating that he agrees in principle on all
five points.
May 20, Thursday
Letter did not arrive.
May 21, Friday
Letter did not arrive. Deborah said channel 11 had called . They had
received the memorandum I'd sent to Secretary Howes.
May 24, Monday
John called my office shortly after 11: a.m. He said the letter from Secretary Howes had
been completed and would be faxed to the Warren Record today. I insisted to John that
no unreasonable time constraints be placed upon public comments that evening
at the meeting in the Warren County courthouse at 7:p.m. John agreed. I told him
that I would read my memorandum to Secretary Howes, then translate it into
a common language (the language of civil rights), and ,finally, propose a mechanism
through which to attempt a resolution within the 5-point framework. I read this proposal
(See Enclosure A, pp 5+6) over the phone to John. The letter from Secretary Howes,
dated May 21, proposing a" first-of-its-kind joint advisory committee," and addressing
each of the conditions mentioned in the 5-point framework, was faxed to the Warren
Record at approximately 4:30 p.m on May 24th, too late for us to see it before the
meeting. However, after the meeting, John handed me the original letter (Enclosure B).
May 28, Friday
John Humphrey called at almost 5: p.m. Said samples would be taken maybe week
after next. Maybe ten per well for a couple of weeks. Wanted to know if we
wanted split samples on all or some of the wells. He also asked us to choose
our scientist. I said we needed to talk with Billie Elmore, Executive
Director/Coordinator of North Carolina Waste Awareness Reduction Network (NC-
WARN). Billie had agreed earlier in the day to serve on the joint advisory committee. I
made it clear that Billie would need to be central. John indicated that there wouldn't be
a problem.
June 1, Tuesday
Billie called about 3:15 p.m. to suggest we consider a scientist recommended by
EPA official Bill Sanjour. Concerning independent testing of well water, Billie
suggested a contact who recommended Pauline Ewald.
We were not able to establish communication with John from June 7 through
June 11, so on Friday, June11, I faxed the enclosed memorandum to John, with copies
to Governor Hunt: Secretary Howes, DEHNR: Robert W. Estill, Episcopal
Bishop of North Carolina, and the news media (Enclosure C). John called me on the
following day, Saturday, June 12, to discuss concerns mentioned in my Friday, June
11th memorandum to him: members of the joint advisory committee,
split samples, an independent scientist to evaluate detoxification, etc.
June 14, Monday
Martha Waggoner of the Associated Press called. Asked why the 500,000 to
1 million gallons of water hasn't proven to be more embarrassing to
Governor Hunt. She had heard that the reason was Steve Leviticus: I indicated
that to my knowledge Steve wasn't involved. I then called back and gave Martha
a more comprehensive explanation based on what I did know.
June 14, Monday (continued)
I called Pauline Ewald and told her I would fax to her a copy of my June 11
memorandum to John Humphrey (since the first paragraph referred to her and certain
aspects of the memorandum were based on my conversations with her) and that she
should then submit a resume and proposal concerning testing well water in close
proximity to the PCB landfill. She agreed. I called her again about 5: p.m. and
suggested that she consider a proposal, not only for the testing of wells, but for serving
as independent science adviser concerning detoxification evaluation, etc. She agreed.
June 15, Tuesday
Joel Hirschhorn, who had been recommended to be the independent science adviser
for the proposed joint advisory committee, called and I suggested that he fax a resume
and proposal to John Humphrey and to us. Pauline·s proposal arrived this morning,
Joel's, this afternoon.
Margaret, I'll send this package to you tomorrow, June 16, since I've been working on it
most of the afternoon and since it is now 9:30 p.m. Thank you for your interest.
Please call as needed. I'll stay Close to you and keep you abreast of things as they
continue to develop.
To: Jonathan Howes: Secretary of Environment, Health and Natural Resources p__d_
From: Ken Ferruccio: Ecumenical/Environmental Leadership Coalition, Director ) 'V
Subject: Response to State PCB Plan: Conditions, pp 3+4
Date: 5/17 /93
For Immediate Press Release (919-257-2604)
I assume you've been briefed on the complexity of the issues, specifically,
from the historical perspective, and more specifically from the perspective
of Warren County and the targeted communities.
Certainly, we of Warren County understand the historical perspectives. We should.
We lived them, helped to create them, and gave them a language, And it was this
language that ignited the spark, that lit the fuse, that blew the powder keg in 1982
and again in 1983. The light and heat from those explosions fused forever concepts
that for too long had been kept apart: environmental justice, environmental civil rights.
So when the dust clears, and when the history of the environmental/civil rights
movement is written, it will begin with Warren County, and with the language that
Warren County created in response to events from 1978 through 1982, in response
to events of 1983, and, more recently, in response to events of 1992, when Lickskillet,
a poor, black community, three miles downstream from the PCB landfill, was targeted
for a 1000 -1500 -acre-regional solid waste landfill.
We had to remind public officials advocating that siting, that Warren wrote the book on
opposing sitings. We had to remind them that in 1982, and again in 1983, members of
three races, blacks, whites, and Indians carried a cross here and were sacrificed in
defense of principles universal to all people, places and times -to all races, colors,
classes and creeds.
We had to remind them that that sacrifice changed the way we see the world, that it
was the spark that ignited a revolution, that it was a major, a lasting historical
achievement, or, as EPA calls it, the watershed. We had to remind them that it
was the beginning of a pilgrimage of conscience, a pilgrimage of activism that
would go on forever. And therefore in this deeper, in this more profound and
eternal sense, everything concerning siting since 1982 is a footnote to Warren County.
And now, here we are again, continuing the pilgrimage under the
authority, not only of the county and of the state, but also under the
authority of the National Episcopal Church, under the authority of
the National Council of Churches, and, ultimately, under the authority of
God, and supported by ecumenical and environmental leaders throughout
this state and nation. And our responsibility together now is to formulate the
best language in response to this PCB crisis, to formulate the best, the most
environmentally sound and equitable solution for everyone.
(I)
We are deeply disturbed about the PCB crisis here and about the trends
this crisis represents throughout our state, our nation, and our world. The Afton
crisis symbolizes the prevailing model for economic/industrial development:
the model for waste expansion and inequity. The goal of this expansion/
inequity model is to establish a massive waste management infrastructure to
solicit waste from other states and from overseas.This model is informed by a rationale
for selective human sacrifice because it requires for its implementation
the transformation of targeted communities into sacrifice zones by toxic, hazardous,
and nuclear waste facilities , and by massive solid waste management
facilities. The model requires the gradual, but inevitable extinction of the
targeted community by the preemption of its civil rights.
Afton, Warren County, symbolizes the loss of just about everything that the 13th and
14th amendment rights are meant to protect. The 1982 siting put Rosa Parks in
the back of the bus once again, and now the bus is self-destructing.
The Waste Management Act of 1981 and the Sub-D regulations continue to
perpetuate the rationale for selective human sacrifice. And so I think, Secretary
Howse, you can understand why we must continue to resist these sitings, to resist
them absolutely, and the trends that they represent, and why we cannot permit trucks
loaded with solid waste or PCB waste to enter or leave our borders. Our waste
management problem, and our PCB crisis must be resolved, but must be resolved
locally.
Afton symbolizes also a crisis within the soul of the state, and this crisis must also be
resolved. The crisis involves the two diametrically opposed and conflicting
models for economic/industrial development struggling to control the soul
of North Carolina: the model for waste expansion and inequity, and the model
for waste reduction and equity. These are not false polarities. These are not false
choices. They are true choices. They are profoundly ethical choices.
EPA siting regulations, Governor Hunt's Waste Management Act of 1981,
and Sub-D regulations are the reverse of what is needed for waste reduction
and equity:
(1) Instead of siting to solicit waste, we should be reducing and
preventing waste to preclude sitings.
(2) Instead of preempting rights to sacrifice communities, we
should be reaffirming rights to preserve communities.
(3) Instead of sacrificing the few for the many, we should be creating
and preserving quality settings for every community.
(4) Instead of preempting the significance of public hearings, they
should be the corner stone of our democracy.
(2.)
(5) Instead of exclusiveness in decision-making, inclusiveness.
The prevailing model undermines the fundamental premises for a sound theology,
for a sound democracy, and for a sound ecology. It leaves us ultimately without
God, without freedom, and without a planet. It is a self-destructive model, a suicidal
model. It is a model for social disintegration, informed by a rationale for selective
human sacrifice. These are our concerns from the more global perspective.
Turning now to our local crisis, we need to resolve it within a framework
compatible with the principles of waste reduction and equity. These are the
bottom lines:
(1) The proposed Band-Aid approach is unacceptable. It's only
a stopgap measure. Our objective must be to restore the
ecological status of Afton to what it was before the siting
and to restore its property values, by creating the
reality and the perception that Afton is a very fine and safe place
to live so that the people of Afton and of Warren County will
be able to move forward once again to a safe and prosperous
future. We need therefore to explore the option of on-site
detoxification, assessing costs, risks, etc. In other words, we need to
help Governor Hunt keep all promises made in his 1982 letter to the
people of Warren County.
(2) If our research indicates that on-site detoxification is not presently
a viable option, then, after on-site stabilization, future activity
at the site must involve monitoring and maintenance only.
Repeating the 1992 attempt to take advantage of the sacrifice
area by expanding from the foothold will be resisted.
(3) The solution must be restricted to the site. The solution
must not include an expansion of the present site, nor in any way
transcend its present borders. Expansion will be resisted.
(4) The trucking initiative must be precluded. Under no condition
will trucks loaded with PCBs leave the borders of the PCB
landfill. Such an attempt will be met with the most serious
forms of resistance.
(5) We will need to be convinced by disinterested scientists that
the filtering process will extract the PCBs from the 500,000
to one million gallons of contaminated water that
the state is planning to spray all over the site. The attempt to
(3)
initiate this process before a disinterested scientific assessment
of risks has been explained and consented to will be resisted.
If the above conditions can be met, we can move forward together.
Finally. when your people come to Warren County, tell them that in 1982, three races
carried a cross together in the poor and predominantly black community of Afton.
here in Warren County, and that here. together. they were sacrificed. Tell them,
therefore, to come with reverence and with awe. Tell them that in 1982, in Warren
County . North Carolina, blacks, whites, and Indians transcended a history that had
divided them and came together in brotherhood and love, and that from their sacrifice
emerged new hope for a new history, informed not by a rationale for selective human
sacrifice, but by the universal brotherhood of man. Tell them to come as pilgrims on a
pilgrimage, because all this land is holy land. all this ground is holy ground.
Secretary Howse, that concludes my memorandum to you. And now I would like to
translate what I have said into the language of the people: What we have out
there, folks, in the poor black community of Afton .is a bus. Now I know it doesn't look
like a bus. It's not supposed to look like a bus. It's supposed to look like a landfill.
But I'm telling you, it's a bus. And the bus is self-destructing. And I'm telling you that
one of our neighbors is on that bus. And her name is Rosa Parks. I know Rosa Parks.
Rosa Parks is a friend of mine. But instead of trying to get Rosa Parks off the bus,
and keep her off the bus. we're getting ready to build a whole fleet of buses, just like
that one, and getting ready to fuel them with the high octane of Sub-O regulations.
And then we're going to drive those buses into the poor black and other poor minority
communities, put the poor folks in the buses, and then wait for the buses to self-
destruct, just like we did in Afton.
These are the big buses; these are the massive solid waste buses. containing toxic
and hazardous waste; these are the 800 acre buses, the 1000 acre buses, the
1500 acre buses. These are the buses that will contaminate the groundwater of the
poor black and other minority communities.
How long? Not long.
1 n December of 1978, I was 36 years old, when I told the state of North Carolina that it
would be due process first, then civil disobedience if the state attempted to bury PCBs
in the poor and predominantly black community of Afton.
How long? Not long.
In 1982, I was 40 years old when as a last resort we had here the largest nonviolent
civil disobedience in the south since Dr. Martin Luther King. Jr. marched through
Alabama, according to the Duke Chronicle, and when I was arrested 8 times.
How long? Not Long.
in 1983 I was 41 years old when I began the second civil rights movement
in response to the state's plan to spray 750,000 gallons of PCB-contaminated
water all over the site and fasted 18 days in the Warren County jail.
How long? Not long.
Before I was 42 I'd been arrested 9 times on this issue.
How long? Not long.
In 1992, I was 50 years old, when I cautioned the local. state, and federal government
that the attempt to site a 1000-1500 acre landfill three miles downstream from
the PCB landfill in the poor. black community of Lickskillet would be met with the
most serious forms of resistance.
And now, It's 1993, and I'm 51, and I'm telling you again that the bus is self-
destructing. And that we're getting ready to build a whole fleet of buses
just like this one. with the same self-destructive mechanisms. and fuel them up
with Sub-D , and drive them into the poor minority communities.
And then we 're going to put all the poor folks inside with Rosa Parks. and wait
for the buses to self-destruct. Estimated time of departure: October 9, 1993.
How long? Not long. Because the high octane of Sub-D regulations. the high octane
of The Waste Management Act of 1981 , and the high octane of the philosophy
of waste expansion and inequity is the same high octane that drives the rationale
for selective human sacrifice. the same high octane for discriminatory and
segregational sitings.
But like the sun through the foliage on a green day, I know my way. I'm not going
to follow the Sub-D regulations; I'm not going to follow the Waste Management
Act of 1981; I'm not going to follow the rationale for selective human sacrifice,
because I can't accept this rationale. I couldn't accept it in 1978 when I was 36; I
couldn't accept it in 1982. when I was 40; I couldn't accept it in
1983, when I was 41 ; I couldn't accept it in 1992, when I was 50, and I cannot
accept it in 1993 at 51 . And I will never accept it, because to accept selective
human sacrifice is to perpetuate it and to encourage it.
Now I would like to suggest a process through which I believe we can work together
toward a resolution to the problem. There will be a Director for Research.
Planning, and Communications in your office, Secretary Howes, whose sole
responsibility will be to deal with this issue. And that same research. planning, and
communication process will be coordinated from this end by Deborah and me,
(5)
and by others who would like to participate as well as by those who may need to
participate because of their official positions.
Communications between your office and my office must be open and fluid. Obviously,
you'll decide who the Director of Research, Planning, and Communication will be
at your end, but we will expect someone with the following characteristics: An
open and flexible mind that can
(1) assimilate information quickly
(2) evaluate information from interdisciplinary and multidimensional
perspectives and within the context of criteria and objectives
compatible with the 5-point framework, and in accordance with
principles of waste reduction and equity.
(3) contradistinguish what is central from what is peripheral, especially,
concerning the needs of the Afton community.
(4) Communicate information clearly, concisely, and accurately.
A committee will be needed consisting of various experts. and we'll
need to formulate an acceptable plan together. When we think we've got
a plan compatible with the 5-point framework. we'll have a town meeting
and present it.
'
-. _oeparrmenr or tnv,ronmeni. '-·;-J: /Health and Natural Resources
Jomes B. Hunt. Jr .. Governor
Jonathon B. Howes. Secretory
Mr. Ken Ferruccio
May 21, 1993
Ecumenical/Environmental Leadership Coalition
Warrenton, North Carolina ·
Dear Mr. Ferruccio:
Thank you for your memorandum of Monday, May 17, rega~ding the
PCB landfill in Warren County.
As you know, the St.:1 te i s very concerned about potential
breaches ot the landfill liner that might occur because of the
estimated 500,000 to 1,000,000 gallons of water which has collected
in the bottom of the land! i 11. We want the aol 1Jt ion to this
problem to be worked out jointly with citizens. Therefore, we have
contacted local citizens and officials about the problem: we have
set up opportunities for broad public input: and we will create a
first-of-its-kind joint advisory committee comprised of local
citizens and State officials to develop a process by which the
water can be removed.
In your memorandum about this matter you raised five specific
concern• which I would like to respond to.
First, the State stands by its commitment tc detoxify the
landfill once a process is developed that will do so without posing
a greater risk to citizens than the landfill itself. In 1984, a
State advisory committee examined options for deto~itication and
determined no feasible process yet existed. I have directed
Departmental staff to work with citizens again to determine if new
technology has been developed which wo~ld effectively detoxify the
Warren County landfill.
Second, the State has no intention of expanding the current
landtill. Moreover, legislation was passed in 1983 which prohibits
the construction of any PCB or other hazardous waste landfill
within 25 miles of the existing warren County PCB landfill. You
also raised concerns about the siting of regionc1l solid waste
landfills in Warren County . Local governments in North Carolina
have total responsibility for siting solid waste landfills. The
state is only involved through permitting such faciliti~s based
upon established environmental regulations. Prohibitions on siting
a solid waste landfill would have to be don~ through the
legislature.
P.O. Box 27687. Rolelgh. North Carolina 276 l l -7687 Telephone QH1-7JJ-ll9SA
Ari EQuol 0ppor1unlty Afflrmoilve .Acllon Employer 5()'1, recycled/10'1. pos1-con.sumer pooer
(7)
) ·'):/ Third, the State's goal is to find an on-site s,olutlon to the
problem of water in the landfill. We are very ser,sitive to the
concerns of Warren County citizens that ,PCB waste !::-om the Warren
County landfill not be transferred to another community, especially
to one that is rural, relatively poor, and predomin;!ntly African-
American, Native American, or Hispanic.
We . havo a JJt1rong desire to avoid S\?Ch a transfer as well. Our
Hazardous· Waste Section staff have identified an on-site means to
handle the water to be pumped out of the landfill which they
believe will protect public health and safety. As of yet, however,
no technically feasible means to handle on-site the sediment that
will be pumped out with the water ha~. been identifietj~• A principal
goal of the joint advisory committee will be to reviaw the proposed
solution for on-site handl'i.ng of the water and to datermine if an
on-site solution for the sediment can be identified so that off-
sita options will not have to be exercised.
Fourth, once again, the State pre(ers not to truck any waste
otf-aite, and therefore will be working .with citizens to identify
an on-site solution that will preclude the need for material to be
removed from the site.
Fifth, we are eager for outside review of the entire process.
The purpose of the joint advisory committee will be to bring
citizens and the State together to devel~p, monitor, and review the
process by which the water will be removed from the land!ill.
Additional outside review would be welcome.
I will be at the public meeting r~garding the landfill which
we have set up tor 7 p.m. on Monday night at the warren County
Courthouse. I look forward to seeing you there.
{
To: John Humphrey, Policy Director
Department of Environment, Health and Natural Resources
cc : James B. Hunt, Jr.
Governor of North Carolina
Jonathan B. Howes, Secretary
DEHNR
Robert W. Estill
Episcopal Bishop of North Carolina J/--l.-
From: Ken Ferruccio, Ecumenical Environmental Leadership Coalition /fv ·
Subject: Technical Assistance Concerning PCB Crisis
Date: 6/11 /93
For Immediate Press Release
I've had extensive conversations with Pauline Ewald, President,
Environmental Compliance Organization (ECO), 106 Robinson
St., Ashland, VA 23005 (tel.: [phone]). She has a degree in environmental
engineering and law. Her firm will test designated wells in close proximity to the
PCB landfill for PCBs and dioxins the last week of June. She estimates
that full-scans for PCBs and dioxins will cost from $1500-1700 per sample
and $55. per person per hour. It should take a day or two at the most to
collect the samples. we want approximately 12 to 15 wells tested. Debbie Crane
said yesterday that funding for independent samples couldn't come from the Waste
Management Board's community assistance funds because those funds are being
transferred to another program, but that several other sources are available.
We feel that this independent testing is necessary because reliable conclusions
concerning the relative safety of well water tested cannot be extrapolated from the
sample parameters chosen by the state (PCBs only, unless tests for other
contaminants are specifically requested by the citizens) and because
it's obviously advantageous to the state to prove that the dump is not leaching.
Many contaminants other than PCBs are likely to have been included in the 10,000
truckloads of PCB-contaminated soil because it was extracted from 21 O miles of
highway shoulders possibly exposed to hydrocarbons, lead, etc. A comprehensive
full-scan would involve testing for 3500 different contaminants. But, most important,
it's irresponsible, and probably criminal, that the state is leaving it up to ordinary
citizens to know what other possible contaminants they should ask to have their wells
tested for. The state is privy to the fact that testing for dioxins is essential because the
environment acts on PCBs producing dioxins through heat and through the interaction
of PCBs with soils, and to the fact that dioxin is often a side-contaminant of transformer
oil because of the manufacturing process, and to the fact that the landfill contains
transformer oil laced with PCBs and mixed with soils possibly containing other
contaminants as well.
I
Particularly disadvantageous to the state would be for it to discover dioxins in the wells
because such a discovery would magnify the problem one thousandfold. the risk to
human life and wildlife from dioxin being one thousandfold more than from PCBs.
Since there is presently no place to dispose of dioxins. what would the state do with
them if it found them? Of course, dioxins can't be found if not included in the sample
parameters. Another advantage of not testing for dioxins is cost-effectiveness. Testing
for dioxins is expensive: $1 ,000 or more per sample. This is the kind of thinking that
informs the rationale for selective human sacrifice on which the philosophy of waste
expansion and inequity is predicated, the prevailing economic/industrial orientation
of the state.
What is needed, of course, is the most comprehensive and aggressively technological
approach available. The sample parameters chosen by the state indicate that
the state is not interested in quantifying what the health risks really are. Not doing
full-scans (testing for the full range of possible contaminants, or, at the very least.
for dioxins as well as for PCBs) is understandable, not only because of the reasons
stated, but also because the state. under the previous Hunt administration, spent
$514, 375. 71 to construct the PCB landfill; almost one million dollars worth of force
to site it; and another $2.8 million dollars from Superfund for cleanup and more. It's
therefore quite understandable why the Hunt administration is trying to make a virtue
of parsimony regarding the testing of Afton's wells after having spent so much money
and so many years trying to destroy them .
However. if the state really wants to help us. let us know by Wednesday of next week
whether funds will be appropriated for independent testing of wells during the last
week of June. We do regret that the state agreed to split-samples of wells and then
began testing before providing funds needed for us to exercise the alleged option.
Let us know also if the state is still planning to have a joint advisory committee, as
there are several people ( local. state. and national) who have expressed a
willingness to serve on the committee and to work within the 5-point framework
agreed upon. We also need to know if the state is still planning to appropriate funds
for a scientist to represent our interests. EPA official William Sanjour and
NC-Warn Coordinator/Director Billie Elmore have recommended a person we'll
be talking with on Monday. I believe Bill Meyer and the folks up there know him well.
We will continue to try to work with you. However. since you have not returned our
calls for several days, we have begun to wonder whether a more recent policy
of incommunicado has superseded the earlier public commitment to work with us
to resolve the PCB landfill crisis. Under no condition will communications be
terminated at this end, but we will continue to seek other channels of communication
when we cannot get through to you.
I must say that I have been particularly impressed with you and continue to believe
that we have established an atmosphere of trust and good will. I will not deny that at
times I become frustrated because of the lack of communication. Although I continue to
be informed by a healthy skepticism concerning the Hunt administration on this
particular issue because of the history, I continue to hope that perhaps a new
era of enlightenment is dawning in North Carolina regarding matters pertaining to
the environmental waste management crisis as related to economic/industrial
development.
If the state really wants to work with us, John, there will be no need for face-saving
political maneuverings and empty promises meant to delay the inevitable --namely,
a resolution consistent with the principles of waste reduction and equity. We are
committed to such a resolution and are prepared to work in good faith with the state to
achieve it. Of course, the state can fall back to the old policy of incommunicado, of
bad faith, deception, and breaches of law, and, ultimately, of following the principle of
doing what it wants to do through force. But such an approach reflects an old world
leadership that can't think, or that refuses to think, any other way; an old world
leadership that should have retired years ago; an old world leadership that helped
create the revolution that revealed its obsolescence; an old world leadership that
continues to rule like the light from a star already extinct. Which light will you follow,
John?
... : ,.
North Carolina
Department of Administration
James G. Martin, Governor June 11, 1991
Secretary Thomas J. Harrelson
Department of Transportation
Raleigh, North Carolina
Secretary William w. Cobey, Jr.
James S. Lofton, Secretary
Department of Environment, Health & Natural Resources
Raleigh, North Carolina
Re: PCB Land Fill Agreement -Warren County
Dear Secretary Harrelson and Secretary Cobey:
On June 15, 1990, the environmental permit under which the
PCB landfill site is operated was issued to the Department
of Administration. This department has agreed to assume
managerial responsibility for the site with the Department
of Environment, Health & Natural Resources providing
technical assistance and the Department of Transportation
providing maintenance.
The mutual responsibilities of our departments have been
previously discussed. The purpose of this letter is to set
forth those responsibilities in writing. The
responsibilities to be performed by each department are as
follows.
Department of Transportation
1. Mow landfill grass as needed.
2. Maintain existing structures such as fences,
roadway, and entrance gates.
3. Incorp9rate the expenses to perform all of the
above -tasks into the operating budget of the
Department of Transportation.
Department of Environment. Health and Natural Resources
1. Inspect the landfill site monthly and report
findings to the Department of Administration.
116 West Jones Street• R,lcigh, North Camlina 27603-80C3 • Telephone [phone]
State Courier 51-01-00
An E'-l""I C''rrnrruniry / Affirm~rh·r Act inn Emrlnyrr
Secretary Thomas J. Harrelson
Secretary William w. Cobey, Jr.
June 11, 1991
Page 2
2. Report to the Department of Administration any
malfunctions or irregularity in the operation
and performance standards of the PCB landfill.
3. Provide technical assistance to the Department of
Administration on future projects necessary to
maintain the integrity of the landfill site.
4. Inspect and test privately owned wells within one
and one-half mile radius of the landfill site,
upon special request from the owners of the wells.
5. The Department shall include in its operating
budget funds to monitor, inspect, and report on
the landfill site.
Department of Administration
1 . The Department of Administration shall supervise
the management and operation of the landfill site.
2. Any additional construction or activity at the
landfill site shall be approved by the Department
of Administration.
3. The Department of Administration will be re-
responsible for any future expenditure of funds to
improve the landfill site. These funds will
include, but not be limited to fencing the lagoon,
replacement of wells, and replacement of irrigation
pumping equipment.
Please indicate your approval to this agreement by signing
below. I am forwarding herewith three duplicate originals
of this letter so that each department will have a fully
signed original for its files.
Sincerely,
~1~0
APPROVED
DEPARTMENT OF TRANSPORTATION DEPARTMENT OF ENVIRONMENT,
H ATURAL
Harrelson)
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North Carolina Department of Environment, Health, and
Natural Resources
William L. Meyer, Director
Solid Waste Management Division
To: ------------Mr. Earl Llmer Dale: __ 6 ___ /_10 ___ /_93 __
Please:
__ Draft a reply for my signature __ For your information
See me about attached
__ Handle and report to me
__ Take appropriate action
__ Approve
Note and return attached material to me
Remarks: Mr. Litner,
My office bas been trying to reach you every day for the last
week and I have tried over the weekend from my home and my secretary
has tried on two different nights. However, we have been unable to
reach you at [phone]. We called the telephone company and
verified your number and they gave us your address. Please give us a
call and we'll be glad to help you with your concerns. I'm sure you bad
questions regarding the PCB Landfill there in Warren County.
I will be in the office most of next week. As of no~ I do not
have any meetings scheduled Monday -Wednesday and should be
available during those times from 8:00 a.m. to 5:00 p.m.. I will be in the
office on Thursday from 8:00 -12:00 but do have a meeting out of town
all afternoon and evening. Friday, I have meetings from 8-12 Noon and
4:00 -6:00 p.m. but should be available between 12:30 -4:00. If you
cannot reach me during these times please drop me a note with your
concerns or let my secretary, Phyllis Jackson know when I can reach you
at home night or day.
Respectfully,
&tlkut11v
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· fvorth Carolina Department of Environment, Health, and
., Natural Resources
William L. Meyer, Director
Solid Waste Management Division
To: ------------Mr. Earl Llmer Dak: __ 6~/_10..;.../9_3 __
Please:
__ Draft a reply for my signature __ For your information
See me about attached
__ Handle and report to me
__ Take appropriate action
__ Approve
Note and return attached material to me
Remarks: Mr. Limer,
My office has been trying to reach you every day for the last
week and I have tried over the weekend from my home and my secretary
has tried on two different nights. However, we have been unable to
reach you at [phone]. We called the telephone company and
verified your number and they gave us your address. Please give us a
call and we'll be glad to help you with your concerns. I'm sure you had
questions regarding the PCB Landfill there in Warren County.
I will be in the office most of next week. As of no~ I do not
have any meetings scheduled Monday -Wednesday and should be
available during those times from 8:00 a.m. to 5:00 p.m.. I will be in the
office on Thursday from 8:00 -12:00 but do have a meeting out of town
all afternoon and evening. Friday, I have meetings from 8-12 Noon and
4:00 -6:00 p.m. but should be available between U:30 -4:00. If you
cannot reach me during these times please drop me a note with your
concerns or let my secretary, Phyllis Jackson know when I can reach you
at home night or day.
Respectfully,
fj/t~iJv
North Carolina Department
of Environment, Health, and
Natural Resources
WILLIAM L. MEYER
Director
Solid Waste Management Division
Post Office Box 27687
Raleigh, N. C. 27611-7687
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North Carolina Department of Environment, Health, and Natural Resources Phyllis H. Jackson, Division Secretary Solid Waste Management Division To: ~ Please: -For your information -Note and return anached material to me -Share wiJh your Section Remarks: Dale: 6-~ ~ td.lh.J &1-11nlUV 1&-1-(1/~ (h.,d_ ~ -;tlu_ J./J.,tf) . ,t)U µ:zvct ~ r, /Je /j LF ~ ~~ W-dJ.4J, ~ ~ ~ M± ~d. 0/, J q~ Cvu4 /J~ ,tu.d{; ~1 (ilJJ 0,, fo o /0 fh-d I ( ~ 10 .t)dm.f!w u.·-~ ~tr:~ ~--~ ~~ ~ ~ ~+tuo~(JA. f)~
TELEPHONED CALLEO TO SEE VDU WIU C.AU. AGAIN 'MNTS TO SEE VDU URGENT
JAMES G. MARTIN
GOVERNOR
THOM/\S J. HARRELSON
SE CRETARY
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
P.O. BOX 25201
RALEIGH 27611 -5201
May 29, 1990
MEMORANDUM TO: Mr. Earl Stegall
Mr. Bil l Johnson
. •'S/.':::P'<-;'-; / Wayne Bailey, .. .,,.,..-.,,.r ,., -: --;, ;.'; { c X
Chief Rn_gln~er -Operationfr'
-_ ~
ndfill✓-Warren County
/
FROM:
SUBJECT:
,4 -.
~r:,0 ,y1$ION OF)i_~d-~wAYS
-~ ! .1 ~ ,.~ I' t ~r:. ,:r -~"::::,.~ .. J...·
GEORGE E. WELLS, P.E
STATE HIGHWAY ADMINISTRATOR
Attached is an (J,--1990 memorandum from the Department of
Environment, Health, and Natural Resources and a May 8, 1990
memorandum from the North Carolina Department of Crime Control
and Public Safety concerning the cutting of grass and the use of
herbicides near the PCB Landfill in Warren County.
Please review these memos with all members of your staff involved
in the cutting of grass and the use of herbicides near the PCB
landfill to insure that our staff fully complies with the request
that: (1) no herbicides are to be used around the fences or in
the vicinity of the monitoring wells. This could introduce
contaminates to the wells, and (2) the grass around the wells
s hould be cut periodically to enable a clear area for sampling of
the wells. A weed-eater, however, or some other manual means of
cutting the grass should be used in the vicinity of the
monitoring wells.
Please insure these requests become standard operating procedures
for all workers involved in the maintenance of this area.
DWB/edw
cc: Deputy Sec retary Jake F. Alexander
Assistant Secretary Kevin Brown
Mr. Wi l liam G. Marley, Jr ., P. E.
Mr. E. D. Walke r
Assistant Secret ary E. B. Jackson,
Dept. of Crime Control & Public Safety
Secretary William W. Cobey,
Dept. of Envi ronment, Health, and Natural Resources
Mr. William Meyer, Director,
Division of Solid Waste Management
Mr. Bobby Lutfy, Hydrogeologist, Solid Waste Section
An Equal Opporlunity / Affirma tive Action Employer
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DEPARTMENT OF ENVIRONMENT, HEAL TH, & NATURAL RESOUAiCES
FAX COVER SHEET
TO: ~ ~~
FAX NUMBER: __ 4_· ,.....:....~_l_O ______ ~----
FROM:_L~ORJ.....i...=-' ..........;;S~-~ZJ2.J'~m.pk~. ~~~--~
DIVISION:. _______________ ~-------~-
OFFICE PHONE NUMBER:. ___ 3_.L.· _-_:f:..,l....__j~8~, -+1------~---
PUBLIC AFFAIRS FAX NUMBER: 919/715-3060
REF: _________ ~-----------~----
TOTAL NUMBER OF PAGES INCLUDING COVER SHEET! 2
DATE SENT: 3/J ~
MAY 25 '93 02=02PM EHNR ·PUBLIC AFFAIR~ .. . ,, · The Warren Reoord, Warrenton, Horth caroiM, 1Noon666 f, 1 .,;,.y 28. t993--
PCBj-'ACfivist Calls ...
For Cor.rective · Action
By THURLliTTA M. BROWN 111imUar public rncetlng In the court•
News Editor house and announced their plans to ·
·"How long?" pqmp the accumulated wat~r from
"Not tong." the PCB landfill. The Ferruccios
W~n County's Afton resi-wen.mot present at that meellng.
dents are not happy with tho news ''If I find one mon: meeting lhaL
that 13 fr.ct or water ,re trapped in-I arn ~eluded from, I wilt ftteze
side the PCB landfill and •·not things up agaln,°' Ferrucclo said
tong"' was lheir wacchword Moo<1$y Monday nlghL "1'bis never would
night during an impassioned plu have happened lfl had not been CJt·
for corrective action lodged by eluded from lhe meeting," he said-
longtime PCB activist .K.en Ferruc:-Last wcel:'s meeting was publi·
cio. ciz.ed by notices posted on the
.. I'm not-going lO follow the cQUfthousc door, but it was sched-
Sub-0 n,guladoM, I'm nol going 10 uJc.d too late !Of a notice-to be pub•
follow the Was~ Muagerncnt Act llshed in this newspaper. That
of 1981. I'm not going to follow ihe meeting was auended by citbens
rationale fo.r selective human and pUbUc officialJ.
sacrlllce because r can't accept this Citizens were also pn:sent at blit
rationale. I couldn't accep, it in Wednesday nlght•• county com•
1978 when I was 36 ... and I cannot mi.1slooers' meeting when Deborah
accept it in 1993 al SI. And I will Fc:nt.1cefo u!ICd iCenl& lakcn frorn a
never accept it, because lo accept beach bag to graphically display
,elective human sacrifice is 10 per-water accumulation and leaks at the
pctuato It and lo cnc:ountge it.." Fer-PCB landfill. "Yo11 ~ntended to
tuccio said. "How long?, not long." have a one-half-hou, hearing on
Monday night's meeting in the something so serious." ,he &a.id IO
Wsnen Coul'lly courlhouse was lhe rommls.sioners ~ho had lk:hed·
c.arfed h1 the Department of Envi-uled the pubJlc moet.ing at 7 p.m,,
tooment. HealLh and Natural Re-only 30 minult8 before its regular
~s (OEHNR). Last week, offi. midmonddy meeting:. ·.. -Page 11
ciali f'rom dlti department held e tC.OOlinued otJ nae! t l)
Joint PCB Task Force Is Being
Formed Following Session Here
(Cc.itinucd froot page t)
The county commi&sioners last
Wr.dncsday received a report from
Denni~ Reu.laff, health director,
conceming the advlsabllil'y or clos.-
lng lhc counly'a regular landfill by
Oct. 9 to avoid stringent financial
and monhoring ,cqulrcments. Fer-
naccio last week questioned liabili-
ties Warren would face by uansfet'-
rlng lts wmtes to landfills In other
counties.
No actJon was tak.cn by the,.
county e0n11nissloneff last ~ on
dQSing Wanen's landflU and offi-
cials seemed satisfied with what
they had been told by DEHNR offi•
cials concerning the alatus of the
PCB landf dl.
But ali were hOl Rady to let the
iMue rest In the hands of s&.a1te om.
ciah.
.. Earlier we tnel IO get ainsweu
ID OW' questions about wh:lt caused
tho. problern, how ll co11sld be
sol~, and whether il was sauc. We
got our answers and were 1pleased
with the state's offer,'". sald Interim
County Manager Luclo~s. Hawkins
tl Monday night's PCB ilandfill
meeting. ••we were satisfied, but
there is fllllher concern in ttte pub-
lic to dascuss the issue whh 1ta1.e
orfidab. We consented (tf> allow
too.ight'a meeti,ig)," he said.
St.ale Officials Havr 11lelr Say
•'The govc:mor rogrc;IS what WU
found. He wants lhc Community
and the Oep,umcn\ of
--=a:nwmnmr~l11. 'k.!hb, 11\tHL. 'mllffil.
~ ID make decisions (abooC
•ha 10 do) ... hOl just ooe-*•Y wl.lh
no Input from cldzcns.,. aald
Carolyfl Colclman, {](wemor Hunt'&
special assi~Lnl Mr.nd.ty nigh\.
Coleman httrJduccd DE.HNk
Secreaary J(Jnl&hlUt Howes who said
that no c.e t-,.d taken action until
tbc Hllftl ad,rninisuation had re-
turned to "flrice. -rhis is not be--
came so~1c1hing is wrong, on the
CJ1J11n·. t: be said. 'lhe PCB land-
fdl ;. pcrfcm1ing as it wm designed
u, ~orm.,.it is a safe f.cility (but)
dlrl'e is conc:1:m tJud the liner could
be compromised by buildup (or
wa~r). Now somel!ling should be
done," he said .
Howes sii1id the state proposes
the crea\ion of • joint advisot)'
commhleC u, develop a proce&1 IO ."
)ovcrsbls .mon1ltotlna ;.and· .con:cciloP
or the PCB landrllt problem. ".'t
don't want ll> 1rBJ1Sfer the problem.
if one existJ,. to another commu~
nily, .. ho pid. "We stand by OW'
commitment. to detoxiry lh~ land-
fill. ir needed,"
"Wc'te £:aced with the task or
removing water •.• excepl,· it•• not
like pumpi111g water from yow-
weU," &aid Bill Meyer. DEHNR
$01id ,..attt, directo,. Meyer said he
wanted citiwna• input on whe&her •
Jot-type or subrneulble pump
should be w·.c=d, whether the opera-
tJon should be manual or auto•
ma&ed, and whether lhe extracted
water ahouM be placed in ._., oruitc
unlh,ed holding basin or in,;tallcd
tanks. ..Tb1~re are lots of op-
tlons ... lotS 0,f cholcca .. .and we uk
for your inplll on ho.., it is I.O be
done," he said.
Cltlztns Are Not lltaSSUrtd
Several <:it.liens expressed dis•
belief. ''I v.•aJ shocked when tho
engineers f)lllt the PCB landfill het-e
in Warren County whlch has the
shaUowest water table of any
county In tho state I .. said fl'Bl\ces
Williami. "And now. these same
engineen are the ()nC!l who arc go-
ing ro sol\le Itr
"I think not." said Meyer.
.. And we: as non-engineers are
supposed to aolve h?" Williams
continued.
The motives of the state and lhe
pro~ solution or pumping wa-
ter from the: PCB landfill and the
cstimat~ U00,000 e,;penditurc
n,a..,..,.•&.IIIN:,-.. ...d
MAY 26 '93 02:03PM EHNR·PIJBLIC AFFAIRS
• "You're wasling the state's
rn1ney roe an illusion."' wd Debo-
nth Fenuccio. "We will not let you
pump out wat.er to create • facade.
u wu your word against our word.
We don't want to have input into
what pump to usc ... we want 10
make sarc you detoxlry the site,"
she u.id. '
1bc ~ malnl$.I~ tha' infor-
mation was not av-1lable coocem-
ing the ctetoutlcation ot PCBs. Bil-
lie Elmore of NCI Wasto A ,ivarc-
ness Nctlllork. and the· Ferruecloa
cit.eel studies which dealt with puri-
fying llJe tmic subsuinces. .
"There UC ciUunt who ,.,m
work ror peace and resolution of .
this problem .. .1 do not want to tee
us shortchanged," ,aid Rep. J.P.
Ort.en, a Henderaon phy.lician 1m0
for three years aaught school . In
Warren CoWlty.
. BoLh this week and last. stat.o
officials wd &hey had rrtonitcred
the wells in the PCS arca.t. but
A!ton residena.s e.~ disbelief. :,1,d~~iy like ·10 have my ..-c~l-
waltt checked," said Dennis Hartis.
.. l'Jtt d1C c:losest ~~t t.0 tho PCB
dump and my well was never
chected, unless I ukcd for it. .. he
said,
Afton resident Doris Dcyden
aald she had paid $35 co have her
waatr -=sk:d aft.er a "peculiar odor"
had been delected. "It seems not
fair that the •&a&e ~ould seltct us
(for ailing the PCB landfill) and·
the.fl I must pey my money to get
my .,.let chectedt Ille said. Dry-:
den noted that hCf test rel)Ort had
been .. negadve," and Meyer said
his olface had popmed dun tesuna
tar PCB• in water be done at nq
charge. .
04We've recentty replaced our
well,.. aid Af'loft rest dent Joyco
Lubben. ., mo• of four others ... l
don't know ,r other puts or the
00unty have the problem, but wo
stn do," she said. :
Meyer said state olficJals ha4
tested wiuu in lhc sb~. He said the
sta&e had pumped . wa~r from the
she 30 times. He al$D Aid lhe IUICO "-d pwnpod water from the f>CB
landfill 60 times, and it was that
discrepancy that ·crlggued nerves
-,_'fdch had been worn raw ln the ts
years ainm the origfna! siting or the
Afton PCB dump.
~ b insulting lo us." said
Afton l'Cllident Dollie Burwell.
•~ dtuens of Wam:n County did
not promise the state we would
monilor 1he landfill. I did 11ol ~rt
my fcarl fl) ~ ~ because I felt I
would ~ al!:l anvlbin1t done in re-
~ ---Dtyd6n. a fo,mer Wanen
Coun~ Health t>epann,ent nut1e.
ut.,d -offlcWs whit ud ha:,,
doN .tlh amplel of blood whkh
hlllll lwierl drawn ,~m .-e.a ttsidcJU5
when the landf'tll was fltSI liu:d.
''We've got il 6o7.en ln our lab
and will teat it if anyone wants Ill,, ..
said Dr, Ron Levine. ataae health
d.i:teaot.
VWc know that so goes Wam=n
County", environment. so aoes
Nonh Carolina's," aaid Huni'a spe•
c&al u&laant Coleman. ••we ha·ve
no reason 10 sweep ,nyching under
1he rug ••• we wanl 1101 IO make de•
cisions on your b(.half." she said.
'"We"se not pcetcnding it will lbe
~ ... frankly, we have to set pasl
the history of mis1n1s1.· said Sccrc-
. tary House. .. Jllow k b up 10 ~Ile
teadenhip o( the coonty ~d. ,l!tie
S1Ate so -..ode whb u~," he said.
The Fenuccios had contacted
Secretary House by PAX and out~
11.ned a follc,wina Ovc-l)()int pl~1n~
(l) Rcswrc the ecological S&alUS of
Afton to what il was befote: lhe sit-
ing; (2) Use only moni10ring a1rid
maintenance activities if on-siac cle-
toxific:ation is nol possible; (3) Re•
slst eJ.pansion a( the PCB landfill
site:(◄) Eliminaac lrUCking of PCIBs
from the landfill: and (5) Supp,ly
evidence from disintere8ted scien-
tlsu th.al waltt t.o be spuyt.d 011cr
&he PCB landfill tw be¢n delo)ti-
f.cd.
Tht "Bottom Lint''
Pcnuccio said his group woold
be coopci-.tivc •-.. lottg as we work
within the five-point framcwor1c:."
But, reminiscent of years pan wh,~n
lhinga did not go u defined by 11)-
cal residents, "when you atcp 0111-
aide of lhc five-poinl framewot,C.
I'll f ,c:c-.t0 h again." Ftmicdo aaltt.
""If that water" is leaking. we~II
find out." warned Deborah Fcm.i~-
cio. '
P.3/3
Also dcma111ded by Ferruc~io
was lhe a.uignmeot o! a staff ~r-
SOt' in OEHNR-a diteGU>r for ic~
aemch, planning and comm_unl~-
uon--..,.hh aolo rcsponsibiluy for
working on W111TCfl '1 PCB landftll
problem. 11.And Iha! amc ~h.
planning and c:ommuniution pro-
ceu will he C<lOldinalcd from lhis
end by Dc~i and me," Femlc::f io
said, "as · well aJ &hose who ff\a.y
ntcd 10 panklpa&e because of ~ir
off,ci.al pooltiotliS." '.
Howtc: alcl a joint advisory
commhtce wo1114 be cstsblished.
but he c:ould nc:,t My lh,i a ~ial
person would be auisned to wotk
Oft lhe PCB pniblem ... I'm nol sure
lhal's the heal\ lhine to do ... J'm
pleased Dr. Green ii here ... lhe ,cc-
retary said. "'l •110w he'll look over
my shoulder 1'l1 be aure we. do the
rigl1l thing," he said.
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23-021 CARIONLES8
DEHNR I EN VI R. EPI. TEL:[phone]
State of North Corollna
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt Jr., Governor
Jonathan B. Howes, Secretary
The Honorable James Green
176 Beckford Drive
Handerson, North Carolina 27536
Dear ► Green:
May 19, 1993
Jul 19,9 4 10 :1 8 No.004 P .03
NA
DEHNR
On May 14, 1993, Ms. Kay Ruocchio forwarded to our office a request from
you related to PCBs. Enclosed is information which I hope you will find ·
helpful for your presentation.
If you have any questions or need additional information, please call mo at
[phone].
CGS:lp
Enclosures
Sinceraly,
~4~
C. Gregory Smith, M.D., M.P.H.
Medical Epidemiologiat
Environmental Epidemiology Section
P.O \Box ?76A7 . r~oleioh. Nnrth r.rvnlinr, ?7A 11-7AA7 Tolor.hr.no o,o_n 'l_'l.-101
DEHNR I EN VI R. EPI. , TEL:[phone]
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
James B. Hunt, Jr., Governor
Jonathan B. Howos, Secretary
MEMORANDUM
May 19, 1993
Jul 19 ,94 10 :20 No.00 4 P .04
MA
DEHNR
TO: John I. Freeman, D.V.M., M.P.H., Chief
FROM:
SUBJECT:
. Environmental Epidemiology Section
C.d~reg
1
oryiSdmi~hl, M
1
.D., M.P.H. .~
Ma ica Ep emio og st
Envi~onmental Epidemiology Section
Representative Green's Request for Health-Related Information on
PCBs
I havo assembled copiea of several scientific references which discuss the
toxicology of PCBs and havG taken the liberty to highlight sections which
relate to Representatj_ve Green's raqueat. With respect to definition, PCBs are
polychlorinated biphenyls, a group of 209 stable, fat soluble organic chemicals
which contain from 12 to 68 percent chlorine. l?CBs are not known to occur
naturally; they.are mBn-rrtade chemicals which ware used extensively as
insulatort:; in transformer and capacitor fluids until their manufacture was
discontinued in 1977. PCBs are essentially ubiquitous in nature today,
distributed throughout the air, water, soil, and food chain of the biosphere.
Virtually all humans carry some body burden. Fish, dairy products, poultry,
and eggs ar.e major dietary sources of exposure to PCEs in the United States.
In response to the question related to symptoms and clinical findings
associated with exposure to PCBs, one would not be able to identify any
spacific symptoms or adverse henlth effects associated with exposure to
background or low concentrations of PCBs.
Animal experiments have clearly darnonstrated that aorne PCB mixtures produce
adverse health effects which include liver damage, akin irritations,
reproductive and developmontal effects, and cancer. Workers exposed to
relatively high concantrutions of PCB mixtures may develop acne-Uke lesions
and rashes (chloi:acne). Chronic occupational expoisure also may result in aya
and mucous membrane irritation and liver injury (chemical hepatitis).
With respaet to carc.i.nogenic::ity, thore are sufficient animnl model data
demonstrating that PCB1:, are carcinogenic, ca.using the production of liver
tumors in rats and mice. A recent re-evaluation of the animal data indicates
that positive evidence of carcinogenicity is rast;dcted to 60% chlorinated PCB
r.o. Box 2'/687, Raleigh. North Carolina 27611 •7687 Telephone 919·733-3421
DEHNR I EN VIR. EPI. TEL:[phone] Jul 19 ,94 10 :21 No.004 P .05 •
Dr. John l•'reeman 1 Page 2
May 19, 1993
formulations.
aro claasifled
evaluating tho
that exposures
chemicals such
J
At .this _tirne, using a wcJght of evidence classification, PCBs
as B:2, probable human carcinogens. To date, human data
carcinogenicity of PCBa are inadequl!l.te.' One major problem is
to PCBs were confounded by contamination with other highly toxic
as dibenzofurans and dibenzodiox.ins.
rn the attached copy of tho August 1988 issue of Health and Environment Digest,
Dr. Renate Kimbrough, an internationally~recognized expert on PCBs discusses
their effects: on human health. A few of her more important points are:
( 1) '.'Thus far, no conclusive advarae eff acts have been demonstrated in people
who carry body burdens of PCBs from environmental exposure to trace amounts
of PCBs. Ir
(2) 11Even workers with exposures two ardors of magnitude greater than
environmental exposures saem to show no convincing chronic health effects.11
. '
( 3) "There is reason to believe that chloracne and other. health effects
probably associated with PCBa are really caused by chlorinated ·
dibenzofurans. 11
(4) 11 Attempts to conclusivelx demonstrate health effects in populations that
aat fish from (PCB) polluted wata:r.ways have generally failed.11
(5) 11sevar.al occupational studies have presented no concluaive scientific
evidence that PCBs have caused cancer in humans."
(6) 11Despita positive laboratory animal data., and except for chloracne,
exposure to PCB has led to no convincing clinically demonstrable, chronic
health eff~cts in humana.11
I am not aware of nny new information or studies which woul~ alter her
statements made in 1988.
CGS:lp
Enclosures
cc: Dr. Ronald Levine
Pr. Peter Morris
Mr. Bill Meyer.
D1~. Kan Rudo
Dr.. Luanne Williams
Ms. Kay Ruocchio
~ PCB\9s North Carolina Department of Environment, Health, and Natural Resources Phyllis H. Jackson, Division Secretary :Jf]i'~ ~~S;fl, Please:/ _V For your infonnation Note and return attached material to me _ Share wilh your Section / Remarks: JwLJ !hll4L U-/4 Yl J-'3/J ~f Iv waJi/,uc . ;!'_d,,_u) r:rr~~. ~~t&~ jJ __ ~ c/2) ~-l, fJ'-M ~ -()~ . /,,l~J. ~ C/lV ~ ~~~h~µ ~ -~~ ~
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
Division of Solid Waste Management
James B. Hunt, Jr., Governor Teleph~&919f f31~3 y ' Jonathan B. Howes, Secretary
Dear Mr. Retzlaff:
Enclosed is information on resampling of residential wells around the landfill.
I hope your Department will be able to take the samples. We will supply the sample bottles
(21) and perform the analysis.
I will work with you in any way that you feel is appropriate for this effort.
When you receive this fax, please call me at [phone].
Sincerely,
Bill Meyer, Director
Division of Solid Waste Management
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax # [phone]
An Equal Opportunity Affirmative Action Employer
@ SOlfo recyded/!Olfo pool-CDNWllff poper
Post-It" brand Fax Transmittal Memo ::mpfJQf)n,·s ~kla-f,C Location Faxllq /<j-=2_5 7-~897 Comments . , ' Telephone# 7672 No. of Pages / {) Today's Date / / Time _s jt., From b/ / / ~ Company Location Dept. Charge Fax/173.3-t../<;j Jd Telephone#'733 -L/99b Original Disposition: ODestroy OReturn 0 Call for pickup
.,,
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
Division of Solid Waste Management
James 8. Hunt, Jr., Governor Telephone [phone] Jonathan B. Howes, Secretary
Dr. Levine
• Background Health Data
-55 private well tested -no PCB detected at 1.0ppb
-More than 50 blood serum samples obtained from Warren County citizens; have
names and addresses of citizens' samples (enclosed is 10/19/93 letter on
problems with PCB serum analysis)
-84 ground water & 92 surface water/sediment samples indicates no PCB
contamination
-Environmental data indicates no exposure to PCB from landfill
-Will sample water supply wells soon
•Enclosed is 11/23/82 & 11/17/78 letters
11/17 /78 letter (talked to Dr. McKinney and his recollection was the data was from
randomly selected persons from the 241 miles of spill; nQ1 a Warren County
population
•Note 11/17 /78 McKinney letter -no dioxins confirmed -Furans max of 66ppb
• Luann Williams to fax additional data
P.O. Box 27687, Raleigh, North Carolina 27611'7687 Telephone [phone] Fax # [phone]
An Equal Opportunity Affirmative Action Employer
Post-It•· brand rax1~ansmittal Memo 7672 @ No.of Pages s-Today'sDat:5'-/cry Times.·~o
To ~ &~ From Sa,La~.A//2)
Company "'--"---'~ ~~ -Company , · --3-..,
Location '-<.,,1A,"'--' ~ ~ Location Dept. Charge
C
Fa
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Poat-It'" brand Fax Transmittal Memo To DJJJ0l CraM Company Qe.o.:u-f ~ Location Archd a.Ji Fax# 7 /5 ,_. 36 ~(j Comments CONFIRMATION LIST SENDER: RECEIVER: PAGES SENT: DURATION: L """"'c ''-'', ·-u-v I r'-...Je'--'a a 7672 Telephone II 7-33 -t./9 gt/ 9197334810 919 7153060 04 02:32 , / Today's Dater ,& ~ Time No. of Pages "-f ...;> /~ From /6, / / /1.p_ Lj..U , '>r. /JHIO~ ,~""'--5,o lie . /,JJ,5_-½,,};J~.r· -·· ""'°oo ~lophooo# 7..33 -'-1996 Fax# Original Disposition: ODestroy MAY 14 '':l3 09: 06 OReturn D Call for pickup NC SOLID WASTE ►-a'"'m'""r""S t
FACT SHEET ON PCB LANDFILL
What are PCBs?
•
•
•
Abbreviation for Polychlorinated biphenyls .
~ (means many); Chlorinated ( contains chloride atoms, such as the chloride .
in table salt which is sodium chloride); hi (means two); Phenyls (is an organic.
compound with a six sided closed ring structure).
Many chlorides on two or~anic compound rin~s
~
+--Many Clilorides
H H
CL CL
2 Ring Structure
What are the characteristics of PCB?
Clear viscous liquid.
Very low water solubility (25 parts per billion).
Strongly sorbed to mineral and organic surfaces.
Approximately 1.5 times heavier than water.
Evaporation at 100 degrees celsius for 6 hours is less than 0.1 %.
Stable at high temperature-requires 2000 degrees celsius for destruction.
What are PCB 's used for in industry?
Primarily used as an electrical insulator to prevent electric arcing in transformers,
also used as heat transfer and hydraulic fluid, vacuum pump fluids, lubricants,
and carbon paper.
PCB 's have not been manufactured or used since 1978.
What is the toxicity or PCBs?
PCBs are very stable and remain unchanged in the environment which results in
biological magnification or accumulation in both plants and animals. Small organisms
consume PCBs and higher life forms consume the smaller organisms thus increasing the
PCB concentration. Higher life forms develop organ disfunction, especially liver disfunction
at high PCB concentration. The primary human health concern is cancer. PCBs have
induced liver cancer in animals, and liver and skin cancers is suggested in humans, however,
there is inadequate evidence of carcinogenicity of PCBs in humans. PCBs are regulated
primarily for environmental impact rather than health impacts.
What is the source of PCBs in the landfills?
In 1978 approximately 30,000 gallons of PCB was dumped on 241 miles of roads in
14 counties in North Carolina. The source of the PCB's was Ward Transformer Company
located in Wake County. (Alamance, Chatham, Edgecombe, Franklin, Granville, Halifax,
Harnett, Johnson, Lee, Nash, Person, Wake, Warren, Wilson Fort Bragg, are the 14
counties)
What is the concentration of PCBs in the Landfill?
The maximum concentration of PCBs on the road shoulders was 4,900ppm. The
average concentration of the soil-grass-PCB materials placed in the landfill was 135ppm.
How did water get into the PCB landfill?
The landfill received PCB contaminated soils from September 15 through October
27, 1982. During this time several rainfall events, including 2 strong thunder storms,
occurred. Some of the rainwater was diverted to a comer of the landfill and solidified with
cement kiln dust. A major part of the rainfall soaked into the PCB contaminated soil like
a sponge. The final plastic and clay cap was contructed and prevented any further
infiltration of rain water. The trapped rain water over the years has moved by gravity to the
bottom of the landfill. It is estimated that between 500,000 to 1 million gallons of water are
trapped in the landfill.
When did we find the water in the landfill?
The state was aware of the potential for trapped rain to move from the soil mass to
the leachate collection system at the bottom of the landfill. From 1983 to 1990 small
amounts of water was removed, however, the rate of removal was very slow. Less than 50
gallons could be removed before the removal system would become dry. It took several
hours for the water to refill the leachate pipe. It was assumed that the trapped water was
still largely retained in the soil mass and not moving to the leachate or water removal
system. In March 1990 the combination of past pump malfunctions and slow recharge to
the water removal system led to the dismantling of the pumping system and examination of
the internal leacheate or water collection system. At that time a 10 to 20 foot saturated
zone in the bottom of the landfill was identified.
What was done about the water in the landfill?
The detection systems under the landfill and the monitoring wells were checked to
ensure that no leakage was occurring from the landfill. There was no leakage. The
DEHNR was notified. The water needs to be removed to ensure the long term integrity of
the landfill. The proposal is to provide resources to remove the water.
How will the water be treated and disposed?
The PCB landfill site contains an above ground sand and carbon filter to remove
PCBs. Once the PCBs are removed and treated the water will be applied through an
existing irrigation system to the surface of the landfill. The landfill surface is covered with
fescue grass which will utilize the water for growth.
How will we keep PCBs from being applied in the water to the surface of the landfill?
119 samples of water in the leachate collection systems have been analyzed. When
the samples are filtered throurgh the sand and carbon systems no PCBs were detected in
the filtered water. The maximum concentration of PCB in the rainwater has been 0.3ppb.
The reason for this low concentration is the very low solubility of PCB in water and the high
affinity of PCB for soil particles removed by pumping. Filtering removes the soil particles
which are retained in the sand and carbon filters. The sand and carbon will be disposed of
in an off site PCB landfill of the water in the landfill. Monitoring of the detection system
below the landfill and groundwater monitoring was continued and no leakage was detected.
No additional resources were provided to remove the water. In 1992 a budget request was
submitted to address removal of the water from the landfill. The Budget request was not
. included in the budget for this budget cycle.
Why do we need to remove the water?
The water does not pose an immediate threat to the landfill through leakage to
groundwater, however, it does increase the pressure or driving forces on the bottom liner,
In order to reduce the potential for failure of the liner and prevent leakage the water needs
to be removed.
How is the water proposed to be removed?
New submergible pumps need to be installed into the bottom of the landfill through
the existing collection and removal systems. Pumping tests need to be implemented to
determine the maximum rate of removal. Once this is done the water will be pumped on
a routine and continuing basis until all the water is removed. The new proposal is to add
storage tanks for filtered water so the water can be tested prior to application as irrigation
to the landfill surface. If any PCBs are detected the water will be refiltered until no PCBs
are detected before irrigation.
How long will it take to remove the water from the landfill?
The current proposal is two years. The removal actions during this time will identify
the rate of removal and if more time is required for removal it will be accomplished by
pumping for more than two years. The actual time of removal is not yet known.
What monitoring will be implemented to ensure the effectiveness of the new effort?
Background sampling of ground water, surface water, grass and soil on the landfill
surface has been accomplished. Additional samples will be taken to ensure a high
confidence level in existing conditions before irrigation is initiated. The proposal also is to
add new storage systems for treated water to ensure proper treatment before irrigation.
This will prevent any PCB application to the landfill surface.
How will the public be kept informed?
It is the intent of the Department of established a mechanism to identify community
leaders of Warren County and establish communication and information transfer systems
to interact with the Department in all phases of this effort. Our intent is to have maximum
participation by Warren County citizens in this effort.
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
Division of Solid Waste Management
James B. Hunt, Jr., Governor Telephone [phone]
s-/13/93 Jonathan R Howes, Secretary
Dr. Levine
• Background Health Data
-55 private well tested -no PCB detected at 1.0ppb
-More than 50 blood serum samples obtained from Warren County citizens; have
names and addresses of citizens' samples (enclosed is 10/19/93 letter on
problems with PCB serum analysis)
-84 ground water & 92 surface water/sediment samples indicates no PCB
contamination
-Environmental data indicates no exposure to PCB from landfill
-Will sample water supply wells soon
•Enclosed is 11/23/82 & 11/17 /78 letters
11/17 /78 letter (talked to Dr. McKinney and his recollection was the data was from
randomly selected persons from the 241 miles of spill; nil1 a Warren County
population
•Note 11/17/78 McKinney letter -no dioxins confirmed -Furans max of 66ppb
• Luann Williams to fax additional data
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax # [phone]
An Equal Opportunity Affirmative Action Employer
@ S011 r«yded/10ll poot-mnawnor ~
DEHNRIENVIR. EPI.
•
'1'0:
F'AX NUMBER:
PROM:
TEL:[phone]~5~
FAX Tl:tANSMI'l"l'AL
DATE: 1;~/ 9 3
~-ffftU( _________ _
-l/ufJl!W_~u~
Environmental Epid _. l -----em:1.o ogy Soction
FAX ___ L.:ll,_~-'J 33•9555
~9..: Box 2'7687
Raleigh,.Ji.:_~. 27611
f.HONE: 919-733-3410
• .. NCLUDING covER SHEET: . le J NUMBE~ OF PAGES l fllrtwe ~~CM
'l!M. mi 13 J ·· 3l/;o .
DEHNR I ENV IR. EP I ;--------TEL: 1-919..:733-9555
;:_ and 0.51-581 ppm in their adipose
{itssue (NIOSH, 1976).
··.,,,1n 1973, about 2,000 lb of
{polybrominatod biphenyls wore
:r.··lnadvertently mixed into livostock feed
?, in Michigan. Thousands of animals
' ,·. died or were destroyod. Initially,
),· 8,000·12,500 Michigan residents were
f.· ··exposed in 1973 and i974 to meat,
·\: milk, and eggs contaminatod with
·. ,:, · polybrominated biphonyls. A general
population survey conducted in
Michigan at a later date revealed that
\if only , 0'% of the population did not
ii'.-;·•:• havo detectablo levels of poly ..
.;,, brominated blphenyls in their blood
~:_:?-(IARC V.18, 1978). In 1976, 524
dairy f armors had a median ·,:f, . •.. concentration ol 2.6 pg/I polybro• . ··~". · ·•. minated blphenyls in so rum . An ~~: Independent study conducted from
1976 to 1977 in Michigan on 3,639
subjects (mainly farm residents nnd
chemical workers) showed a median
value of 3.0 ~•gtl in serum. Another
1
·• 1977 study of 3,683 Michigan
rcsldonts showed concentrations
ranging from < 1 to 3150 µg/1 with a
geometric mean of 4 .1 ug
polybrominated biphenylstl. Signifi-
cant body burdons could persist
throughout the lifetime of expo sod
individuals beca1Jse polybrominated
biphenyls aro biologically stable and
eliminated slowly (IARC V.41, 1986).
REGULATIONS
EPA regulates polybrominatod
biphcnyls under the Toxic Substances
Control Act (TSCA) and regulates
technical-grade hexabromoblphenyl
under the Suporfund Amendments
and Reauthorization Act (SARA). A
broad category of polybromlnatod
blphonyls potentially containing up to
some 200-300 incJividlJal chomicals is
subjoct to a special TSCA reporting
rule . Tho technical grade of
hcxabromobiphenyl, FireMaster B-6®,
is subject to reporting roquirements
undor SARA. EPA has proposed
handling and reporttrecordkccplng
requirements for polybrominated
biphenyls under the Resource
Conservation · nncl Hecovery Act
(RCRA). Under the Food, Drug, and
Cosmetic Act (FD&CA), FDA
regulates polybrominated biphonyls
as unavoidable environmental
contaminants. In cooperation with 11,e
Centers for Disease Control and tho
Public Health Department of the State
of Michigan, FDA monitors tM long-
term human health effects from acute
expos1i rn to polybrominated bl-
phonyls. OSHA regulates poly-
brorninotcd biphenyls undor the
Ha,arcl_ Comrnunicolion Standard and
as ct,cmical ha1.ards in laboratories.
POLYCHLORINATED
BIPHENYLS
CAS No. 1336~36-3 ((lo.-.; ·I c r ;~ i CGl (
C/\RCINOGCNICITY
/ -k)1ill e.f{ec::f.
There is suflicient evidenaJQLU1e
~rc1nogenicify·-orsavcrai"mixtures of
-Jmlyct11onn:lltfdoiptrenyls, Tnclirdfhg
"Aroctor®1_?_69'1Q~S-Ncfl 1 mre-:·02-5),
. 'ArE§J..o~~ ~ 254 (11.0·97:·69_:",1};. -~nd
~a nec~l.or.~ .. ;,Q_0_J~.~12.~:~J_:!), in
experimQ.ntaLan.i mals (IARC V.18,
19l'-a;··1ARC V.4, 1-982; Norback &
323
••' ; .•
·woltma,o_.1~ IARC S.7, 1987). When admlnlsteroaTrilln! dtm, i\r'aclor
1260 Induced liver turnors Including
trabecular coll carcinomas, nooplaslic
nodules, simplo cholangtomas, and
cystic cholangiomas in rats of both
sexos, and hepatocellular carcinomas
and livor adenocarcinomos in femalo
rats . When rats tl1at had undorgona a
partial hepalectomy were adminlsler-. ea Aro·c&.L!F,6]_·:m:m:.:me,. livor
tumors wo.r.e lnducod, Including
OQ.~~slic' n_qd'J'es jn both sexosand
simple and cystic cholangiomas,
trabecular cell CEHcinomas, and
adenocarcinomas in f cmalcs. Wilen
ad,ministeredJn_thq _<;Ii~!.,_ A.!"9.9f9.illM
Induced hopatornas _ir).J~.?,IO mice a~nd
Kanechlor 500 induced hepato-
celTDTar-canii\oma's· in •nfaio· rnf.co
{Norback &-Weitman, , se·5: !ARC v.,a, 1978).
TJt~r.e.~Jr,i~~U.~l,!l ovidence for
tho carcln.Q_goniciJY. .. t>J .poiy.chtoricla\&d
bij51,enyls In humans (IARC S.4,
1"9'S"2). A slight lncroase In the
lncidonce ·6l--c~rn~~;:]2affic1ffa-rly
rnmno-ma ~1-tho .. s~in.l 'E~i' 6"oon
r~f>cHfed Iii a small group of men
oxp~Uc o·ccupatlorial,!Y.'.to Aroclor
125°4..A study o·f ·; ,310 workers with
at leas'f tnnonlhs 1>1·exp0-suro to
polychlo1IMited '6lprie·ny"B-1n a eap~eiror mariufactimng piaAt-·showed
an excess ol·an cance·rs"1m10ng male
work°Efrs:,n1nixc~!r'WM-mt1iAly due
1.9 cant.ers..o.LTI-ro::-d~es:uv~~sy~tem
and of tho lympt,atic· and
h ~ itf ~1QpoTc1rc.J is.s 0£.S··uARc s . 4 ,
'--~~??1--···---...
PROPERTIES
Theorolically, there are 209
P.O s s 16!~.-po I yo htQ.L.Tfuo d ~bll)h e nyl
isomors, a!lhougtl not all ara found In
manufactured products. Polychlorl•
nated biphonyls vary In appearance
trom mobile, o~ liquids to wn-ttv, -~~s~W~,1~~;~~~~ ~~:~i~~~ ~
,ru_able, resistant to ___ ox,i~ation, acids,
baieii; ... and ··of11BT chcrnfo_iir .age.nts,-and.tiave-· .. ·o·x·celient ·· .o.ielectric
propu1iti~s·: ·e1,1ofoblphenyts are
colorless crystals in the pure form.
Commercial products are liquids
bocause the melting point is
depressed when polychlorinated
biphenyls are mixed . .J;olychlorinated,
_ _Qipheayls are practica~ltJD~ublo In
water and soluble in oils and organic · ~,wu;--·-vv'fi e· ;;·• .. ti e~ate"d ___ ·1 o
decomposition, they emit toxic fumes
of hydrochloric acid and otl1or
clilorinated compounds. Tochnical-
grade polychlorinated biphcmyls have
varying proportions of the different
chloroben2.one Isomers with small
amount of polychlorinated dlbonzo-
furans and polyclllorinated naph-
thalenes ns contaminants. ·
USE
Since 197 4, all usos of poly•
chlorinated biphm,y1s In tt,e United
Statos have been conf lned to closod
systems such as electrical capacitors
and transformers, vacuum pumps,
and gas-transmission turbines. Bof ore
1 ~_gJy.chlo_Cinatcd _.blp!1~nylswere
used l~Jr~n..ito.r.nier .. ~Q.~H~g· Uguids,
~@::fr.~_rJs.f4t .. ao.d.hy_oJ~.l!.lic. fluids,
vacuum pt,mp fluids, lubricants, ~ .... -----.. . ... "•' ···-· ·---··· ........ -. ·--•··--··•·-
324
!•'•\I.
·:i\f~t•.
.. \(.'(
;;,~tasticizer~J.!!l~(S .In il)V..e.6tment casiing waie~, ... .!l!rf ace coatings nnd
slfala·n1~·;_·_1e·~ticide . oxt~ nd_ersi and
M COPY paper (IARC v.,a, 1978; Merck,
:-:'.:1983),
·: }~·~ODUCTION
-:-::·::'-· Polychtorin~~e_d __ bphe_!)Y.l&.. . ..ar.e.J.10
~\/~,iQ-nger_p!oouc~~-.1.QJ_h_e !Joited.S.WDs,
t1::,:; except for f1m1teQ_rQ.S.aar.ciLa.r.,d ><: :cfcvefopmenf SQP.)!Qa!iO!}& lr.r:i_p_on_ and ,-,;·: 'ex'porror th~_c.;>_l)}P_Olltlds.has not tt· bce~pe~"'.'illc~~-if.1.9e)9.7~~; :I'he 1979
1'!::, ·1·scA Inventory 1dent1f1ed one
i1.-.f company producing 35,555,500 lb of
[/ polychlorinatod biphenyls In 1977
?:;, (TSCA, 1979). Domostic production t : reached a peak volume of 86 million
~-. . lb in 1970 and decreased to about 41
:::·' million lb by 1974 . ._Polychlorl'!!led
~/:. bjphen~_ were ~._pffilJllced
commerciailylnThe Un ited Stotos in
19'2'9. nARC"~ .Ts:T9 7 a). --
c~:.:~ ~·;;·;: ~ ~~-J )E ..
-.""'itte-prlmary routes or potential
hu-mari e~p]isur1f tcf p6l_~cfiloriiiafed
6iphenyls are ingest_!~nJ..JP.b.l!.1?..l.!_o·n,
l'fffi-derrnal cQntact. The release of .. .. ......... .. ........
polychlorinated biphenyls from prior
Industrial uses and the persistence of
tho compounds in tho environment
have resulted in widosproad
contamination of water and soil, with
subsequent potential exposure of 1he
general population. Polychlorinated
blphenyls have been ldentlfiod at 1 o
haiardous waste sitos designated In
the National Contingency Plan. Tho
Toxic Chemica·1 Roloaso Inventory
(EPA) llstod 116 industrial facilitios
that produced, processed or
325
DEHNR/ENVIR. EPI.
\
TEL:[phone]
. I May 12,93 15:13 No.014 P.01
management of these fires can
greatly reduce possible h11rnan
exposure (F.PA ORD, 1984). F..PA
ostimatod that about 12 million
persons within 12 miles of three
oxistlnc and nine projected
commercial incinerators may possibly
be exposed to rnleascs of
-polychlorinat~d biphcnyls in !ho air. In
1977, NIOSH estimatud that 12,000
workers had poteritial oCCl1palion,1I
expOSlJr0 as a result of polychlori-
nat ed bipl1enyls in the work
environment (NIOSHb, 1977b).
R[GULATIONS
Tl1e CPSC rec:oived a petition to
declare sewage sluclge produc:1s
containing polychlorinatcd l)ipl1enyls
hazardous substances . GPSC did not
take action based on an ·anticipated
EPA determinalion on lhis matter.
EPA rcglJlates polychlorinatccl
biphenyls uncler lhe Clean Water Act
(CW/\). Comprehensive l::nviron•
montal nesponsa, Compensation,
and lial)ility /\cl (CERCl.A), Federal
Insecticide, Fungicic.le, arid
RorJenticidc Act {Fl!-"RA), Rccource
Conservation and necover)' Ac:t
(RCl-1A), Supe-:rlund Amp,nclnwnts and
Rcautt10ri1.Ht ion Act (S/\ RA), and
Toxic; Substances Control Act
{TSCA). C:rA hciS eslf.iblished water
quality criteria ancl a toxic: poll1Jtant
effluent stnndard undcH CWA. ·rhcsc
che-)micals am subject to roportino
requirernonts under CWA, ci:nc1. A,
and SAHA. EPA eslablisl1ed a
slatutory rcporiable qu.rntlty (nO) of
10 lb for polychlorinated biphcnyls
under CtnCLA t,ut lowered t11e final
no to 1 tt., for theso chemicals and
specifically for seven commercial
mixtures of them. EPA banned the
use of these charnicals in pesticides
under rlfRA. Certain specific
disposal . practices of sludges
contnining polyc1,lorinatcd biphenyls
are prohibited under RCRA. Based
upon ct1rci11ugenicity, EPA published
a Maximum Contaminant Level Goal
(MCLG) of zero and a maximum
contnmirwnl 1Cvijl (MCL) oi 0.0005
mg/I for these chemicals lmdcr the
Sal~ Drinking Water Act (SOWA).
Uncler TSCA, CPA banned
manufacturing, processing, and
distribulion of polychlorinatcd
bip11enyls and promulgated marketing
and disposal rules. EPA has
establishad a polychlorinated biplrnnyl
Spill Cleanup Policy under lSCA.
Uncler 11·,e Clean Air Act (CAA), EPA
ossfJSsed riir pollution sources of
polyclilorinatcd biphcnyls ond is
<:onsidcrino the ncccJ for mgutation of
emissions I rom incinerators, the only
t,ource for wtiich controls may be
esse11tinl. ~DA regulates polycl1lori-
nat~:u .t,ipl1c/nyls uric!or the rood,
Dr~9. }-lllCI Cosm~lic A?I (fD&CA),
estahlisl1i11g tolerances for poly-
cl1l6fihated biphenyls in s·cvcfrar ·1oodi;
-~o.d .i~ j_irncts fcu f oocrprod1;cing
anlrnols. The tolerances aro , .5 ppm
(fHt" bai=:iH) in milk and ritanufaCllHCCI
,!pili.l?tRdllC.tir -~.J>prli. UaJ. ~a sis) in -
rio~!IIJY.1. 0.3 ppm in eggi:;, 0.2 pr.im"fn
fi.!_!_i~l;ecJ i~ir_r_iJ1J. lecfit t ·Ji,jjr1}ri arii1nal
f ced components of animal origin, 2
pp rn ·1n-f I s·11 "a·ncr tili o iif"isii ( !fcJ tbl e
porlio11). ~~~ __ Q,1 _ppm_ .~1_!111.f!~!. and
junior fc,od:.. rD/\ established action
32~ ·P~d -~·-; Q, ( ( Ef A')
d. r· ;n ~ ,· n3 w q./ er
s· f t<.1'\ d .'< r l. i ) c.c20t,S rr
DEHNRIENVIR. EPI. TEL:[phone] May 12,93
~{Jel"~.Of.:\ .. pp~_ (!Pl_!).~S!f~). in_ re~I l~~at
~ai)c('10 pprn in paper fOC>CJ•p~c:kn~Jlnq
.;,nfu1erial;~NIOSl ~ has recorrn ncn_Cled a
'f:ceiliri(f8lCP0S\JTe of 1 .0 µgtm3 H1 the:
. ?;workplace. OSI IA aclor>ted pc r·
!\m1ssible exposuro lilJlits (PELs) or ·1
•\{n,g/m3 as an 8-hr time wci~Jhted
7[.average ('fWA) 1or chlorocllphe rtyl!l
ticontaining 42% chlorine c.1nd 0.5
7r::_:m{J/m3 ns an 8-hr 1WA for ";li;;i -'.chlorodipl1enyls cnntninin,i r,t.% 'i:f•: .chlorine. These ~ t £1 nci a rrJs w c re .-:p~: · adopted by OSHA for toxic elf eels
•~i~'.-/, other t11an cancer . OSHA al~:o
i-//:· regulates polyc:hlorina\P.d biphenyls ;)?: under tl)e 1-laz.ircl Communication
!\< · Standard and as cherr1ic.;al 11a7arns in ,, ....... + laboratories.
• 1_,.
~·-, ..... ',.,..
POLYCYCLIC AROMATIC
HY.OROCARBONS, 15
LISTINGS
CARCINOGFNICITY
There is sufficient P-vide nce tor tl1e
carcir109t:nicity of 1110 following
polycyclic aromolic l1yrJrocarL>ons
(PAHr,) in P.xpcrimental tlnirnnl!.:
b e n z I a } a n 11·1 r ,1 c e n c ( !.i 6 • f; :i • ~i } ,
be n'lo! b]I iuo ra r1tt10 n e ( 2 05-~J 9-2).
ha n 7 o I j} f I u or an 11.1 c n e ( 2 O 5 · 8 2 · 3),
bonzo[k)fluoranthene (207-08-9),
bonzo[a]pyronc (50-3?.·8),
diboni( I n,1'1} acrid inc {??. 6· 3 G-ll),
diben2[a,j)acridi11c (224-42-0),
dihen1(a,h)an1hrocene (5:i--lO<i), 7H·
dibenzo[c ,g)G.:ubaznle ( 194-59· 2),
dibonzo[o,c]pyrenc (192-65-4).
d ibc nzo[ a J1)pyre 1w ( 18 9-f>4· 0),
diben1o[a,i)pyrcne ( 11rn-55-9),
clibenzo[c1 ,l]pyrene (191 -30· 0),
lnclono[ 1 ,2,3-c.;d)pyrene (Hl3-39-5),
,md 5-inethylchry!.Cl'IC (3697-24-3)
(l/\1-lC v.:~. 1!373; IAHC v.~i2 , 1987;
1/\RC S.7, 1987) .
When administernd by gavage,
uenz[aJanthrac:e11c induced papi11o-
mas ot till! forestomach In mice . In
anntlmr 9,1va~10 stucJy, benz[a]nnlt)ra-
ccno induced lung odonomas and
hcp.ttoma~ in mice . When
ac!m inist f: red topically. benzo[n]·
anthrm;onc inclLJCecJ sl<i11 µapillomas ln
mice. w11e11 adrninistcrcc! by a singlE-~
SUl:iC1Jlnll~OLI$ injer.tion, bcnz{O]•·
,rntl11,1t:cne inclticed sarcomas in ad1Jlt
mice nncJ pulmon,iry odenomai:, and
.iclcnocarci1wmns in newborn mice.
When tidrninislerHd by bladder
implantation, benz[o]anthracene
incJucc1 cl !oc .. ll c.:i rci no mas in mice
(IAHC V.:1, 1973).
Wl1cn aclminl!'>tered topically,
bcn:w[jjfluorHnthenc induced sl<in
papillomnF-flnd carcinomas in female
mic:P.. When injected directly into the
pul111or.ury tissues of female rats,
bc n1.o(ilfluoroantl1ene nnd benzo[k]·
11uoranthE-:11c imlucE'!cl squarnous cell
carci11011H1!.. When adrninistorecl
topic.illy, benzo[k]fluoranthene was
.ictivo aF, art inilinlor o! skin tumors in
ferrrn lB mice . When adcninistcred by
sub<.:utaneous injec:tion, ben1o[k)•
fluorunlhcnc induced locnl sarcomas
in rnic:c ot both sexos (IAr~C V.32,
198:-1).
WI.en ;id111inisterod by g,1vagc,
ben1o[a]pyrcnc inclucecJ malignant
and ben ign lore~tomach tumors in
rnicci anti llamsters ,rnd mammary
tumors in female rots. When
aclmini!-;tered in tho clict, benzo{a]•
327
15:13 No.014 P.02
1 .
l
\
DEHNRIENVlK .. t~l. l'I d \:I .I.~ • ::, ..; J.~_: . .:!:_'-+ 1'4U ■ V.L ...
Pt·oduc,>.ei by Micr-oroede.x 1 lnc. Vc,l, 17 Fxpires 7/31/i:13
1 op i r: :
TFHS
POI VCHLORTNATEO BIPHENYLS (PCB S )
I.Rst Revi~ed --01/01/90
Sec:t.,on !J pr·ovidf'ls i1,fo1•111;:1tior1 on 1:hre~ r.-1~pect:!=. of the:
c~rcinogenic risk as~essment for th~ ~gent in qu~stinn; the U.S.
FPA c:1a;sifi-.r.ttion, and qu,!lnt.itati1H! +'.:~tim;.;tes of ri~k from ora l
exposur<?. and fr·om inhF1l.,,.tion f.1)(po~L1r·r-. Tlic1 c1 ;,:issific.;.tion
r·f:flet.1".'.ts ~, weight-of•ev'idence. Judgmf!nt' of the. H lrn11hood thl:'lt.
thf! P.lgf>nt. ii; a humnn cAt·ci nogen. Th!': qu,rnt i tctfi ve ,.; sk
~~timAt~s ~re pre~Pnterl in thre~ ways. lhA ~1cpe factor i~ the
rf':slll1. of app1icr.ition of t.1 1ow-do:.~':! e.xtrr1pole1tior, pr•oc:edur-e -!Ind
ir:, p1·eseni..t:1d as the r-isl< per· (mg/kg)/d;:-.y, Th€: trnit. dsk if: i:h1:r.
q11-lntitaHve estirn.;1tf" in t.erm~ of f'lithf:!r• ri~k p~!r· ug/1. cfrinldng
wl.'lter 01· r·isl< per· ug/c:u.m /lljir· bt·E:F.li.hF:<1. Th~ third fm•m iri whi<.;h
r· i s k ; s pr~ t=: e n 1:. fl d i !',; Fl d r-i n k i "g w .:i t e r or r.1 i r· e; on c fH1 t. rat-i on
providing cancer ri~ks nf 1 in 10,000. 1 in 100,000 or 1 in
1,000,000, Background Document 2 (Service Code~) provid~~
det~il~ nn the r~tionale ~nd mAthodA u~ed to derive the
c ~ r-c i "og e n i c i t y v a 1 u e s f c:) u n d i n T R 1 S • U s e! r· fF. r.1 r· e: ,., fl f e r re. d to
~ecti<",n I for· infc:,r·m~tion 011 long-·1.er·m 1:o)(ic f.!ff~ct.s C'.>ther t.h;-:n1
c: ;...r· c i n og en i ,~ i t y •
-. ..!.L~--F V l' I) F NC F F O ~ (: l AS !=-I E..!.f..81 ! ON 4 $-I.Q_ _H II MAN, ,.!:.AB c:.r.til.au..E..t'H C t TY
11 .A.,. wnr,;i:.rr=t:rr•·EVfbFNCrb c1 Af.SHJCA110N
C1P1'-!'\ificrttion --P.:?; i:21~c,f.l.:;ible h1.11n.:=11i"c:atcinng~n
~;:,!:;1 !!; -.:· bf b~..,nurar.:..2,9 I" C 1 ~Qmr.1 ~ , ,0m·;W::"e;t rai..D ~ ..._2.f_r:.? t !',;
nn_~ ~o s'l._~.:~~-~• of -':'.1~C.~d inar!!:...~""t~_l'..~t ..,'-¥,9.9~_=-t~_y.!:_t:vigenc-!l
~._!':...~ ~~.:;-.r:, ::-~. _rir _ :J .. 1_v_c-::_r· .• (: ~ nc e c_...1.n ... lii.LIT1fi.'."~--~'t.. ... ,_!'1_9P;.~ t.2.~-~ s nd 1nh~lat,on or riPrmal contR~t. 1.T: A: 2' .---·;~· li~1-AN ... CA R0C:0 T N C>(fr°N Ir.TT V ()A TA
Tl"lr.Hfoquat.(?. Alt.b,:_">!.!...,q__h ttH~re o:1re rr,1,1,y ~h1_cJ.i~~..S..1-!_I~~-d.-.t.::i Ar'~
i IH1cieq11_;:,.:t1~ d_t~~ -to c:oi-ifb"irnd''i l'i"g-expos11r:f;S ()I'' 1 Eilr.k (')1 -expo!'ll.ll''P.
q uanf. if i c.:nt i c,n. ··-1"he.. 'f 1 r"·st.' ··no·ciTme nt ~i iro·ri'••·c,-f ··cl'il r·c-i nor:ie n i cit. y
85-'.:~oci,•dP.d with PCP, li'lXpC>!'.l1rf-wns l't,!pc,rte.d r•it ;.; New ,J,·H·se:y
pr,!tt·octv~mic~1 pL=H\1: i nvnl ving 31 r-esP-<'1rch i"!nd development
F.-n1rloyt=1<H: An<i 41 l'F.!fin(H'Y wc>r·ker~ (P.r.1hn et al., 1976, 1A77).
A l t h o tt g h r.1 ~ t c1 t i s t· i c a 1 1 y s i g n ·i f i c a n 'I.-i n r; t • e a s e i n rn A 1 i g n a n t
me1Rnom&~ w~s r~port~d 1 thn two studiec failed to report~
quF.intified r.!Xpo:Htr'E• 1evl.;!1 eind tel accoimt for H,e pr-Ed5P.l"lc:';f: of
,.ith£:r· po-t.e.nti<'11 or l<nnwn cAr·c.inC'lg~n~. In ~n ~xpEinded reepor-t
C:>-f thf!se !:tud1~s, NTOSH ( Hl77) concurred with the Bahn et ~,.
(1976) findings. Brown And Jones (1981) r~ported ~
r<?.trnspec::ti v,~ cohc,rt mc,rti!'ll i t:y s111dy on ?.bfl7 wor•kt'H'S who h-'i!d
completed at 1A~si ::i mnnth~ of ~mplnyment at one C>I' two
r.apr1citor man11f1.1cturing plant~. F.xpo:i.11r·e 1eve1s WtH·e 2.4-393
mg/cu • m Et t p 1 ant A an ci 3 1 A -1 :? 6 0 rng / c 11 • m ;;, t · p 1 .=. n t: f', • No ex c €: s ~
risk of c~n~er w~s observed, ln a 7-ye~r fo11ow-up study,
Brown (1987) r~port~d ft st~tistically signific~nt exce~s risk
nf liver nnd hili~ry c~ncer, with four of the five liver
can<:.-!rs in fernal1:: wnr·l<1H·s ;,;t plant: e.. A r·eview of t.:he
p&thnlogy r-~pnrts inrlicated th~t two of the liv~r tumors
co,rn+~!d in thf~ follc:,w-up study we.PP. not pr·imRl"Y liver· turno,·s .
WhPn 1'.he5!~ tumor·~ are excluded the e1civad:ion in inc:idence is
nc:>t-~;tat.i!r.tic;jlly s ignificant. The r•£i su1ts ~lso rnay be
c,">nfo11nded by population differences in i:"tlr;cihol cc,nsurnption,
dif'it,eir•y li,'.'lbi'l::~. And rithnic c::01nposition.
BertArzi ~t ~,. (19A7) ~onduoted 5 mortality ~tudy of 54~
m~le ~nd 1558 femRla emp1oyAes of~ c~p~citnr-making f~cility
I • .._,,.._,,
DEHNRIENVIR. EPI. TEL:[phone]
Produc:ed by Micr-omE>df'lx, Tnc. Vol. 17 ExpirP.~ 7/::l1/Q3
TR It.
Topi c : POL V CH L OR IN AT F. D R IP HF NY L S ( PCB S )
in Nnrt.h~rn 1tei1y. Ar·oclm· 1?.54 &1,d Pyr·al~ni"! 1471:i wer•f-J us,,..d
in thi~ plant until 1964, Thp~e wAre progre~sively repl~ced
by Pyr·alenc~s 3010 and 3011 1rnt.il 1970, afte1~ which 1ow~r
c h 1 n r· i n;:., t E: d 17-' v r I.it 1 e n e !'", we r P. u 5 ~~ d e >: ('; 1 u ;. i v r~ 1 y • 1 n 1 9 RO tho u s e
of PCBs was &bandoned. Some employe~~ a1so used
trich1or·oP.thyl~ne but, acr:nrdit"lg t.o the tl:'11i.hor·s, wE!r-e pl'e~wn(':c:I tC> b1=-proteci:fHi by efficitrnt. VP.ntihd.ion. Air ir.ampl1.1s wc:~r·e
cn11•ct~d ~nd ~n~ly2ed for PCRs in 1954 ~nd 1977 be~~us~ of reports of chlor~cne in work~rs. Qu~ntities of PCB~ on wor·k~r·!'l I hnnds Rnd wc,rl<pl e1c.-~ surface ,. al ~n wen:, meP.l~Llt'l'!d in 1977. In 18 ~ample5, 1eva1s rRnged from o.,-159.0 ug/sq.m on wc:1r·kpl.;;iice. sur·fact'l5 anrl 0.~-9-~ ug/5q,m nr1 wo1•kf-=r·s 1 h,;rnd!'i,
The aut. hor· s compF.11·ed ob !--fH' v,-:id mnr·ta 1i t y with t ha 1: expected
bP.twet~n Hl~6 l':lnd Hl82 b;,s~d (HI nRt.ional Find 1oc"11 Ita1iar,
rno1·tr.1lity rat.es. With vi+.~1 st~d:Ltr, ,:iseP.r·te1inment 99.5%
complet~, rnlativ~ly few deEths w~re report~d by 1987 [30
mA1e5 (5.51) and 34 fem~le~ (2.?%)). In cohnrt mA1es, the
number· of de,='lth~; from malign,;u,t tumor·!'-was signif·ic.1'11'd.ly
hi ghP r t· han r. xpfH::ted cornp~ r•ed with l or.a 1 or n1-:1t i onr:11 rat~ fl:., as
wc1:=:. th,~ numhf:r• nf clenth,, f rnm Cl'lnc~r of th!'! en t rac ➔. (6 observed VA, 1.7 national exp~ct~ri and ,.2 1oc~1 exp~cte.d).
Of 1.hF! six GT canc:P.t' deaths, nne w1.1s d11c-: to liver c,qncet· and
one to bili~ry tract c~ncer. De.~t.h!'i frum hemAtologic
ne.op1,:qsm~ in mal~!'i Wf:!r•e. ~lso hi~ih,sr i:hr1n e>-:pf-:cteci, but t.ht~
("><Cr•s!> w;,s 1101: str.ii.i!;;tic.;:illy signific::1:1nt. Tnt.;;:il c:;:;incer· dflt1th!:,
in fE:rnr...:ile~: WEH'~ si£11,·ifir.,::int1y alevated ·in c;ornpar·i~on t..o lc:>c"=ll r~tes (12 ohs~rved vs. 5.3 exp~cteri), NonA of the~A were li'vEH' or biliar·y c;;nc~~r·s . ThF! n1:1mber cit deAth :::; fporn
hE:mn'l'.ologic n~:opl;,gms in f€nH,1es wa~ hi9h~r 1:hf:'ln exp£,cted when
cnmpF.1r•-?.d with loc..::.1 ratc":!F; (4 ob~F•r·ved v-5. 1. 1 f.'Xpe.c:t.ed),
T h i s !l f· u d y i s 1 i m i 1. P. d b y s e v e r· ~i 1 f c1 c~ t or s , p .=.i r • t i c 11 1 .•:tr· l y t h e
small n1unb,:1r· of deMth~i th.;it occur·r·t=:d by the cut-off peric.>d,
Th~ pnwer of the ~tuciy is in~ufficient to dAtect an elev~ted
r·isl< of i::ii:A··spf.!cifir. c1:1ncf!r•. In ~ddit.ion, the ~wth()r'l!'i
s t .. , t E' d , .;1 f t.fH· .:i n e x ,1 rn i r1 i'I t i o n of t h ~ i n cH v i rl u;, 1 c ;;:i s e s , t IH1 t
interpret~tion ot the increas~ in GJ trMct cancer in ma1~s was limited, as it. eppe~r·ed 1il<e1y 1:h;,t some of these indiviclut.t1s
had only limiterl PC~ e~posur~. Confounding f~ctors may have
inr1uded possible ~ontsmin~tion of the PC~s by dibenzofurans
~nd ~xpo!.11rE! of sornt~ of 1.he wor·lrnn, to tf"ichlc:>roe-t.hylenf:1 alkylb~nzene, and epnxy resins.
Twn occ.urt·r➔nC:fJ/:. of ingestion c:1f PCP.,··<':ontandn.qte.d ric::.,, r.>i1 hAve
been r·epc:wi:ed: 'the Vusho i nc·i d~nt of 196A ·in Je1p,rn and t:he.
Vu-Ch~ng incident of 197R in Tai~~n. Amano ~t ~,. (1984)
c:ornp 1 et:P.d ~ 1 6-year red: r·ospect i 11e cohort mor ta 1 it y !It udy of
5fl1 mr:i1e end F,Qf1 f~rn.i:i1r:: victim!'-of-thf! Vusho ir,cident. A
r.:onsistc~n+.1y high ri!';k of 1ive.r r:,..1nct:r in fem~1e!'i OVfH' the
'entire 1~ ye~rs was observerl; liver cancer in males was A1so
~ignificently incre~sed. Sever~l serious limit~tiaA~ arA
~vident in this mt.11dy, Ther-e w~s ~ lack of information
re.g.:ird i ng job histories or t. he inf 1 uPnce of ;;, 1 coho 1 i :i;m or
~.mol(ing. Th~ informe1t.·io1"1 concerning the~ diagnosi~ of livE!r
cancer w~~ obt~ined from the victims' fmmi1ies, ~nd it is not cl~Ar wh~thAr thi5 information wa 5 indep~ndently verified by
he~lt.h prof~ssionA1~. For some of the canc6rS de~cribed, the
DEHNRIENVIR. EPI. TEL:[phone] Ma~ 12,93
Pr·orluc~Hi by Mir.roni~dex, Irie. Vo1. 17 Fxpires: 7/~1/9'.~
lRIS
To~ic: POLVCHLORJNATfD BTPHENVLS (PCB R)
1.r.tf-ncy P'=t·ic,d is shor·tet• than wou1d he expected.
F II r· t h ~ r mo r P. , t he r. on 1:;:; rn i n ,=d. e rl o ·i 1 s c.: on t 1:d n e d po 1 y ch 1 o r-i n ol;f t e. d
dibern:oflw1,ns and po1ych1orinatt", .. n quinonc.~s a s w~11 .-.s PC~s,
anrl the ~tudy lack~ d~t~ r~garrling expneur~ to the first two
c:l,!u!'ies of c.:ompound!'l. Ther·e i!!I str·ong evidenr:e ·lndic::l!!lt.ing
that the her1Hh f:ffc<:ct~ seen in V11sho victims were du~ 1:.o
i"gC1stion of po1yr:hlm·in,1ted ciibenzofur•t.➔ns, r·,1=1ther than to
r-·c.:~s the.m~elvef. (re.-vi~wf.!<i in fPA, 1988). lhf:' rc;-,s .. ujts of the ----.__. Am<'inn et al. st.!1£!.Lc.,.r1 t thP.r·efo1'E:~, be C<"Jnc:id,H·eti -~~ no mc:>r·e
t hnn 5ll9Qf';..S± i Ve• Q_f Ct~'.cTi,'og;"n fc::i _fy__ eif ~tr15--;--··-
1 J: .A.~. ANIMAL CAfi CTNOGFNfc:~CTV-DATA .
f:11ff;c;ao+. PC.R m, )(T_ure?. J!IF~·ct-·+rt '1:hf: fol lowing !itudi,'!ls
werP commercial prepar~tions and may not bP. the ~ame a5
mi xtur~1s c.>'f i ~orne r·s f ounr! i 11 th.i! envi r·c>nmen1'. 4.1 though ani m,,d
f t~P.rl 'i.~~-t . .ud if'!~ df<mon s't· r a t.e t hfl c-::a r r.: in ng en i r. it y o--r-colnme7.-c:':'i a7 ·vc_fi_ P r~en2::a-tio,1r-:~1.' 1.:Li~-oc>±.:.Jwlo..wJ1 __ whLiE . .siLJ.b.i.::·. P(P~:c:·onje't,i;~ r ~
in such pr·epa"Fatinns .=ir·~ r·e.spQ_n~it:>.le. f.o.r .thfl.~~ ~ff_~cb,, or if
cle"cornpo'sii-1'"0TlJ2_'Fr.'l°t11Tc.'fs~··c:cil'lte1mi n,=rnts (.H' metAbei) i t'ol!!S . ,;i;e
i ,,_yor~.£:.LT~-f ~e_-(c1xT~ t:'~~-pc:~nse"';. 'E~·,:;1 v··b 'i rii:is~i-1•/i wTtl, rats
(l<irr,11r·& .=tnd P,abn, 1973, It.net a1 •1 rn74) Wf!r•e ir,ade.quatl'l +.:o
.-.~:~<'!5~ c.,i:i1•c:inc,9P.rdcity dLH~ tn the sm lf,11 rwrnb,~r· of Anirn;:,1~ F.tnd
~;hort. durr1t ion of e)(posurf: to Pr.B. A 1 nng:_!_!:_l.::.!_r!.... bi na5My C'.>f
Aroclor 1260 ~e_c!.l::J.e.d by, __ K5.rnb.!~Ol!.9J.1J.t __ _!;l_~ ... L1~7~J.~'.t'?R'Clc:ed
h"fp;,i'f:oc~TT1TAt· cr.1rr.inom,;,c.: in_fem.;,le ~-h~1·rr1o;"-1n r·;,.1t.:\I when 100 ppm
w~~ci adini"i,isfE .. r;·nd ... for· 1530 d'"1y,:; t.(.) 200 ·;;;rllir,.ifl's ·. He·p~toc~11 u1 !ljr
CAl·r::ihomii's ·a-nc:I' ne6pl1"1st-ir.. nodules WtH'f• obsf~rv~d ir1 ,4 ,qnd 7At,,
re~pectiv~ly, of thA do~ed anim8l~, cnmp~red ~1th 0.58 ~nd o~.
l'f! sp,':!ct i Vf'l 1 y, of th<'! cont r·n 1 s.
ihe NCT (1978) r·~portt~d t·£i su1ts for 2u m.=tlE'! ,.:ind ?.4 fernr11e
F'i;.c:htH' 3411 nd.~ tr·e.F1ted with Ar·oc'lor· 1!'54 at. 25, 50, or· 100
ppm for 10~ to 105 week~. Although c~rcinoma~ of th~
gastrninta~tin~l tr~ct wAre obRerved among the traAted animal•
only, the incidence was not statistic811y ~ignificRnt1y
f< 1 e v ,;.d fHl • A n 1.:i p p " r-~ n t rl o ~: C➔ -r· f'! 1 ;,:it e d 'i n c i cl fHH": P. of h fl p ;.;i t i ,~
nociul ;:.n· hyprH·p1r-isi.=i in bot.h sc-,,xe~ i::l!'l we11 as hitpatar:el111lat·
car·cinom;;~: MY1ong rnid-t.o high ··dri~t"-1:rei'ited rnale1s w.=rn reportE:1d
(ti-1?%, comp;;n•P.d ton% in UJntt·o1s).
Norbeck ~nd WA1tm,i:in (19a5) fed 70 male anrl 70 f~mal~
Spr£1911e··tH=iw1 AV r·at~ a di e1: conte:d ni ng Arnc:1 or 1 =>FiO in cc,r·n oi 1
~t 100 ppm for 16 months, fo1lowed by A 50 ppm di~t for ~n
additional 8 months, th~n ~ ba~,i:il di~t for 5 months. Control
-!<111imr.-1l!':; (6:l r-.=,ts/sex) r·ec~ivec1 a c1iet containing C::(")rn oil for ,a months, t.he.n;;;, bAsal di ,1t ;;ilone. f<:>r 5 months. Among
animals that survived for-at 1eaftt 10 month~, f~mAlea
~xhibitAd ~ 91% incid~nce (4~/~7) of hopatoce11u1ar c~rcinoma.
An additional 4% (2/47) h~d n~opl~Etic nndu1es. In mA1es
correr;.ponding inc·icfonoP.s we1'e 4% (2/46) for cBr·cirlom;ii and 11%
U•/46) fr.w neopll'lst..ic 1,odulei:;. Conc::1.H•t·ent liVf'I" morphology
st11di€!': WFH'e car-r·ieci out on tii::;!!!l11e sample'" obt:ai1,ed by perrtial
hepatP.ctC".>1nie~ of thr·et'! anirnl!li~.:/gr·oup c1t f!':!ight t ·ime points.
These studie!', showt:d the sequen1:ia1 progt•P.sP:ion of Hve.r
1e~ion~ to h~patn~ellul~r C8rcinomas,
Or~lly admini$tered PCB ra~ulted in increased incidenc~s of
h~p.=d.n~~11u1M· c.~:r·r.:inoma!l\ in twn mc11s~ strain~. :rtc., ~t. ,.,,1.
( 1973) 1:t•f!!ate.d malf.'! dd mic~ ( 1?./grnup) wit.h 1<111n!:lr:hlor·s 500,
----.,..., ,,..., ·-·...:·_.:,.·..;·---
~•r·oduc.ed hy Mic:rornedex, Inc.. Vol. 17 f.)(pire~ 1/31/93
~ IRlS
Topic: POI VCHLOf<lNATFD P..)PHFNYLS (PCfi~:)
,no ~nd 100 e,:fch at ~i~tary levels nf 100, 250 or 500 ppm for
3? WP-~:l(!a.i, Th'!'! gl"(>llP fec1 500 ppm ot K&nechlor 500 had ~ 41.7'%
ine:irlenc~ of hepr.1tocP-11111ar· Cf.tr•ci11omr..H, ~1H'i 1:1 fi8.'3% incidenc€:
of nodulrH' tivp~1·pl1:l~i&. H<,patocf'l"llui'lr' r:a1·cinotnF.l5 snn norlular
hyper·p1a,;;ia wer·e r,ot obsf>r•ved in mice fM.i 100 or n,o ppm of'
Kan~chlor SOD, nor among thos• fed Kan~chlor s 400 or 300 at
any concentr~tions.
fi c~~:.Lutr-• .e.t.. -~l .. • ....... U..:~-~-".. L.!..~ d ... ~ J. ~L ... W_:i_s ~ 11.x: _ . t~ t .~ -~-~ ~.:tl? ... 9 QJ1 t e i n i n g 100 pprn cif t.hc~ PCB mi x1·1.11~el".: Cl oph1rn_ A _3_0 {.3 0% chl ~)!.:.iD!-by
W'-~·i51_hr.}_:,t!r· ... c:l.Qp_l~~-,f· A·--g-o .(.150'% c~_~_C"!~·.i11~ by -~e_ight)_.fo_t'_ _RQQ_ ~e1y!!,
1h£'. ~•'cF', mixt.Lll''es-we-ir•c!-1''!,;·pc:,r•te.d t .o bf: fr·e.e nf fur-ans. C1oph1;in A 30 wa~ administered to 15? rats, Clophen A 60 to 1~1 r~ts, anrl 139 r~ts rAceiveri a st~ndArd diet. MortR1ity ~nd
h'i~tolosdc le:1sions werP. r.a.porte--d fur an ·im,:11~ necrC>psif!d during
P.;:,ch 1oo~dr.1y ·i nterva1 for a11 three gt·oup~. Of th~ ~niml.!ll s
t.hat sur·viwid thA 800-·d,:,y treatmer,t. pP.r·ic>d, 1/53 rats (?I) in
thn control group, 3/87 (3%) in the Clophen A 30 group anrl
5?/85 (61%) in the C1ophen A 60 group h&rl d~ve1oped
h~ratoce11u1;:u-· C.i:'il'cinoma. The. ir,cide.nc:l; int.hf:; C1(')phen A 60
gr'oIIr, wr:.s !=iigrl'ifir:an1:1y ~lf:'VF.1ted in cc:>11,p.;;risnn tot.he C(")nt.rol
gr-01.q:,. Ne.opla5tic nod1lle~ w~rf': rP-pr.>r·tecl ir, 7/r;'.1 cnntr·ol,
3~/87 Cloph~n A 30, ~nrl 3~/8~ ClnphAn A 60-tre~ted animals.
1h~ incidence of nodulf'~ wa1r-: 5igniticant1y i11c1"'~r,se.d in both
tr•ecd:mf'!nt. groups in c-:nrnpi1r·i !'lc,n t.o the CC'Jntr-ol group,
Neopl&!=:tic:: liver-nociull\!!=. ;;,n<i hf'rnd:or:f11u1.:.r· c.;i1"ci11onuin:::
appeEir-ed e.;;r'l iM· and Rt highiH' incidenr.E: in t-he-Clopher1 A 60
g r· o up r ~ l r.1 ti v f! 'i: o t h P C 1 op hf" n A 3 0 t~ r o up • T hf: .r-11.1 t hon:
interpret~d the re!'-11lt:s t1~ indic:,qtiv~ of r.i c,qrci,,ogenic effeci:
r ~ l ~ t £~ d t o t. h r1 d ~ g r· e P. of c h 1 o I" i n A t i on o, t h €! P C 8 m i x t. 1,r· f: • T h e
~uthors ~,~o ~uggosted th~t th~se finrlings ~upport tho~e of
<,tl1f:t•s, incluciing lt.c, flt a1. (1973) An<i l<imbrough e.t S11.
( 1 9 7 5) , j....!J __ Yih:Lcb. .. JiE:.12,.~ oc A 7 1 111 a r-c .;, r-r; i n omt.1 s we r· e pr <>cf u Cf! d by mo,..€: hi $. h l_y .. .ci:u..o.r:.:LQ r.l t e cl -mix fiir'e.s :-... " . --. ·--. --. .. ----·-·
l<lmhr·oiigh .. l':lnd Li,,de~-(1974)··cro§.~d gr·oup~ c,f 50 m.;.1~ BALB/c~l
micc:: (a !-trc.dn with i?I 1ow spont1:1nf?o11s incicie:11c:e of heplltornF.:1)
with Aror.lor· 1?5h at ~no pprn in the di~t for 11 month5 or 8
month s , followed by a 5-rnonth recovery period. Two groups of 50 mic~ were fed a contro1 diet for 11 months. Th& incidence
c:,f hep,;,t:c:,ma~; in survivor·::,: ff>-rl Aroc:101· 125'-! for 11 monthi; wae::
1 0/?.2. One hep;;,it.ome wa ~; nb se r v~d in the. ?4 ~ u r vi vor s fed
At·oclor 1254 fr.H' f-i months.
TT,A.4. SUPPORTJNG DATA FOR CARCJNOGENTCTTV
~11 /93 . --
PCB LANDFILL
SUMMARY OF SAMPLES ANAL VZED FOR PCB'S
PRIVATE
MONITORING SURFACE STEAM WATER
DATE WELL WATER SEDIMENT LEACHATE WELL SOIL OTHER
1982 2
1983 59 35 4
1984 8 16 16 19
1985 16 16 16 19 2
1986 16 16 16 4
1987 4 4 4
1988 4 4 4
1989 8 8 8 1 1
1990 8 8 8 12 1 5 6
1991 8 8 8 3 1
1992 8 8 8 1
1993 1 1
PCSLANDFll
SMtPUNG ~TA
DATE MONITORING WELL SAMPLES SURFACE WATER SAMPLES
1984
06-06 <0.1 PPB (4 SAMPLES) <0.1 PPB (8 SAMPLES)
12-11 <0.1 PPB (4 SAMPLES) <0.1 PPB (8 SAMPLES)
1985
06-24 <0.1 PPB (8 SAMPLES) <0.1 PPB (8 SAMPLES)
11-13 <0.1 PPB (8 SAMPLES) <0.1 PPB (8 SAMPLES)
1986
05-06 <0.1 PPB (8 SAMPLES) <0.1 PPB (8 SAMPLES)
11-18 < 0.1 PPB (8 SAMPLES) <0.1 PPB (8 SAMPLES)
· 1987
06-04 <0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
1988
02-02 < 0 .1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
1989
03-21 <0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
10-25 <0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
1990
04-19 < 0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
10-25 < 0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
1991
04-24 < 0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
10-28 < 0 .1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
1992
06-13 < 0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
11-24 <0.1 PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES)
PPB • PARTS PER BILLION PCB'S
PPM • PARTS PER MILLION PCB'S
§TREAM SEDIMENT SAMPLES
<0.1 PPM (8 SAMPLES)
<0.1 PPM (8 SAMPLES)
<0.1 PPM (8 SAMPLES)
<0.1 PPM (8 SAMPLES)
<0.1 PPM (8 SAMPLES)
<0.1 PPM (8 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
<0.1 PPM (4 SAMPLES)
The PCB Landfill haa 4 monitoring wella, 4 surface water aampllng altea and 4 atream Mdlment aampllng altea that are currently umpled
aeml-annually.
PCB LANDFILL
LEACHATE SAMPLES
DATE INFLUENT EFFLUENT
03-07-83 0.42 PPB 0.24 PPB
03-07-83 0.44 PPB
03-08-83 0.34 PPB 0.28 PPB
03-08-83 0.25 PPB 0.043 PPB
03-08-83 2.80 PPB 0.062 PPB
03-14-83 <1.0 PPB
03-16-83 <1.0 PPB <1.0 PPB
.. 03-21-83 2.471 PPB 0.184 PPB
03-22-83 1.408 PPB 0.294 PPB
03-23-83 1.349 PPB 0.107 PPB
03-24-83 <0.1 PPB <0.1 PPB
03-28-83 <0.1 PPB <0.1 PPB
03-30-83 0.279 PPB <0.1 PPB
04-01-83 0.10 PPB <0.1 PPB
04-05-83 0.40 PPB 0.10 PPB
04-07-83 0.20 PPB
04-11-83 0.20 PPB <0.1 PPB
04-12-83 0.50 PPB <0.1 PPB
04-13-83 1.114 PPB 0.708 PPB
04-14-83 0.708 PPB 0.196 PPB
14-18-83 <0.1 PPB <0.1 PPB
04-19-83 0.22 PPB 0.21 PPB
04-20-83 0.27 PPB 0.24 PPB
04-25-83 0.60 PPB <0.1 PPB
04-26-83 0.20 PPB <0.1 PPB
04-27-83 <0.1 PPB
DATE INFLUENT EFFLUENT
05-10-83 0.20 PPB <0.1 PPB
05-25-83 0.10 PPB <0.1 PPB
06-01-83 <0.l PPB
07-20-83 1.63 PPB
07-29-83 <0.1 PPB
01-21-83 <0.1 PPB <0.1 PPB
11-29-83 <0.1 PPB <0.1 PPB
· ·01-26-84 0.30 PPB <0.1 PPB
03-07-84 <0.1 PPB <0.1 PPB
04-03-84 0.60 PPB <0.1 PPB
05-03-83 0.60 PPB <0.1 PPB
06-06-84 <0.1 PPB <0.l PPB
07-17-84 0.30 PPB <0.1 PPB
08-16-84 · <0.l PPB
09-11-84 0.20 PPB <0.1 PPB
11-05-84 0.20 PPB <0.l PPB
12-11-84 <0.1 P~B <0.1 PPB
02-18-85 <0.1 PPB
03-26-85 <0.1 PPB <0.1 PPB
04-13-85 <0.1 PPB <0.1 PPB
05-23-85 <0.1 PPB <0.1 PPB
06-27-85 <0.l PPB <0.1 PPB
07-16-85 <0.1 PPB <0.1 PPB
08-13-85 <0.1 PPB <0.1 PPB
09-18-85 <0.1 PPB <0.1 PPB
10-24-85 <0.1 PPB <0.l PPB
DATE INFLUENT EFFLUENT
11-13-85 <0.1 PPB <0.1 PPB
03-04-86 <0.1 PPB <0.1 PPB
04-24-86 <0.1 PPB
05-06-86 0.18 PPB
03-21-89 <0.1 PPB
04-19-90 <0.1 PPB <0.1 PPB
05-03-90 <0.1 PPB <0.1 PPB
. 05-08-90 <O.l PPB <0.1 PPB
08-28-90 <0.1 PPB <O.l PPB
09-27-90 0.20 PPB <0.1 PPB
10-25-90 <0.1 PPB <O.l PPB
04-25-91 <0.1 PPB
05-30-91 <0.1 PPB
10-29-91 <0.1 PPB
10-27-92 <0.1 PPB
02-26-93 <0.1 PPB <0.1 PPB
PPB -PARTS PER BILLION PCB'S
INFLUENT -LEACHATE PRIOR TO ENTERING TREATMENT WORKS FILTRATION · SYSTEM
EFFLUENT -LEACHATE AFTER DISCHARGE FROM TREATMENT WORKS FILTRATION SYSTEM
PRIVATE WATER WELL SAMPLES
DATE SAMPLE LOCATION RESULT~
08-24-82 PRIVATE RESIDENCE WELL <1.0 PPB .
08-24-82 PRIVATE RESIDENCE WELL <1.0 PPB
01-13/19-83 PRIVATE RESIDENCE WELL <1 .0 PPB
(35 WELLS FOR 45
RESIDENCES)
07-16-85 PRIVATE RESIDENCE WELL <0.1 PPB
03-16-90 PRIVATE RESIDENCE WELL <0.1 PPB
PPB -PARTS PER BILLION PCB'S
\
.J
PCB LANDFILL
MISCELLANEOUS SAMPLES
DATE SAMPLE IPCATION
01-06-83 GAS VENT EXHAUST
01-06-83 LEACHATE COLLECTION
PIPE EXHAUST
01-12-83 AMBIENT AIR SAMPLES
01-12-83 GAS VENT EXHAUST
08-28-89 LEACHATE LAGOON .. WATER
05-03-90 SOIL SAMPLE
04-18-90 GRASS (4 SAMPLE
SITES)
04-18-90 SOIL ( 4 SAMPLE
SITES)
04-18-90 CHARCOAL FROM
TREATMENT WORKS
04-18-90 LEACHATE LAGOON
SEDIMENT
10-29-91 SOIL
02-26-93 LEACHATE LAGOON
SEDIMENT
PPB -PARTS PER BILLION PCB'S
PPM -PARTS PER MILLION PCB'S
ND -NONE DETECTED
RESULTS
3.00 PPB
<1.0 PPB
ND
2.00 PPB
<0.1 PPB
<0.1 PPM
<0.1 PPM
<0.1 PPM
<0.1 PPM
0.27 PPM
<0.1 PPM
0.12 PPM
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September 9, 1991
Re: PCB Landfill in Warren County
Pumping Rate is about 7 to 8 gal/min
It takes about 15 to 20 minutes to pump the system dry
About 120 gallons are pumped per cycle
It takes about 2 hours and 45 minutes to recharge
Assume about 3 hours to pump and recharge for one cycle
Assume a constant rate of pumping and recharge
8 cycles of 3 hours per day
8 cycles X 120 gal/cycle= 960 gal/day
1,400,000 gal. / 960 gal/day= 1458 days= 4 years
assuming constant rate, 24 hrs/day, 365 days/yr
4 X 3 = 12 years, assuming constant rate, 8 hrs/day, 365 days/yr
12 / .68 = 17 .6 years, assuming constant rate, 8 hrs/day, 250 days/yr
Assumes constant rate of recharge and pumping
Assumes no additional infiltration
Set up continuous pumping operation
1. slow rate of continuous pumping
2 . cycled pumping at higher rate with float valve on/off switch
Someone needs to be on site to monitor pumping, sample leachate,
measure draw-down, etc.
Permit requires certified waste water treatment plant operator???
Operate by using existing staff or contract out the work
IJ L -flt:'-_f ;{lf.oJ.. (,•,d" ' ~" Coe..-,<~:.<; W,St I\S,
MAY 05 '93 06=39PM EHNR•PUBLIC AFFAIRS
M E M O R A N D U M
TO:
FROM:
RE:
DATE:
Bill Myer 0 Debbie Crane ~\7~1.-
Items needed for next week's press release
May 5, 1993
As per our conversation this afternoon, here's the
information I need to receive from you by Friday in order to
prepare for next week's press conference:
P.1/1
1) Chronology of events since 1984, including who knew what
when. When and how did you let the last administration know this
had happened. If you have paperwork to sup,port this chronology,
please include it.
2) Go through the 1984 task force report, note each item that
wasn't done, and detail what would have happened if it had been
done.
3) If the oversight group had been formed, what would it have
done? Could its actions have affected the situation?
4) If continuous maintenance had been doirie, how would th.ings
have been different?
5) How did the water get in there? Is th1:!re something we could
have done to prevent it? Why didn't we rem<:>ve the water belfore
the landfill was capped?
~
*House #1
.1 House #2
House #3
House #4
, House #5
*House #6
House #7
House #8
House #9
· House #10
House #l0A
House #l0B
House #11
PCB LANDFILL
List of Residents Within 1\ Kile Radius
State Road -1603
R.L. Williams
State Road -
Tommie & Diane Harmon
Rt. 2, Box 47
Warrenton
John R. Limer
Rt. 2' Box 47A
Warrenton
R. Edgar Limer,
Alice Limer
Rt. 2, Box 49
Warrenton
Al Kimball
Joyce L. Lubbers
Rt. 2, Box 50
Warrenton
E.N. Brantly
Rt. 2, Box 50A
Warrenton
Jr.
Ethel Tharrington
Durwood Patterson
Rt. 2, Box 52
Warrenton
Empty Cabin -
Owned by Mr. Patterson
Empty House -Elam
Dennis Harris
Rt. 2, Box 54
Warrenton
Page 1
1604
Right Side
Right Side Trailer
Left Side
(Same well w/#4)
Left Side
(Same Well w/#3)
Left Side
Right Side
Right Side
Right Side
(Same Well
Right Side
(Same Well
Right Side
Left Side
w/#9)
w/#8)
t "
•/ House #12
*House #13
*House #13A
/ House #14
" House #15
./ House #16
-1 House #17
✓ House #18
v House #19
v House #20
v House #21
v House #22
state Road -1604 -continued
Paul Pope, Jr.
Rt. 2, Box 53
Warrenton
State Road -1605
Massenburg Kearney
Farm House -Empty
(frequent visitor)
Emma J. Alston
Rt. 2, Box 56
Warrenton'
Wilbur Alston
Rt. 2, Box 56
Warrenton
Lugenia Kearney
Rt. 2, Box 55
Warrenton
State Road -1604
Charles Edmonds
Rt. 2
Warrenton
Albert Tuck
Rt. 2
Warrenton
Janie Valentine
James Kerney
Larry Green
Rt. 2, Box 58
Warrenton
Ed Sommerville
Rt. 2, Box 59
Warrenton
Page 2
Right Side
Trailer
Right Side
Right Side
(Same well w/#19 & 20)
Left Side Trailer
(Same well w/#18 & 20)
Left Side
(Same well w/#18 & 19)
Left Side
*House #23
,, House #24
✓ House #25
✓ House #26
✓ House #27
*House #28
" House #29
✓ House #30
., House #31
✓ House #32
v House #33
../ House #34
*House #35
*House #36
State Road -1604 -Continued
Large Empty White House
state Road -1650
Rosa O'Neal
Rt. 2, Box 61
Warrenton
Phillip Lynch
Lucious O'Neal Jr.
Rt. 2, Box 60-B
Warrenton, NC
Campbell
State Road -1604
Empty House
Walter Burroughs
Rt. 2, Box 62
Warrenton
Arthur Gooch
Rt. 2, Box 63-A
Warrenton
Jerry Abbott
Rt. 2, Box 63
Warrenton
David Munn
Mattie Bledsoe
James Williams
Rt. 2, Box 227
Warrenton
State Road -1600
George P. Alston
Spencer Davis's House
Page 3
~ight Side
(Same well w/#25 & 27)
(Same well w/#24 & 27)
Trailer
(Same well w/#24 & 2&)
Trailer
Left Side
Left Side
(Same well w/#32 & 33)
(Same well w/#31 & 33)
Trailer
(Same well w/#31 & 32)
Right Side
Left Side
.....
✓ House #37
✓ House #38
*House #39
*House #39A
✓ House #40
✓ House #41
v House #42
.,. House #43
*House #45
.,, House #46
/ House #47
• House #48
, House #49
✓ House #50
State Road -1600 -Continued
Spencer Davis
Rt. 2
Warrenton
Percy Davis
Haywood Perry
Empty House
Bay & Willie Williams
Rt. 2, Box 237
Warrenton
Willie Williams
Mary Williams
Rt. 2, Box 237
Warrenton
Henry Twitty
Rt. 2
Warrenton
Left Side
(Same well
Left Side
(Same well
Right Side
Right Side
Right Side
(Same well
Right Side
(Same well
Right Side
Others Residents In The Area
Sharon Miller
Doris Dryden
Rt. 2, Box 76EE
Warrenton
Thomas H. Rooker
Rt. 2, Box 12
Warrenton
Macey J. Paynter
Rt. 2, Box 27
Warrenton
Gary Campbell
Rt. 2, Box 33A
Warrenton
south Warren School
Rt. 2, Box 65
Warrenton
Page 4
w/#38)
Trailer
w/#37)
w/#41)
Trailer
w/#40)
Trailer
March 6, 1990
To: Ernie Carl
Edythe McKinney
From: Bill Meyer
Subject: Warren County PCB Landfill
Summary
The PCB landfill has been in operation almost 7 years with no release
to the environment
There is no clear authority and responsibility for the permit and
operation and maintenance
The landfill is currently subject to renewal of the state waste water
permit and the Federal EPA Toxic Substance Permit
Permit renewal(s) offer the opportunity for a comprehensive
evaluation of the landfill to ensure continued protection of public
safety and the environment
Commitments have been made by previous administrations and need to be
evaluated for applicability and appropriateness to the facility at
this time.
Recommendations
Consideration should be given to establishing a small work group to
address the PCB landfill
Clear authority and responsibility for permit(s) operation,
maintenance, and monitoring should be established and permanently
institutionalized into a single state agency. Conflict of interest
issues will need to be addressed.
The responsible agency should ensure timely permit renewal(s).
Consideration should be given to establishing a specific continuing
budget for landfill, monitoring and should include contingency
remediation procedures
Past commitments that have been made by the state should be reviewed
and where applicable and appropriate continued and coordinated with
Warren County.
Warren county PCB Landfill
General Background
A 1973-1984 chronology of events on the PCB Project is
enclosed. {Enclosure 1)
The Warren County North Carolina chemical waste landfill was
given final EPA approval on December 14, 1981. A combination of the
December 13, 1981 approval letter and a June 4, 1979 approval letter
is considered to be the "Permit." {12/14/81 & 6/14/79 letters
enclosed -Enclosure 2)
The approval letters were issued to Governor James B. Hunt.
The cooperative agreement between EPA and North Carolina for
construction of PCB landfill and clean up of the PCB contaminated
soil under CERCLA was signed by William w. Phillips Jr., Special
Assistant to the Secretary of CCPS {Enclosure 3)
CCPS was designated by Governor Hunt as lead agency for this project.
{Enclosure 4)
Permit #7634-R2 {waste water treatment) for the landfill was issued
by NRCD to CCPS {Enclosure 5).
October 4, 1982 DOT notified CCPS that DOT will routinely:
1) Maintain access road, landfill fence and gate
2) Maintain vegetative cover to prevent erosion and mow twice
annually {Enclosure 6).
The cooperative agreement states that monitoring will be the
responsibility of OHR, Solid and Hazardous Waste Branch from existing
state appropriations and site maintenance problems will be corrected
using state funds (Enclosure 7).
Background State Commitments
The state made the following commitments:
October 20, 1982 open letter from Governor Hunt to citizens of Warren
County {Enclosure 8)
1) Review safety features at the landfill by state and respond
to citizens concerns (meeting held and concerns addressed)
2) Establish work group to study detoxification of landfill
(work group established and final detoxification report
issued 12/12/84) (Enclosure 9)
The report recommended
a) Landfill not to be disturbed at that time
b) Program for routine maintenance responsibility clearly
set forth in record and in public (not implemented at
this date)
c) Regular monitoring (solid waste Section implementing
this now). Monitoring of private wells within 1 1/2 mile
radius of site to be initiated and 25% monitored at
least once every four years (55 wells were monitored
once in 1984, wells identified by name and location
-no monitoring since 1984) (Enclosure 10)
d) Develop contingency plan for site (not implemented at
this date)
e) Funding and statutory authority for items (b) (c) (d) -
(not implemented at this date)
f) Establish mechanism within state government to continue
surveillance of PCB detoxification (not implemented at
this date)
3) The state will monitor landfill and surface water (Solid
Waste Section implementing this now) and monitor residential
wells within a 3 mile radius of the landfill (this has not
been implemented)
4) State and County health departments to provide environmental
and health monitoring for citizens (not being implemented at
this time) (enclosed is correspondence between state health
director, staff and county health director 10/20/82,
10/19/82,10/20/83) (Enclosure 11)
5) Legislation to keep from expanding landfill and prohibiting
the state from placing another landfill in Warren County
(resulted in current 25 mile separation from PCB landfill in
Hazardous Waste siting statutes)
6) State assistance to help Warren County attract industry
Current Status
1) The landfill is being monitored and is not releasing any
contamination to the environment
2) Several potential problems exist at the landfill
a) Leachate removal pump is in poor condition
b) Litter on access road
c) Access to monitoring well #2 and Leachate collection
basin needs to be improved
d) Irrigation system is in disrepair
e) The inner well casing on well #3 is cracked
3) There does not appear to be sufficient clarity of
responsibility for site operation and maintenance
4) There is no specific funding for of the landfill monitoring
5) The waste water permit is due for renewal
6) EPA has notified the state that the permit document needs to
be updated to present standards. A permit revision process
will be initiated by the EPA toxics section to ensure that
the landfill approval is in conjunction with all current PCB
landfill regulation. The EPA schedule for and updated permit
is by the end of this (federal) fiscal year.
Recommendations
1) The landfill has been completed since July 1983 and needs
additional maintenance and permit(s) renewal. A comprehensive
inspection should be performed to identify all potential
problems.
2) Clear authority and responsibility for permits, operation,
maintenance, and monitoring should be established and
permanently institutionalized into a single regulatory
agency if practical.
3) The responsible agency should ensue timely permit renewal.
4) Consideration should be given to establishing a specific
budget for the landfill operation and maintenance and include
contingency remediation procedures.
5) All commitments that have been made by the state should be
reviewed and applicable and appropriate commitments continued
and coordinated with Warren County.
6) Consideration should be given for establishing a small work
group to address the PCB landfill
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
/
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary
Ronald H. Levine, M.D., M.P.H.
November 26, 1986
MEMORANDUM
TO:
FROM:
SUBJECT:
Jerry Rhodes
Bill Hamner
Gordon Layton
Bill Meyer 6JY1
Monitoring of the Warren County PCB Landfill
State Health Director
Effective December 1, 1986, responsibility for monitoring the Warren County
PCB Landfill will be transferred to the Solid Waste Management Unit.
Please jointly determine the most appropriate means to facilitate this
transfer. Let me know if there are any problems.
The reason for the transfer is to ensure funding of this activity with
State funds.
North Carolina Dl:'pamner:t 0(
Crime Control ~
& Public Safety
512 N. Sub/nm,> Street f'. 0 Bu, 21/6R7 Roh·11Ji: 27611 -7687 /919) 733-2126
James B. Hunt, Jr., Governor
Mr. Al Hanke
Environmental Sc ientist
EPA, Region IV
345 Cour tland St., NE
At lanta, GA 30365
April 8, 1983 H1-•111a11 it Clark, Secretary
Re : Warren County PCB Landfill
Wate r Disposal
Dear Al:
Enclosed are test results of wa t er sample s t ak en from t he up per
leacha te Collection system on March 11, 14 , 16, 21, 22, 23, 24, 29,
and 30 . As indicated al l the effluent samp les from the filtration
sys t em con tained less than l part per bil l ion PCB.
Yo u wil l al so note that samples Nos . 301572 and 301573 were not
reported. The reason for this is that laboratory pure water analyzed
at the same time contained detectable l evels of PCB, indicating PCB
contam ination dur ing the laboratory analysis. Prior analyses of
sam ples from a spill site in Catawba County was t he cause of thi s
unrel ated contamination.
If you have any que stions, please let me know.
WHPjr:jj
Enc.
cc: Joe Lennon
Jim Sca rbroug h
0. W. Stricklan d ✓
Bob Helms
~
ice ely yo ur~~/ <.... '"' ~
~Kio· ~ '
mW . Phillip~
Assistant to the Secretary
North Carolina Department of
Crime Con trol .,,rWV~
& Public Safety
512 N. Salisbury Street P. 0. Box 27687 Raleigh 27611-7687 [phone]
James B. Hunt, Jr., Governor April 7, 1983
MEMORANDUM
TO: 0. W. Strickland -OHR Solid & Haza rdou s
Waste Branch
Robert E. Helms -NRCD Division of Environmenta l
. ...,-Management
M. C. Adams -DOT
Joe Lennon -Warren County He alth Director
FROM: William W. Phillips, Jr.'J,/~/fo.
RE: Warren County PCB Landfill Wat er Dispo sa l
Heman R. Clark, Secretary
Enclosed is a copy of the Leachate Collection and Trea tment System
Evaluation Report as prepared by the Unit ed States En vironmental Protection
Agency. As you can see it is very po s itive in its con clusions.
Also enclosed are copies of the EPA l aborato ry data sheets supporting
the results of the water samples taken on March 7 and 8 by EPA offici als.
These results had bee n sent to you on March 10 by Tom Karnoski but without
the accompanying data sheets.
If you have any questions, please l et me know.
WWPj r: jj
Enc.
____ .,. .·. curre~t .terms.·and_.,impo&ed''..C0n;;.i··:' ·'''•' <<-:. ,.,._.t ~ . ..:.~rr. t ·n~,•-i.•c;r#:,, ,.'; · -I
:~~:;1i:0;;tes;er1!ak ~= Governmeitt ·.·.
'
before he's ehg1ble for parole. . · · 1 .. ,·: -:· • :: : ·• • · : ;:-; -· •·• : • • • .
~PA says ordinary ll~e I tagged as • ,: .· ...
can destroy PCBs b. ··• · · · ·· , •. ·.· ·. . . .. .:
~~~~~GgatcI~i:el~~~:~~ .. · 1g .. w~t~.r .:. . :'. ..
an environmental problem, feder-of.· energy
al workers have found that ordi-·
nary lime appears to be an inex~ ·
pensive -and effective ·way to ------------destroy PCBs. . _Th_e_w_as_hl_ngt_o_n_Po_st ______ _
Tests are being done to deter-WASHINGTON -The federal
mine the effects of non-toxic lime gov_ernnient is "not only the · larg-
used in making steel, sewag~ est energy consumer but also the
treatment, acid neutralization nation's _biggest energy waster,"
an.din a~~~g calcium to farming according to.· a study released
soil. But 1rutial results are promis-Mond by th f't Alli ing, a U.S. Environmental Protec-ay . ~ non-pro l . ance to _Save Energy: ··
tion Agency .official said Monday •
.PCBs, · polychlorinated biphe-After several years of gains in
nyls, are heat-resistant chemicals ' e~er~ efficiency prompted by the
used as coolants in older electrical · oil pnce shocks of the 1~70s, the ·
equipment but.suspected of caus• study says, the governme·nt :re-.
. ing cancer and birth defects. sumed its wastefuf, habi'ts during
Their manuf actlire was banned in the ~eagan administration and
1977. They have been e~temely . · now uses more energy than it did I difficult and c_ostly to destroy~ , : · _·· 1 in·o19~; It. ~s L~v~y unlikely'.' that··::
L_1ouislana's governor .··. federal agencies··will be able to .·. comply_, with . energy efficiency ..
becomes a Republican targets set by Congress in a 1985 .·
. WASHINGTON -Gov. Charles law, '1CC~rding tp th,~ study._
"Buddy" Roemer of Louisiana The cost of heating and ~ightmg
said ~onday that he had become federal · buildings . and .. powering
a .Republican. the government's ·fleets of vehi-
'The gubernatorial campaign in cles and airplanes was $8.67 bil-
Louisiana promises to be a lively · lion in 1989, the last year for which
one, with former Gov. Edwin complete figures are available,
Edwards, a Democrat, and state according to the study.'·Even·in an
Rep. David Duke, a Republican era of low oil prices, federal
and a former Ku Klux Klan agencies are spending hundreds
official, also in the race. Republi-of millions of dollars a year more
can officials have denounced Mr. on energy than they would be: if.
Duke's candidacy. . they had made the investments
needed to comply with the la~,.
, Crand Jury begins the study ~ays. ·. .. , . : : . • ' . ' ~ I. I
l hearings on beatings . ''Fed~ral energy management
i ., .... ~Ja,9S ~GE~ _ A Los Ange• . lS a highly d.ecentralized effort
-.::,,•::_ .. :i_.·_.~7J.Couat)IJ~sr~~jury~·-q>ene,f~~:.~~~~~Xs~!f~~q -ai~~~~~le ...
. ; . . · b,ar~gs Monday into . the . P9.lice ...... ,, d . . , ::-:~·, . rewar ,, or
· .. · · .. beatmg of . a black· motorist/ and ecreases m" e~rgy use, " ~e
_ · ·-.• demands for the ·resignation···o( · study_ foun~. · Time and again m I Police Chief Daryl F. Gates con-. ?ur interview~,,, we heard that l tinued to mount with the repeated nobody cares. . • ·
\ broadcast of a · videotape of the Federal spending · on energy
beating. efficiency improvements declined
Thousands of calls have been · from $256.2 million·in 1985 to $44.8
•
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,, ~ ;:; UNITED ST ATES ENVIRONMENT 1\L r•F<OT EC TION AGENCY 0 ,,
\ cf "'1-, c:·' REG I O N IV _..L PHu\'-
April 1, 1983
RF.F: 4AW-l~R
3 45 COURTLAND STPEET
ATLA NTA. GEORGIA :io·:,65
William W. Phillips
Assistant to the Secretary
North Carolina Cepartment of
Crime "Control and Public Safety
P. 0. Box 22687
Raleigh, North Carolina 27611
~ar Bill:
I am forwarding to you for your files a copy of the Report prepared by
EPA Region lV Environmental Chemist Rod oa.vis , who evaluated the Leachate
Collection and Treatment System at the PCB Landfill in Warren County, NC
during our March 7-8, 1983 field trip. l\lso enclosed are copies of the
laboratory data sheet s showing the analytical results of the sampling
conducted during the first three leacha t e pumpi ng episodes.
The data for all three of these pumping t ests show that the treatrrent
system was effectively r~moving PCB's from the l eachate and thus the
system appears to be working as designed.
We would like to resample the system in the neat· futur:-e , aft er several
thousand gallons of leachate have passed through the sy~;t ern , in orde r to
again ve rify the effectiveness of PCB :rermval frcrn th1~ leachate stream.
We appreciated the ass i s t ance rendered by per sonnel fr:om the NC OHR Solid
and Hazardous Waste Branch and the NC [D'I' Was t e Water Tn,atment Plant
operators during this evaluation and we l ook forwacd to worki ng with them
again. If you have any questions concerning this r eport, please Lio not
hesitate to contact me at (404)R81-?.643 .
Sincerely,
/ --y //' ··--7 /''. / rAA~:;~Ce-
A. R. Hanke
Project Officer
rmerge ncy & Rented ial Resp()nse Branch
Enclosures
DATE
5LJBJECT
FROM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ATHENS, GEORGIA 30613
North Carolina PCB Landfill Collection and Trea tment System Evaluation Trip
Report and Data Transmi ttal
Hazardous Waste Section
Engineering Support Branch
To Al Hanke, Superfund Project Officer
Remedial Action Section, ERRB, AWMD
THRU: M. D. Lair, Chief
Hazardous Waste Section,
Michael R. Carter, Chief
Engineering Support Branch, ESD 7!
I accompanied Mr. Al Hanke, Superfund Project Officer for the PCB Landfill
located in Warren County, North Ca rolina to the site on March 7 and 8, 1983.
The purpose of the visit was to evaluate the effectiveness of the leacha t e
withdrawal and treatment system tha t was being opera t ed by the North Ca rolina
Solid and Hazardous Waste Management Branch, Envirorunental Health Services
Section, North Ca rolina Department of Human Resources .
(The landfill was designed with a leacha te coll ection system as a safety measure )
to prevent the buildup of hydrostatic pressure within the landfill. A s econd
leachate collection system was installed below the clay-liner and plastic liner
which separates the landfill from the natural earth. If any leacha t e were to
leak through the l a ndfill liners , it would accumulate in the lower sump.
Both sumps are
which connect
connected to a
accessed by inserting PVC pipes int o the 6-inch PVC conduits
the s umps with the outside of t he landfill. These pipes are
gasoline operated pump which is used to evacua te the sumps .
During this inve stigation, liquid was found in the upper leachate sump, while
the bottom sump was dry.
In order to dete rmine the PCB removal efficiency of the treatment system, and to
determine the daily expected flow rate , a pumping pattern was developed. The 3
initial pumping occurred during the morning of March 7, 1983 and proceeded for
approxima tely 1.5 hours before the sump became dry. The f low r ate was l e ss than
5 gallons per minute and the total pumpage wa s es timated to be 300 gallons .
Since the sand and charcoal filters had never been satura t ed with wa ter, it wa s
decided that the sand filter should be ~ulved shut to let the l eachate saturate
the system. After the pumping ceased, the va lv~ on the charcoal filte r W3S
closed and the valve on the sand filter \~as oywned . The sand filtered l eac hate
was then allowed to saturate ti~ charcoal filt e r. After the charcoal filter was
saturated, the valve was opened and the treated lea cha te was a l lowed to flow
into a clay-lined ho lding basin.
EPA F,><m 1370-6 (R ... 3-761
-2-
In order to check the PCB removal efficiency of the system, an untreated grab
sample was collected from the influent t o the sand filter and an effluent grab
sample was collected at a point before the water enter ed the holding basin.
The first set of samples were split with the North Carolina Solid and Hazardous
Waste Management Branch personnel and the analytical r esults showed very good
agreement. The state results were 0.4 ug/1 for the influent and 0.2 ug/1 for
the effluent. The US-EPA results were 0.34 and 0.28 ug /1, respectively.
The second pumping of the system occurred during the afternoon of March 7 begin-)
ning at 2:50 p.m. and continued for 32 minutes . Approximately 100 gallons were
pumped before the leachate sump became dry. Crab samples were collected from
the influe nt to, and from the effluent of the treatment system. Samples were
collected simultaneously for the US-EPA and a local citizens group.
The next pumping occurred on March 8, 1983, beginning at
for 20 minutes, at which time the system was pumped dry.
lons w~s treated. Grab samples were collected from both
of the treatment system for US-EPA analyses.
9:15 a.m. and lasted '\.
An es tima t ed 60 gal-}
the influent and effluent
The data for all three pump tests show tl1at the trea t ment system was effectively
r emoving the PCB's f rom the l eachate. Tlie hi~hes t concen tration delt:!Cted in the
effluent was 0.34 ug/1 which was the firs t leacha te treated in the sy&tem, and
was not necessarily representative of the system effluent. It should be noted
that only Aroclor 1260 was detected during this investiga tion. The l ast tw0
effluent samples contained 0.043 and 0.062 ug/1 PCB'~ respec tively. These con-
centrations approached the minimum detection limit of exi s ting analytical tech-
nology.
One trend not determined during the pumping was that of a n established influent
PCB concentration. The last sample collec t ed during the final pumping test had
a concentration of 2.8 ug/1, which wa s over e i ght times higher than concentra-
tions of the first and second pumping influent concentrations (0.28 and 0.25
ug/1). This could be an anomaly, or it could be the established level of PCB
in the water flowing into the leachate s ump. However, based upon the data from
the evaluation, the system appears to be working as dE,signed.
It was recommended by Mr. Hanke and mys elf , that the system could best be oper-
ated by pumping the sump dry and allowing approximately 1.5 hours to recover
before add,itional pumping is attempted. If the same basic pattern is followed
after a few days, the n a two-day-per-we..::k pumping schedule appears to be feasible.
All sampling and chain-of-custody procedur e s were in accordance with the
Water Surveillance Branch Standard Opera ting Procedures and Qua lity Assurance
Manual (Draf t, August, 1980). All labora tory analyses we r e in accordance with
the Laboratory Services Branch, Operations and Quality Control Manual (March,
1981).
Enclosed is a copy of the analytical data for the PCJ:i La ndfill sample!;.
YI~/!, /JMtA
William R. Davis
cc: Finger/Adams/Carter/Lair
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·····························~·································· •••f8QTNOT£S••• "UE:RBL *~•AVE~AGf VALUE •Nl•NJT ANALYZfO •NAI•l~TERrEP~NCfS ~J•ESTl~Ar~D v,Lut ·~•PR~su~PTJVE EVID~NCE o, PRES~~:E Of •K•lCTUAL VALUE Is KNOWN TO er LESS THAN VALUE GlvEN 01:•~AT€kilL ~AS ANALYZED FOR RUT NOT DETECTED, TH~ NU~~~R 1S THE ~INJWU~ DETECTJnN Lt~IT 1. WMEN ~o VALUE IS Qr~DRTtn, SEE ~ML8R~lNt c~~STITUEYT~. 2. co~sr11ur,rs Of TEC~~lCAL CMLORnA~F:. SPIPLE UID lNHYSIS llllHGV·-l~Xt' SYS!l':"I F:PJ.•P'Sn REG IV ATl-lt'-i5 GEOAGU O]/IC/83 ?tSTI:~otS/PC~•s lNO DTMER CHLORINATED COWPOUNOS OATl RP'PORTJNG SHEET WATtll S~~PLE N0,1 83CtS49 Sl~PLt TYPE! I~DEr PRD~ECT ~D,t 83•107 PROGRAW F.L~~~NTI ssr sou~ct, NC P:~ ROADSID~ SPILL CITY! Wl.RRCN!ON STlT[I NC &iATIO~ r,o,, ~~RRCN co, LA~DFILL t•1 rrrLUtNT S!ORtT 6!~Tl0~ NOi 5~~~Lr COLLr:r10~1 STlRT Dl.Tt/TI~t OJ/07/B) 1220 Sl~~Lr COLLt:1IDNI STOP DAT~/TI'I~ 00/00/00 0 ~OLLE:TED BY! R OlV!S A~Ct!VtD riio~, p DAVIS ll~PLE REC101 DATE/TJ~g 031oe,s3 204s A[C•D ~r, w ruPNRULL EHLl.:Dt ns ~i-iE~ISTI KLR ht.1,'!UCAL ~ETHODI Rt~1Rl<I t:;[i,A-:f(I Sl~PLE LOG VE~lrIED QYI T~8 •••:l.E,HR!<S••• n1TA VE?IrIEO ~Yt J~T •••••••••••••t•••••••••••••~•••e•t•••••••••••••••••••••••••••••• •••P-J'1TtlOT[S1•• ·~•AVER~GF VILU~ •W~-~nT -~ALYZFD •WA!•T~T~Rr~Rf.NCE~ •J•ESTiunr~n V~LUE tN•PRf~!!~PTtVf ~vID~~~~ 0~ PR~S~~:E Or ~~f£PIIL •~•ACTUAL VALU~ lS K~:J~~ JJ R~ L~SS TH,~ V•LUF GtV~N ••'••'.ATE:RlAL .. .\S a,,AJ,Yi'.C::'l F'-,P R;JT >JOT nE:r~crrn., TtH: llU••:>.F:ll Jc; T4f ~l~I~0Y o~rr::rr~N LTVJJ. 1 • •I HF. N "'r'\ V "'I, i If. l s ~ ,: p ') 'l H' f' • s <: r C ,n. 0 RD~'• F, CC ... s T J '! 1 ,. ,: Ts • 2 • C ,l" ST IT LIE: 'ITS D • T f-C .u, IC AL :: ,n ri ;> r., A~ E • RE:SULTS •JA l>IA NA "" ~, ... tU N /1. ,.,. l>IA NA NJ. ~-,.. Ill IIA 111,. O,QSU C,, li 0 I C,5 u (1,0~Li C'·,05U r,,~H h 5U q. "" ------.. --•1 A ( \ ••~••ANALYTICAL AE.SULTS••••• UIIJiS l0'"1P'.)UND eH~n UG/L LDRIN i!G II, HE.PHCHLJP 39410 ilG/L HE.PTACHL~R CPOXIO~ 39420 llGIL lLPHA•8H1. J9P' UG/L E',E;Tl•BHC 9 JB UG/L GA'l~l.•51-iC (LINDA.i-.!:) 39H0 '-'GIL ntLP,•BHC: 34r9 LIG/L f>.1'.)0SU~rlN I (lt,Piil) Hn llG/ L DI E:LDR N UG/L 4,41•DOT CP,P'•DDT) 39 00 IJG/L 4, 4. 1 •C'DI'.: (P,P1•DDt~ nrg UG/L 4,4'•00D (P,P1•DDD H io UG/L F.:~DR!N UG /l, tllDDSVLrlN II JBtTl) 14J56 UG/t, ENOOSULrA~ SU~ lT~ 4 ~1 ugn CKLJRDANt (TII: H~ ~IX!URE) /l 393~0 ti /!, P:iB•i:'.42 (ARD§L• R 1~42~ j9496 1.IG/L PCB•1254 (~RD LOR ! 54 9504 IJG/L P8~•1221 (AR0iL□ R 12]1) pue UG/l, P 8•1232 (£RD..,L~R 121 ~ 949~ L'G IL PC8•1248 (t~DCL1R 124b 3950 "&IL Pi-S"\t60 (i-.R08L□R H60~ ps9e U IL p._;,, .. J 016 (,_llO L:JR !.6 46 l UG/L I0.0.PHE:"~ 39400 UG/L E:liOF'I'-ALDf.HYDE: 34366 iJG/L r:oo ( DI OXH) )4675 LI G Ir, C>ILCIROE~II: /2 77'!84 !JG/ L lt.PHA•:1.1LDRD.ENF: /2 Ur.IL Gl.-l"L•C'-{LDPDi:i.E /2 llG/L 1 • l-l Y il el:) X Y CH I, DR D !: i.; E !tG/L Gr..i~t •CHLORL AN[ /2 pe10 UGI! r-..r..i;5.i.'.)i,AC.;LOI<. /2 9071 UG/L l LPiU •C •H,C'l?DHE /2 393{8 llG/L CIS•"'O'HCHLOR /2 3906S I' GIi, 11£2T>-iJXY:"'LnR 39480
···~···························································· • • • r Or, T •l O T E: S • • 1 •t•lVERlGF: VALUF: -~,-~o, lNALYZ[D •NlI•INTERrgR[1,CE5 •J•ESTI~tT(D VlLUE •N•PRESIJ~PTIVE ~VlDf.:~CE or PRfS~NCE or ~~ftQIIL -~•lCTUAL V~Lug Is KN□,;N T) ~E L~SS THlN VALUF GIVEN l(l•~t.TERIAL ,it\S lNIL\'ZtD r1R PIJT •JOT ogrr::CTED, THF: tJU"Bl!:R 1, TH£ ~!Nllll,UIII, o,r~C?ION Lt~IT 1, WFF.N NO v,i:,oe: IS l!e:PC~T.::r,, ~E:£ ~1-!l,ORD1>.NE co1,s1n1.1r,~JTS, 2, CONSIJTUtNTS Of T£:HNlClL CHLORDlNE, S~~PLE ll,D lHAE,YSIS ~lNAGt~ENT SYSTE~ ,:PJ•ESnt}•F:i, lV ATHENS Gf.ORGIA 03/10/83 PE:STI:•IJES/PCB1S f<',I) QTHE~ CHLORINATE:D CQ111,POt1NDS DlTl RfPDRTING SHEET -.ATER Sllll,PLr N011 RlC1550 SAMPLE TYPE! INDIN PROJECT N0,1 83•107 PR~G~A~ tLEUtNTI ssr S~u!sCF:1 1,: P:e RQADSID! SPtLL CITYI ~l.R~ENTDN !TAT~I NC ~r,r:ON 110,1 ~ARREN co. LINDVILt 1•2 JNrLUENT sro~~T ST T,JN Njl SAlol.PL! COLLE:1JONI ST~RT rA.T~/T!~t 03/07/83 1510 s~~rLE COLLE:r10~1 STDP l'~it/!IME 00/00/00 0 ~OLLECT~D ~YI R DAVI! FE:tlVED FRDMI R DAVIS S~k?LE fsfC1DI OlfEITIM! 03/05/83 2045 Rr.C1D RYI W TU~!IBULL SULEDt H! CHE••HTt %R l~-LYT1Cl[, ~!:TH~)I ~[ .... l.lll(I REMHl(I SAHFLE LOG VERirJED 8YI TB~ •••REl'lRKS••• D,.TA VfRir!tD PYI J~T •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• •••F"OOTNOT-.St•• •A•AVfRA~[ VALUE tN~-~o, A~ALYZEn •~A!•INTEArfQ~~CES •J•[STiwl.TED VALU~ •N•PRfSll~PTTVF: fVIDrNCE nr PRF"SENCE Of uAf!RilL tl(•IICTtJt.L VALU!: IS IPIJ,./N T'l BP: LESS !Hf<'< VALllF.: GJ\/F:PJ •Ll•UAir::RIAL ... hS /INALYZEr:l F"'1R !<!IT P.C,T nETECTF:n, THF: 'IU"P.P:P IS THE ~l~T~U~ OETE:fION LtMIT 1, WHEN ~D VALUE ts RfPORT~D, srr. ~HLORrlA~E CQNSTtTUEMTS, 2, CO~STITUE:-.iTS DP' re::f-l'll::klt, C~LORn~lllE, Fl!:SULTIS NA ~A "" 'll t;A NA '4A 0. IJl lliiA NA NA '4l Nl -a IJA 0,1tl 0 1 2 IJ o,1u o.1u o,1u 0,25 O l 1 LI -i. •n, "II. .. ----.. ... Ill \ •••••A'IALYTICAL Rr,SUL!S••••• UNITS CD"'-POUtJD STORt5 UG/L ALDRIN 3933 L'G/L '1rPTA~HLOR 39410 U G /I, HfPTACHLOR t?OXID!: 39420 UG/L HPfO,•RHC 39337 UG/1, R!:Tt •BHC p))8 iJG/L Gl.,.lol.A•EIHC (LINDAIIE) 9340 llG/1, OE:LU•HHC J4P9 UG/L ElilDDSULf"Af-1 I (ALPHA) 4 61 IJG/L DlE:yDRIN 39380 llG/L 4,4 •DDT ~P,r1•DDT~ p3oo UGIL 4,41•00!: P,P'•DD!: 9320 UG/L 4,4'•DDD (P,P1•DDD} J9310 IIG/L @:'IORIN 9390 UG/L E:"IDOSULrlN II (BETA> 34356 llG/L EIJDOSULrAN SULrArt HB6 UG/L ~liLDR~A-it cT;cH~ ~1xru~r> /1 PH UG/t, ... , ,, , .. 1·' ,,,, H96 UG/L ?:8•1254 ~ARQ LOR 1~54! H~04 UG/L Pi&•122l ~RD LOR 1 21 39488 ugn c-t-121 f•Ro tOR lj3i >9H~ ll / L ~s-" 4 lRO DR 4 1950 UG/L P!8•1~60 AFJCLDR 1 bO) )9508 UG/L P:6•1016 (AADCLDR 1016) 3071 llG/L 'I'OO.PHf.:lil[ i9400 UG/L El/ORIN lLDtHYOt 4H6 UG/L T:OD(OlOXIN) 34615 UG/L :i;~ORDt'<t /2 "liH4 UG/L AL 1-!A•CHLOPD!!:Nt /2 UG/L Gl~"il.•CHLDRDCNE /2 LIG/L 1•HrDRDXYCHL1PDtS£ ur,;t, Gt. ~ ""· .\ • C H LOR [1 A. N E /2 puo u::;/L ro,.-s-N□lilACHLOR /2 901i ljG / L ll,PHt.•CHLOROli;£ /2 HH UG/L ClS•'<ONlCHLOR /2 p::68 IJG/t, ~E!HQXY:I-ILOR 9480
SA~PLE l~O lNILYSIS MINJGE~E~T SYSTE~ f'.PA•E::'SDtRfG IV ATHE:1-1S C.F.:ORC:l I 0)/10/R) P[SI1:10£S/PC815 lND DTMtR CHLnR!NITED cn~PDU~DS DlTI RfPORTINC: ~~E~T wh!ER Sl~PLE ij0,1 83C1551 SA~PLE TYPEI INDtr ?ROJECT NO,t 83•107 PRJGRA~ [LEMfNTI ssr 68VRCt1 NC P~~ ROADSIDE !PILL CITYI •ARRENION STAT~I NC ~?lTlON 1,0., ~ARRCN co. LA~DrILL t•2 ~rrLU~NT 610~ET 5T T!ON ~DI SlWPLt COLLt:1IONI STl~I !l~PLE COLL[C!I0•1 STOP ~OLLtCTtD BYI ~ DAVIS llMPL[ RtC1DI OATt/Tl~t HH£0l HS "~t~!LHt llt,R k~lLYIIClL MtTMODI Rtl'lll:0:,1 RE!O,RKI OlTt/l!~t 03/07/83 1,,0 DAT~/TI~E 00/00/00 0 RECtivro rRo~, R DIVIS ~3/08/83 2045 RECD er, • TUR~8ULL SA~PLE LOG V[RiritD SYI T~S ••11Rt"'t..RKS••• OIi.TA. VtRirlED BYl J•T ··········••11••················································· •••"Dcl!NDTe:S••• •A.•lV~RAGE VA.LUE •"IA.•"IOT A'1ALYZEO •NAI•INTERFERENCES •J•ESTl~AT-.J VALUE ·~-pqF;SU~PTJVE EVID'-NCE or PRrSE"ICt 0~ WA.T~RTA.L H,•I\C'TllAL nLUE IS l(o;J,11,1 TD RF'. J,F;SS T!iA.N VA.LllF. GIVE"/ •'T•"AT►:RllL •AS a•HLYU;O rrJR EIUT llDT DE:Tl':CTf.D, THE '1ULIBER JS THE ~l'iIMU~ DETF;:TJQ"I LI"IT 1, ~HEN ND VALUE: IS ~~PORT .. D, ~f.E ~HLORDA~t CONSTITUtNTS, 2. CD~STlTU~~rs 0~ T~:q~1:,~ CHLGROA~E. HSULTS Nl 10, "'" ,a '1A IIA NA '°· NA Ill ,a '°· IIA Nl ,u Ml 0,0:20 01040 o,o:rn o,o~u o,o u 0,0,1 o102u II NA Nl ·-.. ... .. ----.. •• Nf>. \ •••••AIIALYTICAL P~5ULT5••••• U~ITS Cv~POU~O &TOHT UG/L At,ORIN 39330 UG IL HtP!lCHLC\l; 39410 UX/L HEPTlCHLOR EPOXIDt H'H U-,/L lLPHA5RHC )913i llG/L ~ETl•f-1-lC LJGIL Gl"IMA•t\H8 CLIN::>A"'E) HH0 UG/L DtLTA•f\M UG/L ENDOSULfAN I (HPHA) ri•l UG/L DI UDP IN UG/L ·••'•DDT IP,P'•ODT) 9 00 llG/L 4,41•0Dt P,P1•0D[~ 9120 lJG/L 4~t1•DDO P,P'•ODO 9 §o UG/L t ORIN 9 0 U GIT, [IIDOSULrlN II ~BtTA) 1:ni UGIL tllDOSULrAN !UL art tlG/L CKLORDAN[ CT5CH~ MlXTURt) /1 935 UG/L P"<•l242 A> 1· I 1>•2l J90 UG/L P~8•1254 ARO LOR 1~54) 1~504 UG/L P e-122~ ARD LOR 1 'l! 08 IJG /t Pi~•!?l ARO tOR 121 co~ UGI p~e-11,e ARO DR 1jf8 950 UG/L PxB•l 60 AR08LDR 1 bO! 9508 UGIL P~c•i016 APO LOR 1016 l0'A UG/L TuXl HtNE 940 UG/t, fllOR!N H,D?HYD!: ·r3u UG/L COD(O?DXIN) 4675 UG/L lHLOR0£Nt 62 7814 UG/L LfHll.•CHLOR [liE ~j UG/L GI. !"lo!A•C H LDF<'DEN £ UG/L l•HYDRgXYC~LORD[~t UG/L Gll.~~A• HLC'~DlNt /2 Ug;i UG/L TIV,t,S•NDIH.CHL,OR 12 UG/L ll,P H l •C 1-i LOR 01' Nt /2 pl:, llGIL C!5•N0NACHLOR /2 UG/L M[THOXYC+iLOR 900
•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• •••'0DlNDTES••• ,,-,v~PAGE VALUE .~,-~□T AN•LYZED •~AI•INTERrtRr~CES •J•ESll~ATE~ VALUE •~-P~ESU~PTJVE EVI~ENCE Or PR~SE~CE 0~ ~lT(RllL •K•ACTIIAL VALUE IS K~J~N TO 8~ ~~ss THlM VALU[ GIVE~ •U-~ATERilL ~AS ANlLYZED r~R ~UT NOT DEI~crro. THE MUUBER rs TH[ ~1~1~u~ DEI~:rJ~N LIUIT 1. WHEN NO VALUE IS ~EPO~TfD, ~ff ~HLnRDA~E CONSTITUE~Ts. 2. CD~STtTUE~rs o, T~C➔Nicai C~LORnA~E, SA~PLE A~~ lNl~YSI~ µlNlG[~ENT SYSTE~ EPA•ESDtREG IV ATHE~S GfQRGIA 03110/83 PESTI:1DES/PCB1S A~D OTHER CHLORINATED CO~PJUNDS DlTl RFPDPTING SHEET WATER Sl~PLE ND,1 63C15!2 SAMPLE TYPES INDTN PROJECT ND,1 83•107 PPJr.RA~ r.LE~ENT1 ssr SOUFCE1 N: PC9 RJADSIDE SPILL CITYI ~APRENTO~ STAT~I NC ST~TION I,Dfl iAR?~~ c~. LlN~rtLt I•J INrLU~NT 6TORET S!~i J~ ~~r SA"' P lE CO t, [, E: !I '.Hit S T.t RT C: H ti T ! 1~ E O 3 / 0 e / S 3 1 0 4 0 SA~~LE CDLLE:TIONI ST~P DlTf/Tlu~ C0/00/00 0 rOLLECTED BYI R DlV!! RECEIVEJ rROUf R DAVIS ~A~PL~ R~C1D1 DATE/!!ur. 03/08/83 204~ REC O BYI ~ TJRNBULL SEU!:Dt HS CHE"lSTI HLR l~AlYlI:&L ~ETHODI R[,.,1,tni:1 RF:-i A ~I( I Sl~PLE LOG VEQirlED ~YI T~~ ·••R.::UARKS••· nATA VtRirl[O PYI JWT •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• •••rJO!NO!ES••• •A•lVERA~F Vll,UE ..... NOT ANlLYZe:n •NAI•lNTERrtR£11CES •J•tST!~A!ED VALU-. •N•PRE:Sll~PTIVE [VIDE:NCE: or PRF,St~ce: 0~ ~ATERIAL ·~•ACTUAL VALUE IS K~O~N ro BE LESS TH~N VALUE GIVt"I •ll•lll.Tr,R!AL ,u,s AIIALYZP:O rn11 P.l!T NOT DETECTED. TJ.il". NU ... BF:R IS lHE ~I~l~U~ DtTtCTl~"I Ll~IT 1, WttfN Nn VALUE IS R>.PJRT~D, SEE tHLOROANt CON~TtTUENTS, 2 • CD"' ST I TU ;: NT S OF' Tr. C rl N T C A I, C LI l, 0 P !) AN E • RESULTS Pwl NA NA. NA NA NA NA I.IA ~· .. ,. NA NA. NI ,.,. NA ,.,. 0 SU 2~ 0,6U 0,6U 0 • 6 U 2,8 ~l !",U Iii. I.IA ... --■K -----· ..,, \ •••••AI.IALiTICAL PESULTS••••• UNITS C Qi,l,PQUNO aiiRn UG/L ALDRIN 191!8 UGIL 14£:Pp:HLDR UCi/L HEP ACHLOP EP~XIDE 94 0 UG/L AL,PHA•t\HC 9337 l!G/L BEH•BHC ppe UG/L GAM~l•BHC (LINDANE) 9 40 UG/L DELfA•B>iC Hp9 UG/L £:ND')SULP'AN I C HPHJ.) 1:.:1 l!G/L DltLORIN UG/L 4141•DOt ~P,P1•DDT~ 9300 UG/L 4,41•DD P,P1•DOE 9320 UG/L 4,41•0DD CP,P1•0D0 nio llG/L Et.ORIN 93 0 UG/L tl.lDJSULPd-1 I I CS!:TA} rr6 llG/t, ENDOSUt,rlN su~rATE • !A IJG/L ~HLDROANf CiE H3 wIX!URE) /1 9 5 U~/L •e•1242 (ARD~L R 1247) 9496 UG/L P:~•!254 ~ARDCLJR l~54 39504 llG IL P;~•1221 lRDCLJR 21 J908 UGIL p ~-1~32 lRD~LJR 1~3i 9492 UG/L P:8•1 ~8 (ARDCLJR l 4 psoo LIG / L p•~•1260 (1-ROCLOR 260 9501 UG/L P:B•1016 (J.ROCLJR 1016 34671 llG/L TJXAPl-1£1;( iHOO ~IC:/L tllDRIN ALDEHYDE J4lH liG/L lCODCDI'.lXlll) iH75 UG/L CKL,QPOE:N!: /2 H84 11::;;[. l LP HA• C f;L.,ORQE:N t /2 PG/L G/.'lWl.■CKLO~DE'-E /2 liG/ L 1-K~DRRX YCH:,JRDtNE UG/L GA~Ml• HLDFOANE ✓i pelo ilG/L TRA~S-~ONACHLDR / 90 l LIG/ L lLPHl-•CHLORDA~e: /2 H!:S UG/L C!S•NONI.CHkOR /2 PG/L W,[I"IOXYCHL, R 39480
··••&••························································· •••r,OTNOTES••• •A•lVE~AG>. VlLUt 1Nl•NOT lNlLYZr.D 1NAI•lNTERrtP>.NCtS •J•ESTI~lTED VlLUE IN•PR[SU~PTJVE EVIDE~CE o, PR!SE~Cf Or •K•ACTUlL YALU[ 18 KND~N TO Bt LESS THlN VALUE GIVEN -'lHII.HL •U• .. ATERIAL ~,s ANALYZED roR RIIT NOT DETECTED, TH~ NU~~ .. R IS TKE ~lNI~U~ DETt:rroN LIMIT 1. WHEN NO VaLUE IS ~~~DRTtn, ~EE !MLORDANt CO~STITUt~,~. 2, CONSTITUE~rs or T~C~NlCAL C~LORDl~E, SAMPLE lNO ANALYSIS ~lNAGEMENT SYSTE~ F:PJ•F'.SCltRtG H' lTHS:NS GEQRGH 03/10/83 PESTI:1DES/PC~1S AND DTH[R CHLDRI~ATfD CD~POUNDS D\TA REPnRTING S~Ef.T .. ATER SA~PL~ NO,I A3C1~S3 SA~PLE TYPF:1 JNnEf PROJECT ~□.I ~3•107 PRJGRAM ~LE~ENTI 5Sf SOU~CEI NC P:~ ROADSIDE SPILL CITYI RARRE~TJN STII.TEI NC STATIQl,I 1,011 WARRtN co. Ll~DfILL E•3 rrrLU~NT STORE? STAT J'I NOi SA~PLF COLLE:TIDNI STAR! DAT~/Tiwt 03/DH/B3 1105 SAMPLf CDLLt:II~NI STOP DATE/TIME OO/~G/00 0 CDLL[CTED RII P DAVI! R~CETVE~ fRO~I R DAVIS SA~PL£ REC1DI DlTE/TI~E: 03/08/R3 2045 R>.C1D nit ~ TURN~ULL 5EALtDI YES CHEwlSTt ~LR ~NALYTICAL ~gTHJDI P.!:~l PK I F.E"'-ARK I Sll."'-PLr. LOG VERIFitD BYI TBB ••Hl(WARKSt•• DA.TA. VE~IritD ~YI J~T •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• •••rODTNOT!:S••• •A•AVf.RA.GE VALUE •~A-•DT A.NA.LYZED •~r.I•!STERrrRtNCt5 1J•ESII~ATED VALlJ~ •••QRfSUUPTIVE EVID~NCE OF PRESENCE OF ~ATtRlA.L •K•A.CTUlL V~LUE rs Kt;'.)~N TO HF LESS THA.N VALUf GIV~N •U-~lTENIAL, -A.S A~~LY~ED roR ~UT NOT nET[CT~D, THE ~u~~~R IS !HF ~I~I~U~ DrTE~TIO~ 1-t~IT 1, ~Hf.~ NO VALUt TS ~-PoRt,o, ~~E ~HLO~~A~E co~STITUE~TS, 2, CD~ST)TIJE~TS or T~CH~lCAL CHLORnA~E, f:'tsULT!S NII. NA 'IA ..,. f.JA Nf,. 1'lA MA HA NA "'"' !IA NA NA NA "1A 0,02U 0,061.! o,O2u o,02u 0 • 0 '.t U O,Ob2 ~l02U NA. !;l --.. .. .. ·" --Nf>. . \ •••••ANALYTICAL RE!ULTS••••• UNITS C:i"'IPnllND 8T~RtT UG/L A~DRIN ~ no UG/l "t-PJACl-iLOR .9410 UG/L HEPTACHLDR EPOXIDE 39420 llG/L, 11.~PHA•FIHC 39337 UG/L e IA.•BfiC 39 338 UG/L GAlollo!f..•F\HC (Llh'Ol'-E:) pHo LIG/L, De:LT A•l'll<C 4~59 IJG/L ENOOSllLfAN I ClLPHl) 34H1 LIG/1, l)JE;LDQI'I J9l80 l!G/L 4,41•DDT ~P,P1•DDT~ 9300 llG/L 4,41•CDf. P,P'•DDt r~po UG/L 4,41•0D0 CP,P'•DDD 9 10 llG/T, F:t;ORI N )9390 UG/L E"DOSULrlN II ~BETA) HP6 UG/L E~DOSLILFA.N S~L Aft i· 51 llG/L CHLORDAN!: (H~H~ "!IXfUR!:) /1 9HO llG/L P:6•1~•l ~1-RO L R 1242~ ?9496 IJG/T, P:6• 1 5 AROCLOR 1,~4 :9~04, llG/L Pxe•l 22; ~uo;L::iR p21i J9488 UG/L P.~•123 ARD..,LOfs • 2 32 949~ llG/t, p:,:,,•1248 (f<ROCL'JR 1248) H50 UG/L P:B• I 2bO (AROCLDR 1260 ~ )9508 PG/L PC8•101ti (ARDCLOP 1016 ) l !, 71 ilG/L TOXAPHF.:NI!: H400 lfG/L ENDRIN l l,t')!:HYO!: HH,6 u::;n T:DD(DIOXIN) lo,s UG/L CHLORDtNr. /2 7 81!4 l!G/L A.LPKhCHLORDPI! /2 UG/f; Gl'il<,J•Cl-i!,ORDENE /2 IJG/L 1•HrDROXICHLJRDtNE: u::; / L, Gl'. II IJ. A •C KLORC ·, Nt 12 pg1O llG/L UkNS•N'.l'-'A~!il,OR 12 _9071 UG It, ALPHA•CHLD DA!-E /2 !9348 UG/L C 1 S •" 0 NA C Ii l,0 R /2 3,068 1.IG/T, 1-1e:rHon:~noR 3900
Ronald H. Levine, M.D., M.P.H.
ST A TE HE.t..L TH CiRECTO R
DIVISION OF HEALTH SERVICES
P.O. Box 2091
Raleigh, N.C. 27602-2091
January 17, 1983
MEMORANDUM
TO: Ronald H. Levine, M.D., M.P.H.
State Health Director
Division of Health Services
FROM:
a:~6 , ~W~ Strickland, Head
SUBJECT:
Solid & Hazardous Waste Management Branch
Environmental Health Section
Warren County PCB Landfill
The State of North Carolina has the responsibility to properly maintain
the PCB landfill in Warren County following its closure. These post-closure ,
long-term maintenance tasks are related to short-term, temporary work t hat
needs to be performed until t h e weather will permit the contractor to
complete construction. The following is a list of those tasks:
A. Access Control and Site Security
Procedures to control access and provide protection for the groundwater
monitoring wells and easily damaged landfill components need to be
implemented as soon as possible. The contractor is hesitant to put
up his final fence until he has completed the landfill construction.
This conceivably could be next April or May . Local residents currently
wander freely around the site.
B. Removal of Water from Leachate Collection System
Water currently inside the landfill needs to be removed immediately to
protect the integrity of the liner system. EPA permit conditions
specify that any water discovered in the leachate collection systems
be removed on a monthly basis. Sverdrup and Parcel's water removal,
treatment, and disposition system has been designed; but the equipment
has yet to be purchased or installed. A Class II wastewater treatment
plant operator needs to be provided to run the system legally.
C. Miscellaneous tasks that need to be performed by the contractor include :
1. Concrete pads for leachate collection pipes
2. Manhole covers for treatment works
3. Cover cap for leachate detection system
4. Final length of treatment works effluent line
James B Hunt. Jr/ · Sarah T Morrow. MD , MPH
STA TE OF NORTH CAROLINA DEPARTMENT OF HUMAN RESO.URCES GOVERNOR SECRET ARY
Memorandum
Page 2
January 17, 1983
5. Regrading of eastern portion of landfill to eliminate ponding
water.
6. Repair holes in top liner
7. Finish construction of final cap
D. Tasks whose financial responsibility has yet to be resolved:
1. Contingency funds (fuel, etc.) to operate pump stations
2. Any additional activated carbon that may be needed in treatment
works
3. Monitoring and analysis of treated water prior to land application
4. Final disposition of used (contaminated) activated carbon, sand
filter, treatment works structures, and surface impoundment liner
5. Stabilization and maintenance of access roads to groundwater
monitoring wells and stream sampling locations.
6. Materials to provide N. C. Solid & Hazardous Waste Management
Branch means to determine existence and depth of leachate
7. Carbon filter for gas vent if required by EPA
8. An inspection, at least once a week, to determine potential site
problems (i.e., erosion, vandalism, etc.)
9. Routine engineering inspection to determine subsidence, function-
ability of leachate collection systems, liner systems, etc.
OWS:TK:ct
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•· .;l:t.22 _;· Ui,JITEO STA ft::~: r~i'i°'/1-~(j;;::_ ::.:,,_ .·, , . .'!, I ,
' I r, \ ' ') ') ·l Q Q ') I\! U './ '-' '-l-..1u1..
REF: 4AW-RM
Mr. William W. Phillips, Jr.
Assistant to the Secretary
N. C. Department of Crime Control
and PUblic safety
512 North Salisbury St.
Raleigh, N. C. 27611-7687
Dear Mr. Phillips:
~~CEIVt°l;)~
291982
c:peration and maintenance of the warren county PCB landfill was agreed to
by the state of North carolina in the cooperative Agreement signed on
May 25, 1982. We have examined this question and the following will be
required of the State after closure to fulfill the agreement:
1. Monitoring, leachate collection, record keeping, notification,
and reporting requirements contained in the landfill's approval
under the TOxic substances control Act (TSCA), 15 u.s.c. § 2601,
et seq., as found in EPA's letters dated June 4, 1979, and
December 14, 1981;
2. Maintaining in good working order the access road, fence , and
gate as required by the landfill's TSCA approval contained in
EPA's letters dated June 4, 1979, and December 14, 1981;
3. Proper disposal of any removed leachate as required by the
landfill's TSCA approval contained in EPA's letters dated
June 4, 1979, and December 14, 1981 ;
4. Establishment and maintenance of vegetative cover: (1)
semiannual inspection; (2) repair of erosion and
reestablishment, if needed, of vegetative cover; and (3)
semiannual mowing of cap to prevent establishment of deep rooted
vegetation;
5. In addition to the requirements enumerated above, full
compliance with all applicable requirements under TSCA and each
applicable condition of the landfill's TSCA approval contained
in EPA's letters dated June 4, 1979, and December 14, 1981.
suggested additional items related to post closure:
1. Establishment of a permanent bench mark on top of the landfill
cap for future measurement of settlement;
J
2. Establishment of permanent bench mark adjacent to landfill on
state property in undisturbed soil;
3. Consideration of available security precautions to protect the
integrity of the monitoring wells, the leachate collection sumps
and standoipes! and vents;
4. General visual inspection of the entire facility to be done at
the same time as the leachate collection monitoring required by
40 C.F.R. 761.4l(b)(7) and the conditions to the landfill's TSCA
approval contained in EPA's letters dated June 4, 1979, and
December 14, 1981.
This letter does not alter or modify any of the Special conditions
contained in the Cooperative Agreement signed on May 25, 1982.
Sincerely yours,
~-------· ---------_ -_;~,,(~=,~~
Thomas w. Devine, Director
Air & waste Management Division
cc: O. W. Strickland J
Department of Hwnan Resources
Raleigh, N. C.
'I N orth C arolina Department uj
Crime Control .I~
&Public Safe ty
512N. So/isbwyStrcet P CJ 1~(), !/1>8:' ll.il,·uli:.!/611 7687 [phone]
James B. Hunt, Jr., Governor l krnJ ,, R. Clark, Secre tar')
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Mr. Al Hanke
Environmental Scientist
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
November 19, 1982
Re: Moisture Content Profiles
PCB Landfill
Dear Al:
Enclosed is a copy of the report from Soil & Materia l
Engineers, Inc. of soil test borings made November 3 at the
Warren County landfill . Also included is a copy of a report
of the same from Tom Karnoski of the N.C. Department of Human
Resources.
WWPj r:jj
Enc.
cc: Jack Reavis
11~~/
William W. Phillips ,
Assistant to the Secretary
Bill Raney /
0. W. Strickland~
Joe Lennon
DIVISION OF HEALTH SERVICES
P.O. Box 2091
Raleigh, N.C. 27602-2091
Ronald H. Levine, M.D ., M.P.H.
STATE HEALTH DIRECTOR
The following assumptions are based upon a t el ephqne conversation with
Dr. Dan Marks (Soil and Material Engineers, Inc.) on Novembe r 10, 1982. He
communicated to me the percent water by weight measur e d in contaminated soil
at 31 locations in the landfill as well as his personal opinion of percent
saturation of each sample.
(1) The free water surface measured in the l ea cha t e collection pipe a nd
sump area is not indicative of the saturated zone i n the landfill. This
implies much less saturated water (free wate r that will mo ve or migrate under
the force of gravity) exists in the fill than wa s previously thought. Non-
saturated soil was found at elevations below that of t he wate r level in the
leachate collection pipe.
(2) Isolated pockets of saturated soil exi s t s ca tte r ed throughout the
fill. This is to be expected due to the intermitt ent rai nfa ll that occurred
during the filling operation.
(3) The vast majority of all saturated soil exists in the Northeast
corner (sump area) of the fill. The volume of dra i nab l e /pump able water is
still impossible to determine or even estima te, with any hint of accuracy.
(4) An effective, but temporary, cover exi s ts tha t will prevent any
more infiltration into the fill by rainfall .
./
Jomes B Hunl, Jr/ Sarah T Marrow. MD . MPH
STATE OF NORTH CAROLINA GOVERNOR DEPA RTMENT OF HU MAN RE SO URCES SECRET ARY
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SOIL & MATERIAL ENGINEERS INC.
M)ISTURE CXl'ITENT PROFILES
~ LANDFILl., SITE
AFICN, NORTH CAIDLINA
S&ME JOO NO. 051-82-251-A
RECEIVED
NOV 17 1982
SVERDRUP & PARr.FI
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SOIL & MATERIAL ENGINEERS INC. ENGINEERING-TESTING-INSPECTION
3109 Spring Forest Road, Box 58069, Raleigh, NC 276 58-8069, Phone [phone]
t·Jover:iber 16, 1982
Sverdrup and Parcel and Associates, Inc.
2211 West Meadowview Road
Suite 114
Greensboro, North Carolina 27407
'v.. ,) Attention: Mr. Frank Rainey 'f '.J<_
Reference: Moisture Content Profiles
PCB Landfill Site
Afton, North Carolina
S&ME Job No. 051-82-251-A
Gentlemen:
Soil and Material, Inc. has completed the authorized soil test
borings within the PCO landfill site to determine the e x isting moisture content
profile within the disposed soils. Four soils test bo rings were drilled at the
following coordinates within the landfill site.
B-1
B-2
B-3
B-4
N-10310 E-9770
N-10310 E-9830
N-10163 E-9800
N-10050 E-9800
Soil test borings were advanced to depths of 18 to 25 feet
below the existing surface. Split-spoon sampling , in accordance with ASTM
D-1586, was initiated at a depth of 5 feet in eac h boring and continued at
regular intervals to the termination depth of each boring .
Visual descriptions of soils encountere d in the
are presented on the enclosed Test Boring Records.
contents are presented in tabular form and a re p r es ented
function of depth.
soil test borings
In-situ moisture
graphically as a
Because of the random nature of the PC B ladden soils which have
been placed in the landfill, estimation of the deg r ee of s atur ation is somewhat
difficult. However, with the exception of samp les obtt1 i11ed from 19. 5 to 20. 0
feet and 23 to 24. 5 feet in boring B-2, 18. 5 to 20. 0 fe e t in boring 8-3, and
9 . 0 to 10. 5 feet in boring B-4, the soil samples ,ippea r to be on the order of
60 to 70 percent saturated. Soil s amples obtained fror.1 the depths previously
indicated appear to be localized zones whi c h are ne,ir sa turation. These wet
zones are likely a result of rainfall whidi occurred a t tha t particular level of
filling or the inclusion of truck loads of soil tha t we r e obtained from wet
RALEIGH, GREENSBORO, ASHEVI LLE, WILMINGTOtJ. FAYE I T EVIi I E, CHAHLOTTE, NC
SPARTANBlJHC;, COLUMBIA, CHAHL l::S f ON MYH II I:. Ult,CI I ~,C
ATLANTA, ALBANY, GA-TRI-CIT IL:S. l,NOXVILLE TN --MONTG\JME:Hr' Al Cl r,CINN A f l, OH -ORLANDO, F.L
Sverdrup and Parcel & Assoc.
November 16, 1982
Page 2
areas along the roadway.
Soil and Material Engineers, Inc. appreci a tes the opportunity to
assist you in this project. If there are questions concerning this report,
please contact us at your convenience.
IMC.
·s-
N. C. Registration No. 9631
d¼t~~<-~✓-~--_;:; fc~-
Edward B. Hearn, P.E.
N. C. Registration No. 9520
BDM/EBH/bsp
SOIL & MAlEAIAL l:NGINE.EA5 INC.
North C arolina Depar1m ent of
Crime Contro l Jf7#
& Public Sa fety
512 N Salisb11ry StrC'el P () Rox 27687 Ralei1ih 27611 -7687 [phone]
James B. Hunt, Jr., Governor
Mr. Al Hanke
Environmental Scientist
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
Re: PC[3 Clean up
Dear Al:
November 17, 1932 Hernan R. Clark, Secretary
This is to advise you that the N.C. Department of Transportation
picked up an additional strip of approximately 600 feet along N.C. 49
in Person County today and delivered 12 truckloads of contaminated
soil to the Warren County landfill. This was a result of the recent
roadside sample analyses and brings the total to 7,223 truckloads
deposited in the landfill. The last truck completed at 12:20 p.m.
WWPjr:jj
cc: Jack Reavis
Frank Rainey
Bill Raney
Bob Jansen
Bruce Parker
Bob Adams /
0. ~J. Strickland v
Ted Mew
Joe Lennon
~~~~-
Assistant to the Secretary
North Carolina Department of
Crime Control ~~
& Public Sc1fett;
512 N. Salisbury Street P. 0. Box 27687 Ro/,:,i~il, 276J J 7687 ,✓ (W11 J:B -2126
James B. Hunt, Jr., Governor Heman R Clark, Sc,cierary
D
f
y
Mr. Al Hanke
Environmental Scientist
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
Re: PCB Cleanup
Dear Al:
October 27, 1982
This is to advise you that the private contractor employed
by Fort Bragg authorities completed dumping ~t 2:40 p.n1. today.
Since Fort Bragg began its operation on October 6th, 768 truck-
loads of the PCB-laced soil have been hauled to the Warren County
landfill from the reservation. Combining the state's portion
with Fort Bragg's portion, a total of 7,211 truckloads of con-
taminated soil have been deposited in the landfill.
WI.JP j r: jj
cc: Jack Reavis
Frank Rainey
Bill Raney
Bob Jansen
Bruce Parker
Bob Adams
0. W. Strickland
Ted Mew
Joe Lennon
fl; ta~~.
Assistant to the Secretary
ECO -... · .. , TEL N0.804
ST ATE OF NORTH CAROLI NA
OFFICE OF THE GOVERNOR
RALEIGH 27611
Jun 10,94 14:24 P .02
JAMH 8 . Hurn. Jfl.
OOll'tl'INOl'I October 20, 1982
An Open Letter to the Citi~ens of Warren County:
I _appreciated the opportunity to meet with community
leaders and members of the executive committee of the Concerned
Citizens of warren County on Friday, Octobar 8.
We had a full and frank discussion, lasting about
two hours. We did not a9ree on everything, obviously. But
it was a valuable meeting for me ~nd, I hope, for &ll of
you.
I told your representatives that I understand and
respect your concerns about the PCB landfill. Nobody wants
a landfill of any kind in their community. Your representatives
expressed your concerns in stron9, clear terms. They did
not hold anything back, and 1 appreciated their frankness.
In turn, 1 was frank with them. I told them that,
in my judgment, the State of North Carolina had no option
but to place the PCB-tainted material in a safe and secure
landfill. The Environmental Protection Agency would not
approve handling the material in place along the ~oadside.
I told your representatives that Warren County was
chosen for the site solely on the basis of technical reasons.
No other con5ideration whatsoever was involved.
I also said during the meeting thAt the State of
North Carolina does not intend to simply walk aw~y from any
responsibility once the landfill is completed. I made
several commitments to that end, and l want to spell those
out for you:
1. At the request of your representatives, the
state will aponsor a public meeting in Warren County at
which our agency officials, engineers and scientists will
review the safety features -at the landfill and respond to
your specific concerns an~ questiona. The meetin9 will be
held at 6:30 p.m., Wednesday, October 27, in the National
Guard Armory in Warrenton.
(more)
t. l-U
, ' .
Warren county Citizens
Page Two
October 20, 1982
2. The state will push as hard as it can for
detoxifica~ion of the landfill when and if the appropriate
and feasible technology is developed. We will seek to
establish a joint local-atate•federal working 9roup to
pursue this end. The State Board of Science and Technology,
which l chair, will have the specific responsibility for
pressing the Environmental Protection Agency to develop this
process and for monitoring research to determine when
detoxification is possible,
3. The state will maintain continual monitoring ot
the landfill. ThiG will include the monitorinq systems
included in the design of the landfill itself, monitoring ~f
the residential wells within a three-mile radius of the
landfill and checking streams and creeks in the area.
4. The state will cooperate with your county health
department in providing environmental and health monitoring
for those p&rsons who live, work or go to gehool near the
landfill. Warren Cou.nty Health Director Joe Lennon and
or. Ronald Levine, the 1tate's health director, will be
responsible for developing a monitoring program that will
guarantee that the health of the citizens in the area is
bein9 protected.
s. My administration will support legislation
prohibiting any additional contaminated soil from ever being
placed in this landfill an~ prohibiting the state from ever
placing another landfill in your county for any purpose. I
understand that Frank Ballance will be preparing legislation
along these lines, and we will work with him on this i11ue.
6, The State Department of commerce will make
special efforts to help Warren County att.act indU'ttry and
jobs. We will encourage businesses and industries to visit
the county and consider sites there for expansion.
The5e are the commitments I made on behalf of the
State of North Ca~olina. It is my responsibility to see
that they are carried out~ and I take that responsibility
seriously ..
(more)
ECO
-
TEL N0.804 798 4305
Warren county Citizens
Page Three
October 20, 1982
Jun 10,94 14=26 P.04
I know how controversial this matter has been.
Again, l respect your concerns. And r take them seriougly.
Your state government has a responsibility to you and to all
the people who live along the roads where the PCB material
was dumped, as well as all the residents of North Carolina
who might have been affected had that materiAl spread and
entered the food chain. The state is convinced, on the
basis of the best scientific evidence that is available to
us, that the landfill is safe and will remain safe in the
future.
But you and I have seen that scientists can disagree,
and their disagreements concern u5. That is why I intend to
see that the State of North Carolina keeps its commitment t'o
you, your children and your grandchildren to continue to
press for detoxificaton of the site, to closely monitor it
and to guarantee its safety for generations to come.
That is the pledge I made to your representatives in
my office last Friday, and it is the pledge I make to you
' now.
My very best personal reqa~ds.
North Caro lina Departrnen t of
Cri me Control ~l,
& Pu blic St1.fefv _,,
512 N. Salisbury Street P. 0 Box 27687 F?o/eiq/i 2/f! I 7f">i7 "· (G i9) /Ti 2126
James B. Hunt, Jr., Governor October 14, 1982 Hr!man R. Clark, Scuddry
c...
(J
Mr. Al Hanke
Environmental Scientist
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
f Re: PCB Cleanup
/ Dear Al:
The N. C. Department of Transportation picked up an additional
strip of approximately one-tenth mile on N. C. 53 in Nash County today
and delivered three truckloads of soil to the Warren County land-
fill. This brings the total to 6,443 truckloads hauled by DOT.
WWPjr:jj
cc : Frank Rainey
Bi 11 Raney
Bob Jansen
Bob Adams /'
0. W. Strickland ·
Ted Mew
Joe Lennon
){~;I, --..A'.,..,----,r Miam W. Phillips, r.
Assistant to the Secretary
North Carolina Department of
Crime Contro.l .1;-i.
· & Public Safety
512 N. Salisbury Street P. 0. Box 27687 f<olei9h 276 ! .I 7f~'37 ('J 19) TB 2126
James B. Hunt, Jr., Governor October 12, 1982 I ern<'ln R. Clark, S2u etary
0
Mr. Al Hanke
Environmental Scientist
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
p Re: PCB Cleanup
f Dear Al:
This is to advise you that the North Carolina Department of
Transportation dumped its last truckload of contaminated soil at
4:54 p.m. today. Since cleanup began on September 15 , 6,440 truck-
loads of the PCB-laced soil have been removed from 241 shoulder
miles of North Carolina highways.
Transportation of the approximate 11 miles of spill on the
Fort Bragg Military Reservation began October 6 and i s expected to
continue through the week of October 18.
WWPj r:jj
cc : Jack Reavi s
Frank Rainey
Bill Raney
Bob Jansen
Bruce Par ker
Bob Adams .,,,,.----
0. W. Strickland
Ted Mew
Joe Lennon
North Carolina Department of
Crime Control .la
& Public Safety·
512 N. Salisbury Street P. 0. Box 27687 Raleigh 27611-7687 (Yi 9j 733-2126
,James B. Hunt, Jr., Governor September 23, 1982 Heman R ~::lark, Secretary
0
/J
i
Mr. Charles Jeter
Regional Administrator
Environmental Protection Agency
Region IV
345 Courtland St., NE
Atlanta, GA 30365
Dear Mr. Jeter:
The Warren County PBC landfill permit allows the discharge of
treated rainwater that comes in contact with the PCB-soil mixture.
In order to increase protection of the public health and environment,
it is requested that the following modifications be approved for the
operation of the Warren County PCB landfill with respect to rainwater
management.
l. Utilize rainwater collected within the landfill for dust
suppression in the landfill.
2. Rainwater collected in excess of the amount that can be used
for dust suppression will be solidified by mixing in a con-
tainment structure in the landfill with a sorbant until no
free water remains and then disposed of within the landfill.
3. Rainwater collected in a major rainfall event that cannot be
removed quickly enough to prevent clay liner saturation will
be pumped through the carbon filtration system, discharged
to the holding basin, tested for PCB, solidified until no
free liquid remains and returned to the landfill. The hold-
ing basin materials will be tested for PCB and if contaminated,
returned to the landfill for disposal.
The procedures will decrease the potential for any PCB discharge
from the landfill site.
~~ JViO Jt., {Ji_
~~mW. Phillir:,~/,,
\iJWP j r: jj Assistant to the Secretary
MEMORANDUM OF MEETING -"-~ /~
1/c2i /t:!e
l :I: AUG 1 T
FROM: R. W. Boone
DATE: August 16, 1982
SUBJECT: PCB Waste Disposal Site
Warren County, NC
Job-Site Meeting
0' WASTE
A job site meeting for the above project was held at the site, in
Warren County, at 2:00 p.m., August 13, 1982. Attending were:
Bill Phillips -NC Dept. of Crime Control & Public Safety
M. C. Adams NC Dept. of Transportation
Bill Rosser -NC Dept. of Transportation
Brent Crisp -Jim Lineberger's Grading & Paving, Inc.
Jim Lineberger, Jr. -Jim Lineberger's Grading & Paving, Inc.
F. B. Rainey -Sverdrup & Parcel
R. W. Boone -Sverdrup & Parcel
D. H. Biechler -Sverdrup & Parcel
The meeting was held primarily to cover the details of placement of the
PCB waste material. After considerable discussion, the following method
of operation was accepted by all: The state trucks will end-dump the
material, beginning at the south end of the pit. Lineberger's will push
the material over the working face, levelling and compacting from the
toe up. The fill will progress northerly in this fashion and will be
built up to approx. elevation 342. As the fill moves north,
Lineberger's will place a layer of clean earth approx. 1 foot thick x 30
feet wide, along the N-S centerline of the pit, for the trucks to drive
on to keep their tires from touching the PCB contaminated material.
When the fill has progressed to the north end of the pit at approx. the
342 elevation (except for the northeast corner, which has been kept
lower to collect storm-water runoff), the placement of the material will
begin progressing southerly, with the state trucks staying on the 30'
wide strip of clean earth, and Lineberger' s pushing and shaping the
material to final grades.
Sverdrup & Parcel gave Lineberger's permission to use tracked vehicles
and sheepsfoot rollers for placing and compacting the PCB material, once
sufficient cover (2'±) is in place to protect the filter fabric.
Mr. Phillips spoke about the need for a security guard at the site, but
nothing was finalized. He will proceed with this if and when the need
~~
R. W. Boone
cc: File 7219
All Participants
Tom Karnoski V--
DEC 14 1981
honorable JaIIEs b. Hunt
GovE:rnor of North Carolina
State Capital
\
.l:<aleigh, North Carolina 27611
Lec.r Governcr f:ilmt:
.... --. rf
. ._,,\ l V ,
On June 4, 197S, ke<;ion IV gave conceptual approval, with cert.cin
ccnaitions, to the harren County, North Caroli.n.:., site as a chemica.l waste
landfill ~ author.1.zro in 40 CFR, Part 761. One of tbe conditicns wc.s t.riat
the Sta~e sut::(pit fin:il plans and SF,eCificaticns to this office for apprcv-d,
in writing, prior r.c the initiation of construction. These i_:,lam; anc
s:i;;,ec.ifications have been suw~tteo ana are hereby approvec subject to the
enclosed concli tions.
we colII!enu you anc t.t,e r:,any involved fer your deGicaticn to reaching a final
solution to this envuonn:ental problem basec en the tecnnclog'.l as it exists
today. If we car~ be oi: further assistanee, please let rr:-e knew •
.Sincerely yours,
/s/ Charles R. Jeter
Re.giona1 Administr;~cir
OlGr:les h. Jeter
l~icnal Administrator
Enclosure
cc: tn.r • .burley B. t1it.cht:.u., Jr., Secretary,
t.orth Caroline. Lepartirer.t
ot Crime Control and Ptblic Sciet.y
i<aleish, .Nort.'"l Ca.rol1.J.'7a.
0. h. s er icklanc, BeE:-ci
Solie & Ea.zaroous vJaste t,-:.anagerrent brar1ch
Er..vi.ror:n~nc.al i:iE:s.l tt Secticn
Def-€.!:urtnt of. hu;;,211 r-csources
.Givision of hec.lU1 Services
i:\aleisr:, 1-brti: Carolina
:..-r. Sara .t<.orrow
i..:Epc.rtr.er.t oi Hur.an ~sources
Livision of health Services
Rc:leigh, t-0rth Carolir12
DEC 14 19Si
Final Approval Conditions for PCB Chemical Waste Landfill in Warren County,
North Carolina, owned and to be operated, closed and post closure cared for
by the State of North Carolina on property formerly owned by Carter C. Pope
and Linda w. Pope, found in Deed Book 278, page 252.
I. Reference June 4, 1979 approval letter signed by John C. White
A. General requirement numbers 1, 2, and 5 remain in effect.
B. Technical condition numbers 1, 2, 3, 4, 6, 7, and 8 rernain 'in
effect. Condition numbers 9 and 10 have been satisfied.
II. Additional conditions of this approval are:
A. Leachate collection will be monitored monthly and collected
leachate disposed of properly, if required (761.41 {b) (7)).
Records will be maintained on file at a designated State office.
B. The operation plan will be followed, as approved (761.41
(b) (8) {ii)).
C. Records will be maintained and sutrnitted to the Regional
Administrator within 90 days of closure (761.41 (b) (8) (IV)).
D. The fence, gate, and access road shall be maintained in good
working order as long as post closure monitoring is required.
E. Report to EPA Region IV any instance of detection of PCB' s through
the rnonitoring program irmnediately.
F. Designate a State departmental person who will be responsible for
operation and for :post closure rrontioring prior to initiation of
construction (761.41 (c) (5)).
G. Notify EPA Region IV 30 days prior to transferring resF(Jnsibili~J
for operation or any change in ownership (761.41 (c) (7 )).
H. Monitoring Program
1. General
The parameters for ground and surface water rnonitoring for
this program are found at 40 Ci.4R ( 761. 41 (b) ( 6) ( iii) (A) , (B)
and (C)). Sample~ --should be collected and analyzed in
accordance with EPA approved procedures.
2. Ground Water
a. Background -Each well must be sampled at least three
times and the data submitted to Region IV prior to any
dis!?()sal. A minimum of one week should elapse between
sarnpling. At each sampling a minimum of two replicate
measurements for each value or concentration should be -
made.
(
(
/
b. During Operation -During operation or for a period of
one year, whichever is shorter, all wells must be
sampled monthly.
c. Post Closure -Each well must be sampled on a semiannual
basis.
3. Surface Water
4.
a. Background -EPA Region IV will designate surface water
sampling locations. These locations will include, at a
minimum, two (2) sampling points per surface water body
(one upstream and one downstream). Each of these points
will be sampled each time the background samples are
taken for ground water quality.
b. During Operation -Each of the designated surface water
sampling points will be sampled monthly during operation
of the facility.
c. Post Closure -Each of the designated surface water
sampling points will be sampled on a semiannual basis
during the post closure period.
Changes in Program
Upon a determination by the State or EPA that containment has
failed, the sampling frequency of either ground or surface
water sampling may be modified. EPA may also require the
installation of additional monitoring· wells and an expansion
of the list of monitoring parameters.
5. Well location and screened elevations shall be coordinated
with EPA Region IV in the field or by telephone as
appropriate.
I. Undisturbed samples of the soil liner will be taken and the
laboratory permeability determined and submitted to EPA Region IV
prior to any disposal (1 sample per 25,000 square feet of liner).
('-s s a I "
II
Lln•to•d StJI~<;
tnvuonmcntJI Proh!C!IOA
Agency
June 4, 1979
4AH-RM
Ut~quu, -~
J,4~> Cc11.·1l.u1tt !~,,.-,.: Ni..
All.int,, · ,;,. .~OJOi:!
Honorab 1 e James IL llunt
Governor of ::orth Carolina
State Capitol
Raleigh, North Carolina 27611
Dear Governor Hunt:
/, i ,If 1.1, I '-1 ( ~ ••• ;t ,, :,1 f"I-. • f ;' ?. t
~ .. l,·.·.~·.·.1; .. n1. ,._ ,::11 C.1tn:,P,I
'.'-,qp(h ,-·,u~i1t· 1. ff~fHH•',·,1~1•
On February 17, 1978, the Un ited St.iu~•; C11·:\r-or:;::~ntJl ?rot'..:cth··
1\13cncy ([P~\) published final rr~qulc1t i on::; in t:,2 F,:,Jeral P.c'iis':er
(43 FR 71S0-7164) on Polychlnrinatcd Bi;;i:f;!:/lS CPt3~Ts-Gosn_l_
and Marking. These regulJtinns w •n' ,1:::r:l!r;~.~ by t:,,_. r~ • ..... r ,:1 ?·.:,!l-:~::r-
(43 FR 33918-33920) Oil /\u1•11st L, 19 ::~. J::,.:-,i.; rqt1lc1L.i i)-:;·s-pr;0·:1i;:i'(:~-·-
the di sposJ l of PC!3s .:it J11•: •_; i tr. nn t ;q,:in,, .. ,i ~-,, th(: Ef',;\ ,1 ft.tJ
/\cril 18, 1973, and these rrqu1iltio;1:; r ,·<11J 'r,~ t,,1t t'l? cv:n0r 2n:./'Jr·
operJtor of J chemical 1·1ilSte Li ncJfi 11 w.•:·,: :-u r :_fi,~ ,i i;;,-os.!1 of r::,::
suhutit infon;;ation in accord,;11,-e 1-iic !1 S"'-::~:,-,11 7n J.,;1 , Cr:c:::icc:1 .L ,~e:
Landfills, to the Regional Ad:,1i nist 1·c1tnr ~u rc:•,1i;...'.·1.
tn accordance with the al.Jove rr.fr:rf':1i:r1'.I ,·1 •1:ul.·1:.io11 s , .1 fon::,1; a;Jr:1:-
ca~ion 1'f'as filed \'lith t!,is office dJu:d i>~':!:i10~ P, 197'.':, ;-(;11uf's:inq -
approval of a site in Harren Cuunty, ::,ir:h C.iro l inJ \-,hich \•1i11 hi:·
Ol'med and opcrJted by the Stat~ cif ;:,,r~:i C1 ,·ol in.:i Jnrl us~d ;-01· ~i-~
disposal of PCI3 contaminated soil frr,1:1 Uie riigh•da/ shoulders ii! tl1e
State and from the Fort Gragg 111i 1itJry r0.s 21--1,1tion. t, public hl:lring
wJs held in \-1.lrrenton, r~orth CarolinJ on J ,:nuary •L l'J79, fr.r ~• .. 1b'.ic
input. Tne heuring record l'f'<Vi held ui•e~1 u,,t.i l J.:u:uary 12, 197:i, for
.:iclditional written public input into tl10. decision process.
Th<: result of EPA's revie1'f' i s th.:it t!H' riro;<,sc!d site will flied a11 the
technical requirements for a ch emiCJl \·1~ .... tc i',rndfill JS requfred in
Section 7Gl.4l(b), when cons tructed in ~c c.,,-dJncc \·lith Utt! enclosed
c:o,;di tions tot.his approvJl except fu r t he fol1o\"in<J:
(1) 761.4l(b)(l)(vi) ";\rtifici ,:J li!w:· U1ickness 30 :nii. ur
great~r."
(2) 761.-'il (b )(2) "T he site sll,1 ;; i.,,
11ec1 r~s t g rounJ11a te ,."
i iH.;sr~ ttu-cc rc1 1uircn:0.nt~. ,J ,~t~ !:~:r (~!l'I ·::.:!·,·.,.: ::-or ·~:ic' l·:_-1..1s1H tJ c1·1£.::1 i n
th,, .::1:close.J tcch11icc11 n ":it"::. 'f,,1;r :·1:":_ic.: I.;; ·:1,1i•1c r.11c lc,:r;1 :'...c:
UJ '1<:ction s:1st1~rn undcrnc ,1t!1 ~::c ]ii::.•:· i5 '~e:;;i~.: :·r,r tile re2s ons
st~ t2J in t :10 enclosed !.e~!i:: i cc11 i·r":, r-·.;.
. 2-
Accordingly, the W.:irren County. No,·t11 C,,n;! ,;;., -;1:.c ,.; C' .;•.-n1ed and c;;eratcj
by the State of r·lorth Carolina for t111.~ Jis,;0:,i: •.,~ ;:-c:, CG .. ~::,·1 i1Jt:::d !1 igr.'.iJ.Y
shoulder soil is hereby approved ~,,lncct : , :_:,,~ •.:n::1 :';-~,J ,:,~nrji t~uns J::; a
chemical \·1aste landfill as authori;:ed i1! .. ;,) U:·:, ?,1r~ 76L lt i:; understood
by EPA and the State of North Carol in.:i thJr. U;i'.:i Jppro:.::: i,; ba·:~-: :n the
conceptual design only and thJt the finul con-:;t:·1;c~i1r. plo:1s ;::nd :,pecifica-
tions (if any) must be approved in writ~;10 b:,· r.i1i:; office ;.i,ior tJ
the initiation of construction.
This approval is net to be construed to be apprr,v;1 hr incineration,
storage, marking or records and monitoring, ~-;(? ~,ill continue .:o work
with you in any way we can to expedite a puhl ic health oriented and
environmentally sound solution to the PCB problem in i·iorth C~rol ina.
Sincerely yours,
. C]~~/h~ .. ~ ,,
~~ional Administrator
Endosures
cc: Herbert L. Hyde, Secretary
NC Dept. of Crime Control
& Public Safety
Kl rsL.:i 11 Sta ton, Chief
Sanitary Engineering Sect~ori
Divis ion of Hea 1 th Services
NC Dept. of Human Resoufces
Jerry Perkins. Head
Solid Haste & Vector Control
N.C. Dept. of Human Resources &
Division of Health Services
~.··--~-,'._,. 1/
'_/
-~-
;::.
:; Approval Conditions fo,· tile PCJ Ui,1ms,:i1 Site ().-1:,ed
And Operated by the St,1tc of f!orth Cc:ir·n1inJ in
Warrer. County, ~lorth Cz.r:Jl inu on the Prooi::rty D2scribec.
in C--overnor Hunt's Cec:::H:b~r 12 , 1972, i,ppl i::.:1.:ii..ln a:; C.-ff_-:d
by Carter C. ?8;Je ilnd Lin-:!J '.!. f11i ~c round ir. De~d Bc~f: 278,
Pase 252.
A. General Requirements (a 11 r~;:;orts s ho,.:l d ::;: sent to the Re;iona 1
Administrator, Attention: J.:u;:es H. SCJrbrouc;il):
1. Notify EPi\ at least tv,o we~:<s in ,.1lJ -.•:.11 c-~ of the expected star't of
-construction.
2. Notify EPA at least t·.·.o ·.-;eeks in c:dvJnce of the initiation of disposal
of PCB waste at the site.
3. Send EPA the data \-1hich ~s r21uircd t:y 43 FR 761Al(b)(S), monitoring
systems for baseline ar.ct Oi1 tne frr:quencics sp>2cified.
4. 1-iaintain re::ords as .soeci fied in 43 Fi~ 761.45(b)(3) as 'appropriate
and submit ,·iithin 90 9~ys after cl 1J SJr'~ of the site to the P.egional
Administrator. ·
5. Advise EPA illliledii:tely of any c 112n<3es, .:ilterJtions or divergences
in the operational and manageriJi ~olicics and procedures as out-
lined in the documents submit.:rd i ,1 :.upport of 1:he application.
6. Report to EPA_any instance of de:ection of PCBs through the ~onitor-
ing program i1T1nediately.
B. Technical Conditions of Approval:
1. The one foot of cover to be placed only on the middle 20 feet to
30 feet of the first lift of wa~te to preclude shunting any infil-
tration to the side walls.
2. A soils engineering finn shall be employed to provide quality control
during the construction of the'clay-silt liner.
3. Engineering expertise shall be provided by the State or a consulting
firm on-site during all operationr; to provide and assure conformance
with the final plans. Such assur,rnce Shull be furnished to the
Regional Administrator .:it the co:11pletio11 of the µroject vdth a copy
of "as built" plans.
4. A record sha1l be plJccd on t :1c r,·::wT ty deed -~h ich s tipu lates
the particulJr bour1 d,1ry of t !ie di~,;,,1·~.Jl ,w::,1 .J nd ·.-,as te cofl tc1incd
therein with the associ 2.t 2d .,.,a ste c l c·✓Jt i on s .
5. The State shall maintain an "J 11 ·.-11~,1 1.:,r•r" -1 c cess rnarJ i ndr:fi,1itel y
to pem.it access t.o t he s i te a nd co ,,1cil1 t ,He cc ll ection of :;c1n;ples
from ~;onitoring w~li~.
-2-
6. Waste will be corn~acted as ~uch 1s prJcticJble with tracked equipment to ;ireverit settler.ient aft~r c1osu n~.
7. AppropriJ te eros~on control :;:c:1s~res sh<1\l be applied during excava-tion, filling and after closure to minimize erosion.
6. Trucks us2d for hauling the waste ~u~t be covered.
9. The fina1 J1a;,s .3nd :,;:ei:i fico.tL;ns ( i ;-Jny) shall be submitted to the Regioncl Ad;71inistr.::tor (f\tte11tio11: J,1111es H. Scarbrough) ,rnd written approval received prior to the initiation of construction.
10. A leachJte collection syst~m with J sump Jnd access which will allow pumping out of ~nv collected leachate is required above and below the clay liner.
J .
: I
I I •
I
,.
(
·'
December 1, 1981
Mr. Frank Raney
Sverdrup & Parcel
Consulting Engineers
2211 West Meadowview Rd.
Suite 114
Greensboro, North Carolina 27407
Dear Prank:
Enclosed are EPA's comments on the proposed design for
the Warren County P.C.B. site. If there are any questions
please contact me at [phone].
WLM:sms
cc: Bill Raney
Enclosure
Respectful l y,
William L. Meyer, Environmental Engineer
Solid & Hazardous Waste Management Branch
Environmental Health Section
,,,\,,f.u :•r4,.e
.... ,,::r, .r-y
~:~\¥ti(~ UNITED STATES ENVI F~ONMENTAL PF~OTECTION AGENCY
~1~._ ............ :-:-~~ .... -~.,,>-"' .t-
1-r,IL ~r.o·1<5~ • R E'. G I O r'-J I V
34!, cour<TLAND STH£ET
fo10V 1 0 1D81
ATLANTA. GEORGIA 303():;
REF : 4.AH-Tu'-1
Jvl.r. O. W. Strickland, Direct.or
Solid & Hazardous Waste Management Branch
Department. of I-Iwnan Resources
P.O. Box 2091
Raleigh, North Carolina 27602
Dear Mr. Strickland:
On March 31, 1981., EPA res_ponc1ed to your request for couunents on the
preliminary plans and specifica tions for the pro_fX)sed cl.1emica.l ,,.iaste
landfill in \·larren C' . .ounty. Several weeks ago we received the consulting
firm's resJ?Onses to our comments. We wish to summa rize the adequacy of·
these responses!
(a) Placement of sump; adequute.
(b) Perme2tbility of liner; cldeqt1c1te.
(c) Slope of pit.; adequate.
(d) Vandal protect:ion; c:i.c1eg_uate, provi de~ the <-lrea is :co~it:i.rn~ly
patrolled ( this should be docwnented in the post clo~.;ure plan) .
(e) Silt pond contingency; inadequate.
Region IV b:~lieves that if PCB is found at all, it wLU })2 found
in the sediment ratJ1e r than in the water layer. Consequently,
the sediment should be sarnpled prior to close out in. a manner
which will provide a representative sample; th2 sedime nt f;hould
be analvzed and handled in accordancewiti1 40 CFR 761. lf the .,.
sediment shows contamination, the 1,,;1ater layer and liner s11ould
be handled :i.n accordance with 40 CFR 761, unless it can be
derronstra: · ·, that the material is not subject to regulation
urrler 40 C . ;< 761.
( f) Lining of holding pond area; adequate, provided tl1e consultant
furnL:hes the following information with regard to the
construction of the liner:
(lr Assurance t11at no he:wy equipmen t will enter the s:il.t pond
are<.1 during the operoting l:i.fe of the ,mit.
(2) Assurance thc1t th.~ 01:x,,rating life of the unit Nill not
exceed the capacity of the one fCX)t liner to prevent
leakage.
-2-
(3) Quality control during c...'Onst.rcctior1 will 1::>e excercist<l such
tlu:,t the liner minimum thickness wi1r be one fc-.ot, anc1
~:ix_i_rnu~~ permeal-;Lllt.ywi ll re l X lo-/ cm/ sec.
(g) Location of c:tdditiorul m_onitorin~1 \,1cUi adequate, provided it is
designed and l·x:atc-oe1 in a mmmer \•;hich will :i.ntercept Sf)uthward
groundwater wove.11ent. Boring data should be provided_ in the
final report to verify t11e location of this \,1elJ..
(h) Grouting of annular space; adequate :i.n part. 1I'he co:rn11ent
regarding s0.asonal fluctuation of groundwc1ter eleva.tion has not
been adguu.tely addrosss>d.
In the latest transmitt.alr we c1id not receive a copy of the post closure
care progrc:tm, which \.:e requested in our March 31, 1981 letter.
"11"1erefore, we are asstun -i.ng that _ this plan \,lill be submitted. with the
final plans and sp2cifica-t:ions at some 1x->int in the future.
If we can be of further ass istance to you, do not hes:i. hrte to contact me
at [phone].
Since re] y yours, .
,,/4£~-.l-~~-~-{?[~
::im2s n. Scarbrou9h, Cbicf
hes:i due:1ls Man0.9e1.1ent B.ranc11
"'
..
RUFUS L. EDMISTEN
ATTORNEY GENERAL
~tuft of ~ort~ ©nrolina
c!Elcpnrtmrnt of 3Justicr.
P. o. Box 629
RALEIGH
27602
UL 3 198
MEMO
TO:
FROM~
RE:.
1 July 1981
Bur'ley Mitchell, ~~t~1 Meyer, Dave Kelly r Bob Adan~s,
John Freeman, Frank Vick Barney O'Quinn, Page Benton I
Bill Raney ~
Warren County v. State (PCB)
Attached for your information is a copy of the brief
filed in support of the State's motion for summary judgment
in the Warren County PCB case. If everything proceeds as
quickly as possible we may get a decision by the end of the
summer.
/ck
.,,. ~ North Carolina Department of Natural F Resources &Community Development
James B. Hunt, Jr., Governor Howard N. Lee, Secretary
MEMORANDUM TO:
FROM:
SUBJECT:
Mr. Jerry Perkins
Dept. of Human Resources
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
August 23, 1978
Solid waste & vector Control &!---~
Robert A. Carter, Head G ~ --==--
Water Quality Operations Branch
Soil Analysis
Samples were taken under vigorously controlled conditions at four locations,
two in Johnston County, one in Chatham and one in Granville. These results are
as follows:
Sample Location Type PCB 1260 PCB 1242
Johnston Grass 68g/kg
0-1" soil 6.9g/kg J) J
l"-2" soil 25~kg
2"-3" soil 49mg/kg
311-611 Soil 4mg/kg
Johnston l"-6" soil composite l.6mg/kg
l"-12" soil composite l.3mg/kg
Granville Grass 18.7g/kg
0-1" soil 4.9mg/kg_ 5.7mg/kg
l"-2" soil 2.3mg/kg J_ (r 2.6mg/kg
3"-6" soil 0.48mg/kg 0.4mg/kg
Chatham Grass 207g/kg
0 -1" soil 2.8g/kg
l"-2" soil 40mg/kg
2"-3" soil 0.4lmg/kg
311-611 soil 0.93mg/kg
Three inches of material should be more than adequate to bring the concentration
of the soil-grass mixture to less than 500 mg/kg. If you feel additional soil samples
are needed, let me know.
RAC:mnf
P. 0 . Box 27687 Raleigh, North Carolina 27611
An Equal Opportunity Affirmative Action Employer
1,pril 11_., 1981 ·
MEHORANDUN
'.fO: Bill Heyer
FROM: Charles Gardner
SUBJECT: Review of Plans and Specifications
· Pen Disposal Site
Wa rren Co. Propos ed
As request~~d,.. ·w2 have reviewed the plans and spee:if:ie<1tions prepm:ed
by Sverdrup and Parcel for. the proposed PCB waste disposal s:i.t:e in
Wan·en County. The plans are dated 1/30/81 and we r e received by us f:co:n
your office on J/3/81.
I have some concern that a seasonally high ground wate:r. table eoulcl
be at or above the proposed pit bottom. Acc0rding to the · dnta pn)sented
oa the plans, the measu:t'c-!d groundwater levels arc roughly 10 :f: e e t below
the proposed plt hotLom; the date of the ground wa ter readings i s not
noted. ThE! normal range in seasonal variation fO): upland l?:i.eclmont
ground wate:r: leve ls is 5 to 10 feet> and variations elf; rnueh as 25 fc~ct
have b e e11. ob<.;ervec:. I unde:cstand that there is an ob[;ervat:i.on \,;rell over
one mile away that shm,s his torical variations of only a very f ew feet;
in the pj_cd1:!oi1t, pJ:oject ion fro:.1 that distance i s CJttcs tionnhJe, In the
absence of long term site specific ground water data~ you 1nay wa nt to
consider instaliing a cove red drain trench and coJ.lection/moaitoring
point extending from the northwest corner of the pit bottom to about the
308-310 foot ground surface contour as a safety measure. Accon1Jng to
the site topography shown on the plans, this trench would be about l,OO
feet long. Alternatively, a short 11dea<l--end" trench could be e x tc:mckd
about 50 feet out from the northwest corne1.· of the pit and could be
extended later if monitorii:1g wells indicate a ground water level problem
is developing.
I am attaching some hand written comments from H:lll Weldon, our Chief
Engineer at the time of this review. These c~mments apply mostly to
erosion and sediment control considerations. It is emphasized that
additional details on erosion and sedir1~ent contr ol will he needed prior
to construction. The more detailed plans should be forwarded t:o John Holley,
Land Quality Regional Engineer, at least 30 days prior to beginn ing
construction. Mr. Holley ,.;ould be glad to meet with you or your engineers
to discuss the details, at your request .... ~---·-
Thank you for the oppo::'.'tunity to review this information.
CIIG:gf
cc: Steve ConraJ
Harlan Br.itt
. John Holley
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UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
REGION IV
345 COURTLA ND ST Rc:ET
A"J"LANTA. G EORGIA 303 65
MAR 3 1 1881
REF~ 4AH-Ri.\1.
Mr. O.W. Stricr.land
Solid & Hazaraous Wa~--:.t e Management Branch
Deparbl-:ent of Ht: · ,n Resources
P.O. Box 2091
Raleigh, North Carolina 27602
Dear Mr., S tr ickl2nc1: .
EPA has received and reviewed the preliminary plans and specifications
for the Warren County PC'B Disposal Site, prepared by Sverdrup and Parcel
Consulting Engineers •. A copy of the comments is enclosed ..
We must have a copy of the facility post-closure care program. It shonld
include details on ground water monitoring, ana the collection and
management of leack 1te .
Should you have any quest.ions regarding this matter, please contact
Emilio Gonzalez or Don Hunter at [phone].
Sincerely yours,
zj~,t,/✓ ~-
,es H. Scarbrough, Chief
:.siduals Management Branch
Enclosure
A'ITACHi.'1f~l\"1'
The preliminary plans anc1 ::;pecifications for the \·~arr0n County Dis;x>sal
Site has been reviewed as reqi.1ested. The following c.1re our comr:ent s;
(a) The pipe used for removal of l eachate from tJ-,.e leachate detection
_system suITt_P should be buried in the compacted aggregate layer, and
not placed on top. The drawings and the specifications for landf i .i.l
construction do not s eem to agree.
{b) 'I'be clay liner permeability must be 1 X 10-7 cm/sec or .Less.. ~l'he
specifications does not make reference to this.
(c) We suggest a minimL1In 2% slope for the bottom gracJe of the disposal
pit£
(d)
{e)
(f)
(g)
Vandal protection should be· provided for the gas vent and the
leachate collection pipes. · l\bne is provided as shown on d:r a,v:i.ng
nurnl::JE:r eight.
Section 5. 6 r eads, "If contaminated water is found :i.n the silt pmi.l,
the s ediments in the botto:n of the pond will also be p1aced the
1.:mdfill prior to pit close out. 11 The sedimen t should be an3lyzed
toe~ 1 not the water only.
Baf:ed on bore hole log data, it appea rs tha t less than favora ble
p,2rn12ab:i.lit.y conditions exits in tl1e pro}.X)secl. bold:i.n~ po nd ar~a,
tl1Prefon': thi.': holding pond should b e linc-·d to prevent any
contarnina ticn of the ground water.
Ground Water Monitoring -There has not been a detailed 9round water
study at this sitew Three borings intercept the water tc"lble and are
not adequate; in themselves to thoroughly characterize the
configu1'.'ation of the water table below the site. Well number one
probably can serve as the uwradient monitoring well. The problem is
adequ;:,tely IT!-Onitoring all downgradient ground water zonesr Wnile
we lls number two ,:md three monitor ground water zones that are in
fact downgradient from the disposal area as required, it appears tJ1at
anoth?r downgradient zone is left unmonitored. This situation is
defined in the following manner. Well number one is located on a
narrow east-west trending divide which terminates in a blunt
north-south trending face facing west. It is within this featm:e
that the dis-cosal area is located. '11he indications are that there is
definitely g~ound water f:low north from the divide (monitoiea by well
number two) and west from the face terrninciting the ridge (monitored
by well num½or three). There is als_o .the _stro..Q,g_ indication, based on
I I
(h}
-2-
topocJ ·,:aphic evid-2r.ce tha t ther e is probc.ibly grollnd water flow south
from the disposc1l area. Unless it can be s hown conclusively t·ha t-
ther.:2 is no g.round wc,ter flow t o the south beneath the disposal urea,
a well to mon:i.tor a;,y southw2rd flo•.,;, would be highly a dvisable. Its
location should be o.pp.r.oximately 50 . feet from t he fence and near th2'.
centerline-of the landfill._
The specifications call for only two feet of cement grout in the
tmnular space. EJ?A would like to see five feet of grout to anchoI
the well more securely and to provJ.de more isolation .from the ·
surfaCE':!~ We would also like t o see each well screened so that a
minimum of ten :feet of the upp2.:-ground water zone can be ·sarrpled at
anytime (ten f eet J:--,e~low seasonal low water table evaluation).
•
Unilecl Sli!ll!S
Env,rorimenlal Proleclion
Agency
June 4, 1979
4AH-RM
negion d
345 Courtlanr1 StrP.el NE
Atlanl,l GA 30308
Honorable James B. Hunt
Governor of Horth Carolina
State Capitol
Raleigh, North Carolina 27611
Dear Governor Hunt:
Alabama, GeorgicJ, Florida.
Mississippi, Norlh Carolina,
Soulh Carolina, Tennessee.
Kentucky
On February 17, 1978, the United States Environmental Protec ti on
Agency (EPA) published final regulations in the Federal Register
(43 FR 7150-7164) on Polychlorinated Biphenyls {PCOs), Disposal
and Marking. These regulations were amended by the Federal Register
,(43 FR 33918-33920) on August 2, 1978. These regulations prohibit
the disposal of PCBs at any site not approved by the EPA after
April 18, 1978, and these regulations require that the owner and/or
operator of a chemical waste landfill used for the disposal of PCBs
submit information in accordance with Section 761.41, Chemical Waste
Landfills, to the Regional Administrator for review.
Jn accordance with the above referenced regulations, a formal appli-
cation was filed with this office dated December 12, 1978, requesting
approval of a site in Warren County, North Carolina ·which will be
owned and operated by the State of North Carolina and used for the
disposal of PCB contaminated soil from the highway shoulders in the
State and from the Fort 13ragg military reservation. A public hearing
was held in Warrenton, North Carolina on January 4, 1979, for public
i input. The hearing record was held open until January 12, 1979, for
additional written public input into the decision process.
The result of EPA's review is that the proposed site will meet all the
technical requirements for a chemical waste landfill as required in
Section 761.4l(b), when constructed in accordance with the enclosed
conditions to this approval except for the following:
(l) 7Gl.4l(b)(l)(vi) "Artificial liner thickness 30 mil. or
9rcr1 ter."
(2) 761.4l(b)(2) "The site shall be at least fifty feet from the
nearest groundwater."
(3) 76l.4l(b)(·5)(iii}(d) "Chlorinated Organics."
These three.requirements are hereby waived for the reasons given in
the enclosed technical review. Your rc~uest to waive the lea~hate
collection system underneath the liner is denied for the reasons
stated in the enclosed technical review.
. ..
-2-
Accordingly, the Warren County, North Carolina site to be owned and operated
by the State of North Carolina for the disposal of PCn contaminated highway
shoulder soil is hereby approved subject to the enclosed conditions as a
chemical waste landfill as authorized in 40 CFR, Part 761. It is understood
by EPA and the State of North Carolina that this approval is based on the
conceptual design only and that the final construction plans and specifica-
tions (if any) must be approved in wr.iting by this office prior to
the initiation of construction.
This approval is not to be.construed to be approval for incineration,
storage, marking or records and monitoring. We will continue to work
with you in any way we can to expedite a public health oriented and
environmentally sound solution to the PCB problem in North Carolina.
Sincerely yours, .
·2)d_c2.~ ohn.C. White
Regional Administrator
Enclosures
cc: Herbert L. Hyde, Secretary
NC Dept. of Crime Control & Public Safety
Marshall Staton, Chie.f
Sanitary Engineering Section
Division of Health Services
NC Dept. of Human Resources
Jerry Perkins, Head
Solid Waste & Vector Control
N.C. Dept. of Human Resources &
Division of Health Services
. .,. ; . . ·,·
Approval Conditions for the PCB Disposal Site Owned
And Operated by the State of North Carolina in
Warren County, North Carolina on the Property Described
in Governor Hunt's December 12, 1978, Application as Owned
by Carter C. Pope and Linda W. Pope Found in Deed Book 278,
Page 252.
A. General Requirements (all reports should be sent to the Regional
Administrator, Attention: James H. Scarbrough):
1. Notify EPA at least two weeks in advance of the expected start of
construction.
2. Notify EPA at least two weeks in advance of the initiation of disposal
of PCB waste at the site.
3. Send EPA the data which is required by 43 FR 761.4l(b)(S), monitoring
systems for baseline and on the frequencies specified.
4. Maintain'records as specified in 43 FR 761.45(b)(3) as appropriate
and submit within 90 days after closure of the site to the Regional
A9mi ni stra tor.
s. Advise EPA inmediately of any changes, alterations or divergences
in the operational and managerial policies and procedures as out-
lined in the documents submitted in support of the application.
6. Report to EPA any instance of detection of PCBs through the monitor-
ing program inmediately.
B. Technical Conditions of Approval:
. .
1. The one foot of cover to be placed only on the middle 20 feet to
30 feet of the first lift of waste to preclude shunting any infil-
tration to the side walls.
2 •. A soils engineering firm shall be employed to provide quality control
during the construction of the clay-silt liner.
3. Engineering expertise shall be provided by the State or a consulting
firm on-site during all operations to provide and assure conformance
with the final plans. Such assurance shall be furnished to the
Regional Ad111inis1·.r,:itor at the completion of the project with a copy
of "as built" plan:;.
4. A record shall be placed on the property deed which stipulates
the particular boundary of the disposal area and waste contained
therein with the associated waste elevations.
5. The State shall maintain an "all weather" access road indefinitely
to permit access to the site and to facilitate collection of samples
from monitoring wells.
6. Waste will be compacted as much as practicable with tracked equipment
to prevent settlement after closure.
7. Appropriate erosion control measures shall be applied during excava-
tion, filling and after closure to minimize erosion.
8. Trucks used for hauling the waste must be covered.
9. The final plans and specifications (if any) shall be submitted to
the Regional Administrator (Attention: James H. Scarbrough) and
written approval received prior to the initiation of construction.
10. A leachate collection system with a sump and access which
will allow pumping out of any collected leachate is required
above and below the clay liner. ·
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. . ·-UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: June 4, 1979
sueJEcT: Technical Review -Chemical Waste Landfill for
PCB &lbm1tted by the State of North Carolina
FROM: Chief, Residuals Management Branch
To: John C. White
Regional. Adm;lnistrator
'Ihe State or North Carolina submitted an application for the approval
of a disposal site 1n Warren CoW1ty, North carolina on December 12,. 1978.
'lbe Technical review has been perfonned. The results of applying the
~riteria foW1d in~FR 761.41(b) to the application are as follows:
(b)(l) Soils -The site is not 1n a "thick,·relatively :1mpenneable
fonnation such as large-area clay pans." 'lherefore., the soils are evaluatec
on the following criteria:
Required Proposed
(1) Soll liner thiclmess 3 .ft. (cgnpacted) 5 .ft. (canpacted)
(11) Penneabllity (cm/sec) mo-7 or 6.8X10-8 or
(0.0000001) (0.000000068)
(1:µ) Percent Soll Passing 2, 30 75 Average
No. 200 Sieve
(iv) Liquid Limit 2, 30 51 Average
<v> Plasticity Index 115 18 Average
(vi) Art1.f1c1al Liner 30 mil. None proposeaY
1/ A waiver was requested for this requiranent. The primary justification
-for the waiver was that the State would instead place a 10 mil. plns tic
liner "wnbrella" top on the landfill covered by two feet or soil · .. 1hich
would be ccedcd wl tt1 r,ra.::;s anrl slopcrl. Till~, de::; lgn woulcl rnl.n.l.m.l:~~ arw
rainwater infiltr-ation into the landfill. This waiver-request zhould
be approved •.
··, . .. . .
IPA. ,_ 1320·6 (A .... l-76)
-2-
(2) Hydrology -The site is located on the crest of a ridge at lati-
tude 36° 20' 13", longitude 78° 09' 58" and is above the 100 year
flood level. This is verified by the U.S. Geological Survey (see
letter dated November 29., 1978, to Jerry C. Perkins). The bottan of
the waste will not be 50 feet ab9ve the groundwater. The m1n.1mur.1
distance will be held to 10 feet above the seasonal high groundwater
table. The State requested a waiver for this criterion. In reviewing
the justification of the waiver, I have concluded that the clay liner
1n the bottom of the trench plus the liner on top of the waste which
will act as an umbrella for 1nf1ltration prevention, plus the leachate
collection system and sump above and below the clay liner will
sufficiently protect public health and the erwironnent fran "unreasonable
ctsk of injury" as stipulated by paragraph 761.4l(c)(4). Therefore.,
. this waiver should be approved as requested.
(3) Flood Protection -The application states that the diversion structures.
will be designed to divert the 24 hour., 25 year runoff fran the active
'portion of the landfill.
(4) Topography -The topography at the proposed site is low to rroderate.
'lhe approval should -be conditioned to require all practical erooion
prevention rreasures to be used.
(5)(1) Monitoring Systems
a. 'lhe application states that baseline data will be collected
prior to final approval. The approval soould be so conditioned • .
b. The application states that the surface streams and the grcund-·
water will be sampled rronthly during operation. The approval ·
slx>uld be so conditioned by referring to paragraph 761.4l(b)(5).
-c. Bi-anrual m::,nitoring will be done after closure.
(11) Groundwater Monitoring Wells
'The application states tt1r1.t these w11 l be constructed and lor..2.ted
as rt."'C}uired. FP/\ sta.ff should verlf:1 tile loeation of these in
the field.
(111) Water Analysis
'Ihe analysis for chlorinated hydrocarbons is requested to be
waived. The regulations were written for canrrcrcial facilities
which would be dlsfX)sing of many different wastes. Since PCB is
the only .waste which will be dlsposed in this site, there is no
point to m:::>nitorlng for other chlorinated organics. This waiver
should be approved.
-3-
(6) Leachate Collection
'Ihe proposed design does not show a leachate collection syst:em unrter
the liner as C'e(luired by the regulation. Because of the grcxmdwater
proximity an:i the demonstrated public concern, I recanrrend that a
leachate collection system and sump be installed under the sou liner
to monitor the integrity of the soil liner. In addition, the leachate
collection system above the soil liner soould be required w1 th the
appropriate sump to provide the rrechanism to allow pumpi~ out of any
leachate collected to prevent aey significant hydraulic head buildup
on the clay liner. Therefore, this wcuver soould not be approved.
(7) Operations
The operations plan submitted is satisfactory with the exception of
the one foot of clean soil to be placed on top of first lift of .waste.
• 'nus clean soil is to be used to prevent the trucks fran talcing out
contaminated soil on the wheels. This one foot should be restricted
to the rrd.ddle 20 to 30 feet of the trench so as not to provide a
, shunt to the side walls should any infiltration occur. This restric-:
tion·will allow any infiltration to proceed down throogh the waste
to the leachate collection system which would lead it to the sunp
for pumping rut. ~-
(8) Supporting Facilities -The supporting facilities are satisfactory
as described. No rrention was nnde of long-tenn nnintenance of the
·access road. The approval soould be conditioned to insure that all-
weather access is rra.intained •
.. .
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·: ,•,·,.
r, J 2 ') ·lQ('') Nu\ '"' 1-..1'-''-
REF: 4AW-RM
Mr. William W. Phillips, Jr.
Assistant to the Secretary
N. c. Department of Crime Control
and FUblic Safety
512 North Salisbury st.
Raleigh, N. C. 27611-7687
Dear Mr. Phillips:
cperation and maintenance of the Warren county PCB landfill was agreed to
by the State of North Carolina in the cooperative Agreement signed on
May 25, 1982. We have examined this question and the following will be
required of the state after closure to fulfill the agreement:
1. Monitoring, leachate collection, record keeping, notification,
and reporting requirements contained in the landfill's approval
under the TOxic substances control Act (TSCA), 15 u.s.c. § 2601,
et seq., as found in EPA's letters dated June 4, 1979, and
December 14, 1981;
2. Maintaining in good working order the access road, fence, and
gate as required by the landfill's TSCA approval contained in
EPA's letters dated June 4, 1979, and December 14, 1981;
3. Proper disposal of any removed leachate as required by the
landfill's TSCA approval contained in EPA's letters dated
June 4, 1979, and December 14, 1981;
· 4. Establishment and maintenance of vegetative cover: (1)
·semiannual inspection; (2) repair of erosion and
reestablishment, if needed, of vegetative cover; and (3)
semiannual mowing of cap to prevent establishment of deep rooted
vegetation;
5. In addition to the requirements enwnerated above, full
compliance with all applicable requirements under TSCA and each
applicable condition of the landfill's TSCA approval contained
in EPA's letters dated June 4, 1979, and December 14, 1981.
Suggested additional items related to post closure:
· .. 1. Establishment of a permanent bench mark on top of the landfill
cap for future measurement of settlement;
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2.
3.
Establishment of permanent bench mark adjacent to landfill on
state property in undisturbed soil;
consideration of available security precautions to protect the
integrity of the monitoring wells, the leachate collection sumps
and standr;,ipes_. and vents;
4. General visual inspection of the entire facility to be done at
the same time as the leachate collection monitoring required by
40 C.F.R. 761.4l(b)(7) and the conditions to the landfill's TSCA
approval contained in EPA's letters dated June 4, 1979, and
December 14, 1981.
This letter does not alter or modify any of the Special conditions
contained in the Cooperative Agreement signed on May 25, 1982.
Sincerely yours,
~ -----············.. ··---
_·--~/~~~ ~
Thomas W. Devine, Director
Air & Waste Management Division
cc: O. W. Strickland J
Department of Hwnan Resources
Raleigh, N. C.
'M111,1fWD
4APT-PT
Mr. William Meyer
Director
North Carolina Solid Waste Management Division
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Meyer:
Please find enclosed a copy of the December 14, 1981, letter
sent to the State of North Carolina from the Environmental
Protection Agency (EPA), Region IV's, former Administrator,
Charles R. Jeter. This letter served as the final EPA approval
for the Warren County, North Carolina chemical waste landfill.
A review of the "Final Approval Conditions" section indicates
that this permit document needs to be updated to present stan-
dards. A permit revision process will be initiated by our
Toxics Section to ensure that the landfill approval is in con-
junction with all current PCB landfill regulations. These
standards are found in the Code of Federal Regulations, Title
40, Section 761.75.
At this time, we expect to have an updated permit issued for the
Warren County site by the end of this fiscal year. If you have
any questions or comments on this matter, please contact Carin
DeBenedictis at [phone].
Sincerely,
Richard D. Stonebraker
Chief, Pesticides & Toxic Substances Branch
Enclosure
DEC 14 1981
.oonorable Jaires b. Hunt
Governor of North Carolina
State Capital
\ \
l<aleigh, North Carolina 27611
~ar Governor Ht.mt:
.... -. -·· u.l~Co
On June 4, 1979, Rec;ion IV gave conceptual approval, with certain
ccnaitions, to the \\arren CoLmty, North Caroline, site as a dlemical we.Ste
landfill ~ author.1zea in 40 CF'.rt, Part 761. One: of the conciticns was t..'1at
the .State ::..Ui::11'.it final pl.ens and si:,-ecificaticns to this office for approval,
in writing, prior t.e the initiation of construct.ion. These i:,lans a.r~
sf,eeifications nave been subnitteo ana are hereby approved subject to the
enclosed conditions.
rve corrnenu you and t.he many involved fer your dedication to reaching a final
solution to this envu-onm:ntal problem baseci on the tecnnology as it eXists
toca}·· lt we can be oi: further assistance, please let me know •
.Sincerely yours,
/s/ Charles R. Jeter
Re.gional Administra~0r
Olar les R. .Jeter
i'<e<;i ic.,-nal Administrator
.l:.nclosure
cc: r-ir. burley B. M1tcht:il, Jr., ~ret.ary,
l-orth Carolina uepartiient
of Crime Control and Put.lie Satety
i<aleigh, l\orth Carolina
O.\"i. !:it.ricklanc, Heac ·
Solie & Hazaraous Waste Z.:..anagenent Branch
£nv1ror~~nt.al tlealth Section
Der~t.rnt,nt oi human ~sources
Division of hec:.lt..ii Services
Rale1sh, Horth Carolina
Dr. Sara Morrow
Lepartrrent oi Human kesources
Livision of health Services
F;.;;leigh, t·-orth Carolina
-------·----------------·-------~:....-
(_, ., ' OEC l 4 l'j~I
Final Approval Conditions for PCB Chemical Waste Landfill in Warren County,
North Carolina, owned and to be operated, closed and post closure cared for
by the State of North Carolina on property formerly owned by Carter C. Pope
and Linda w. Pope, found in Deed Book 278, page 252.
I. Reference June 4, 1979 approval letter signed by John C. White
A. General requirement numbers 1, 2, and 5 remain in effect.
B. Technical condition numbers 1, 2, 3, 4, 6, 7, and 8 remain in
effect. Condition numbers 9 and 10 have been satisfied.
II. Additional conditions of this approval are:
A. Leachate collection will be monitored monthly and collected
leachate disposed of properly, if required (761.41 (b) (7)).
Records will be maintained on file at a designated State office.
B. The operation plan will be followed, as approved (761.41
(b) (8) (ii)).
C. Records will be maintained and submitted to the Regional
Administrator within 90 days of closure (761.41 (b) (8) (IV)).
D. The fence, gate, and access road shall be maintained in good
working order as long as post closure monitoring is required.
E. Report to EPA Region IV any instance of detection of l?03's through
the monitoring program imnediately.
F. Designate a State departmental person who will be responsible for
operation and for post closure montioring prior to initiation of
construction (761.41 (c) (5)).
G. Notify EPA Region IV 30 days prior to transferring responsibility
for operation or any change in ownership ( 761. 41 (c) ( 7)) •
H. Monitoring Program
1. General
The parameters for ground and surface water monitoring for
this program are found at 40 CFR (761.41 (b) (6) (iii) (A), (B)
and (C)). Samples should be collected and analyzed in
accordance with EPA approved procedures.
2. Ground Water
a. Background -Each well must be sampled at least three
times and the data submitted to Region IV prior to any
disposal. A minimum of one week should elapse between
sampling. At each sampling a minimum of two replicate
measurements for each value or concentration should be -
made.
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b. During Operation -During operation or for a period of
one yeat, whichever is shorter, all wells must be
sampled rronthly.
c. Post Closure -Each well must be sampled on a semiannual
basis.
3. Surface Water
4.
s.
a. Background -EPA Region IV will designate surface water
sampling locations. These locations will include, at a
minimum, two (2) sampling points per surface water body
(one upstream and one downstream). Each of these points
will be sampled each time the background samples are
taken for ground water quality.
b. During Operation -Each of the designated surface water
sampling points will be sampled rronthly during operation
of the facility.
c. Post Closure -Each of the designated surface water
sampling points will be sampled on a semiannual basis
during the post closure period.
Changes in Program
Upon a determination by the State or EPA that containment has
failed, the sampling frequency of either ground or surface
water sampling may be rrodified. EPA may also require the
installation of additional rronitoring· wells and an expansion
of the list of rronitoring parameters.
Well location and screened elevations shall be coordinated
with EPA Region IV in the field or by telephone as
appropriate. ·
I. Undisturbed samples of the soil liner will be taken and the
laboratory permeability determined and submitted to EPA Region IV
prior to any disposal (1 sample per 25,000 square feet of liner).
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, ... LEACHATE·,.::_ . . liEMovAL:··:.;;~/~lq~ · ~~---SPRINKLER LEACHATE -POND 3-STAGE FILTER PIPES',:·.· ~~~~~.i·:.;~ .. ~· .. ~ • ~ ~ • -r.f WIJrf.JZ. Uil>Cl... • .... , F'-ltt.1'~0.0 9ii \.)t)~ ~~ t.n,~1... ~ 'NfJrrll.L1:l)[.LUlj)(Jt.~~ ~ CLEAN EARTH/TOPSOIL ARTIFICIAL LINER LEACHATE COLLECTION SYSTEM CLAYUNER ------------------• 1991 Water level in Leachate collection pipe fluctuated approximately ±2' -f _WATERT~BLE ---------This could indicate that the top liner was leaking by allowing rainfall to infiltrate which would raise the water level, subsequent lower water levels could indicate leaking of the landfill through the side walls or bottom line system. However, the leak detection sump never indicated a leak of the bottom liner system and there is no apparent leakage, which would be visual of side walls. • S&ME (original contractor for Soils Engineering work at the site), at the request of the Division, evaluated the landfill and observed no apparent water leakage but observed a significant generation of gas [from decomposition of organic material (grass) in the landfill] . .The 6" venting system was observed to have sufficient pressure to rapidly fill a plastic glove attached to the vent exit and force the attached glove from the vent. S&ME suggested that the vent was not sufficiently sized to vent the volume of off-gases at the rate generated by decomposition resulting in increased pressure. The increase in pressure within the landfill indicated that if gases were not being vented then water would probably not be infiltrating or leaking from the landfill. The gas pressure also indicated that the landfill was "tight" and the integrity of the line systems were not violated. In addition, even slight increases in internal gas pressure would be reflected by forcing the water level in the leachate pipe to rise. The fluctuation of water levels in the leachate pipe is an indication of differential gas pressure not due to water infiltration and exfiltration. --
. . CR1MitCONTROLW
& PUBLIC SAFETY
I
Slaw Highway Patrol· Alcoix:ll Law Enbcemm1 · Crime Calirol · Natialal Guard ·Civil Preparedness· Civil Air Patrol
James B. Hunt,Jr.,Governor
Memorandum
To:
From:
Subject:
December 7, 1978
Dr. Martin Hines
Mr. M. C. Adams _
Mr. Jerry Perkins ~
David E. Kelly Q L/ L--
Meeting in Chatham County, December 11, 1978
J. Phil Carlton, Secretary
Attached is an additional list of questions from Chatham County in regard
to the l andfi 11 sit~ -for PCB di sposa 1.
Please be prepared to respond to these questions Monday night in Chatham
County at the public hearing.
DEK:jj
Enc.
P.O. Box 'Zl6ffl · 512 N Salisbury Street · Raleigh.NC. 27611 · (919)733·2126
:· •• >. ,4' •
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,•' .· ' . ..
. wrica:RnS ABOur THE SUIT ABILTI'Y OF THE PROPCSID ,a{ATHAM COUNTY LANDFil.L SIT! FOR
PCB DISPa3AL.
Preaented to the Chatham County:_ Commissioners December 4, 1978, by concerned
c1t1z~na in Chatham C.:>unty,
',. ;i;f
'1, What assurance is there that the geologic· conditions ·of fthe proposed site
· meet the minimum criteria_ of the state and EPA standards? ~ •. fur:ther, what
aaaura.ncea a.re there that these standards, even if met, woul(Jf sategy.a_rd the
publ1C? ., . ~fl -~ •.❖,.
;,',I
2,. Wl,lat efforts have been made t _o contact EPA about
. this :a1 te? ·
their rea,o'.D\lllendations on
(f
Th,,_ · J. What efforts,pave been made to find other disposal sites DI Chatham County?
'-.What ·other dispd'i!al. sites have been found? How does the safety of any other site•
· found. COJlp&re with that of the landfill site?
4. Aecording ta an article 1n the Deceab,er 3rd Raleigh News·a.nc1 0bserver,.·state
•: o:f'ficiala have said .. that up .. to half of all the PCB .wastes in the state would be
.• \put. 1n the proposed Cha th.am county la.ndf ill site. Is this true, and was this
'/."': ~·:intent~ of the couissionera when they ·.a:iroposed the transaction?
s.· Hov m&ny cubic yards of PCB watste exist on Chatham county roads? How aany
..-cubic ya.rd.a of PCB waate exitt 1n the state? What is the proposed acreage of
the landfill PCB disposal. site? What is the proposed depth and cover of that .,·:a1te?· · -.. :_,:
· ·. 6. If a. hyperlon liner were to be used at the proposed site, how could equipment
PQH1bl1 place the PCB waste into the liner without puncturing the liner?
. _'._7, .What 1s the concentration of PCB wastes on the roads? . ••.:,,. '.· ..
'8,·,.Ia the waste material pure PCB, or does 1t contain PBB also?
~:_,f;;.}'.~·;'!,:,>;.:\s:·9, ~t oonaid~ration has been. given to other possible solutions, including -the
:·'.'.;<:: · · .<following, -· · . · ·
: · '::,,\ &~ burning the PCB waste . . · · · ·
b. treating the PCB on the roads.
o, finding other sites
d. storing the waste temporarily until it can be burned
e, taking the waste out of state to an KPA-approved site?
10, Chatham county residents have noted a spring on the proposed landfill
dispoaal site. Are the commissioners aware of the spring, and of the fact
that this would make the site unacceptable from the safety standpoint?
APPLICATION TO U.S. EPA REGION IV
for
PCB DISPOSAL SITE
CHATHAM COUNTY, NORTH CAROLINA
by the
STATE OF NORTH CAROLINA
James B. Hunt, Jr.
Governor
. l J '
TABLE OF CONTENTS
Pages
SITE LOCATION-----·---------------------1
LANDFILL DESCRIPTION--------------------1-2
ENGINEERING REPORT-----------·-----.2-6
SAMPLING AND MONITORING-----
WASTE VOLUMES EXPECTED -------·-------
6
6
GENERAL DESCRIPTION OF WASTE MATERIALS ------------6
OPERATIONAL PLAN-----------------------------7-9
LOCAL .AND STATE PEfu~ITS ------------------------9
SCHEDULE OF C0NSTRUCTION -----------------------------9
WAIVERS REQUIRED-------------------------------4,6
ATTACHHENTS: 1, 2, and 3,4
I. Site Location
The PCB landfill in Chatham County, North Carolina, is located on the .
property of an existing county-owned sanitary landfill. The State of
North Carolina will buy approximately six acres from the County on
which the trench will be constructed. The exact site location is shown
on County Map. the USGS quadrangle sheet and a property boundary drawing
to scale on Pages 1.0-12.
II. Detailed Description of Landfill
The State of North Carolina proposes to construct the PCB landfill as
shown on the conceptual sketches shown on Pages 14-19. In general 5
the landfill wlll be constructed as follows~
Excavate to within five feet of the high groundwater elevation.
Select borrow and stockpile which will allow reconstitution and
compaction of a five-foot liner which will have a permeability
of lxl0-7 cm/s.
Construct five-foot liner in the bottom of the trench and up
the sides five feet in elevation.
Install 4-inch PVC perforated leachate collection system leading
to a sump which will allow liquid withdrawal for the relief of
any head buildup.
Place one foot of selected sand or other high permeability
material around the pipe over the entire bottom of the trench.
The trench will be sloped to drain to the sump ..
The side slopes will be 2:1.
The waste will be placed on top of the one foot of sand in lif~s
as described in the op erations plan.
When all the waste is in place, the landfill will be covered \,.'ith
one foot of Foil ( ·~~avated from trench). A 10 mil artificial
liner will be placed on top of the one foot of soil. A 1.5 foot
layer of excavated soil will be placed on top of the liner and
six inches of topsoil will be placed on top of this.
The top surface will be sloped at about two percent to facilitate
runoff of rainfall. The top will be seeded with a perennial grass.
All surface drainage during construction and after completion will
be diverted from the landfill surface.
III. Engineering Report
1. Description of the general geology of the area.
The proposed site is located in the central eastern part
of the North Carolina Piedmont physiographical province.
The Jonesboro Fault is more than 20 miles east of the site.
Site geology consists of well-bedded metavolcanic phyllite
and argillite slates of the precambrian or lower palezoic
period. The slates are deeply weathered forming thick layers
of dark red, red-brown clay and silty clay residum, (clayey»
kaolinitic, thermic; typic hapludult, soil classification).
Surf:icial clays grade to silt and sandy silt directly above
slate beds. The slate beds are thousands of feet in thickness;
vertically fractured for 100-200 feet, fractures strike north-
east and beyond the 100-200 foot fractures, the slate bed is
compressed and contains essentially no voids and, therefore,
impermeable. An aquifer exists below the proposed site that
is limited to the upper fractured zone of the slate bed.
Transmissivity within the aquifer is a furiction of fracture
size and continuity (See schem3tic on page 13 ).
Therefore, this site does not me et the first technical require~ent
-2-
of being "located in thick, relatively impermeable formations such
as large-area clay pans". Since the above is not possible, the site
meets or exceeds the remaining criteria of paragraph 761.41 (o)(l)
as follows or a waiver is requested with justification:
Required
(i) In-place soil thickness four
feet, or compacted soil liner
thickness three feet.
(ii) permeability lxl0-7 cm/s
Actual
Five feet compacted soil.
. -1 .
lxlO cm/s permeability
Discussion: The soil characteristics as shown by the sieve analysis
and the atterburg limits ar.d the percent moisture vs. compaction curves
indicate that the native clay MR-CH will compact to 93 lbs. /ft. 3 which
-7 should yield lxl0 permeability. To date this has not been verified
by laboratory permeability. This verification is in progress, and if
the permeability is less than lxl0~7 additional depth of compacted
soil will be added so the equivalent of five feet of lxl0-7 will be used.
Required
(iii) Percent passing No. 200 sieve >30
(iv) Liquid limit > 30
(v) Plasticity index> 15
(vi) Artificial liner
Actual
Average passing No.200 = 85%
(See soils data attachment)
Average LL= 46
(See soils data attachment)
Average PI = 16
(See soils data attachment)
None
Discussion: A waiver is requested for this requirement. The State of
North Carolina does not feel that the lack of an artificial liner will
present an unreasonable risk of injury to health or the environr::2nt from
PCB's for the following reasons:
-3-
. '
...
This landfill is not a commercial facility which will be
in operation for a long period of time. It is a one-shot
(90 days open) operation for a special problem. (Soil with
low concentration of PCB generally expected to be less than
500 ppm based on test dig, see attachment.)
The 5-foot compacted clay liner exceeds the requirement
found in 761.41 (b)(l)(i), EPA -Part V -PCB Disposal and Marking.
There will be a 10 mil hyperlon liner placed on top of the
landfill. This "umbrella" top will be covered by two feet
of soil which will support the growth of grasses. The grass,
the two percent slope, drainage ditches, and the top liner
will effectively prevent any rainwater infiltration into the
landfill.
2. Hydrology -The landfill is located on a hill slope well above th.e
floodplain, as can be seen by the location on the USGS quad sheet •
. There is no hydraulic connection between the waste and any ground or
!I surface water. The bottom of the waste will be a minimum of 10 feet
above the seasonal high groundwater table.
y A waiver is requested ~or the 50 feet separation between the site
and the groundwater. The. State of North Carolina does not feel that
this will present an unreasonable risk to health or the environment
from PCB for the same reasons stated for the liner waiver. In addition,
we do not believe that this requirement can be met in North Carolina in
a reasonable manner by maintaining proper compliance with the other re-
quirements, keeping in mind that taxpayer dollars must be spent to
achieve this task. This is based on the fact that the ground~a ter is
within 50 f~et or less of the surface in essentially all the Piedmont
area of North Carolina.
-4-
. ' 3. Flood Protection -The site is above the 100-year floodwater elevation
(See Attachment 3). The runoff diversion structures will be designed
to handle the 25-year 24-hour storm runoff.
4. Topography -The topography of the area is low to moderace as evidenced
by the USGS quad sheet.
5. (i) Monitoring Systems
(a) Baseline samples of gn,und and surface water will be
collected and analyzed prior to the initiation of con-
struction and the data will be forwarded to EPA prior
to the issuance of the final approval. Sampling loca-
tions are shown on Page 12.
(b) The monitoring wells and the surface streams will be
monitored monthly while the site is op:!n.
(c) The monitoring wells and the .surface streams· will be
monitored biannually after closure of the sit.e.
(ii) (a) The wells are located on Page 12.
(b) The wells will be constructed as stipulated by paragraph
761.41 (b) (5) (ii) (b), EPA-Part V-PCB Disposal and Marking.
(iii) All samples will be analyzed for:
(a) PCB
(b) pH
(c) Conductance
(d) Request a waiver for the analysis for chlorinated organics
since PCB is the only chlorinated organic to be disposed in
the landfill.
6. Leachate Collection y
A leachate collection system will be installed on top of the 5-foot
compacted clay liner. The system will consist of one (oot of sand ·with
-5-
a 4-inch PVC perforated pipe in the bottom four inches· of the
sand. The entire bottom of the trench will be sloped toward
a sump. The sump can be pumped out to the surface through an
8-inch pipe. The individual collection pipes will be connected
to a header which will drain into the sump.
2 The Sta~e of North Carolina is requesting a waiver for the
leachate collection system being urider the liner. We are of the
opinion that a more practical, sound engineering design is to
construct a collection system on top of the liner which will allow
any head buildup to be removed quickly. This leachate collection
system design and the "utJbrella" top to prevent infiltration seems
to negate the need of any leachate collection monitoring system
being placed under the five feet compacted clay liner.
IV. Sampling and Monitoring
The groundwater, surface water and sediment samples will be collected and
analyzed by the North Carolina Department of Human Resources, Division of
Health Services, Laboratory Section. The samples will be analyzed in the
Division's Laboratory Section.in Raleigh, North Carolina.
V. Expected Waste Volumes
This site is expected to receive approximately 17,000 cubic yards of soil
contaminated by PCB from the state highway shoulders.
VI. Waste Material Other Than PCB
The only waste to be disposed of in this site is contaminated soil. The
PCB contamination is 210 to 380 ppi71 (See samµle dig results, Attr.chment 1).
-6-
(
. .
VII. Operational Plan
(1) Record Keeping
All plans>· quantity of waste received, and other information will
be placed in a permanent file. The EPA approval letter, including
a legal description of. the disposal site, shall be filed in the
Register of Deeds' office in the Chatham County Courthouse,
Pittsboro, North Carolina.
Results of all monitoring will be placed in the permanent file as
well as other necessary information.
(2) Excavation
The excav~tion shall be carried out as shown on the enclosed drawing.
The backfill or placing of the PCB waste will be as follows:
Two 10-foot lifts will be used. The trucks will back into
the open end of the pit and place the waste ~s near to working
face as possible without the truck wheels getting on the ~-:aste.
A track piece of equipment will be used to push and compact
the waste into place. Clean earth will be plac~d on the
floor of the pit as needed to keep the trucks out of the ~aste.
The leachate collection system will be constructed as placement of
first lift progresses. The open end of the pit will be closed
to the level of the first lift. A 1-foot layer of clean earth
will be placed over the first lift so the trucks can· be on a
clean surface and the second lift will be completed as the first.
After the secon<l lift has been completed, including placing the
residue from the run-off collection system, the open end of the
pit will be completely closed. One foot of clean soil wi ll be
placed on the top cf the waste. A ten mil plastic co·:er 0:1 a
2 percent grade will be plnced ovl?r the .one foot of Sl)il.
-7-
Two feet of compacted earth will be placed over the plastic cover
on a two percent grade. Erosion control procedures will be
utilized as required by the Division of Land Resources; Department
of Natural Resources and Community Development.
(3) Vehicle and Equipment Movement and Use of Roadways .
Access vill be controlled at all times. Vehicle and equipment movement
will be strictly controlled. Dust control methods will be applied as
needed.
(4) Surface runoff from the pit area will be collected in a holding pond as
shown on Page 16. The water collected in the holding pond will be
analyzed for PCB, and if n~gative, the WRter will be released to surface
drainage. If the analysis for PCB's is positive then the water will be
processed through a carbon filter prior to release. The carbon filter,
if used, and the silt from the pit will be placed in the disposal area
prior to final closing.
(S) Leachate Collection System
Leachate collection system will consist of placing 4-inch PVC perforated
pipes on top of the clay liner graded to a sump with a stack to at least
two feet above the comple~ed surface with a cover and lock. One foot of
porous material will be placed over the clay liner to enclose the per-
forated pipes.
(6) Sampling and Monitoring
Three monitoring wells will be placed on a line through the site. One
of the wells -will be located above the disposal pit and t~-10 below, with
one of the w~lls located at the area with the lowest groundwate r.
Sampling and monitoring of the l eachate collection system, the wells,
and the receiving stream will be carried ot:t as r ec0:::r.1encL~d by the~
Environmental Protection Agency.
-8-
(7)
(8)
Background samples will be collected and analyzed prior to the
placing of any waste.
Types of 'Waste
Earth contaminated with PCB. (Test clean-up analys:l.s is enclosed
on Attachment 1.)
Supportive Facilities
A six-foot wire fence will be placed around the disposal area to
prevent unauthorized persons and animals from entering.
(9) The .site shall be operated and maintained in a manner to prevent
safety problems and hazardous conditions. The State will have its
inspectors on-sce_ne during all operations.
VIII. Local, State, and Federal Permits
The disposal site will be in accordance with local zoning codes. A State
permit will be issued by the North Carolina Department of Human Resources.
IX. Schedule
Submittal to EPA----------------------------------December 6, 1978
Public Hearing-------'--~-------------------------January 3, 1979
EPA Tentative Approval Expected ----------------------January 25, 1979
Detailed Plans and Specifications Completed------------February 20, 1979
Final Approval Expected from EPA---------------------March 7, 1979
Construction Started: (Upon completion of a North Carolina State Negative
Declaration and as weather permits.)
Site Closed: Approximately 90 days after site preparation completed (as
weather permits).
-9-
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Attachment 1
October 19, 1978
MEMO TO: Mr. Robert A. Cart~
FROH:
.
Ray E. Kelling; L:iboratory Section . .. . , ,..
SUBJECT: PCB Results.:.. Warren County Test Cleanup
Given below are the PCB results for the Warren County Test Cleanup
taken on October 5, 1978. All results are qua.ntitate<l on the PCB-
Aroclor 1260.
A
B
C
E & D
(1)
170 ~/kg
.
0.13 'l!!.g/kg
<100 JJg/kg
Wash down
<0.77 µg/1
Special 1
If 2
" 3
Background 1
.. 2.
(2)
3.8 mg/kg
33 mg/kg
0.33 mg/kg
41µg/l
130 µg/kg
77 mg/kg
330 mg/kg
(1)
(2)
(3)
(l•)
(5)
<100 µg/kg <tes µg/kg
(3) (4) (5)
210 mg/kg 41 mg/kg 10 mg/kg
3110 mg/kg 6 r.g/kg 0.25 mg/kg
<190 pg/kg <100 11g/ki~ <100 µg/kg
150 µg/1 75 }Jg/J. 127 µg/1
Storage Pile
290 mg/kg
270 mg/kg
380 mg/kg
210 »r/ko 0 :;,
270 tng/kg
Attachment 2
• .
RESOLUf ION
1. The Counti.Commissioners of Chatham Co~~ty a9ree to se11 to .the State
of North Carolina, six acres of land at the county landfill site to be
used for th~ storage and disposal of PCB contaminated soil to include a 11 ..
PCB contaminated soil now known to be in Chatham_ County • ..
2. No material shall be so stored prior to obtaining all pennits require·d .
by law including but -not limited to rules and regulations set forth in
Federal Register Volume 43, Number 34; Part V dated February 17s 1978, en ~
titled Environmenta\ Protection Agency. polychlorinated biphenyls, PC8s
disposal and market!ng.
3. Specifically,no.:material shall be stored prior to obtaining permits
from EPA and after a notice and public hea.ring to be he1d in Chatham County -Courthouse at a date to be announced.
•' ..
, ,
United States Department of the Interior
GEOLOGICAL SUtVEY
P.O. Box 2857
~leigh, NC 27602
Attachment 3
November 29, 1978
Mr. Jerry C. Perkins, Head
Solid Waste and Vector Control Branch
Division of Health Services
N. C. Department of Human Resources
P.O. Box 27687
Raleigh, North Carolina 27611
Dear Mr. Perkins:
The proposed PCB disposal site located in Chathar:. County at la~itude
35°42'30", longitude 79°15'36", is above the 100-year flood level.
The site is located near a hilltop about 1300 feet from Harland Creek.
I estimate, based on flood records collected on North Carolina streams
that the 100-year flood height is not more than 10 feet above the low
water surface elevation of the creek. The proposed site is approxi-
mately 50 feet above the creek and well above the 100-year flood
elevation.
NMJ:ceh
Sincerely yours, ;z;::tP~ cf/({6
74; N. M. Jackson, Jr.
Hydrologist
Attachment 4
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
.I!. A ·,· t"<>rrn
11-1-73
' .1 MATERIA!; ... S & TESTS UNIT
(. SOILS LABORATORY
ltd.
1 ...,roj. . ............................. ------------.
{
REPORT ON SAMPLE~ OF Soil_f~!'. ~~~~ty __ &_Pll. ................................................... ...
Project ________ J_._?.rQ'!JQt ................... County Ch~t~~ . _______ 0\mer ___________________ _
Date: Sampled J..Q.::15.::7§3 _______________________ ..... Jle:ei'Ted .J.Q::1= ?::'(~------------~--Reported _J.o::-:i:.~:-J8 ___ _
Sampled from ~.fCJLPi~_/D.,9 ____ :-~--:~-.~. ____ : __ ·---·--.•--By J~--s~ .. f!ri~! ... _____ : __________ ~---------· __ :__
Submitted by ___ \i_._J}_. __ '8j,ng!1~11 ..................... ~ -........... -------------·. -----..... --~-----··· ---19 ...... J ... ~ ... Sta~tinrd SJ,ec.ification
397591~97606 TEST RESULTS ~ ()--()__ (o --------.------,,----.---r-----:----.----,----..:....,..::..!..::::...:~--
Proj. Sample No. 1-B 1-C 2-A 2-0 3-A 3-D 13-C
I.ab. Snmple No. 397591 397592 397593 397594 · 397595 397596 397597 . 397598
Rrtaincd :4 Sieve 'it' -1 --
Passing tlO Sieve 100 95 I 100
Pt.ssing J:.JO Sieve
Passin~ ~00 Sieve
~ 99
'1c 98
'rn 95
I 95
99 82 s6 I ss 100
90 j 67 85 ! 69 ! 93
100 100 100
99 l 99
87 I 87 -
~ 1 3 13
~ 3
. "l'r. 1 36
-I 14 14
51 I 49 ··-· --·-
L. I..
P. I.
AA-S!°iO
Classification
-·
c~:
to
Ph
.,./21r. H. c. Adanis (2)
Hr. \\'. D. Bingham
Soils l'ile
with ~1/D Curve ,, II II
n. ,,
Request ?·klisture Density .::uc\·\.~ on
·sai:ip I c 1-A ()n.ly.
, .
ef .
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
MATERIA!..S 8c TESTS UNIT
SOILS LABORATORY
• ·roj. -· ----------··•--:--·-----------
. REPORT ON SAMPLES OF Soil -·-... -. --------•-·•-·-----·-----------------------
... ---·-----~ .. ---------------------
Date:. S.o.rnpled -----------------------·-----------Received . ----. .. . ----------------neported _____________ :..
PCB Pit #10 . . . ·.. .
S:i.mpled from --------------------------···------------.,. __ By -··-· --.•..• ----------------------
. . Submitted by ____________________________ :_· ________ ---. -----·---------. --·•---------------19 ____ Standard Speci!icaUor.
397591-J97606 -TEST RESULTS .
Proj. Sample No. 4-A 4-B 5-A 5-D 5-C 6-A 6-B 6-C
Lab. S:imple No. 397599 397600 397601 397602 I 397603 397604 397605 397606
RPtained ::4 Sieve
Pniisin~ ~10 Sieve
Passing t-10 Sieve
• ~ Cr.&rc., So.nJ-2.0 to i 0.25 mn1. Re-L :i;o
0
c: I Fin~ Sand-0.25 tc,
.. 0.IIS mm. n~t. :270 .. -£ J ;,,,1 ~}lo.o~-gs mm.
~ --=~· .. 01:.. ••j Cl:,y-~•
., Ill I tho.n o.ons mm.
i p,., .. ,tnsr :ii t-10 Si.-ve ct,.
c;('
%
ct,.
ct.,
%
%
0/o
%
-
99
98
12 --~--1--I 82 99 99 I 99 100 --l. I 81 99 99 I 95 100
--
100 100 --99 97
95 62 95 9 5 ! 78 ! 97 I ss 76 .. J Is 8
3 14 20
'33
62
-
61 ! 33 i 69 I so . : 41 j 59 ! Js I 29 _L=::.;·:...:L:::.:.·-------t-----:-: _____________ I -+·------+-------
_:.P:..:,.•..=,:_I·~=------·-t--29 ____ ~_9 ___ _j__37 _ _µ± _____ ill j 28 jg ~
.....:t:.:.:.1~:;;:~::..:.;if:.:.::?c..:::..at~io.;.;.:, ____ 1_A-_7-5(20 L::\-4(il __ .1.,\:-7-5(20 )A-7_::_~(1.~ l~::l-5(9 }l A-7-5(19 A-4(8 )~
: 1· I ! I _____ i
1. __ f ______ i ! i : --.... ,1---
_.:s~t:!.:n~ti:::.:o"~------ir----"7"---· ----t-·-·--·-t-------~----'-------:-'-----..___ __ _
Hole ..:.N;.:'o:..:..· ------+-4·'------i 4 I 5 I 5 ; 5 ! 6 1. 6 ! 6
Dt:p~h crt.> o 7~:~----L-~---_ -~-~-.l s -~~~-;;o _ ~ o ! a _ ..... I 1.;;;...3 __
---··---'t;...;oc..-_--1--~5~•-5 ___ ....,.[~6,S ~8 1 _________ Lo 1 _j 32 1_j 81 ! 13' I 211
____ --J-0:::.:.1=-, __ ...__,4-%.--=s..;...1 _____ ! ~5._,.G,._;.,o __ i-"s'-"-=,23. __ T4,57 ! s.sB i s.09 ! s.41 i s.s1
~r'.=.e--------+---
\
\ . \
COMMISSIONERS
... . . . ... . . , .,,,,,,,, . ,, , . -., -,, . ,,
_A/ .a'ij ,v/,t//. 17 7~ ~
COUNTY OF CHATHAM
A . •~::·~: ~~..:;.~;!, ~ , ..,~r.-:1.I
.,, (/
£AHL 0 . THOMPSON, Chairman
EARL J . DARK
~~~~!" R. E. BEAUCHAINE
Clerk
GORDON B. WHITE
HENRY DUNLAP, JR.
GUS MURCHISON, JR.
ROBERT L. GUNN
Counly Attomey
ORGANIZED 1770 707 SQUARE MILES
November 30, 1978
N. C. Division of Crime Control and Public Safety
~Ir. Dav id Kelly
P. 0. Box 27687
Raleigh, North Carolina 27611
Dear Mr. Kelly:
As we discussed earlier, there are some points that need to be
cleared up regarding the process by which the State and Chatham County
are attemtping to remove and store certain amounts of PCB contaminated
soil. They are as follows:
Time Frame and Description:
(a) Negotiate land sale
(b) Public Hearings
(1) State, EPA
(2) County
(c) Site Preparation ✓
(d) Collection and dumping of PCB contaminated soil t/
(e) Cover of PCB contaminated soil and finish the site a.:!./
(f) Monitoring U,'2./
(1) What specifically will be monitored? ..,;(,,(.,Y
(2) Who will do· the monitoring? A.#.J-'
(3). How long will monitoring _be done? :,MA/
( 4) How often will monitoring be done? _,1,.,.-/
There are some additional questions which I would appreciate your get-
ting Dr. Martin Hines to answer in a letter to me. They are as follows:
(a)
(b)
(c)
-7'-, How long will the chemical PCB. remain active? ~.,. __
What are the different aspects of the storage procedures .:.~,-=--
and what is the purpose of each?
What is the likelyhood of the chemical PCB reaching the :.,,_-.:_·.-,-
water table at the site?
(d) What are the possible negative environmental impacts to
neighboring lands? What is the probability of them
occuring?
(e) How many tons of material will be dumped?
-. ,...
.. ..
RESOLUTION
The Counti .Corranissioners of Chatham Co~~ty agree to sell to the State
of North Carolina, six acres of land at the county landfill site to be
used for the storage and disposal of PCB contaminated soil to include all
PCB contaminated soil now known to be in Chatham County.
2. No material shall be so stored prior to obtaining all pennits required
by law including but not limited to rules and regulations set forth in
Federal Register Volume 43, Number 34, Part V dated February 17, 1978, en-
titled Environmental Protection Agency, polychlorinated biphenyls, PCBs
disposal and marketi·ng.
3. Specifically,110:material shall be stored prior to obtaining permits
from EPA and after a notice and public hearing to be held in Chatham County .. Courthouse at a date to be announced.
·• .
.JAMES 8. HUNT, .JR.
IIOVPNOII
STATE OF NORTH CAROLINA
DEPARTMENT OF HUMAN RESOURCES
Division of Health Services
JACOB KOOMEN, M.D., M.P".H,
DIR&C:TOII
SARAH T. MORltOW, M.D.. N.P.H.
-lrTMIY P. 0. Box 2091 Raleigh 27602
December 5, 1978
MEMORANDUM
TO: David Kelly
Crime Control and Public Safety
FROM: Marshall Staton, Chief '-11la-~lt-,.J/ p$..,--,
Sanitary Engineering Sectfo~ 1
SUBJECT: Letter from Chatham County Regarding PCB
In accordance with discussion of Monday afternoon, we have compiled
a draft of answers to various questions contained in Mr. Coleman's
letter of November 30. As you will recall, there were a few questions
on which we were to collaborate with Epidemiology and with Bob Carter.
Since Bob Carter nor Dan Baucom were available to work on this today,
and today has been our most opportune time, we have prepared a response
unilaterally. We have forwarded a copy of our draft to Bob Carter and
Dan Baucom along with a request that they add any comments which they
believe desirable.
cc: Mr. Bob Carter
Mr. Dan Baucom
I I
First question
(e) There will be placed over the PCB contamJnated earth after it is placed
in the pit, 12 inches of clean earth, a 10 mil plastic cover, and l½ feet
of compacted earth, then 6 inches of top soil. All of the cover will be
on a 2 percent grade.
(f) (1) PCB, Ph, Conductance. No other chlorinated organics will be placed
in the site.
(2) North Carolina Department of Human Resources, Division of Health
Services, Laboratory Section.
(3) As long as necessary but at least 10 years.
(4) As required by the Environmental Protection Agency but at least
semi-annually.
Second Question
(b) The storage procedures as outlined b~low:
Two 10-feet lifts will be used~ The trucks will-back into the open end
of the pit and place the waste as near to the working face as possible
without the truck wheels getting on the waste. A track piece of equipment
will be used .to push and compact the waste into place. Clean earth will
be placed on the floor of the pit as needed to keep the trucks out of the
waste. The leachate collectio~ system will be constructed as placement
of the first lift progresses •. The open end .of the pit will be closed to
the level of the first lift. A 1-foot layer of clean earth will be placed
over the first lift so the trucks can be on a clean surface and the second
lift will be completed as the first. After the second lift has been com-
pleted, including placing the residue from the run-off collection system,
the open end of the pit will be completely closed. One foot of clean soil
will be placed on the top of the waste. A ten mil plastic cover on a 2
percent grade will be placed over this one foot Qf soil. Two feet of
compacted earth will be placed over the p.1.,stic cover on a two percent
-I I
(c)
grade. Erosion control procedures will be utilized as required by the
Division of Land Resources, Department of Natural Resources and Community
Development.
-7 . With a five foot clay liner (lxl0 ) a leachate collection system to
prevent any build up of a head, a plastic cover and three feet of earth
on a 2 percent slope to prevent the entrance of water. The possibility
of groundwater contamination is "nil".
(d) All contaminated waste will be placed at least 100 feet from all property
lines. We see no negative environmental impacts.
(f) Under the plan of operation, there will be more than enough built-in
security to prevent a public health hazard.
(g) There will be a minimum of 13 feet of soil between the waste and the
-7 groundwater with at least 5 feet of this being lxl0 • There will be at
least 3 feet of soil and a 10 mil plastic liner over the waste.
(h) All of the land except the approximately one acre pit area which will be
fenced, can be used as any other landfill border area, ·seeded or tree
farming. The fenced area will be grassed and not planted in trees so the
plastic cover will not be affected by roots.
\
345 COURTLAND STREET
ATLANTA, GEORGIA 30308
September 22, 1978
RE: Approved PCB Sites
TO: State Solid Waste Directors, Region IV
For your information, enclosed is a copy of the Federal Register
listing approved PCB facilities in the United States. As other
sites are approved for disposal, you will be notified.
Sincerely,
Enclosure
I
\
(6560-01]
(FRL 954-IJ
POLYCHlORINATED BIPHENYLS
. Approved PCB Dispos_al FacilitiH
On February 17, 1978, the U.S. Envi-
ronmental Protection Agency pub-
lished in the FEDERAL REGISTER the
final rule for the "Disposal and Mark-
ing of · Polychlorinated Biphenyls
CPCBs)" (43 FR 7150). (This rule is re-
_· quired by section 6(e><ll of the Toxic
Substances Control Act (Pub. L. 94-
469, 15 U.S.C. 2605(e)).)
Under this rule, · disposal of many
PCBs;· as defined in the regulation. is
prohibited subsequent to April 18,
1978, except at EPA approved facili-
ties. All facility approval:; wiil be
granted in writing by the appropriate
· Regional Administrator in which the
respective facility Is located.
· To date, the following facilities have
been approved by EPA under tn~ au -
thority of §§ 761.40(dl and 761.41(c) of
the PCB Disposal and M?.rking Regu-
lation to dispose of PCBs:
',. · EPA REGIO!'l II (26 Federal Plaza, New
York, N.Y. 10007)
.J. F.lC;Uy: ?:cwco Chemical Waste Systems, · Jnc.
Facility Address: 462~ Royal Avenue, Ni-
ai::.ra Falls, N.Y. 14303,
Facility Telephone No.: 716-285.69-H.
T)'p;! · or Facility .Approved:. Chemical
waste landfill. . . · .
. . 'l)·pe of PCB Waste Handfed: Capacitors , . <.small and large); Properly drained l trans!onners; Contaminated soil, dirt,
1 rags, and other debris; Dredge spoils;
t Municipal sludges; Properly drained
containers (drums>. ·
1 Expiration Date of Approval: August 8,
f-:-i:;.!81
~egio~al O!flce· Contact; Wayne I Pierre. · ·
{" EPA Telephone No.: 212-254--0505.·· ._ I : EPA REGION IV (3·!5 Courtland Street , ·:·: ·•. • . : NE., Atlanta..Ga. 30308>. ·
-1. Facility: Waste :Management.of Alabama. Inc.-· · ·
: -.. Facility Address: P.O. Box ·1200, Living-
: 1ton, Ala. 35470. . .
:· Facility Telephone No.: 205-652-9529.
j 'l)'l)e or P:tcility· Approvi:d: Chemical
;. ·. -wa.ste landfill. .
~: 'l)·pe o! PCB W?.ste 11:mdled:" Cap-icitcrs
~-: · (small and large); Properly c!ra:ned
:· - · transformers; Contaminated soil, dirt,
raes. and other debris; Dred):;e i;poils;
' · ··Municipal sludges; Prnperly drained • containers (drums>.
. Expiration Date of Approval: Open-. ended.• .
· EPA Regional Office Cor.t.act: Mr. James ScarbrouJ,th.
EPA Telephone No.: 4047881-3016.
NOTICES
EPA REGION X <1:?00 Sixth Avenue,
Seattle, Wash. 98101)
1. Facility: Chem:Nuclear Systems, Inc.
Facility Address: P.O. Box 1269, Portland.
Oreg. 97205-Main office <silt: located in•
· Arlington, Oreg.>. . .
Facility Telephone No.: 503-223-1912 .
Type o! Facility Approved: Chemical
waste landfill. ·
Type o! PCB Waste H:indled: Capacitors
(small and large); Properly drained
transformers; Contamba.ted soil, dirt,
rai:s. asphalt, a.'ld other c!ebris; Properly
drained containers (drums>.
Expiration Date o! Appro~·aI: _January 1,
1980. . EPA Regional O!!ice Contact: Mr. Roger
Fuentes.
EPA Telephone No.: 206-442-1260.
2. Facility: Wes-Con, Inc.
Facility Address: P.O. Box 564, Twin Falls,
Idaho 83301-Main office <site located in
. ·· Grand View, Idaho>. ·
--~ • Facility Telephone No.: 208-734-7711.
·.·---Type cf F.:.cility Approved: Disposal in
·,-·s.·mlssile silos.
·• ·a · Type of. PCB Waste Handled: Capacitors
<small and Jar.;e); Properly drained
. : .. trans!ormen;; Contaminated soil, dirt, ·. •··rags.asphalt, and other debris; Properly
drameJ cor,tainers (:lrJm~).
Expiration Date ol Approval: J'anuary 1,
1980.
EPA Regional Office Cont.act: Mr. Roger
Fuentes.
EPA Telephone No.: 205-442-1260.
•Non:.-After. January 1, 1980, PCB ca-
pacitors and contaminated soils, rags. and
other debris cannot be-disposed of in chemi-
cal waste landfills: A !-pt,ci:,I provision does
permit, without time limits, the dispc:;a! i:-i chemical waste landfills of cont;uninated soil and debris resulting from spiils er from
old disposal sites that-predate the PCB reg-
ulations.
Future notices, updating this list or
approved facilities will be published in
the FEDERAL REGISTER approximately
·every month. For further information
on the EPA approv~l of these disposal
. facilities, please get in touch \\ith the
appropriate EPA Regional Offic_c con-
tact.
·--Dated: August 15, 1978.
G. M. DIETRICH,
·· Acting Depuly Assistant
· Admini.stration for Solid Waste.
(FR Doc. 'IS-24017 Filed 8-24-78; 8:45 am}: ............
FEDEIIAl REGIST~R, VOL 43, NO. 166-FRIOAY, ~UGUST 25, 1978
. :
I
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.; . L O G
WEDNESDAY, AUGUST 16, 1978
10:00 A.M. -Met with Groundwater people to discuss potential sites.
2:00 P.M. -Lee Laymon and 0. W. Strickland visited the sites at Bunn (Franklin County)
and Nashville (Nash County).
2:30 P.M. -SCA of South Carolina gave cost estimates.
3:00 P.M. -Rail haul costs provided by Seaboard Coastline.
5:30 P.M. -Marshall Stat@n and Jerry Perkins attended Governor's Conference.
7:00 P.M. -Call to Bob Carter to get drilling rig on the road.
• I
THURSDAY, AUGUST 17, 1978
8:00 A.M. -Call from Prison Department with concern for prisoners' suits.
8:30 A.M. -Call to Highway Department for assistance in cleaning right-of-way at
Franklin County and Nash County sites.
9:30 A.M. -Marshall Staton talked with Mr. Williams at the Governor's office.
9:35 A.M. -Contacted Jack Lurcott, Rollins Environmental Service,for assistance.
Assistance requested from EPA.
10:00 A.M. -Met with Groundwater people to decide on exact locations to be bored.
10:15 A.M. -Notified the Department of Corrections that two of their properties
would be investigated.
1:00 P.M. -Drill rig arrived on site.
2:30 P.M. -Civil Defense called meeting foi costs estimate.
2:45 P.M. -Arrangements made with Groundwater to visit two sites in Alamance County
in a.m., Friday, August 18, 1978.
3:00 P.M. -Marshall Staton, Bill Meyer, and 0. W. Strickland traveled to Franklin
County site.
4:30 P.M. -Called back to Jerry Perkins asking him to contact Highway Department in
reference to drill and right-of-way clearance in Nash County.
THURSDAY, AUGUST 17, 1978 (cont'd)
4:45 P.M. -Jerry Perkins called Highway Department about placing two (2) drill rigs
on stand by and to confirm operator at Nash County site Friday morning,
August 18, 1978. Map was provided by the Highway Department showing location
of proposed disposal area (Chatham County).
5:30 P.M. -Jerry Perkins received call from Highway Department confirming operator on
duty at Nash County site Friday morning, August 18, 1978.