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HomeMy WebLinkAboutNCD980602163_19781221_Warren County PCB Landfill_SERB C_Adminsitrative Action Draft Negative Declaration - Removal and Disposal of Soil Contaminated with PCBs Along Highway Shoulders in NC-OCR' t Removal And Disposal of Soil Contaminated With PCBs Along Highway Shoulders In North Carolina ADMINISTRATIVE ACTION DRAFT NEGATIVE DECLARATION STATE OF NORTH CAROLINA IN COMPLIANCE WI TH THE NORTH CAROLINA ENVIRONMENTAL POLICY ACT av1 e Assistant Secretary Department of Crime And Public Safety lie Safety I. II. TABLE OF CONTENTS DESCRIPTION OF PROPOSED AC1ION A. B. C. D. E. History of PCB Spill Purpose of Action 1. 2. 3. Definition of PCB s Regulation's Pertaining to PCB Spills Cost Estimate Description of Removal and Disposal Action 1. 2 . 3. Soil Removal Transport Disposal Method Alternatives Considered 1. 2. 3. Alternative Methods of Treatment Alternative Sites Considered No Action Description of Enviornmental Setting 1. 2 . Roadside Disposal Site PROBABLE ENVIRONMENTAL IMPAC TS A. B. Soil Removal 1. 2. 3. 4. Air Quality Water Quality Plant and Non-Human Animal Life Traffic Disruption Disposal Methods 1. 2. 3 . 4. 5. 6. Geology Hydrology Plant and Non-Human Animal Life Air Quality ' ' Land Use Cultural Resources Page 1 1 4 4 5 6 6 6 12 12 20 20 22 23 23 23 23 25 25 25 31 34 35 35 35 38 38 39 39 39 I I I. IV. V. VI. C. TABLE OF CONTENTS (Cont'd) Effect on Workers, Motorists, and Area Residents BASIS OF NO SIGNIFICANT AD VERSE EFFECT DETERMINATION A. B. c. D. Standards for Allowable Concentrations Studies and Test Results EPA Penni t Mitigation Measures COORDINATION AVAILABILITY OF STATEMENT SUMMARY Page 39 41 41 .41 41 41 42 42 42 Removal And Disposal of Soil Contaminated With PCBs Along Highway Shoulders In North Carolina DRAFT NEGATIVE DECLARATION I. DESCRIPTION OF PROPOSED ACTION A. History of PCB Spills The first deliberate discharge of what was later identified as PCB liquid materials took place the last week of June, 197 8, on remote, roads of the Fort Bragg Military Reservation. The discharge was investigated by Fort Bragg personnel who secured liquid samples of the material. The next discharge occurred on July 27 and July 29 on the roadway shoulders of NC 58, north of Centerville in Warren County. This discharge was reported by private citizens to the N. C. Highway Patrol, who alerted the Division of Health Services, Water Supply Branch. Water Supply Branch personnel notified Division of Environmental Management, Water Quality Program person- nel in the Raleigh Field Office of the spills. Raleigh Field Office personnel investigated the spill on July 31 as an oil spill and on finding no oil ponded or evidence in surface waters, returned to their office without taking further action. On August 2 the Water Quality Operations Branch, Division of Environmental Management, received a call from a Johnston County farmer concerning a spill on NC 210 in front of his farm. Because of the description of the odor and the effects on field workers being re- ported, by a staff chemist was immediately dispatched to investigate the spill and to take appropriate samples. Grass, soil, and water samples were hand delivered to the Division of Environmental Hanagement Laboratory for analy- sis later that afternoon, August 2. The same chemist who investigated the Johnston County spill encountered a simi- lar spill near Snow Camp, North Carolina on SR 1004, Alamance County, while returning to his home. A samp l e was taken from the spill area and hand delivered to the laboratory the following morning for analysis. On August 4, the Laboratory's Analytical Section Chief notified the Water Quality Operations Branch that the material spilled in Johnston County appeared to be Aroclor-1260, a Polyclorinated Biphenyl (PCB) compound. The Water Quality Operations Branch immediately notified the Chief of the Environmental Protection Agency, Region IV, Emergency Response Branch, of the Laboratory's find- ings. After briefing the Director, Division of Environ- mental Management, a meeting was called with representa- tives of the Attorney General's Office, the Department of Crime Control and Public Safety, and Public Informa- tion representatives of the Secretary of the Department of Natural Resources and Community Development. A noti- fication to all law enforcement officials was prepared and sent over the Police Information Network system during the late evening hours of August 4. A news re- lease was prepared and sent to local newspapers for publication in the Saturday morning newspaper. The same day, the laboratory confirmed material discharged in Alamance and Chatham Counties were Aroclor-1260, the same form of PCB material found in Johnston and Harnett Counties. On August 5, Water Quality Operations Branch met with concerned citizens in Johnston County, investigated the spill areas in Johnston and Harnett Counties, and conducted a door-to-door contact with people residing along NC 210. because of concern by some residents along ~C 210, the Division of Highways, Department of Transportation, was request~d to cover the spill with a layer of sand in order to suppres$ the noxious odors present. This was completed in late afternoon August 5 and continued on A~gust 6. 2 On August 6 the Raleigh Regional Office was directed to secure samples of the spill area in Warren County to determine if similar material had been deposited along NC 58. Because of the publicity being given by the news- paper and TV to the spills, the Fort Bragg Environmental Coordinator requested the Water Quality Operations Branch to analyze material secured from the spill at Fort Bragg to determine if similar material was spilled on the mili- tary reservation. Because of the publicity , reports of spills began coming in from many different sourc~s such as Highway Patrol, Department of Transportation Division Engineers, private citizens, and others in nine additional counties. It appeared that most of the spills took place the evenings of August 1, 2, and 3. While it has not been conclusively determined, as yet, spills may have occurred in Wilson County the evenings of August 5 and August 8. The Division of Environmental Management Laboratory con- tinued to work around the clock to verify the material in the spills in the other counties. On August 7, a preliminary conference was held with representatives of the Division of Highways, Division of Health Services, Attorney General's Office, and Public Information personnel. Specific information gathering activities were spelled out and assigned to specific people. A coordination conf~rence was held with repre- sentatives of the Department of Human Resources, Depart- ment of Agriculture, Attorney General's Office, the Department of Transportation, Environmental Protection Agency, and the news media, on August 10. A working ses- sion was held following the briefing to news media to provide direction, identify responsibilities and initiate specific actions concerning the , spilled material. Advice was solicited from the Environmental Protection Agency Toxic Substances Office, the National Center for Disease Control, Hevi Duty Electric Company, the Health Effects Laborator y, and various academic and private sector per- sonalities known as having expertise in handling this type of material. North Carolina State University was identified as having expertise in detoxifying pesticides. The Univer- sity was contacted to provide expert advice and assistance . A proposal was submitted to the Governor for temporarily 3 deactivating the PCB materials to prevent its migration and to neutralize any hazard to people coming into con- tact with the material on the shoulder of the highway. The Governor provided directive authority to proceed on August 15, 1978. An activated charcoal solution was applied to the PCB contaminated roadway shoulders during the latter part of August. Because the initial sampling procedures only gave gross approximation to the concentration of PCB material on the grass and in the soil column, in order to deter- mine the magnitude of the penetration into the soil column and the strength of the material at various depths, several cross sectional samples were taken at one-inch intervals in order to obtain quantitative data. These samples were taken during the period August 21 -28. On September 6, 13, and 19 alternative methods of removing soil from the roadway shoulders were conducted on noncontaminated sections of roadway shoulders. When the soil removal procedure had been formulated a test removal operation was conducted. The test removal opera- tion was performed on October S, 1978 on a one mile PCB contaminated section of NC 58 near Inez in Warren County. The PCB contaminated soil obtained during the test re- moval operation has been temporarily stored at a dis- posal site in Warren County. B. Purpose of Action 1. Definition of PCBs PCBs (polychlorinated biphenyls) are a class of chlorinated, aromatic compounds which are highly stable, relatively inert and display excellent elec- trically insulating properties. PCBs have been pro- duced since 1929. The Monsanto Company preparations of PCBs are termed "the Aroclors". PCBs are complex mixtures of chlorobiphenyls with different numbers of chlorine atoms per mole- cule. They are nearly insoluble in water and are very stable at high temperatures. PCBs are heavier than water and do not float on top of water as oils do. Some PCBs have been shown to have insecticidal and fungistatic activity however, they have not been used as pesticides. PCBs have relatively low toxi- city to mammals compared with most pesticides. Some industrial usages of PCBs are: 1) dielectric 4 fluids in capacitors and transformers, 2) industrial fluids in hydraulic systems, gas turbines, and vacuum pumps, 3) fire retardants, 4) heat transfer agents, 5) plasticizers in adhesive, textiles, sealants and printing. 2. Regulations Pertaining to PCB Spills The Environmental Protection Agency has pro- mulgated rules and regulations pursuant to the Toxic Substance Control Act to protect the environment from further contamination by PCBs resulting from improper handling and disposal of PCBs. Title 40 Part 761.10 (b) (3) of the Toxic Substances Control Act spells out disposal requirements of PCB mixtures in soil and the legal authority of the Regional Administrator EPA to require clean up and removal. This regulation defines a PCB mixture to mean any mixture with 500 parts per million (ppm) of PCB. The referenced regu- lation requires that contaminated material containing concentrations of PCB greater than 500 ppm must be disposed of through either incineration or disposal in a chemical landfill. Criterion for any such land- fill is contained in Annex II to the referenced re- gulation. Specific wording in C.F.R. 40 Part 761.10 (b) (3) is as follows: "Soil and debris which have been contaminated with PCB as a result of a spill or as a result of placement of PCBs in a disposal site prior to the publication date of these regulations shall be disposed of (i) In an incinerator which complies with Annex I, or (ii) In a chemical waste landfill." The same regulations provide for applying in writing to the Regional Administrator for approval of alternate "disposal methods when disposal in an incinerator or chemical waste landfill is not rea- sonable and appropriate, based on technical, environ- mental or economic considerations, and information that the alternate disposal method will provide adequate protection to health and the environment." 5 3. Estimated Costs for Removal and Disposal The total estimated cost for removal and dis- posal of the PCB contaminated soil from the roadway shoulders is $2.0 million. c. Description of Removal and Disposal Action 1. Soil Removal Shortly after the PCB spills occurred, measures were taken to contain the PCB compound spilled along the roadway shoulders. An application of a 10% solu- tion of activated carbon applied at the rate of one gallon per square yard then followed by an applica- tion of liquid asphalt at the rate of one-tenth of a gallon per square yard were applied to the roadway shoulders where the PCB spills have occurred. Figure 1 is a location map indicating the approximate loca-' tion of the PCB spills. A more detailed description of the spill locations are included in Table 1. The activated carbon solution was utilized to deactivate the surface concentration of PCB by absorp- tion of the PCBs into the pores of the activated car- bon. The liquid asphalt was applied to eliminate dusting of the activated carbon and to reduce run-off of the activated carbon caused by storm drainage. These applications also served to delineate the con- taminated areas. The method of removing the PCB contaminated soil from the roadway shoulders will consist of the fol- lowing sequential steps: a. The contaminated area will be thoroughly wetted down with water, if necessary, in order to control dust during the removal and disposal operations. This may not be required during wet seasons, but on the other hand, may be required as much as 24 hours in advance during extremely dry con- ditions. This operation is recognized as extremely critical in the total removal operation and will be stringently controlled. 6 LOCATION MAP 111n111 PC 8 SPILLS FIGURE I 0 5 I ■ M IQ 20 SC~LE OF MILES 30 TABLE 1 1. SR 1004, Alamance County -From Bethel Church north of Snow Camp to the Chatham County Line. Length: 5.00 shoulder miles 2. SR 1004, Chatham County -From Alamance County Line to SR 1346. Length: 2.22 shoulder miles 3. SR 1346, Chatham County -From intersection with SR 1004 to NC 87. Length: 11 .16 shoulder miles 4. NC 87, Chatham County -From intersection with SR 1346 southerly. Length: approximately 1.42 shoulder miles 5. US 421, Chatham County -SR 2120 to Lee County Line. Length: 9.59 shoulder miles 6. SR 1006, Chatham County -Between NC 902 and NC 42. Length: 3.46 shoulder miles 7. NC 42, Chatham County -From Deep River (Lee County Line) to intersection with SR 1006. Length: 4.56 shoulder miles 8. NC 902, Chatham County -From SR 1006 to Rocky River. Length: 9.68 shoulder miles 9. SR 1146, Edgecombe County -From US 301 to SR 1135. Length: 2.40 shoulder miles 10 . SR 1135, Edgecombe County -From SR 1146 to SR 1143. Length: 2.43 shoulder miles 11. SR 1143, Edgecombe County -From SR 1135 to SR 1141. Length: 0.51 shoulder miles 12. SR 1130, Edgecombe County -From SR 1003 to NC 43. Length: 1.33 shoulder miles 13. SR 1141, Edgecombe County -From SR 1143 to NC 43. Length: 1.43 shoulder miles 14. NC 44, Edgecombe County -From $R 1409 east . . 0.2 miles. Length: 0.23 shoulder miles 7 TABLE 1 (Cont'd) 15. NC 43, Edgecombe County -From SR 1130 to SR 1131. Length: 0.87 shoulder miles 16. SR 1003, Edgecombe County -From NC 43 to Wilson County Line. Length: 3.38 shoulder miles. 17. SR 1432 and SR 1436, Franklin County -From 1/2 mile east of Moulton to a point beyond Gupton, then traces to Center- ville. Length: 5.10 shoulder miles 18. NC 561, Franklin County -From Nash County Line to Center- ville. Length: 4.80 shoulder miles 19. NC 58, Franklin County -From Warren County Line to Nash County Line. Length: 5.10 shoulder miles 20. NC 98, Franklin County -From Nash County Line to Bunn and approximately 5 miles west of Bunn. Length: 4.70 shoulder miles 21. NC 97, Franklin County -From Wake County Line to Nash County Line. Length: 0.90 shoulder miles 22. NC 96, Granville County -From just north of Oxford to NC 49. Length: 15.2 shoulder miles 23. NC 49, Granville County -From NC 96 to Person County Line. Length: 1.80 shoulder miles 24. SR 1315, Halifax County -0.2 miles from NC 4 to 0.1 mile east of bridge. Length: 1.03 shoulder miles 25. SR 1308, Halifax County -From 0.1 mile north of SR 1309 to 1.2 miles north. Length: 1.18 shoulder miles 26. NC 4, Halifax County -From SR 1314 to SR 1308. Length: 3.13 shoulder miles 27. NC 43, Halifax County -From Warren County Line to NC 561. Length: 0.65 shoulder miles 8 TABLE 1 (Cont'd) 28. NC 561, Halifax County -From SR 1317 to Nash County Line. Length: 3.58 shoulder miles 29. NC 87, Harnett County -From Lee County Line to NC 27. Length: 5.30 shoulder miles 30. NC 27, Harnett County -From NC 87 to SR 1252. Length: 12.00 shoulder miles 31. NC 210, Harnett County -From Johnston County Line to city limits of Angier. Length: 1.82 shoulder miles 32. NC 210, Johnston County -From ,intersection with US 70 southerly to Harnett County Line. North side only. Length: 17.00 shoulder miles 33. NC 42, Lee County -From intersection with SR 1322 to Deep River (Chatham County Line). Length: 4.52 shoulder miles. 34. NC 87, Lee County -From Harnett County Line to US 421. Length: 2.14 shoulder miles 35. NC 98, Nash County -From Franklin County Line to NC 231. Length: 1.41 shoulder miles 36. NC 231, Nash County -From NC 98 to SR 1137. Length: 0.94 shoulder miles 37. SR 1137, Nash County -From NC 231 to NC 97. Length: 3.48 shoulder miles 38. NC 97, Nash County -From SR 1137 to Franklin County Line. Length: 4.39 shoulder miles 39. NC 58, Nash County -From Nashville to Wilson County Line. Length: 4.12 shoulder miles 40. NC 561, Nash County -From Franklin County Line to Halifax County Line. Length: 0.7 shoulder miles 41. NC 97, Nash County -From NC 58 west 1 mile. Length: 0.35 shoulder miles 42. NC 58, Nash County -From Franklin County Line to 3 miles north of Nashville. Length: 4.11 shoulder miles 9 TABLE 1 (Cont'd) 43. NC 49, Person County -From Granville County Line to SR 1515. Length: 4.24 shoulder miles 44. NC 96, Wake County -From 98 to Franklin County Line, to traces only. Length: 0.30 shoulder miles 45. NC 97, Wake County -From Zebulon to Franklin County Line and from US 64 Bus. to Zebulon. Length: 4.50 shoulder miles 46. NC 43, Warren County -From Liberia to Halifax County Line . Length: 6.40 shoulder miles 47. NC 58, Warren County -From intersection with NC 43 southerly to Franklin County -both sides. Length: 19.25 shoulder miles 48. us 158, Warren County -Between Macon and Vaughan. Length: 0.60 shoulder miles 49. SR 1407, Wilson County -From SR 1003 to SR 1002. Length: 1. 06 shoulder miles so. SR 1419, Wilson County -From us 301 to SR 1003. Length: 0.87 shoulder miles 51. SR 1003, Wilson County -From Edgecombe County Line to US 301 Bypass. Length: 4.76 shoulder miles Total Length: 210.97 shoulder miles. 10 b. The contaminated shoulder area will be trenched out approximately 24"-30" wide, and approximately 3,i deep by means of a motor grader equipped with a specially designed blade to allow for the cutting of a reasonably neat line trench, working with all motor grader wheels on the pave- ment. The trenched out material will be fed along the motor grader blade to form a windrow of material located inside the edge of pavement. c. The windrow of contaminated material will be mechanically picked up and fed into trailing dump trucks by means of an Athey force-feed loader. This loader operation forces the contaminated material onto a self-contained belt conveyor by means of rotating paddles. The material is con- veyed up the belt and dropped into dump trucks. A specially designed canvas shield will extend from the top of the belt down into the dump truck bodies to prevent wind drift of the contaminated material. d. The Athey loader is designed to scrape the road surface; however, very thin amounts of residue will be left on the road sur- face following the loader operation. Depending on soil moisture conditions, this residue will be either water sprayed back into the excavated trench or broomed, by means of a tractor mounted rotary broom or a corabination of both spraying and brooming. Spraying will be performed by a Hydroseeder with especially designed adjustable outlet nozzles and the broom will be covered with a specially desigped canvas cover to minimize dusting and wind drift. e. Reshaping of the disturbed shoulder area will immediately follow the removal operation. Depending on the width and cross slope of 11 the existing shoulder, reshaping will con- sist of either scarifying and reshaping of the shoul der by a motor grader, or fil ling in the excavated area with borrow soil material and shaping with a motor grader. f. The shoulder reshaping operation will be followed by erosion control operations consisting of seed bed preparation, seeding, fertilizing and mulching of all disturbed areas. 2. Transport Once the contaminated material is deposited in dump trucks, the dump bodies will be tightly covered with tarpaulins using elastic tie-downs. Insofar as possible and practical, contaminated material will be hauled to the disposal areas along rural routes, avoiding highly congested areas. Hauling of contaminated material will take place only during daylight hours. Vehicles equipped with mobile radio units will routinely survey the haul routes for trucks with mechanical difficulty. In the event of mechanical trouble, mechanics will be radio dispatched. 3. Disposal Method a. Construction Procedure The disposal site for the PCB contaminated soil is located on approximately 142 acres of land in Warren County. The exact site location is shown on a County Map and a U. S. Geodetic Map (see Figure 2 & 3). The State of North Carolina proposes to construct the PCB landfill in accordance with plans approved by EPA. Figures 4, 5, and 6 are conceptual sketches of the landfill. A general description of how the landfill will be constructed follows: 1. Excavate to within seven feet of the high groundwater elevation. 2. Select borrow and stockpile which will allow reconstitution and compaction of a five-foot liner which will have a maximum permeabi lity of lxlo-7 cm/s. 12 '\ 0 C -z. 36°:IO' / ' J F R N N WARREN COUNTY D . I e1 'I I ·) u N y I , ' 1 FIGURE 2 13 SCALE' 0 J 'I ,.,, 'b . r~~ ' . ,,,(\/. , I ]: I N \ I, cfl, -\ , ) 1(\(1,_,,/ ' ,v \ \ ' ,) l\\1 ' ! \ , ' I I I . ,' DISPOS ' ' r V Pit Ar ·<> ✓<l, \ "', . . ('\...\ Contour Interval 10' c__,; V . () ~ /·,--. -~ a /." I i , ~ • ' -__.,; ... 11 CONCEPTUAL., PLAN VIEW and Surface Drainage Plan A ~-------+------"', --------~---------:,• I I •1: ------------------ NOT TO SCALE 15 - - - --1 I I I --; I I I I ----, l EXISTING GROUND • • • • • • •E~~V~:I~: ~ ---... ....._• .... .... °' ------..._...._ ..-"'.:. T 10' t 7' --CONCEPTUAL PLAN CROSS SECTION A-A FINISH GRADE /ELEVATION --------1r-------............ lf;://.1::j COMPACTED -CLAY LINER .. . . . . . . . . . • • • PVC PIPE ----e.R1TABLE _____ _ NOT TO SCALE PLASTIC LINER 'y'" ' ' \. \. \. \ \ '-.................. ------. .......... . FIGURE 5 --------~ ., CONCEPTUAL PLAN CROSS SECTION B-B ---FINISH GRADE ELEVATION L---PLASTIC ---;L~N~R-EXISTING ~ • • • • • • • •• GROE~~~ION 'r -• • • • • ••• • •• • 1 EL • • •. •• 1, ........................................ ·-............ . . .. .. . ..... .. -.:i NOT TO SCALE 1' COMPACTED CLAY LAYER ._, . , 7' ....... .... ' ' ' .... . ..... . ... -------------FIGURE 6 3. Construct five-foot liner in the bottom of the trench and up the sides five feet in elevation. 4. Install 4-inch PVC perforated leachate collection system leading to a sump which will allow liquid withdrawal for the relief of any head buildup. S. 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. 6. The side slopes will be 2:1. 7. The waste will be placed on top of the one foot sand in lifts as described in the operations plan. 8. When all the waste is in place, the landfill will be covered with one foot of soil (excavated 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 place,.l on top of the liner and six inches of topsoil will be placed on top of this. 9. The top surface will be sloped at about two percent to facilitate runoff of rainfall. The top will be seeded with a perennial grass. 10. All surface drainage during construction and after completion will be diverted from the landfill surface. b. Operational Pl~n 1. Excavation The backfill and placing of PCB conta- minated soil will be completed as follows: Two ten foot lifts will be used. The trucks will back into the open end of the pit and place the waste as near to 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 18 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 collection system will be constructed as placement of first lift progresses. The qpen end of the pit will be closed to the level of the first lift. A lfoot 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 completed, including placing the residue from the runoff collection system, the open end of the pit will be completely closed. One foot of clean soil ~ill be placed on top of the waste. A ten mil plastic cover on a 2 percent grade will be placed over this one foot of soil. Two feet of compacted earth will be placed over the plastic cover on a 2 percent grade. Erosion control procedures will be utilized as required by the Division of Land Resources, Department of Natural Resources and Community Development. 2. Surface Runoff Surface runoff from the pit area will be collected in a holding pond. The water collected in the holding pond will be ana- lyzed for PCB, and if negative, the water will be released to surface drainage. If the analysis for PCB's is positive, then the water will be processed through a car- bon 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. 3 . Leachate Collection System Leachate collection system will con- sist 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 completed surface with a cover and lock. One foot porous material will be placed over the clay liner to enclose the perfo- rated pipes. 19 4 . 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 two below, with one of the wells located at the area with the lowest ground- water. Sampling and monitor ing of the leachate collection system, t he wells, and the receiving stream will be carried out as recommended by the Environmental Protec- tion Agency. Background samples will be collected and analyzed prior to the placing of any waste. 5. Supportive Facilities A six foot chain link fence with barbed wire topping will be installed around the disposal area to prevent un- authorized persons and animals from en- tering. The site will be periodically inspected and maintained in a manner to insure security and to prevent hazardous conditions from developing. c. Estimated Waste Volume The landfill site will be constructed to accommodate up to 40 ,000 cubic yards of soil contaminated with PCBs. D. Alternatives Considered 1. Alternatives Method of Removal and Treatment a. Removal 1. Cons j dera tion was given to the use of vacuum pick up of the residue l e ft behind the Athey loader operation; however, simulated removal opera tions utilizing both state owned and commer- cially available vacuum trucks r e- vealed that this method was very non-productive and did not elimi nate the need for spraying/brooming of the pavement surface. 20 2. Consideration was given to the utili- zation of mechanical loaders which could load directly from the contami- nated shoulder area directly into dump trucks without moving the con- taminated material onto the pavement. It was determined that the predominant existing shoulder width would not ac- commodate these type loaders. 3. Consideration was given to vacuuming the material directly from the con- taminated area into specially de- signed dump truck bodies. Simulated removal operations indicated this method to be non-productive and sus- ceptible to dusting and wind drift problems and, therefore, not appro- priate. b. Treatment Many unproven techniques for treatment of the PCB spill were considered. Some of the methods of treatment considered included bac- terial seedings, biodegration, microwave de- struction, plasma jet destruction and other methods. Only three alternatives were consid- ered as potentially viable methods of treat- ment and disposal of the PCB contaminated soil. These alternatives are as follows: 1. Treatment in Place It was determined that long-term neutralization and fixation could be achieved through mixing high ionic bonding potential, activated charcoal with the contaminated soil and then distributing this material deeper into the soil column of the highway shoulder. This would be followed by packing, seeding, and reshaping of the highway shoulder and a continuous maintenance program to insure that erosion and soil migration did not occur. This procedure would result in a soil PCB mix- ture well below 500 ppm concentration with most of the PCB particles being deactivated through bonding to carbon particles. The 21 Regional Adminjsirator, Region IV, EPA has not considered this approach to meet minimum requirements of the Toxic Sub- stances Control Act. 2. Incineration Three incinerators have been identi- fied as having the capability to destroy the PCB material through incineration. These incinerators are located in New Jersey, Arkansas, and Texas. At the pre- sent time, these incinerators have not been issued permits by EPA which would authorize them to accept and dispose of PCB materials. Additionally, transporta- tion and handling logistics would make this alternate cost prohibitive. 3. Chemical Waste Landfill Consideration was given to trans- porting the PCB contaminated soil to an existing chemical landfill located in Alabama. This Alternative was considered not feasible, because of limited transpor- tation resources , manpower requirements, and excessive cost of disposal estimated at $12.0 million, as well as the hazardous nature of the long distant haul. 2. Alternative Sites Considered There were approximately 90 sites in 20 counties, on public and private land, which were investigated. Most of the sites were eliminated due to the location being within a public water supply watershed, private water supply well too near, soil conditions, rocky terrain, and access problems. Eleven sites were drilled to establish soil conditions, water table, etc. After all subsurfas e data had been evaluated five of the eleven sites drilled were given fur- ther consideration. It is anticipated that the site chosen can meet EPA requirements and is consid- ered the best site when considering land availability, proximity to populated areas, access, relative loca- tion to total spill and site preparation. 22 3. No Action The no action or "Do Nothing" Alternative was not considered a viable alternative because of EPA regulations. E. Description of Environmental Setting 1. Roadside The discharge of material containing PCBs occurred on approximately 211 shoulder miles of North Carolina highways. The PCB spills have been identified in 14 counties. See Figure 1 for a general location of the spill areas. The discharge of material containing FCBs occurred mainly in ru- ra.1 areas on the roadway shoulder within 12 inches of the pavement edge. 2. Disposal Site a. Geology The proposed disposal site is located in the northeastern North Carolina Piedmont Plateau, approximately four miles south of Warrenton, North Carolina. The site is more than 20 miles northeast of the maximum exten- sion of the Jonesboro Fault. Site geology consists of foliated and gneissic rocks striking in a northeast direc- tion. Predominant rock types include biotite- feldspar gneiss, quartzitic gneiss, garneti- ferous biotite gneiss, and interbedded mica schist and gneiss. All are metamorphic rocks which show banding, foliation, or gnessic tex- ture. The mica gneiss on-site is deeply wea- thereed, forming thick layers of brown-red clay residum soils . Residum soils are clas- sified as: clayey, kaolinitic, thermic, typic hapludults. The aquifer below this site is associated with consolidated bedrock, flows toward topo- graphic lows, and groundwater encountered in the site borings indicates the upper aquifer elevations. Local existing wells on ridges and elevations similar to this site have a depth of 40-47 feet to water table. 23 The disposal site is located on a hill well above the floodplain, as can be seen by the location on the USGS map (see Figure 3). There is no hydraulic connection between the waste and any ground or surface water. The bottom of the waste will be a minimum of 13 feet above the seasonal high groundwater ta- ble. b. Environmental Profile The proposed disposal site occurs on open, rolling cultivated land presently utilized for soybean production. In addition to the soy- beans, various weeds and grasses have been ob- served growing on the proposed disposal site and include such species as foxtail, ground cherry, thistle, broomsedge, ragweed, aster, and horseweed. Mixed deciduous hardwoods in association with pine occur on the periphery of the soybean field. Oaks including white, southern red, black, and post, red maple, sweetgum, tulip poplar, hickory and loblolly pine are the major canopy species present. Understory species consists of redbud, dogwood, American holly, red cedar, and winged sumac scattered among small shrubs, saplings and vines -primarily honeysuckle. 24 II. PROBABLE ENVIRONMENTAL IMPACTS A. Soil Removal 1. Air Qualityl a. Ambient Air Monitoring Off-road sampling sites were established at four locations along the proposed one mile (1.6 km) test site on NC 58 near Inez, Warren County, North Carolina. These sites were 30 m (100 ft) from the line of removal on either side of the highway and are designated as sites A, B, C and Din Figure 7. Two additional air samplers were located on either side of the tem- porary storage site, about 2 m from the outer edge of the plastic soil liner. The storage area monitoring sites are designated E and Fin the inset in Figure 7. Background samples were collected one day prior to the test dig at all sites except A and B. Power generator problems interferred with pre-dig sampling at these sites. All sites were monitored for 4 hr during the removal operation and again one week afterwards. During the removal operation, the air sampling was begun when the first vehi- cle (1st hydroseeder) of the removal train ap- proached within 90 m (100 yds) of the appro- priate pair of samplers. That is, samplers at sites A and B were started when the train came within 90 m and were operated for 4 hr beyond that time. The same procedure was used at sites C and D. At the storage site, sampling was begun when the first dump truck arrived and was continued for 4 hr. Aroclor 1260 was found in the ambient atmosphere at all sites monitored. Air levels were generally in the 0.01 to 0.05 micrograms/m3 range (see Figure 7) before, during and after lThe following Air Quality analysis and results are taken from "Studies Conducted In Connection with PCB Spills In North Carolina", Analytical Chemistry Branch, Environmental Toxi- cology Division, Health Effects Research Laboratory, U. S. Environmental Protection Agency, Research Triangle Park. 25 AMBIENT AIR MONITORING SITE A SITE B SITE C SITED SITE E SITE F AIRBORNE ~ ~ ~ i ~ i ~ i ! ~ i ~ i PCB* i:r: i:r: i:r: i:r: ! 0 H w 0 H w 0 H · w 0 H i H ~ H (µg/m3) ~ i:r: 8 ~ i:r: 8 i:.. i:r: 8 ~ ~ g:: ~ II, 0 r.. 0 ~ ~· 0 ~ 5 ~ IXl 0 ..t IXl 0 0 al 0 Less than 0.01 X X X lt 0.01 -o.os X X X X X X X X X X X More than 0.05 X ·-* as Aroclor 1260 (0.06) ~WIND INEZ -0 END @] 1/4 MILE STORAGE SITE Figure 7. Ambient air monitoring at Warren County test removal site. 26 the dig. This corresponds to 8 to 42 farts- per-trillion (wt/wt) for dry air at 20 C and 760 mm Hg. Several values were below 0.01 micrograms/m3 and one was above 0.05 micro- grams/m3. The range 0.01-0.05 micrograms/m3 constitutes normal levels of PCBs found in most areas of the United States. However, atmospheric levels of PCBs in rural, non-in- dustrialized areas such as that near Inez would be expected to fall into the 0.005 to 0.015 micrograms/m3 range. The fact that levels are generally higher than this and the distribution matches that of Aroclor 1260 (PCBs in the ambient atmosphere usually more closely resemble Aroclor 1254) indicate that there is a specific source of Aroclor 1260 in the area. The quantities of Aroclor 1260 collected as airborned dust and vapors are tabulated in Table 2. In most cases vapor levels were higher than dust levels. However, some of the particulate-bound PCB would be expected to volatize from the collection filter into the vapor trap during the 4 hr sampling period. In only one case was the PCB dust level found to be significantly greater than the vapor level. At site A, the only site where levels exceeded 0.05 micrograms/m3, some 60% of the Aroclor 1260 was found on the particulate filter. This site was downwind from the high- way and near the beginning of the digging operation. The initial sweeping of the road surface after pick-up of the excavated dirt was done without a preliminary water spray. The sweeper was observed to generate appre- ciable dust levels, which were swept by the wind in the direction of sampling site A. The total Aroclor 1260 air concentration mea- sured at this site was 0.06 micrograms/m3 (50 parts-per-trillion), which is at or below PCB levels which have been reported for air in residential areas in highly industrialized areas. Because of the problems with wind- blown dust, the procedure was changed early in the removal operation and water was applied to the road surface residue prior to sweeping. Observable dust levels were considerably di- minished, and subsequent measurements (at sites C and D) were substantially lower. It 27 Site A0 ~ lahle Z Airborne Aroclor 1260 Concentrations in Micrograms per Cubic Heter of Air Near Test Re110val Site In Warren County, North Carolina'" Site e Site C Site D0 Airborne (Tobacco field, west side) (Tobacco field, east side) (Thorne garden, east side) (Thorne lane, west side) state Before During After Before During After Oust 0.038 0.002 -0.001 0.003 Vapor 0.026 0.008 0.010 0.010 Total -0.064 0.010 -0.011 0.013 *Dates of sa111pllng: Before 10/04/78; During 10/05/78; After 10/12/78. '"*Oownwind during dig. N 00 Before During After Before During After 0.005 0.001 0.002 0.002 0.012 0.001 0.017 0.006 0.006 0.012 0.011 0.005 0.022 0.007 0.008 0.014 0.023 0.006 Site E** Site F (Dump site, far side) (Du111p site, near side) Before During After Before During After 0.010 0.009 0.001 0.002 0.00~ 0.001 0.014 0.025 0.011 0.009 0.009 0.006 0.024 0.034 0.012 0.011 0.014 0.007 should be noted, however, that the downwind sample (collected at site D) was the only other sample to show dust levels higher than vapor levels. Weather data for the three sampling dates (October 4, 5 and 12) were not recorded, and will not be available from the National Clima- tic Center, Asheville, North Carolina, until late November, 1978. However, the weather was apparently similar to that recorded at the Raleigh-Durham Weather Station on those dates. High temperatures were 25 to 27°C on each day and lows were 16uC on October 4 and 5 and 9°C on October 12. There was no precipitation during the daylight hours on any of these days. However, heavy rains occurred during the night on October 4-5 and heavy fog prevailed the test site early in the morning of October 5. By the time digging was begun at about 10:00 a.m., there was high haze and the ground ap- peared to be damp (but not damp enough to pre- vent blowing dust). Wetting of the road shoulder before dig- ging was apparently effective in keeping dust levels down during dumping of the trucks at the temporary storage site. No significant enhancement of particulate-bound PCB was de- tected at sites E or F, and little if any in- crease in total airborne PCB was measured within two meters downwind of the dumping. Vertical profile measurements were taken at one site along the test removal route one day before and one week after the removal. Portable low volume air samplers were used for this purpose and only vapors were sampled for a period of 4 hr. Air was sampled at several levels directly above the spill on the road shoulder between sites C and D. Five levels were sampled prior to removal, but due to a shortage of air samplers only three levels were sampled afterwards. Data are presented in Table 3. The concentration measured at 60 cm after removal (0.14 micrograms/m3 is suspected to be in error. 29 Table 3 Vertical Profile of Aroclor 1260 Air Concentrations Directly Over Treated Spill on NC 58 Test Site (Warren Co.) Distance above spill (cm) 2 30 60 120 180 Conclusions Air Concentration micrograms/m3) Before removal After removal 0.90 0.09 0.02 0.01 0.01 0.05 0.14 0.01 The presence of PCBs in the air at normal breathing levels (i.e., above 120 cm or 4 ft) was not f ound to exceed ;he NIO~H proposed criterion for workplace air of 1 microgram/m, even directly above spill sites. There wa s no significant increase in ambient air concentrations of Aroclor 1260 during test re- moval operations performed along NC 58 in Warren County, North Carolina. 30 b. Indoor Air Monitoring The air was sampled for the presence of PCBs inside seven houses or other structures along the test removal route on NC 58 near Inez in Warren County. Sampling was performed before, during and after removal operations. The seven sites monitored in connection with the Warren County test removal are shown in Figure 8. Air was sampled inside six of the structures -on September 19 and inside the remaining one on October 4, 1978, one day prior to the dig. Due to a late and unexpected change in plans, however, the dig route was terminated outside the community of Inez (See Figure 8), so that most of the buildings were not in the immediate vicinity of removal operations. Con- sequently, samples were not collected at sites 1, 2, 4 and 5 during or after the dig. Indoor air levels of Aroclor 1260 are given in Table 4. All were substantially below the NIOSH pro- posed criterion of 1 microgram/m3. There was no evidence of increased air levels in any of the structures monitored during the digging operations. 2. Water Quality A short-term water quality impact will occur as a result of leaving particles of soil contami- nated with PCBs on the surface of the highway after removal. This soil, which is not returned to the shoulder and incorporated into the soil column, will migrate to streams during rainfall events which car- ries the soil particles into drainage channels, ditches, and streams. Wind could pick up the soil particles as dust and create some migration of par- ticles into adjacent fields. Test results of the test pickup suggest that concentration of PCBs con- tained in the soil remaining in cracks and crevices of the pavement surface would be insignificant when compared to the volume and strength of the material being removed from the shoulder. Some contaminated pockets will remain adjacent to the pavement and with the excavated portion of the shoulder which could migrate into the environment through soil erosion. This amount of PCB material is insignifi- cant when compared to the volume and strength of the material removed from the shoulder. The entire pickup operation will be monitored to insure that the volume of the contaminated soil residual is minimized. 31 m --0 INEZ (§1 END II] 1/4 MILE START Key: 1. Thompson Grocery 2. Thompson House 3. Inez Country Store 4. Thorne House 5. Thorne Barn 6. Fleming House 7. Chicken Coop Figure a . Indoor air monitoring at Warren County test removal site. 32 Table 4 Indoor Air Levels of Aroclor 1260 i n Buildings Along Test Removal Route Location Thompson Grocery Thompson House Inez Country Store Thorne House Thorne Barn Fleming House Chicken Coop Conclusions Before 0.10 0.02 0.01 0.01 0.01 0.10 0.01 Air concentration (micrograms/m3) During 0.01 0.01 0.01 After 0.01 0.01 0.01 All air monitoring data taken inside domiciles and other buildings located along roadways on whi~h PCB spills occurred showed no level above 0.10 micrograms/m. This level is one- tenth that of the proposed NIOSH criterion for workplace air. 33 3. Plant and Non-Human Animal Life There are two main points to consider, i.e. the effect on the environment from the removal of a 24 to 30 inch width of soil approximately three inches deep adjacent to the paved roadway and the effect of, if any, PCB contaminated dust or other soil particles that may be distributed in the sur- rounding area. Insofar as the actual soil removal operation simulates the normal Department of Trans- portation shoulder maintenance work along the road- ways, no adverse effect on the plant or non-human animal life would be expected. The excavated area will be back-filled with soil pulled from the ditch area or trucked in from a non-contaminated area. The area will be reseeded; therefore, this repre- sents only a temporary disruption of the plant life along these roadways. The other possible risk that must be considered is that of displacement of PCB contaminated soil to the adjacent area. Previous laboratory testing by the North Carolina Department of Agriculture has shown that the PCB can be translocated up to several hundred yards along these roadways. This transloca- tion is presumed to be via PCB laden dust. The areas under consideration are all in rural areas and therefore the possible contamination of home gardens and agricultural field crops must be con- sidered. In assessing the r i sk of vegetable and field crops, two points must be considered. First, if the removal operation along the roadways is com-· pleted prior to May 1 or begins after October 1, there should be virtually no risk of PCB contamina- tion to vegetable or agricultural crops. Removal operations between May 1 and October 1 would sub- stantially increase the risk of contamination of vegetable and field crops if adequate dust controls were not maintained. However, with adequate dust controls, as demonstrated during the test removal operations in Warren County, any resulting contami- nation would be at insignificant levels and would not preclude the expected usage of vegetable or field crops grown along the contaminated roadways. Air samples collected and analyzed by the Environ- mental Protection Agency during the test removal operations in Warren County showed the PCB contami- nation levels at all sites to be less than 1 micro- gram/m3. It was also determined that the predomi- nance of PCB in the air samples were in the dust phase rather than the vapor phase. 34 B. 4. Traffic Disruption It is not anticipated that the removal and hauling operations will create any major traffic disruption. The PCB spills are predominately along rural routes with relatively low traffic counts. The removal operation wlll be quite similar to shoulder and ditch maintenance operations routinely carried out by state forces. Accordingly, these personnel have a great deal of experience in the handling of traffic und~r these conditions. One way traffic will be maintained throughout the removal sites. Advance warning signs in accord- ance with the Manual Uniform Traffic Control Devices and flagmen will be employed. Emergency vehicles will be given immediate ingress and egress through the areas and local school officials will be kept posted as to the location of current work areas. Haul trucks will be dispatched from the removal area at approximate 5 minute intervals providing adequate passing distance for following motorists. The haul routes will also be routinely monitored by vehicles equipped with mobile radios in order that traffic disruptions that may be caused by mechani- cal failure may be promptly alleviated. Disposal Method 1. Geology The proposed disposal site does not meet one of the EPA technical requirements for a chemical landfill that being "located in thick relatively impermeable formations such as large-area clay pans" (see Figure 9). Since the proposed disposal site does not contain large-area clay pans but does meet the other EPA criteria, a waiver of this requirement with the following modifications has been requested in the EPA permit application. Required In-place soil thickness four feet, or compacted soil liner thickness three feet. permeability lxlo-7 emfs 35 Actual Five feet compacted soil. 2.osx10-8 cm/s permeability ' i ----1-L . I • I • ' t I I ' I . --i----' ' : I , ' I ' i .. . l 1-, • I i ~ 'i ! I : '-r: • j ; ' ' ' t I i l t1·· I I : ; I , I . I I I I t /. I ~I :...11 01 I I \ I I I ':i1 -(/)I \ i I ' ·f···-· ------ / / ~:ll / ID' I c:t i 1-; I I-I i ~ Ct:i I u ...I Lu! 0 -;;; I 1-1 ·a: c:tS :1, 0 ~,-Lu oi1 a:: c:t w (/) I wl I a:: I I- \ a: <{ Lu \ ~ IJ.. \ :z, \ -; ' . \ \ \ . q ~9 ~o 0 a, T-·· ,,, ,,, C\i 36 The soil characteristics as shown by the sieve analysis and the atterburg limits and the percent moisture versus compaction curves indicat~ that the native clay MH-CH will compact 92 lbs/ft. Labora- tory verification indicates a permeability of 2.osx10-s cm/sec. Required Actual Percent passing No. 200 Average passing No. sieve 30 200 = 65% Liquid limit 30 Average LL = 50 Plasticity index 15 Average PI = 18 Artificial liner None A waiver has been requested to delete the arti- ficial liner. The State of North Carolina does not feel that the lack of an artificial liner will pre- sent an unreasonable risk of injury to the health or the environment from PCBs for the following rea- sons: (a) This landflll is not a commercial facility which will be in operation for a long period of time. It is a one-time operation for a special problem. Soil with low concentration of PCB, less than 500 ppm, is generally expected. (b) The 5-foot compacted clay liner exceeds the requirement found in 761.41 (b)(l)(i), EPA- Part V-PCB Disposal and Marking. (c) There will be a 10 mil plastic liner placed on top of the landfill. This "umbrella" top will be covered by two feet of soil which will sup- port the growth of grasses. The grass, the 2 percent slope, drainage ditches, and the top liner will effectively prevent any rainwater infiltration into the landfill. 37 2. Hydrology The proposed disposal site does not meet the separation requirements of SO feet between the site and the groundwater table. The State of North Caro- lina has requested in the EPA permit application a waiver of this requirement. The State of North Carolina does not feel that this will present an unreasonable risk to the environment based on the same reasons listed for waiver of the liner require- ments and the fact that the groundwater table is within 50 feet or less of the surface in essentially all the Piedmont area of North Carolina. Three groundwater monitoring wells will be placed in a line through the disposal site. One will be located at an elevation above the site and two below. One of the below will be located at a point having the highest water table. Samples will be taken and ana- lyzed for pH, conductivity, and PCB on a quarterly basis for the first year and bi-annually thereafter for at least ten consecutive years. At the end of this period, further evaluation will determine whether ad- ditional sampling is necessary. Surface water monitoring in the vicinity of the disposal site will be conducted for the same para- meters on the same basis as the groundwater monitoring. Monitoring will be conducted by the Division of Health Services and the Division of Enviornmental Management. 3. Plant and Non-Human Animal Life To assess the effect at the disposal site, both the short and long range factors were considered . The short range effect, if any, would be due to translocation from the disposal site primarily by PCB dust and soil particles . Any short range effect would be the same or similar to those expected along the clean-up routes except those possible effects on vegetable and field crops. No such agricultural crops will be within the expected impact area. The disposal site will be constructed, filled, closed, and maintained as detailed elsewhere in this report. There are no expected long range adverse effect on the plant or non-human animal life at or near the disposal site. 38 J . c. 4. Air Quality The air quality measurements taken before, during and after the test removal of PCB contami- nated soil from the roadway shoulder were not f ound to exceed the NIOSH criterion for workplace air of 1 microgram per cubic meter. Based on the air moni- toring data compiled during the test removal opera- tion, the ambient air quality at the disposal site would not be signifi cantly effected by the disposal of PCB contaminated soil. 5. Land Use The proposed disposal site is located within the Region K, Kerr-Tar Regional Council of Govern- ments. A Land Use Plan for Region• K was prepared in January of 1978. The existing land uses in the vicinity of the project are classified as rural areas. The rural areas are comprised of forest, agricultural land, residential land and to a lesser extent industrial land. The proposed disposal site appears to be compatible with the existing Land Use Plan and the projected Land Use Plan for the year 2000. 6. Cultural Resources The North Carolina Department of Cultural Re- sources, Divi sion of Archives and History has re- viewed the disposal site for potential effects on cultural resources. There are no structures in the disposal area of architectural importance. The disposal site was also reviewed for potential ef- fects on archaeological resources. It was concluded that there is little likelihood that any archaeo- logical resources will be affected by the proposed disposal site. Effect On Workers, Motorists and Area Residents Based on the NIOSH (National Institute of Occuua- tional Safety and Health) standard of 1 microgram/m~ of PCB in air, there is no reason to believe that temporary exposure, if any, would creat e a health hazard to motor- ists who may drive past a clean-up operation or to any resident who lives along a spill route. The NIOSH stand- ard is based on the expected working life of an employee, i.e. forty hours per week during a lifetime. Within this time frame, any exposure a motorist or area resident would experience would be insignificant. 39 l • While no adverse effect i s expected among the per- sonnel involved in clean-up operations, personal pro- tective wear will be furnished those workers directly involved wit h the removal and disposal operation. In summary, no adverse effect on the workers, mo- torists, or persons living al ong the spill sites is expected. 40 ' " ·( III. BASIS OF NO SIGNIFICANT ADVERSE EFFECT DETERMINATION A. Standards For Allowable Concentrations The rules and regulations promulgated by EPA define "PCB mixture'! to mean any mixture with 500 parts per million (ppm) of PCB. Quantitative analyses of Soil picked up along the shoulder showed concentrations of PCB in excess of 500 ppm in a strip 1"-12" wide and 1" to 2" deep. Test at the storage site of the test cleanup operation in Warren County revealed PC~ con- centrations from 210 to --380 ppm. B. Studies and Test Results The air quality monitoring data obtained during the test cleanup operation along NC 58 in Warren County re- vealed PCB air concentrations directly over the spill sites of 0.01 to 0.09 micrograms per cubic meter. The NIOSH (National Institute of Occupation Safety and Health) standards is 1 microgram per cubic meter. Moni- toring data collected inside homes along the spill sites and in the breathing zones of the test removal team indi- cated values of 0.01 to 0.10 micrograms per cubic meter, which is substantially lower than the NIOSH criterion of 1 microgram per cubic meter. Studies were conducted on the activated charcoal used for containment of PCB spills along the roadway shoulders to determine its sorption and retention char- acteristics. The studies showed that PCB was trans- ferred from soil and sand to charcoal after mixing in either the dry or wet state with 50 to 70% efficiency. C. Environmental Protection Agency Permit An application has been submitted to the Regional Director, Region IV EPA, in accordance with Part V, EPA, PCB Disposal and Marking Regulations. D. Mitigation Measures The streams entering the disposal site, the leachate collection system and the monitoring wells will be sam- pled and monitored as required by EPA. Three monitoring wells will be established at the disposal site. Prior to construction of the disposal pit, baseline samples of ground and surface water will be collected and analyzed. The monitoring wells and the surface streams will be monitored monthly while the chemical landfill is being operated. Further monitoring will be performed in ac- cordance with the procedure descri bed in Hydrology sec- tion of this report. The wells wi ll be constructed as required by EPA regulations concerning disposal of PCB mixture in a chemical waste landfill. 41 IV. COORDINATION The following State Agencies assisted in the prepara- tion of this Draft Negative Declaration: N. C. Department of Crime Control & Public Safety N. C. Department of Transportation N. C. Department of Natural Resources and Community Development N. C. Department of Human Resources N. C. Department of Cultural Resources N. C. Department of Agriculture V. AVAILABILITY OF STATEMENT The Draft Negative Declaration is available for public inspection and review at the State Clearing House, Division of State Budget & Manaagement, De?artment of Administration, Room 508-S, 116 West Jones Street, Raleigh, North Carolina. VI. SUMMARY During the months of June and July, 1978 PCB mixture was discharged on approximately 211 shoulder miles of North Carolina Highways. This Negative Declaration includes the evaluation of potential environmental impacts associated with the removal and disposal of the PCB contaminated soil on North Carolina highway shoulders. Up to 40,000 cubic yards of PCB contaminated soil will be stored in a chemical waste landfill to be constructed in rural Warren County. FV/dc/dk 42