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HomeMy WebLinkAboutNCD980602163_19790604_Warren County PCB Landfill_SERB C_US-EPA letter to Governor James Hunt-OCR• ' . . ,-,;· United States Environmental Protection Agency &EPA June 4, 1979 4AH-RM Region 4 345 Courtland Street NE Atlanta GA 30308 Honorable James B. Hunt Governor of North C~rolina State Capitol Raleigh, North Carolina 27611 Dear Governor Hunt: Alabama. Georgia. Florida. M ississippi, North Carolina. South Carolina. Tennessee. Kentucky On February 17, 1978, the United States Environmental Protection Agency (EPA) published final regulations in the Federal Register (43 FR 7150-7164) on Polychlorinated Biphenyls (PCBs), 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. In 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 Harren 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 Bragg military reservation. A public hearing ·. was held in ~Jarrenton, North Carolina on January 4, 1979, for public ·, 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.~l(~), when constructed in accordance with the enclosed conditions to this approval excep t for t he foll ow in g: ( 1) 7 G l. t1 l ( b ) ( l ) ( vi ) " Art if i c i a 1 1-i n er th i ck n es s 3 0 mil . o r gre ater." (2) 761.41 (b) (2) 11 The site shall be at least fifty feet from the near?$t_ groundvJater.11 (3) 76l.4l(b)(5)(iii)(d) "Chlorinated Organics." These three requiremerits are hereby waived for the reasons given in the enclosed technical review. Your re~uest to waive the leachate collection system underneath the liner is denied for the reasons stated in the enclosed technic~l review. -2- Accordingly, the Warren County, North Carolina site to be owned and operated by the State of North Carolina for the disposal of PCB 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 writing by this office prior to the initiation of constructiono This approval is not to be .construed to be approval for incineration, storage, marking or records and monitoringo 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~~-~ ohn.C. White Regional Administrator Enclosures cc: Herbert L. Hyde, Secretary NC Dept. of Crime Control & Public Safety Marshal 1 Staton, Chief Sanitary Engineering Section Division of Health Services NC Depto of Human Resources Jerry Perkins, Head Solid Waste & Vector Control N.C. Depto 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 2520 A. General Requirements {all reports should be sent to the Regional Administrator, Attention: James Ho Scarbrough): 1. Notify EPA at least two weeks in advance of the expected start of constructiono 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 761.41 {b)(5), monitoring systems for baseline and on the frequencies specified. 4. Maintain ·records as specified 1n 43 FR 76lo45{b}{3} as appropriate and submit within 90 days after closure of the site to the Regional A9mi ni stra tor o 5. Advise EPA irrmediately of any changes, alterations or divergences in the operational and managerial po1icies 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 immediately. 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 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 durin g all operations to pro vid e and ass ure con forman ce with t he fi nal plan s. Such as su ranc e shal I be f urni shed to the Reg ion al Adm ini strat or at the comp l etion of til e pro j ec t v1ith a ·copy of "as bui H " plan s o 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 pennit 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. I. -I I I I' ! '• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY DATE: June 4, 1979 sueJ ECT: Technical Review -Chemical Waste Landfill for PCB Submitted by the State of North Carolina FROM: Chief, Residuals Management Branch To: John C. White Regional Adrn1n1strator 'Ihe State of North Carolina submitted an application for the approval of a dis!X)sal site 1n Warren County, North Carolina on December 12, 1978. 'Ihe Technical review has been performed. The results of applying the ~riteria found 1n FR 761.41(b) to the application are as follows: (b)(l) Soils -The site is not 1n a "thick,·relatively impermeable fonna.tion such as large-area clay pans." Therefore, the soils are evaluatec on the following criteria: Required Proposed (1) Soll liner thiclmess 3 ft. (cgnpacted) 5 ft. (canpacted) (11) Permeability (cm/sec) mo-7 or 6.8X10-8 or (0.0000001) (0.000000068) (1:µ) Percent Soil Passing ~ 30 75 Average No. 200 Sieve (iv) Liquid Limit ~ 30 51 Average <v> Plasticity Index ~ 15 18 Average (vi) Artificial Liner 30 mil. None proposeol/ 1/ A waiver was requested for this requirement. The primary justification -for t he waiver was that the State would instead place a 10 mil. plastic l ine r "urnb rellan t op on the lo.ndfil l covered by two feet of soil ·.•;hich would be seeded 1·rlth gra3s anci sloped . '111is desi/:,n wou..1 d rrJnimi:::':.: arv _ raim1ater infiltration into the landfill. 'I'his waiver reques t six:lllld be approved. IPA pr_,. 1320-6 (Rn. 3-76) •. -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 above the groundwater. 'lhe minimur: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 bottan of the trench plus the liner on top of the waste which will act as an wnbrella for infiltration prevention, plus the leachate collection system and sump above and below the clay liner will sufficiently protect public health and the environnent fran "unreasonable risk of injury" as stipulated by paragraph 761.4l(c)(4). Therefore, this waiver should be approved as. requested. (3) Flood Protection -'lhe application states that the diversion structures . will be designed to divert the 24 hour, 25 year runoff fran the active 'port1=on of the landfill. j : (4) Topography -'lhe topography at the proposed site is low to moderate. 'Ihe approval should ·be conditioned to require all practical erooion prevention reasures to be used. (5)(1) Monitoring Systems a. 'Ihe application states that baseline data will be collected prior to final approval. The approval soould be so conditioned. b. 'Ihe application states that the surface streams and the gra.md-· water will be sampled monthly during operation. The approval · soould be so conditioned by referring to paragraph 761.4l(b)(5). -c. B1-anrrual TIDnitoring will be done after closure. (11) Groundwater Monitoring Wells 'Ihe application states that these will be constructed and located as required. EPA staff should verify the l ocation of t hese in the field. (111) Water Analysis 'Ihe analysis for chlorinated hydrocarbons is requested to be waived. The regulations were written for canrrercial facilities which would be disposing of many different wastes. Since PCB is the only waste which will be disposed in this site, there is no point to TIDnitoring for other chlorinated organics. 'Ibis waiver should be approved. l .. -3- (6) Leachate Collection 'lhe proposed design does not show a leachate collection syst,em tmder the l iner as required by the I'e6'lllation. Because of the groundwater prox1mity and the demonstrated public concern, I recanmend that a leachate collection system and sump be installed tmder the soil liner to monitor the integrity of the soil liner. In addition, the leachate collection system above the soil liner should be required with the appropriate sump to provide the rrechanism to allow pumping out of any leachate collected to prevent any significant hydraulic head buildup on the clay liner. Therefore, this waiver should 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 firot lift of waste. 'Ihis 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 ndddle 20 to 30 feet of the trench so as not to provide a .slrunt to the side walls should any infiltration occur. This restric~ tion·will allow any infiltration to proceed down through the waste to the leachate collection system which would lead it to the sump for pumping out. j _ (8) Supporting Facilities -The sup,IX)rting facilities are satisfactory as described. No mention was rrade of long-tenn rm.intenance of the access road. The approval soould be conditioned to insure that all- weather access is rraintained.