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Home My WebLink AboutNCD980602163_19800125_Warren County PCB Landfill_SERB C_Re Draft Environmental Impact Statement for Removal and Disposal of Soils Comaniated with PCBs-OCRMEMBER UNITS COUNTIES Franklin Granville Person Vance Warren MUNICIPALITIES Bunn Creedmoor Franklinton Henderson Kittrell Louisburg Macon Middleburg NOfl ina OxlOfd RoxbOfO Stem Stovall Warrenton Youngs vii le KERR -TAR REGIONAL COUNCIL OF GOVERNMENTS P.O. Box 709 238 ORANGE STREET HENDER.SON, N.C. PHONE <919/ 492 8561 ), D. Ev•rett, Executive Director January 25, 1980 27536 ✓-=~-f'~ 1\?d -c'4<.·~--:-,.... ·"' ... </.'~, "'. '7' -(~\ Ms. Chrys Baggett Ii~ -t.!11 r J\ ,.:..------,t.,, ,P\ ~ · l .f .. r • ~,, i;f.? \. I '/:~1 N. C. Department of Administration State Clearinghouse \\ A~ Room 504, Administration Building 116 W. Jones Street ~ (" ~-•1 7 ,. >,1--..i/ Raleigh, NC 27603 I) r · '! !Ji 3 l~~· :•/ RE : Draft Environmental Impact Statement for the Removal and Disposal of Sotls Contaminated with PCBs Along Highway Shoulders in Warren County Dear Ms. Baggett: The Kerr-Tar Areawide Clearinghouse Review Committee has completed its review of the above referenced draft EIS. The A-95 Review Corrrnittee does not concur with the draft Environmental Impact Statement per thefollowing statements: .. 1. Additional emphasis needs to be placed on the integrity of the plastic liner. 2. A. There is no proposal to maintain the surface free of trees whose roots could penetrate the plastic top liner and create a connection to surface wat er. Annual mowing should be a minimum requirement. B. The plastic liners along the side walls of the proposed site offer the only barrier between the disposed PCB waste and the surround- ing soil. What other measures does the State propose in order to mitigate any damage of or decomposition of the plastic liner. (root intrusion, damage by equipment, etc .)? Half t he waste is to be buried above current ground level and thus be subject to eventual erosion or slump. The Statement mentions flood diversion structures but does not describe them or indicate how long they might be expected to last: 3. The proximity of the water table and the bottom of the sump is too close. This is of utmost cont:ern since the exact elevation of the water table has not been determined, only estimated . The EIS states that excavation will not come closer than seven feet from the water table (pp. 12, 17), but it is unclear as to whether this includes the new lower sump. It's also unclear as to 7 Ii Ms, Chrys Baggett January 25, 1980 Page 2 IE - how the Digh water table elevation was predicted. It appears that the highest actual measurement taken from several Feb. l, 1979 borings at the site (306 1 ) was added to one-half of the maximum normal groundwater fluctuation in Warren Co. (11 1 ) which gave a high water level of 312' (311½' rounded off). Evidently this figure (312') was then subtracted from the maximum surface elevation at the dumpsite (343') resulting in a 31 1 difference between the ground level and the high water level. Since the study was conducted "during the middle portion of maximum seasonal fluctuation", the water was presumed to have already risen half as far as it was predicted to go which resulted in adding half of the fluctuation. If this methodology or a similar one was utilized in determining the high water level, it wouldn't seem to be too reliable. In addition, the lowest point on the dump surface, not the highest point, should probably have been utilized in determining how much working room would be available in relation to the groundwater table . The exact calculation utilized in determining the high groundwater level should be clarified. 4. The plan allows numero~s opportunities for human errors in construction: installing plastic liners and pipes, compacting the clay liner, driving trucks on top of buried pipes and close to plastic side liners, and close tolerance surface .grading. 5. The site must not be subject to flooding or have a hydrologic connection with the groundwater according top. 16 of the Draft EIS "Surface water discharge is to Richneck Creek ... 40 miles separate the site discharge area and the closest raw water intake." If a disruption were to occur, the PCB material would easily run off into Richneck Creek, and subsequently to the raw water intake located 40 miles downstream. How will the State prevent this from ever occurring? 6. This is not an adequate environmental impact statement. More emphasis has been pl aced on the chronology of events which have occurred and little or no mention has been made concerning the possible effects which the proposed PCB landfill could have on the natural environment. Also, by not exploring all possible environmental effects. the means to mitigate or eliminate factors which could do harm to the environment have been omitted. 7. Humans should also be considered in ascertaining possible environmental effects posed by the PCB disposal activity. Will PCB disposal affect the economy of Warren County through adverse connotations? 8. Reputable sources have disputed the State findings on the availability of clayey material, further investigation should be made . • 9. The express will of the local government concerning PCB disposal should be given more consideration by the State government. 1 o. . . Warren County hired a geologist, Dr. Charles L. Mulchi, who took his own soil samples at the site and reviewed the State's plan. The Environmental Impact Statement does not mention him or the questions he raised about clay type, depth of clay, and groundwater uncertainties. The addition of the 30 mil plastic liner may have been in part a response to his criticism about lack of groundwater protection from leachate. He recommended that the State's proposal be turned down and his paper, A Review of the Proposal to Use Soils I\&~--f"'--••--.!..L. .. -..C 11-.-·--·-£"-···-.l.. .. kt Ms. Chrys Baggett January 25, 1980 Page 3 Contaminated with PCB, still remains valid for the most part. To stop PCB, you must keep it dry. This formation because of the type of clay and the low proportion of cl ay to other types of soil, especially at the lower levels, is not naturally waterproof. James Scarboro ugh of the EPA admits (A ppendix C) that it "is not in a 'thick, relatively impermeable formation such as 1 arge-area clay pans 111 • Liners must be formed from earth dug from the surface. Of eight samples taken from the top layers by the N. C. Dept. of Tr ansportation, only three showed 50 percent or more clay (Appendix B). The percent went down as they went deeper. To quote Dr. Mulchi, (pp. 4-5 Mulchi), "There are very small amounts of clay present deep within the soils at the site which would serve to trap escaping materials in future years. The relatively high sand content in these lower regions suggest that moisture movement below the burial layer would be very rapid and that there could be a risk of groundwater contaminations resulting from leakage from the burial site." · 11 A dependence on such means as artificial plastic liners and barriers of soil less than 50 percent clay may not give the safeguards necessary for storage of large quantities of PCB material . Plastic liners may ultimately deteriorate due ta actions of natural forces operating within the soil. This may result in moisture movement through the disposal site which in turn will move toxic materials. The low absorptive capacity of the kaolenite clay combined with the low moisture retention properties of the clays may not prevent the system from leakage of chemical waste at some future date." RMW:sp • Sincerely, ,I I Roy 1M. Wi 11 iford Planning Director .. \ ' , . . ..,