NCD980602163_19801113_Warren County PCB Landfill_SERB C_Adminsitrative Action - Final Environmental Impact Statement, State of NC-OCR

...
ADMINISTRATIVE ACTION
FINAL
ENVIRONMENTAL IMP ACT STATE.~
STATE OF NORTH CAROLINA
IN COMPLIANCE WITH
------,,--' I
I
f
i.
f
I b
t
f_
THE NORTE CAROLINA ENVIRONMENTAL POLICY ACT
/i/;3/ao
2 Date
: ,'
Burley B.
Department o
And Public
Jr., Secretary
control -
►
TABLE OF CONTENTS
PAGE
SUMMARY OF ENVIRONMENTAL IMPACT STATEMENT i
I . DESCRIPTION OF PROPOSED ACTION 1
1
1
5
A.
B. c.
D.
E.
General Description
Historical Resume .
Purpose of Action.
1.
2.
3 •
4.
Definition of PCBs ..
Regulations Pertai ning to PCB
Spills . . . . . . . . .
Need for the Proposed Action.
Estimated Cost for Removal and
Disposal ........ .
Description of Removal and Disposal
I.
2.
3.
Soil Removal . .
Transport
Disposal Method
a.
b.
Construction Procedure
Operational Plan
5
6
7
9
9
9
11
11
11
13
(1) Excavation 13
( 2) Surface Runoff . . 14
(3) Leachate Collection
and Detection System. 14
(4) Sampling and Moni-
toring . . . . 14
(5) Supportive Facilities. 14
c. Estimated Waste Volume 15
Description of Environmental
1.
2.
Setting . . . . . . ...
Roadside . . . .
Disposal Site
a.
b.
c.
d .
Location and General
Description .
Hydrology and Topography .
Soil Conditions ....
Environmental Profile ..
15
15
15
15
15
17
18
II.
III.
ALTERNATIVES TO THE PROPOSED ACTION AND
A.
B.
C.
D.
E.
F.
G.
THEIR POTENTIAL IMPACTS . . .
Procedures Utilized to Evaluate
Alternative Disposal Site
1.
2.
Locations ...... .
General Area of Potential Site
Locations . . . . ...
General Site Screening & Evalu-
ation Procedures
Alternative Sites Evaluated
1.
2.
3.
Total Sites Evaluated
Site Rejection ... .
Selected Site ... .
Alternative of Treatment In Place
Alternative of Transportation To A
PCB Material Incinerator
Alternative of Transportation To .An
Existing Chemical Waste
Landfill . . . . . . . . . . .
Goodyear PCB Detoxification Process .
No Action (Do-Nothing Alternative) ..
ENVIRONMENTAL IMPACT OF THE PROPOSED
ACTION ·· ..
A.
B.
c.
D.
E.
Soil Removal
1.
2.
3.
4.
Air Quality
a.
b.
Ambient Air ·Monitoring
Indoor Air Monitoring
Water Quality ....
Plant and Animal Life.
Traffic Disruption
Disposal Method ..
l.
2.
3.
Air Quality . . . . .
Water Quality -Hydrology
Plant and Animal Life.
Land Use . . . . . . . . . .
Cultural Resources ....
Effect on Workers, Motorists and
Area Residents ....... .
19
19
19
19
22
22
22
23
25
25
25
26
26
27
27
27
27
31
32
32
33
34
34
34
36
36
36
36
IV.
v.
VI.
VII.
VIII.
SIGNIFICANT ADVERSE ENVIRONMENTAL EFFECTS
WHICH CANNOT BE AVOIDED ..... .
STEPS TAKEN TO MINIMIZE HARM OF UNAVOID-
ABLE ADVERSE ENVIRONMENTAL EFFECTS
THE RELATIONSHIP BETWEEN LOCAL SHORT-
TERM USES OF MAN'S ENVIRONMENT AND
THE MAINTENANCE AND ENHANCEMENT OF
LONG-TERM PRODUCTIVITY ..... .
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT
OF RESOURCES WHICH WILL BE INVOLVED
IN THE PROPOSED ACTION .....
COMMENTS RECEIVED ON THE DRAFT STATEMENT
AND RESPONSES . . . . . . . . ....
Appendix A -PCB Spill Site Locations
Appendix B -Soil Test Data
38
39
40
41
42
Appendix C -EPA Approval and Conditions For the Warren
County PCB Disposal Site
Appendix D -Comments Received on the Draft Environmental
Statement
Appendix E -USDA, Soil Conservation Service
Vegetative Cover Recommendations
SUMMARY
Final Environmental Impact Statement
Prepared by the
North Carolina Department of Crime Control
And Public Safety
In consultation with the
Division of Highways
North Carolina Department of Transportation
Division of Health Services
North Carolina Department of Human Resources
and
Division of Environmental Management
North Carolina Department of Natural Resources
and Community Development
This is an administrative action.
1. Description of Action
2 .
The proposed action is the removal and disposal of
approximately 40,000 cubic yards of PCB contaminated
soil located along approximately 211 shoulder miles of
roadway involving 14 central and eastern piedmont
counties of the State. The 211 miles of roadway shoulder
contaminated with a polychlorinated biphenyl (PCB)
substance is the result of deliberate discharges of a
liquid PCB industrial waste material from a passing
truck. The State of North Carolina proposes to remove
and dispose of the PCB contaminated soil in a specially
constructed disposal pit that is located on approximately
142 acres of land in Warren County.
Summary of Alternatives
Approximately 90 sites located in twenty counties
of the State were evaluated as potential disposal sites
for the PCB contaminated soil. A set of general guide-
lines and EPA technical requirements were utilized in
the evaluation and selection of disposal sites.
One alternative considered for the proposed action
consisted of treatment in-place by applying activated
charcoal on the contaminated soil and then blending the
activated charcoal material into the soil column of the
highway shoulder. Treatment in-place of the PCB contami-
nated soil is prohibited by EPA regulations. Therefore ,
this alternative was considered not feasible.
Another alternative considered was transporting
the PCB contaminated soil to a PCB material incinerator
i
located out of State. This alternative was rejected
because there is no approved incinerator capable of
handling soil contaminated with PCBs. The alternative
of transporting the PCB contaminated soil to an e xisting
chemical landfill was considered. This alternative was
determined to be not feasible because of limited transpor-
tati on resources, manpower requirements and excessive
cost of disposal estimated at $12 million.
The no action or "Do-Nothing Alternative was not
considered a viable alternative because EPA has deter-
mined in the course of extensive rulemaking proceedings
that PCB contaminated soil in concentrations of 50
parts per million or greater should be disposed of in
landfills . It is also sound public policy to be able
to make productive use of state highways by allowing
driveway access to private property and by placing
utility distribution facilities on the highway right-of-
way . The roadside cannot be put to these public purposes
without disturbing the PCB contaminated soil and causing
its further distribution in the environment. For these
reasons its removal and safe disposal is in the public
interest.
3. Summary of Environmental Impact and Adverse
Environmental Effects
The proposed action to remove and dispose of ap-
proximately 40,000 cubic yards of PCB contaminated soil
will result in some adverse environmental effects.
Approximately five acres of agricultural land utilized
for the disposal pit will be taken out of production
for an indefinite period. No significant environmental
effects are anticipated to result from the removal and
disposal operations. Test results during trial removal
operations show no levels of airborne PCB vapor or dust
that exceeded the NIOSH proposed criterion of 1 micro-
gram/rn3 or added significant quantities of PCBs to the
total atmosphere levels. Dust control measures will be
utilized during the removal of the soil to help reduce
the PCB laden dust particles.
The disposal pit will be constructed to completely
contain the PCB contaminated soil. There will be no
hydraulic connection between the PCB contaminated soil
and surface water or groundwater. Installations of
wells and leachate collection systems will allow monitor-
ing of the disposal site.
The removal of the PCB contaminated soil from the
roadsides will have a positive effect on the environment
by substantially diminishing the availability of the
PCB substance to people as well as plant and non-human
animal life. The roadway shoulder and surrounding
environment will be restored to normal usage .
ii
Removal And Disposal of Soils
Contaminated With PCBs
Along Highway Shoulders
In North Carolina
FINAL ENVIRONMENTAL IMPACT STATEMENT
I. DESCRIPTION OF PROPOSED ACTION
A. General Descrintion
The State of North Carolina proposes to remove and dispose
of approximately 40,000 cubic yards of PCB (polychlorinated
biphenyl) contaminated soil. The PCB contaminated soil is
the result of deliberate discharges from a passing truck of
approximately 30,000-35,000 gallons of liquid waste material
on to the roadway shoulders of North Carolina's highways .
The discharge of this industrial waste material containing
PCBs have been identified along approximately 211 shoulder
miles of roadways located in fourteen central and eastern
piedmont counties of the State.
The proposed action involves the mechanical removal of
the PCB contaminated soil from the roadway shoulders and
transporting of the PCB contaminated soil to a disposal
site for permanent storage. The disposal site for contain-
ment of the PCB contaminated soil will be located, designed
and constructed according to Environmental Protection Agency
rules and regulations governing the removal and disposal of
PCBs (40 CFR 761.41). The site recommended for disposal of
the PCB contaminated soil is located in Warren County
approximately four miles south of Warrenton.
B. Historical Resume
The first deliberate discharge of what was later iden-
tified as PCB liquid materials took place the last week of
June, 1978, 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 Divi-
sion of Health Services, Water Supply Branch. Water Supply
Branch personnel notified Division of Environmental
Management, Water Quality Program personnel in the Raleigh
Field Office of the spills. Raleigh Field Office person-
nel 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 reported, 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 Management
Laboratory for analysis later that afternoon, August 2. The
same chemist who investigated the Johnston County spill
encountered a similar spill near Snow Camp, North Carolina
on SR 1004, Alamance County, while returning to his home. A
sample 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) substance. The Water Quality
Operations Branch immediately notified the Chief of the
Environ.~ental Protection Agency, Region IV, Emergency Response
Branch, of the Laboratory's findings. After briefing the
Director, Division of Environmental Management, a meeting
was called with representatives of the Attorney General's
Office, the Department of Crime Control and Public Safety,
and Public Information representatives of the Secretary of
the Department of Natural Resources and Community Development.
A notification 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 release 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. Also on August 4, the N. C.
Highway Patrol delivered soil samples obtained from Chatham
County to EPA. The results of the EPA laboratory analysis
were reported to SBI on August 8.
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 NC 210, the
Division of Highways, Department of Transportation was
requested to cover the spill with a layer of sand in order
to suppress the noxious odors present. This was completed
in late afternoon August 5 and continued on August 6 .
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
2
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 military
reservation. Because of the publicity, reports of spills
began coming in from many different sources 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, spills may have occured in Wilson County the
evenings of August 5 and August 8. The Division of Environm-
ental Management Laboratory continued 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 conference was held with representatives of
the Department of Human Resources, Department of Agriculture,
Attorney General's Office, the Department of Transportation,
Environmental Protection Agency, and the news media, on
August 10. A working session 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 Office of Toxic Substances, the National Center for
Disease Control, Hevi Duty Electric Company, the EPA Health
Effects Research Laboratory, and various academic and private
sector personalities known as having expertise in handling
this type of material. On August 11, the EPA Health Effects
Research Laboratory began ambient air sampling at spill
sites.
North Carolina State University was identified as
having expertise in detoxifying pesticides. The University
was contacted to provide expert advice and assistance. A
proposal was submitted to the Governor for temporarily de-
activating the PCB materials to prevent its migration and to
neutralize any hazard to people coming into contact 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 contami-
nated roadway shoulders during the latter part of August.
On August 15, the Governor requested assistance from the
President of United States. On August 17, a special EPA
coordinator was assigned to the problem.
Because the initial sampling procedures only gave gross
approximation to the concentration of PCB material on the
grass and in the soil column, several cross sectional samples
were taken at one-inch intervals to determine the magnitude
3
of the penetration into the soil column and the strength of
the material at various depths. These samples were taken
during the period of August 21-28.
On August 28 and 29th, the Epidemiology Section of t he
North Carolina Division of Health Services convened a meeting
of national experts on PCBs. Those in attendance included
scientists from the Environmental Protection Agency, National
Institute of Occupational Safety and Health , Nati onal Institute
of Environmental Health Sciences, and the Center f or Disease
Control . State personnel in attendance were f~cm t~e Divis i on
of Health Services, Natural Resources and Community De velop-
ment, Department of Agriculture, and the Department of
Transportation. Industrial users of PCBs were represented
by a person from Carolina Power and Light. The purpose of
this meeting was to assess the immediate risks to the persons
who live along the spill routes and to discuss the safety of
those persons who would be participating in the removal and
storage of the PCB contaminated soil .
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 operation was
performed on October 5, 1978 on a one mile PCB contaminated
section of NC 58 near Inez in Warren County. The PCB contami-
nated soil obtained during the test removal operation has
been temporarily stored at a disposal site in Warren County.
The purpose of the test was to examine the practicality of
picking up the contaminated material as well as any possible
health or environmental effects . On November 6, test results
indicated that the pick up of contaminated shoulder material
was not harmful to the environment or personnel.
On September 29, 1978, Governor James B. Hunt's request
for assistance from the Federal District Assistance Admini-·
stration, Department of Housing and Urban Development was
denied. On October 4, North Carolina officials were notified
by the Federal Highway Administration, U. s. Department of
Transportation, that the request for emergency relief funds
was denied.
During the month of December a Draft Negative Declara-
tion was prepared pursuant to the North Carolina Environmental
Policy Act. The statement was sent to State Clearinghouse
on December 21, 1978 for circulation. Comments received on
the Draft Negative Declaration requested an EIS be prepared.
Therefore, a Final Negative Declaration was not prepared.
On December 12, an application was filed with EPA for
approval of the Warren County site for placement of con-
taminated PCB material . On January 4, 1979 a hearing was
held on the Warren County site at the National Guard Armory.
4
During the period January 25-31, 1979 additional soil
samples were taken by the Division of Environmental Manage-
ment to substantiate the location of the contaminated mater-
ial and determine if any migration has occurred. Test re-
sults indicated that the material was present and had not
migrated. On January 29, 1979, a meeting was held in Washington,
D. C. between representatives of the State of North Carolina
and EPA officials to discuss the current PCB regulations and
to discuss alternative solutions. On February 6, the State
of North Carolina filed petition with EPA to amend the rules
under the Toxic Substances Control Act to allow consideration
of alternate methods of treatment.
On February 15, 1979, a test was run on a contaminated
section of NC 210 in Johnston County and on March 22, on a
contaminated section of SR 1004 in Alamance County to deter-
mine the feasibility of utilizing the theory of PCB fixation
with activated carbon.
On June 4, 1979, the EPA Administrator, Douglas Costle,
ruled against the petition of February 6 to change the
regulations to allow consideration of alternate methods of
treatment. The Region IV EPA Administrator, John White, on
June 4, 1979 approved the State's application to construct a
landfill in Warren County for disposal of the PCB contami-
nated soil (see Appendix C).
c. Purpose of Action
1. Definition of PCBs 1
PCBs (polychlorinated biphenyls) are a class of
chlorinated, aromatic compounds which have found wide-
spread application because of their general stabilities
and dielectric properties. PCBs have been prepared '
industrially since 1929 and are now produced in many
foreign industrial countries. The Monsanto Company's
preparations of PCBs were termed "the Aroclors".
Production of PCBs ceased in the United States in mid
1977.
The outstanding physical and chemical character-
istics of PCBs are their thermal stabilities, resistance
to oxidation, acid, bases, and other chemical agents as
well as their excellent dielectric (electrically in-
sulating) properties. These and other properties have
led to numerous uses of PCB such as dielectric fluids
(in capacitors and transformers), industrial fluids (use
in hydraulic systems, gas turbines, and vacuum pumps),
and plasticizers (adhesives, textiles, surface coating,
sealants, printing, and copy paper).
l · 1 h . f Hutzinger o. et. a., C emistry o PCBs, CRC Pres
Cleveland Ohio, 1974.
5
PCBs were prepared industrially by the chlorin-
ation of biphenyls with anhydrous chlorine, using iron
filings or ferric chloride as catalysts. The crude
product was generally purified to remove color , traces
of hydrogen chloride, and catalyst which was usually
achieved bv treatment with alkali and distillation.
The resulting product was a complicated mixture of
chlorophenyls with different numbers of chlorine atoms
per molecule . (This fact is responsible for the physical
state of PCB preparations). Most. individual chlorophenyls
are solid at room temperature whereas commercial mixtures
are mobile oils.
The most important physical properties of PCBs
from an environmental point-of-view are solubility and
vapor pressure. The solubility of PCBs in water is low
and decreases with increasing chlorine content. Values
given by Monsanto are 200 ppb {parts per billion) for
Aroclor 1242, 100 ppb for Aroclor 1248, 40 ppb for Aroclor
1254, and 25 ppb for Aroclor 1260. studies on the solubil-
ity of PCB in water are complicated by the fact that these
compounds are strongly sorbed onto various surfaces. PCB
has been shown to sorb relatively rapidly onto charcoal,
plastic, glass, and silt or soil particles.
PCBs have a high specific gravity {Aroclor 1260/
1.566) and a relatively high density {Aroclors 1260
weighs 13.50 lbs./gallon at 25°C). Loss of PCB by
evaporation is extremely slow, i.e. Arcoclor 1260 ex-
posed to 100°C for six hours would have an evaporation
loss of Oto 0.1%. PCBs are very stable at high tem-
peratures. A temperature of 2000°c or greater is
necessary before these chemicals are destroyed.
I
In summary, PCB compounds have been manufactured
and used in this county since 1929. Their uses have
varied from the manufacture of many household products
to industrial uses. PCBs are very stable heat resis-
tant compounds that are fat soluble and some are known
to build up in biological food chains. PCBs are re-
latively insoluble in water but have strong absorption
properties onto such materials as clay, soot, charcoal,
and grease. PCBs are found in a wide variety of sub-
strates throughout our environment.
2. Regulations Pertaining to PCB Spills
The Environmental Protection Agency has promulgated
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
6
requirements of PCB mixtures in soil. The regulation
initially defined PCBs to mean any mixture with 500
parts per million (PPM) of PCB. This regulation was
amended effective July 2, 1979. The amendment in 40
C.F.R. 761 .l(b) lowered the concentration of PCBs which
are covered by the regulation from 500 ppm to 50 ppm
(Federal Register, Vol. 44 , No. 106, May 31, 1979).
The regulation requires that soil and debris contaminated
with PCBs must be disposed of either through incineration
or in a chemical waste landfill.
Criterion for any such landfill is contained in
Annex II to the referenced regulation. 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 State of North Carolina petitioned the USEPA
for a change in the disposal requirements for PCB
mixtures in 40 C.F.R. 761.10 (b)(3). North Carolina
requested that the regional administrator be allowed to
approve methods of disposal other than incineration or
landfilling. The petition for a rule change was denied
by EPA on June 4, 1979.
3. Need for the Proposed Action
In early August, 1978, the Water Quality Operations
Branch received a call from a Johnston County resident
pertaining to an apparent chemical spill along the
roadway shoulders of NC -210. Grass, soil and water
samples were collected from the spill site and analyzed.
The laboratory analysis identified the material taken
from the roadway shoulders as Aroclor 1260 a polychlo-
rinated biphenyl (PCB) substance. Reports of other
chemical spills along sections of roadway in various
counties were reported and investigated in the first
week of August.
Because the initial sampling procedure only gave
gross approximation to the concentration of PCB material,
a more detailed soil sampling and analysis procedure
was performed during late January, 1979. The soil
samples taken served to quantify the PCB as to the
7
level of concentration along the roadway and to deter-
mine the depth in the soil column the PCB substance had
penetrated.
The deliberate discharge of industrial waste mate-
rial containing polychlorinated biphenyl substance onto
the roadway shoulders was identified in fourteen coun-
ties of the state. The 211 shouders miles of roadway
on which the spills occurred were grouped to form 15
spill site locations. Appendix A contains county maps
showing the locations where the PCB industrial waste
material was discharged onto the roadway shoulders .
Appendix A also contains descriptions of the sampling
site locations and the soil sampling results in terms
of mg/kg of Aroclor 1260, a PCB substance.
Polychlorinated biphenyls are highly stable com-
pounds that will remain unchanged in the environment
for a very long time. PCB will biologically magnify in
food chains and accumulate in the fatty tissue of both
humans and animals. The long term effects of human and
animal exposure to low levels of PCBs are not clearly
documented; however, studies using laboratory animals
have shown potential chronic effects such as cancer
induction, pigmentation, and behavioral changes. The
PCB contaminated soil may become translocated into
adjacent agricultural crop lands and may have an impact
on agricultural cash crops such as tobacco, feed and
forage, and crops for human consumption. The State of
North Carolina considers the removal of the PCB contami-
nated soil a necessary action to insure the protection
of the natural and human environment.
In addition to the above reasons for removal of
the PCB contaminated soil, the North Carolina Department
of Transportation must periodically reshape shoulders
and ditches adjacent to state highway system travelways
in order to maintain safe egress for the traveling
public and to maintain proper cross slopes for storm
drainage. While these operations are closely followed
by necessary erosion control measures to stabilize the
loosened soil. There nevertheless follows a period of
time during which the shoulders and ditches are suscep-
tible to erosion. In addition normal deterioration of
the highways caused by traffic, climate and age will
require future modifications to the contaminated areas
including resurfacing and possible widening and realign-
ment of the highway facilities. All of these operations
would tend to redistribute the contaminated soil in a
manner which would be very difficult if not impossible
to control.
The presence of PCB contaminated material along
state highway system routes has caused the Department
8
of Transportation to disallow all encroachment requests
along those roadway shoulders which involve activities
requiring excavation or redistribution of the soil
structure. This has included placement of utilities
and commercial and private driveway pipes . These
activities involving the roadway shoulders are necessary
in order to provide needed services to property owners
located adjacent to PCB spill areas.
4 . Estimated Cost for Removal and Disposal
The total estimated cost for removal of the PCB
contaminated soil from approximately 211 shoulder miles
of roadway and disposal of the soil in a chemical waste
landfill to be constructed in Warren County is ~,500,000 ..
A summary of the cost breakdown follows: i~ {.,5':)...,; vv <-'
Removal From Roadway Shoulders
Reshaping of Roadway Shoulders
Hauling of PCB Contaminated
Soil to Disposal Site
Disposal Pit Construction
Leachate Collection System
Impermeable Clay Liner
Artificial Liner (30 mil)
Erosion Control & Equipment
Pit Closeout
Construction Monitoring
Engineering & Contingency
Land Acquisition
$ 365,000
250,000
350,000
56,000
14,000
48,000
150,000
63,000
100,000
8 ,000
75,000
173,000
$1,652,000
D. 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 a lication of a 10% solu-
of activ ted carbon applied at
of a rox ·-
yard were --.:;;;;_;.;.,,.::::.:::,~~.:;;,~:i;:;~~~~;:£.~-;:;e-:-~the PCB spills
have occurred. Figure 1 is a location map indicating
the approximate location of the PCB spills. A more
detailed description of the spill locations are in-
cluded in Table 1 and Appendix A.
The activated carbon solution was utilized to bind
the surface concentration of PCB by absorption of the
PCBs into the pores of the activated carbon and retard
dissipation into the surrounding environment. The
liquid asphalt was applied to eliminate dusting of the
9
VAN:-7•
0
LOCATION MAP
1110111 PC B SPILLS
FIGURE I
,,
JO J
SC~!.E OF Mil.ES _/
'---------i\.
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
i. NC 42, Chatham County -From Deep River (Lee County Line)
to intersection with SR 1006.
Length: 4.56 shoulder miles
8 • NC 902, Chathar.t 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 4 3 .'
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 SR 1409 east 0.2 miles.
Length: 0.23 shoulder miles
--------------------
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 mile5
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
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 -Fro~ 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
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: C.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.
activated carbon and to reduce run-off of the activated
carbon caused by storm drainage . These applications
also served to delineate the contaminated areas.
The proposed method of removing the PCB contami-
nated soil from the roadway shoulders will consist of
the following sequential steps :
a.
b .
c.
d.
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 conditions. This opera-
tion is recognized as extremely critical in
the total removal operation and will be
stringently controlled.
The contaminated shoulder area will be tren-
ched out to a width of approximately 24"-30" ·
from the edge of pavement, and approximately~
311 deep by means equipped
s ecia ly designed blade to allow for
the cutting of a reasonable neat line trench,
working with all motor grader wheels on the
pavement. The trenched out material will be
fed along the motor grader blade to form a
windrow of material located inside the edge
of pavement.
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 conveyed 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.
The Athey loader is designed to scrape the
road surface; however, very thin amounts of
residue will be left on the road surface
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
combination of both spraying and brooming .
Spraying will be performed by a Hydroseeder
10
('I
0
C:
SAaoa,
._o
/ -------1.._
(
' I
F fl " N
N
WARREN COUNTY
D
FIGURE 2
"$CAL!
:: l 1: CONCEPTUAL PLAN CROSS-SECTION --GAS VENT r.:7 • •.•.••••·• • I• • • •,•·•·• ••• • ••• • ••• •••·••• ·uJ.'.• -COMPACTED SOIL a PCB MIXTURE ---------:::;;~;~;~;~;~;~;:;:;:;:~:;:~:;:~:;:;:::;:;:~:;:~:;:;:;:;:~:;:;:;:;:;:;:~~~:;::::~:;::=' _____ y WATER TABLE NOT TO SCALE FIGURE 4 \LEACHATE REMOVAL 0 TOP SOIL \'LEACHATE ovECTION ,,r1· ;t '( ~ "\ ., r ., \., V . 1 ,, f 1 \ -----.. LEACHATE COLLECTION SYSTEM Q S ARTIFICIAL LINER PROTECTOR ~ ARTIFICIAL LINER E:J CLAY LINER ~ NATURAL EARTH --ORIGINAL GROUND SURFACE
I FOOT TOP SOIL ~ m~ ARTt~i~A~ M LINE~------••·l~~f?::::~ 2FOOT COMPACTED CLAY LINER ---1 BRIDGING MATERIAL_ SOIL a PCB --. WASTE MIXTURE CONCEPTUAL PLAN CROSS-SECTION DETAIL COLLECTION SYSTEM . LEACHATE I -....... ..:::::::::·.:::_:•::: :•:•:•:-:".·.··················==: .•.•::::::: :-:•:: '·'·'·'•!,'•"·'·'·'·'·'·'·'·'·"·'·"· •. • ...•.....•..•.• ~ 5 FOOT COMPACTED CLAY LINER " ·r0~· 1·~ ARTIFICIAL LINER .. :•:•:•:•:•:•:•:•:•:•:•:•:•:•:•:::::::::::::::::::::::::::::r:::::::::::::::::::::::::::::::::::::::::;::::::::::::::::::::::::::::::::::;:;:;:;:;:;:;:;:;:;:;::::::::::• LEACHAT. ~.,., w1wrn;pmtt:tWtW),\\:.,\S)/i\),\,,r~fofol\1 DETECT ION SY STEM Ji 0 • • ••• -~-~ ~-~~-~~--~;~·~·~······•·❖'.·'.•:•:•:•:•:•:•:•:•::;:•:•··•::t~{t . ~ :::::::::::::. FIGURE 5 LEACHATE REMOVAL PIPES NOT TO SCALE
with especially designed adjustable outlet
nozzles and the broom wi ll be covered wi th a
speciall y des i gned canvas cover to minimiz e
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 the
existing shoulder, reshaping will consist of
either scarifying and reshaping of the shoulder
by a motor grader, or filling 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 consist-
ing of seed bed preparation, seeding, fertili-
zing and mulching of all disturbed areas .
2 . Transport
Once the contaminated material is deposited in
dump trucks, the dump bodies wil l 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, avoid-
ing 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 mechani-
cal 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 con-
struct the PCB landfill in accordance with concep-
tual. plans approved by EPA. Figures 4 and 5 are
conceptual sketches of the landfill. Final con-
struction plans must be approved by EPA. A gene-
ral description of how the landfill will be con-
structed follows:
11
1. The facility will be designed such that
excavation for the disposal site will not be
closer than seven feet of the groundwater
table as determined by on site soil borings
and investigation of existing water table
levels in the vicinity of the site.
2. Construct lower leachate detection system as
a means of monitoring the artificial liner and
compacted clay liner. The leachate detection
system will consist of a porous material graded
to a sump to allow removal of any liquid mate-
rial.
3. Excavate and stockpile suitable soils which
when co~~acted will have a maximum permeability
of lxl0 cm/sec. Selection of suitable soils
is to be monitored by a qualified soils engi-
neer.
4 . Prepare surfaces and install 30 mil artificial
liner and liner protection materials along bot-
tom and sides of pit.
5. Construct compacted clay liner in the bottom of
the pit and along the side slopes of the dispo-
sal pit.
6. Place a layer of high permeability material
over the compacted clay and grade to a sump
area for collection and removal of leachate.
7. The soil contaminated with PCB waste will be
placed on top of the leachate collection sys-
tem in lifts as described in the operations
plan.
8. After placement of all the PCB contaminated
soil; a layer.of bridging material will be
placed then a two foot compacted clay liner
will be constructed.
9. An artificial liner and protection materials
will then be installed over the clay cap layer.
10. A foot of topsoil will be placed and graded for
surface drainage. The ground surface of the
landfill will then be prepared and seeded ac-
cording to Soil Conservation Service recommen-
dations.
11. All surface drainage during construction and
after completion will be diverted from the
landfill surfaces.
12
b. Operational Plan
(1) Excavation
All necessary precautions and protective
measures will be implemented to maintain
integrity of the artificial liner. The back-
fill and placing of PCB contaminated 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 . Tracked or rubber tired equipment
will be used to push and compact the waste
into place . the waste will be compacted to
the maximum extent practicable. 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 con-
structed as placement of first lift progresses.
A 1-foot layer of clean earth will be placed
over the middle 20 to 30 feet of 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 runoff collection system, the open end of
the pit will be completely closed. A minimum
of one foot of clean soil will be placed on
top of the waste and graded to two percent
slope from the center toward the trench
perimeters. A ten mil plastic cover will be
placed over this one foot of soil. A 2 foot
layer of compacted clay soil will be placed
over this cover, 12 inches of top soil will be
placed over the clay soil, graded to approxi-
mately two percent and seeded for erosion con-
trol. Additional erosion control measures will
be installed as required by the Division of Land
Resources Department of Natural Resources and
Community Development. A gas vent will be in-
stalled to prevent gas build-up and rupture of
the artificial liner.
(2) Surface Runoff
During the process of placing the PCB
contaminated soil in the disposal pit, sur-
face runoff from the pit area will be col-
lected in a holding pond. In accordance with
40 C.F .R. 761,41(B)(4)(ii) the holding pond
will be capable of diverting surface runoff
from the pit area for a 24-hour 25-year
storm. The water and silt collected in the
13
holding pond will be analyzed for PCB and if
negative the water will be released to surface
drainage. If the analysis for PCB is positive,
the water will be processed through a carbon
filter prior to release. The carbon filter,
and the silt in the holding pond will be placed
in the disposal pit prior to final closing.
Since the PCB disposal site is located above the
100 year flood plain, no flood diversion struc-
tures are required after completion of the PC~
landfill operation. Surface run-on at the site
will be diverted by grading the vegetative cover
for the PCB landfill to topographical lows along
the perimeter of the landfill site.
(3) Leachate Collection and Detection Systems
Two leachate collection systems will be
installed. One system above the clay liner and
another below the artificial liner. The leach-
ate collection system will consist of a highly
permeable material with PVC pipe for access and
removal of any collected leachate. The leachate
will be tested for PCB contamination. If the
leachate contains PCB particles and depending
on the concentrations found, the leachate mate-
rial will be disposed of in an EPA approved
PCB incinerator.
(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 groundwater. The
leachate collection systems will be monitored
monthly by the N. C. Department of Human
Resources. The receiving surface water in
the vicinity of the pit will be monitored
biannually by the N. C. Department of Human
Resources. The disposal site will be monitored
as long as required by EPA.
(5) Supportive Facilities
A six foot chain link fence with barbed
wire topping will be installed approximately
200 feet from the perimeter of the disposal
pit to prevent unauthorized persons and
animals from entering. The site will be
periodically insp~cted and maintained in a
manner to insure security and to prevent
hazardous conditions from developing.
14
c. Estimated Waste Volume
The landfill site will be constructed to
accommodate up to 40,000 cubic yards of soil
contaminated with PCBs.
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 PCBs
occurred mainly in rural areas on the roadway shoulder
within 24 _ inches of the pavement edge.
2. Disposal Site
a. Location and General Description
The proposed disposal site is located in the
northeastern North Carolina Piedmont Plateau of
Warren County, approximately four miles south of
Warrenton. See Figure 2 for a county map showing
the site location.
The proposed disposal site consists of ap-
proximately 142 acres of which about five acres
will be used for the actual disposal of the soil
contaminated with PCBs. The remaining acreage
will serve as a buffer zone for the disposal area.
b. Hydrology-Topography
surface water discharges are controlled by
the topographic position of the land. The proposed
disposal area occupies the crest of a gently ·
sloping upland ridge which has 70 to 80 feet of
relief. Surface water discharge from the site is
toward seven draws located in a radial pattern
around the site. See Figure 7 for surface drainage
patterns . Two large draws immediately Northeast,
and West of the site receive the major portion of
surface run-off. Exposed clayey subsoils, topogra-
phic position and side slopes tend to minimize
surface water infiltration and maximize surface
water run-off.
15
Surface water discharge is to Richneck creek
and an unnamed tributary to Richneck Creek via
draws around the site. Richneck Creek discharges
to Fishing Creek. The confluence of Richneck and
Fishing Creek is approximately 3 miles downstream
and Southeast of the Warrenton raw water intake.
Stream classifications for Richneck Creek and
Fishing Creek in the discharge area is class C.
Approximately 40 miles separate the site discharge
area and the closest raw water intake.
U. s. Geological Survey Flood Records of N.
C. streams indicate that the 100-year flood eleva-
tion is not more than 8 feet above average water
levels in Richneck Creek and its tributaries. The
site is 70 to 80 feet above these streams and not
subject to flooding.
Recharge of groundwater resulting from sur-
face water infiltration and percolation is esti-
mated to be low. There should be no significant
fluctuation in water table elevations beneath the
ridge occupied by the disposal site. All features
on the site which enhance surface run-off reduce
groundwater recharge. Rapid run-off and the rela-
tively small area of gently sloping ridge crest
minimizes the volume of precipitation available
for infiltration and recharge. The close proximity
of 2 deep draws for ground water discharge and the
relative low retention and water storage capacity
of deep subsurface weathered rock (silty sand and
sandy silt) indicates a low potential for buildup
of any significant hydraulic head or water table
below the ridge. The net effect of constructing
impermeable barriers on the ridge crest and divert-
ing any off-site surface water will be to further
reduce the potential for mounding of groundwater
below the site.
Precipitation aata from the U. s. Weather
Bureau Station at Arcola in Warren County indicated,
that at the time of the September study, rainfall
in Warren County was approximately 5% greater than
the preceding 5 year average. There were no
observed evidence of reduced soil colors or mottling
of soil colors to Jndicate the presence of a
permanent water table. At the time of the boring,
no water table was observed at the 42 foot depth.
It is concluded that the water encountered in the
September study was a result of normal vertical
movement of percolating surface water rather than
ground water tables.
16
Representative Hydrographs of wells in Warren
County indicate that during September gr ound water
levels are declining. Ground water level s are at
maximum elevations duri ng t he peri od from January
to April . Borings performed during February 1,
1979 by the consulting firm of Soil & Material
Engineers Inc. indicated a static water l evel of
approximately 303 ' to 306' in elevation or 37 to
32 feet below land surface. Boring depths we r e
45' below land surface . In the Warren Section o f
the report title "Geology and Ground Water ?_esou r c es
in the Raleigh Area", comp i led by the U. s . Geolo-
gical survey, the static water level of well
number 122 was measured to be 47' below land
surface. For location of well number 122 see
Figure 3. This well is simi lar to the disposal
site borings with respect to elevation, topographic
position and time of water level recordation.
Hydrographs of observations wells in Warren County
show ground water fluctuations from approximately
5 to 11 feet. The study conducted by the firm
Soils & Materials Engineers Inc. was carried out
during the middle portion of maximum seasonal
fluctuation of ground water. The measured elevation
of groundwater in February, 1979, was 303 to 306
feet. Ground water elevations could be predicted
to rise an additional 5 to 6 feet. The predicted
highest ground water elevation would be 309 to 312
feet. Maximum surface elevation in the disposal
area is 343 feet. The highest predicted water
table elevation is 31 feet below land surface
which would allow a maximum excavation depth of
24' to remain 7' from the high water table elevations.
Construction of a clay liner would afford a 14
foot separation from the high water elevation.
c. Soil Conditions
Soils on the site are characterized within
the standardized engineering concept of surficial
earth materials. Procedures established by the
American Association of State Highway Officials
(AASHO) and the American Society for Testing
Materials (ASTM) were utilized for soil evaluation.
The N. C. Department of Transportation and Soil &
Material Engineers, Inc. independently evaluated
site conditions and performed pertinent field and
laboratory analysis on materials obtained from 19
soil borings in the disposal area.
surficial soils on the site consists of
red-brown silty clays. The top soil on the site
is significantly eroded but where present extends
to a depth of 3 to 6 inches. Subsoils are clayey
17
and silty and extend to depths of 38 to 45 feet.
In general, a gradual transition exist between
upper silty clays and deeper clayey silts. Obser-
vations of soil borings on site indicate that the
clayey silts grade into sandy silts and silty
sands. The general stratifications of clays
overlying silts which grade to fine sands is typi-
cal of the Piedmont province. Detailed analysis
of the soil materials were performed by the N. C.
Department of Transportation laboratory and Soil &
Material Engineers, I::::. ':::l::e two laboratory
analysis indicated an upper layer of clayey soils
ranging in depth from Oto 38 feet below land
surface. Soils at the 45' maximum drilling depth
were classified as silty sands and sandy silts.
Standard Engineering laboratory tests for
maximum density at optimum moisture and permeabi-
lity at 95 and 100 percent maximum density were
performed on the soils. At 95% maximum density
the pen:ie~ility of 1 .9 ~810-' cm/sec and minimum
permeability of 1.8 x 10 . cm/sec. At 100 percent
maximum g7nsity no permeability was greater than
1.0 x 10 cm/sec. The 8 acres encompassed by de-
tailed soil borings and analysis demonstrates that
50,000 to 75,000 cubic yards of clayey materials
are available to construct highly impermeable soil
liners.
d. Environmental Profile
The proposed disposal site occurs on open,
rolling cultivated land presently utilized for
soybean production. In addition to the soybeans,
various weeds and grasses have been observed
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 o~ the soybean field. Oaks in-
cluding white, southern red, blac, and post, red
maple, sweetgum, tulip poplar, hickory and loblolly
pine are the major canopy species present. Under-
story species consists of redbud, dogwood, American
holly, red cedar, and winged sumac scattered among
small shrubs, saplings and vines -primarily
honeysuckle.
18
II. ALTERNATIVES TO THE PROP OSED ACTI ON
AND THEIR POTENTIAL HIPACTS
A. Procedures Util ized to Evaluate Alternative
Disposal Site Locat1ons
The North Carolina Department of Human Resources,
Di vision of Health Services conducted a site search for
potential l and areas that would be suitable for the permanent
storage of the PCB contaminated soil . The objective of the
investigaticn was to evaluate available State and offered ·
private property for potential usage as disposal sites . I t
was anticipated that several suitable sites could be located.
A set of general guidelines was developed to assist in the
evaluation of potential sites.
The following is an outline of general site criteria
and EPA technical requirements utilized in the location and
evaluation of potential disposal sites for the PCB contami-
nated soil.
1. General Area of Potential Site Locations
The search for potential disposal sites was gen-
erally limited to an area bounded by the counties where
the PCB spills had occurred. Areas east of the spills
were generally eliminated due to evidence of seasonal
high ground water levels relatively close to land sur-
face._ Potential sites in areas of the western portion
of the State were given a low priority due to the long
haul distances.
2. General Site Screening & Evaluation Procedures
(a) Site Relief
A PCB chemical waste landfill should be loca-
ted in an area that provides low to moderate topo-
graphic relief to prevent landslides or slumping .
Aerial photographs,· u. s. Geological survey topo-
graphy maps and field measured elevations were
utilized to evaluate site relief suitability.
Sites with potential of land slumping resulting
from required construction activity were rejected.
(b) Topographic Position
Hill, flat, slope and draw are the four basic
topographic positions for surface features . Wells
installed on hill or ridge positions normally
exhibit the lowest average yield of ground water
per foot of well. Hill or ridge positions are
also amenable to diversion of surface water and
control of local recharge to ground water by
19
minimizing areas available for recharge. Hilltop
and ridge were assigned a high priority for topo-
graphic position. Sites predominated by draws or
diffi cul t to manage s lope position were rejected.
U. S. Geological Survey topographic maps and
on-site evaluations were used to determine topogra-
phic position suitability.
(c) Soils
Surficial soils are formed by weathering of
subsurface geological rock formations. The charac-
teristics of the surficial soils are determined by
the chemical and physical properties of underlying
rock formations. Therefore, detailed geological
maps of specific areas and State and County soil
surveys were used to delineate sites with poten-
tially suitable soils . Site specific surface
evaluations, soil borings and field & laboratory
testing of soil materials were performed on sites
with reasonable probability of meeting the high
silt and clay content parameters for PCB chemical
waste landfills. Sites with sandy surface soils,
rock outcrops or exposed boulders, surficial soils
with shallow depth to bed rock and insufficient
on-site soils for clay liners were rejected .
Surficial soils contained within the landfill site
which could not meet the following EPA technical
requirements were rejected.
. . -7 (1) permeability 1.0 x 10 cm/sec.
(2) percent passing no . 200 seive230
( 3) plasticity index 2: 15
(d) Hydrology
Potential contamination of ground -or surface
water were major considerations for screening all
sites . Any site that could not be designed to
prevent hydraulic cbnnection between the PCB con-
taminated soils and surface streams or springs and
ground water was rejected. Sites within the
100-year floodplain, within close proximity of a
class I or II reservoir utilized as a public water
supply or within½ mile of an A-II stream as de-
signated by the D.E.M. were rejected. A separa-
tion distance of 500 feet from the site and water
supply wells was used as a site screening para-
meter. The depth to ground water would limit the
depth of excavation and total storage volume of a
given site. The standard for site evaluations
with respect to ground water separation was 50
feet. It was acknowledge during the site evalua-
tion process that the probability of locating
20
sites with ground water levels below 50' from land
surface would be difficult if not impossible~
Therefore, sites were screened according to the
predicted or measured minimum depth from land
surface to the upper limits of ground water tables.
Transmissivity, gradients and discharge areas for
ground water were considered in site evaluations.
Ground water fluctuations were predicted from
data generated by U. s . Geological Survey publi-
cations on geology and ground water resources and
field observations or measurements . Predicted,
observed or measured upward fluctuation of ground
water resulting in relatively shallow water tables
would cause a site to be rejected. Rainfall and
evaporation data from the U. s . Weather Bureau in
combination with U. S. Geological Reports and .
field measurements were used to predict the maximum
upper fluctuation from the measured static water
levels on sites that were drilled.
(e) Site Size
The disposal site for the PCB contaminated
soil should be large enough to allow adequate con-
struction and protection of the disposal area .
Considerations for sizing a site include: con-
struction of disposal pit; storage area for stock-
piling borrow materials to allow separation of
earth liner, topsoils, leachate collection and
spoil materials; access and turn around area for
haul vehicles, separate sedimentation ponds for
runoff from disposal pit and soil stockpile areas;
areas for installation of monitoring wells up
gradient and down gradient of disposal pit; berms
or ditching for diversion of surface water and a
buffer and security zone. A minimum 16-20 acres
in a fairly regular configuration was the rejection
criteria for ~site size.
(f) Access
Sites with deeded right-of-ways were assigned
higher priority than sites with no road frontage,
no deeded right-of-ways or property access by
easement. Consideration was also given to the
length and construction difficulty of access roads
from state maintained roads to the disposal pit.
(g) Isolation of Site
Population densities within 1 mile of proposed
sites and sites which would require transportation
of the PCB contaminated soil through highly popu-
21
lated areas were considered for site evaluations.
The objective of this standard was to locate sites
which would impact the least number of citizens
during transportation and disposal.
B. Alternative Sites Evaluated
1. Total Sites Evaluated
The above outlined standards were utilized to
evaluate approximately 90 sites in 20 counties. Every
available tract of state-owned land considered to be a
possible candidate as a site to receive PCB contaminated
soil was investigated . These included properties
assigned to the National Guard, institutions, tower
sites, prison property experimental farms, state parks,
state forests, utility-owned property and properties
under Department of Transportation jurisdiction.
Federal property on the Fort Bragg military reservation
was also evaluated.
The remaining sites were offered for evaluation by
private individuals and corporations, and county govern-.
ments.
2. Site Rejection
Approximately 90 percent of all potential sites
were eliminated due to violation of one or a combination
of evaluation standards. A majority of the sites were
eliminated due to the location with respect to private
or public water supply reservoirs, intakes and wells;
high water tables and unsuitable soil characteristics.
The range of site evaluations included sites from 1.5
to 1300 acres; soils from highly impermeable saturated
marine clay materials in Wilson County and impermeable
clay stone pits in the Triassic Basin to sand dune sur-
ficial deposits on the Fort Bragg Military Reservation.
Water table elevations varied from 3' to greater than
40' below land surface.· Topographic positions varied
from relatively flat areas to areas with greater than
30 degree side slopes and population densities from a
few homes per square mile to hundreds within a mile of
the site.
Eleven of the total available sites were considered
to have a high probability for meeting the criteria for
PCB chemical landfills. Detailed soil borings and sub-
surface investigations were made on these eleven sites.
Table II lists these eleven sites. Sites in Franklin
County, the Nash County Prison Site, the Wake County
Prison Site, Chatham County Brick Plant site and the
Harnett County D.O.T. Borrow Pit site were rejected
from subsurface investigations. The remaining 6 sites
22
in Person, Warren, Nash, Wake, Chatham and Granville
Counties were evaluated by EPA and State personnel .
Consideration was given to multiple site distribution
by development of these sites; however 4 of the sites
were rejected and more detailed subsurface analysis
were required on the Chatham and Warren sites .
Maximum density, permeability at 95% maximum dry
density and optimum moisture tests, volume of material
suitable for clayey liners and water table monitoring
test were performed on the Chatham and Warren sites .
Both sites afforded essentially equivalent evaluations.
The Chatham County site was unavailable for purchase by
the State for development as a PCB chemical landfill
and therefore rejected from further considerations .
In order to increase the disposal site alternatives
requests were made by the State to County Boards of
Commissioners for permission to evaluate existing sani-
tary landfill sites as potential sites for disposal of
the PCB contaminated soil. Table III illustrates the
result of subsurface evaluations for suitable soil
materials and water table elevations. The sanitary
landfill sites were either unsuitable for development
or were unavailable for development as a PCB chemical
landfill.
3. Selected Site
Of the six most suitable sites located in Nash,
Person, Wake, Granville, Chatham and Warren counties
the Warren County site on SR 1604 demonstrated the
least restrictions and the greatest degree of protec-
tion of the public health and environment. Additional
tests were performed by an independent consulting firm
to confirm the state's evaluation of the site. Appli-
cation was made to EPA for site approval for this site
to be developed into a disposal site for the PCB con-
taminated soil. Site and conceptual plan approval was
granted.
23
TABLE II
DETAILED EVALUATION OF ELEVEN POTENTIALLY SUITABLE SITES FOR
DISPOSAL OF TOTAL PCB CONTAMINATED SOIL VOLUME
COUNTY
Franklin
Nash
Wake
Chatham
Harnett
Nash
Person
Wake
Granville
Chatham
Warren
USE-LOCATION
Prison Property NC 39
South of Bunn
Prison Property US 64
Nashville
Prison Property,
Blue Ridge Ro?Ld
Cherokee Brick Plant
SR 1916
DOT Borrow Pit
SR 1229
Private Woodland on
SR 1004 South of
SR 1401 Junction
Farmland, SR 1326
NCSU Farm
Farmland, SR 1300
Sanitary Landfill · us 64
Farmland
SR 1604
24
EVALUATION COMMENTS
Static water level within
10 feet of land surface
Water table fluctuation
to within 15 feet of
land surface, 44 percent
of soil volume did not
meet EPA soil criteria,
access through prison
confinement area
Water level within 8.0
feet of land surface
Shallow surface rock
seams, site not avail-
able for purchase
Static water table within
10 feet of land surface
Surficial soils too sandy,
shallow to rock
Close proximity
to populated areas
Close proximity to popu-
lated areas
Site access across undeeded
right-of-way, property tied
up in estate, practical auger
refusal at 11.5 feet
Soil and water table data
satisfactory, site suitable;
site not available for pur-
chase
Soil and water table data
satisfactory
COUNTY
Harnett
Warren
Lee
Johnston
Franklin
Halifax
Granville
Wilson
Nash
Edgecombe
Chatham
Alamance
Wake
Person
TABLE III
COUNTY LANDFILL SITES EVALUATED FOR PCB CHEMICAL WASTE LANDFILL
COMPACTED SOIL
PERMEABILITY
CM/SEC
-5 1.3 X 10
5.3 X 10-7
2.6 X 10-7
7.2 X 10-6
5 .3 X 10-1
4 .2 X 10-8
1.2 X 10-1
6.9 X 10-9
7.3 X 10-8
1.5x 10-8
2.7 X 10-1
WATER LEVEL
FEET BELOW LAND SURFACE EVALUATION COMMENTS
22' Soils too permeable, Leased property
& owner denied request for PCB dis-
posal
13.8' -20 .6'
6 8.7'
7 .5' -19'
none encountered
14 .3' -18.6'
22'
6 I to 10'
22'
6' -15.3'
22' -33'
24A
Site not available
Water table near surface
Soils too permeable, water table
near surface
Rock 3', 7', 11' feet below surface
Water table near surface
I Rock 12 to 17' below surface
Water table near surface
Site not available for PCB disposal
Site not available for PCB disposal
Site not available for PCB disposal
Site not available for evaluation
Site not available for evaluation
Site not available for evaluation
C. Alternative Method of Treatment In-Place
Tests were conducted to determine the feasibility of
applying activated charcoal as a means of achieving long
term fixation and containment of the PCB material within the
highway shoulders. The in place treatment consisted of
applying activated charcoal on the contaminated soil and
then blending the activated charcoal material into the soil
column of the highway shoulder. The disturbed areas would
then be packed, seeded and reshaped. A continuous maintenance
and inspection program would be performed to insure that
erosion and soil migration did not occur.
A test was run on February 15, 1979 on a section of
NC 210 in Johnston County and on March 22, on a section of
SR 1004 in Alamance County. The test results indicated that
vertical and horizontal mixing was accomplished with the
average concentration being below the regulating requirement
at that time of 500 ppm. The average concentration along
the test section is above the current requirement of SO ppm
(amendment to 40 C.F.R. 761.l(b)).
During the test runs representative soil samples were
taken by EPA at the Research Triangle Park to conduct studies
of possible health effects. The EPA study which utilized
rats for test purposes provided evidence that the carbon
fixation process was not adequate and would not be an accept-
able means of disposal.
Because EPA regulations prohibited in place treatment
the State of North Carolina applied for a rule change to
allow the regional administrator to approve in place treat-
ment. The EPA administrator on June 4, 1979 denied the
petition submitted by the State of North Carolina.
D. Alternative of Transportation to a PCB Material
Incinerator
Three incinerators have·been identified as having the
capability to destroy the PCB material through incineration.
These incinerators are located in New Jersey, Arkansas, and
Texas. At the present time, these incinerators have not
been issued permits by EPA which would authorized them to
accept and dispose of PCB materials. Additionally, transpor-
tation and handling logistics would make this alternate cost
prohibitive.
E. Alternative of Trans~ortation To An Existing
Chemical Waste Landfill
Consideration was given to transportating the PCB con-
taminated soil to an existing chemical landfill located in
Alabama. This alternative was considereq not feasible,
25
because of limited transportation resources, manpower require-
ments, and excessive cost of disposal estimated at $12~0
million, as well as t.11e increased logistic problems.
F. Goodyear PCB Detoxification Process
Dr. R.H. Kline, scientist from the Research Division of
the Goodyear Tire and Rubber Company, was contacted to deter-
mine the feasibility of applying the recently developed Good-
year PCB detoxification process to the soil-PCB spill mixture
in North Carolina . Dr. Kline stated that the process was de-
signed for PCB fluids not absorbed PCB and solid mixtures.
The only way the Goodyear process could be applied was to first
extract the PCB from the soil mixture, and while extraction and
detoxification was possible that it is not practical nor econo-
mical.
G. No Action (Do-Nothing Alternative)
The no action or "Do-Nothing" alternative was not con-
sidered to be a viable alternative because current EPA regu-
lations require disposal of PCB contaminated soil which has
concentrations greater than 50 parts per million. The
rights of way of N. C. highways are generally used to provide
driveway access to adjacent properties and to provide for
placement of utility distribution systems. In addition,
highway shoulders require periodic maintenance, enlargement
and improvement to meet the transportation needs of the
public.
None of these right of way activities can be undertaken
without substantially increasing the risk of further distri-
bution of PCBs in the environment by disturbing the contami-
nated soil. Even without such use of the rights of way, the
normal usage of the highways will result in some PCBs being
distributed in the environment due to vehicles intentionally
or unintentionally being operated on the shoulders. It is
felt to be in the public interest to remove the PCB contami-
nated soil from the highway shoulders so that the EPA regu-
lations will be honored and so that the highways can be put
to full public use without further distributing PCBs in the
environment.
26
III. ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION
A. Soil Removal
1. Air Quality2
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 desginated as sites A, B, c and D
in Figure 8. Two additional air samplers were
located on either side of the temporary 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 8.
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
hours during the removal operation and again one
week afterwards. During the removal operation,
the air sampling was begun when the first vehicle
(1st hydroseeder) of the removal train approached
within 90 m (100 yds) of the appropriate 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 hour beyond that time. The same
procedure was used at sites c and D. At the stor-
age site, sampling was begun when the first dump
truck arrived and was continued for 4 hour.
Aroclor 1260 was found in the ambient atmos-
phere at all sites monitored. Air levels ~ere
generally in the 0.01 to 0.05 micrograms/m range
(see Figure 8) before, during and after the dig.
This corresponds to 8 to 42 parts-per-trillion
(wt/wt) for dry air at 20°C and 7603mm Hg. Several
values were below 0.01 ,icrograms/rn and one was
above 0.05 m!crograms/m. The range 0.01-0.05
micrograms/rn constitutes normal levels of PCBs
found in
2The following Air Quality analysis and results are
taken from 11 Studies Conducted In Connection with PCB Spills
In North Carolina11 , Analytical Chemistry Branch, Environmental
Toxicology Division, Health Effects Research Laboratory, U. s. Environmental Protection Agency, Research Triangle Park.
27
AMBIENT AIR MONITORING
-SITE A SITE B SITE C SITED SITE E SITE F -AIRBORNE ~ ~ ~ [! ~ [! ~ r..:, ~ C, ~ ~ pa• a: a: a:: :z: a: :z: c:: a: 0 1-1 ~ 0 1-1 ~ 0 1-1 ~ 0 1-1 ~ 0 1-1 ~ 0 1-1 ~ (µg/m3) 14 a: E-< c... a: E-< c... a: E-< c... a: ... c... a: c... a: :::, c... w :::, c... ::.l :::, c... t:l :::, c... w g ~ t:l :::, "' ill 0 ,:z: a:l 0 ,:z: ilJ 0 ,:z: ill 0 ,:z: ill· ~ a .i:
Less than 0.01 X X X X
0.01 -a.as X X X X X X X X X X X
More than a.as X
as Aroclor 1260 (0.06)
0
END @]
1/4 MILE
STORAGE SITE
Jure 8 • .Ambient air monitoring at Warren County test removal site.
most areas of the United States. However, atmos-
heric levels of PCBs in rural, non-industrialized
areas such as that near Inez would be exp3cted t o
fall into the 0 .005 to 0.015 micrograms/m 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) indicated that
there was a specific source of Aroclor 1260 in the
area.
The quantities of Aroclor 1260 collected as
airborne dust and vapors are tabulated in Table 4 .
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 hour
sampling period. In only one case was the PCB
dust level found to be significantly greater than
the vapor level. At site A, the ~nly site where
levels exceeded 0.05 micrograms/m, some 60% of
the Aroclor 1260 was found on the particulate
filter. This site was downwind from the highway
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 appreciable dust levels, which were
swept by the wind in the direction of sampling
site A. The total Aroclor 1260 air concent3ation
measured at this site was 0 .06 micrograms/m (50
parts-per-trillion), which is at or below PCB
levels which have been reported for air in residen-
tial areas in highly industrialized areas . Because
of the problems with windblown 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 diminished, and subsequent measure-
ments (at sites c and D) were substantially lower.
It 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
were not recorded. However, the weather was
apparently similar to that recorded at the Raleigh-
Durham Weather Station on those dates. High
temperatures were 25 to 27° on each day and lows
were 16°c on October 4 and 5 and 9°C on October
12. There was no precipitation during the daylight
28
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 appeared to be damp (but not damp enough to
prevent blowing dust).
Wetting of the road shoulder before digging
was apparently effective in keeping dust levels
down during dumping of the trucks at the temporary
storage site. No significant enhancement of par-
ticulate-bound PCB was detected at sites E or F,
and little if any increase 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, one week after and one month after the
removal. Portable low volume air samplers were
used for this purpose and only vapors were sampled
for a period of 4 hour. Air was sampled at several
levels directly above the spill on the road shoulder
between sites C and D. Data are presented in
Table S.
The presence of PCBs in the air was not found
to exceed the NIOSH propos3d criterion for work-
place air of 1 microgram/m, even directly above
spill sites. There was no significant increase in
ambient air concentrations of Aroclor 1260 during
test removal operations performed along NC 58 in
Warren County, North Carolina.
29
Table 5
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
Air Concentrat!on
micrograms/m One week
Before removal After removal
0.90
0.09
0.02
0.01
0.01
30
0.05
0.14
0.01
One month
After removal
0.14
0.05
0.01
0.05
0.03
TABLE 4 AIRBORNE AROCLOR 1260 CONCENTRATIONS IN µg/m3 OF AIR NEAR TEST REMOVAL SITE IN WARREN COUNTY, NORTH CAROLINAa SITE Ah SITE B SITE C (TOBACCO FIELD, (TOBACCO FIELD, (THORNE GARDEN, WEST SIDE) EAST SIDE) EAST SIDE) AIRBORNE STATE BEFORE DURING AFTER BEFORE DURING AFTER BEFORE DURING AFTER DUST -0.038 0.002 -0.001 0.003 0.005 0.001 0.002 VAPOR -0.026 0.008 -0.010 0.010 0.017 0.006 0.006 TOTAL -0.064 0.010 -0.011 0.013 0.022 0.007 0.008 SITE oh SITE Eh SITE F (THORNE LANE, (DUMP SITE, (DUMP SITE, EAST SIDE) FAR SIDE) NEAR SIDE) AIRBORNE STATE BEFORE DURING AFTER BEFORE DURING AFTER BEFORE DURING AFTER OUST 0.002 0.012 0.001 0.010 0.009 0.001 0.002 0.005 0.001 VAPOR 0.012 0.011 0.005 0.014 0.025 0.011 0.009 0.009 0.006 TOTAL 0.014 0.023 0.006 0.024 0.034 0.012 0.011 0.014 0.007 8DATES OF SAMPLING: BEFORE 10/04/78; DURING 10/05/78; AFTER 10/12/78. hoowNWIND DURING DIG.
b. Indoor Air Monitoring
The air was sampled f or the presence of PCBs
inside seven houses or other structures a long 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
9. Air was sampled inside six of the structures
on September 19 and inside the remaini ng 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 9), so t hat most of the build-
ings were not in the immediate vicinity of removal
operations . Consequently, 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 6. All were substantially be!ow the NIOSH
proposed criterion of 1 microgram/m. There was no
evidence of increased air levels in any of the
structures monitored during the digging operations.
All air monitoring data taken inside domiciles
and other buildings located along roadways on
which PCB spills ~ccurred showed no level above
0.10 micrograms/m. This level is one-tenth that
of the proposed NIOSH criterion for workplace air.
Table 6
Indoor Air Levels of Aroclor 1260 in Buildings Along
Test Removal Route
Location
Thompson Grocery
Thompson House
Inez Country Store
Thorne House
Thorne Barn
Fleming House
Chicken Coop
Before
0 .10
0 .02
0.01
~0 .01
<0 .01
0.10
0.01
31
Air concentrat~on
(micrograms/m)
During
0 .01
-' 0 . 01
<0.01
After
<::0.01
< 0.01
< O .01
THOMPSON HOUS INEZ COUNTRY STORE D THOMPSON GROCERY "Tl G) C ::0 ('f\ t.D INEZ □ □THORNE BARN THORNE HOUSE I FLEMING END HOUSE CHICKEN 0 COP 0.4 km I SCALE , .. START~-:-(:
2. Water Quality
A short-term water quality impact will occur as a
result of leaving particles of soil contaminated with
PCBs on the surface of the highway after removal. This
soil, which is not returned to the shoulder and incor-
porated into the soil column, will migrate to streams
during rainfall events which carries the soil particles
into drainage channels, ditches, and streams . Wind
could pick up the soil particles as dust and create
some migration of particles into adjacent fields. Test
results of the test pickup suggest that concentration
of PCBs contained in the soil remaining in cracks and
crevices of the pavement surface would be insignificant
when compared to the volume and concentration of the
material being removed from the shoulder. Test results
of the wash water utilized in the clean up operation
indicate that there is an extremely weak concentration
of PCB in solution that will be readily absorbed by the
soil along the roadside. 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 insignificant when compared to the
volume and concentration 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.
3. Plant and Animal Life
The PCB contaminated soil is currently available
to be ingested by animals which may be present on the
contaminated roadside. Removal of the soil from the
roadside and its disposition in the proposed landfill
will substantially diminish its availability to plant
and non-human animal life. At the landfill site the
contaminated soil will have no exposures to plants and
non-human animal life due to the fact that it will be
totally encased in a plastic lining and will be covered
by 1. 5 feet of soil. In addition the entire landfill
will be enclosed inside a chain link fence.
In so much as the actual soil removal operation
simulates the normal Department of Transportation main-
tenance work along the roadways, no adverse effect. on
the plant or non-human animal life is expected to
result from the excavation and grading. 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 represents
only a temporary disruption of the plant life along
these roadways.
32
The ether possible risk that must be considered is
that of displacement of PCB contaminated soil to the
adjacent area during the removal operation. Previous
laboratory testing by the North Carolina Department of
Agriculture found PCB on plant foliage up to several
hundred yards along these roadways. This atmospheric
translocation is presumed to be via PCB laden dust or
aerosol spray. The areas under consideration are all
in rural areas and therefore the possible contamination
of home gardens and agricultural field crops must be
considered. With adequate dust controls as demonstrated
during the removal operations in Warren County, there
would be no significant contamination of crops. The
levels o.f PCB expected to be found on such crops would
not preclude the usage of these crops.
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 opera-
tion will be quite similar to shoulder and ditch mainte-
nance operations routinely carried out by state forces.
Accordingly, these personnel have a great deal of
experience in the handling of traffic under these
conditions.
One way traffic will be maintained throughout the
removal sites. Advance warning signs in accordance
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 ade-
quate 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 mechanical failure
may be promptly alleviated.
33
B. Disposal Method
1. Air Quality
The air quality measurements taken before, during
and after the test removal of PCB contaminated soil
from the roadway shoulder were not found to exceed the
NIOSH criterion for workplace air of 1 microgram per
cubic meter. Wetting of the road shoulder 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 detected at
the dumping sites and little if any increase in total
airborne PCB was measured within two meters downwind of
the dumping. The placement of PCB contaminated soils
in the disposal area will be under similar conditions
and within an excavated pit; therefore, the potential
for airborne migration of particulate-bound PCB will be
further reduced. Designed close-out procedures will
preclude airborne contamination after site closure.
A gas vent will be installed in the disposal pit
to allow venting of gases generated by decomposing
grass contained in the disposed materials. Since all
external sources of moisture will be excluded from the
disposal area, moisture will be limiting for any decompo-
sition process and gas generation will be minimal. PCB
and more particularly carbon-absorbed PCB is not volatile
and will. not generate gaseous products. Disposal
operations will not present an unreasonable risk or
injury to public health and environment through air-
borne particulate-bound PCB or gas migration.
2. Water Quality-Hydrology
Water quality on the site will be protected by
multiple liners, leachate collection systems, and
erosion control measures and devices.
Surficial soils on·the disposal site have a high
clay and silt content. Studies copducted by the state
and a soils engineering firm indicate that the soils
meet or exceed requirements of 40 C.F.R. 761.41 Annex
II as amended. Copies of the laboratory test report
are included in Appendix B of this statement. Nineteen
soils borings of the disposal area were made and continuous
samples were obtained. Samples were analyzed in the
laboratory to determine classification, compaction and
permeability characteristics. The EPA soil requirements
and test results of the samples taken are listed below.
34
Requirement
Liner Materials
In place soil thick-
ness of 4' or 3'
compacted soil
liner
PeE9eability 1.0 x
10 cm/sec
Percent soil
passing #200
sieve Z30
Liquid limi tz:30
Plasticity index 2'15
State Study
Liner Maten.al
Sufficient mater-
ials for a S'
compacted liner
2.1 -2.4 X 10-8
cm/sec
Average 65%
Average SO
Average 18
Soil & Materi al Eng. Study
Liner Material
More than 50,000 cubic yds.
available to construct
5' compacted liner
5.8 to 1.8 x 10-8 cm/sec
59 -88 Percent
36 -71
9 -21
Artificial liners and liners constructed from
these soil materials will be engineered to prevent
infiltration and exfiltration from the site. The
sequence consisting of surface erosion control measures
and structures, compacted earth surface liner, 10 mil
artificial liner, upper leachate collection system. 30
mil artificial, 5' compacted clay liner, lower leachate
collection and removal system and, a minimum 5' separa-
tion from the highest predicted groundwater fluctuation
will prevent impact on ground or surface waters. There
will be no hydraulic connection between the PCB contami-
nated soil and surface or groundwater.
Any leachate generated will be withdrawn by the
leachate collection and removal system on as frequent a
schedule as necessary with monthly monitoring as a
minimum frequency. surface waters will be protected by
sedimentation basins during disposal operations and any
PCB contaminated sediment will be returned to the
disposal area prior to closure.
After site closeout the leachate collection systems
will be monitored monthly and receiving surface waters
biannually. The site will be monitored as long as
required by EPA regulations.
If any system failure occurs all necessary appro-
priate action for correction will be taken by the State
of North Carolina.
The disposal design provides stringent environmental
isolation of the PCB contaminated soil and does not
present an unreasonable risk of injury to public health
and the environment.
35
3. Plant and Animal Life
To assess the effect at the disposal s ite , both
the short and long range factors were considered. The
short range effect, if any , would be due to trans-
location from the disposal s i te 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, f i lled,
closed, and maintained as detailed elsewhere in this
report. There are no expected long range adverse
effectSon the plant or animal life at or near the
disposal site.
c. Land Use
The proposed disposal site is located within the Region
K, Kerr-Tar Regional Council of Governments. 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.
D. Cultural Resources
The North Carolina Department of Cultural Resources,
Division of Archives and History has reviewed 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 effects on
archaeological resources. It was concluded that there is
little likelihood that any archaeological resources will be
affected by the proposed disposal site.
E. Effect On Workers, Motorists and Area Residents
Based on the NIOSH (National Institute ~f Occupational
Safety and Health) standard of 1 microgram/m of PCB in air,
there is no reason to believe that temporary exposure, if
any, would create a health hazard to motorists who may drive
past a clean-up operation or to any resident who lives along
a spill route. The NIOSH standard 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.
While no adverse effect is expected among the personnel
involved in clean-up operations, personal protective wear
will be furnished those workers directly involved with the
removal and disposal operation.
36
In summary , no adverse effect on the workers, motorists,
or persons living along the spill sites is expected. -
37
IV. SIGNIFICANT ADVERSE ENVIRONMENTAL EFFECTS
WHICH CANNOT BE AVOIDED
The proposed removal and disposal of the PCB contaminated
soil from the roadway shoulder will have some adverse effects
on the environment. The most significant effect will be the
taking of approximately five acres of land out of agricultural
production for an indefinite period of time. The remaining
137 acres will be utilized as a buffer zone for the disposal
pit. A portion or all of the land used as a buffer area ma~'
be leased by the State for agricultural or other compatible
land uses. The disposal of the PCB contaminated soil at the
Warren County site will restrict land use within the fenced
area of the proposed disposal site.
38
V. STEPS TAKEN TO MINIMIZED HARM OF UNAVOIDABLE
ADVERSE ENVIRONMENTAL EFFECTS
Although approximately 142 acres of land will be pur-
chased by the State for construction and protection of a
disposal site to contain the PCB contaminated soil, only
approximately five acres will be removed from production.
The remaining acreage will remain suitable for farming pur-
poses . The disposal site will be monitored as indicated
previously in this statement .
The design and construction of the disposal pit will be
done according to the procedures and EPA regulations outlined
in this statement. Every effort will be made to remove,
transport and dispose of the PCB contaminated soil in a safe
and efficient manner as possible to protect the natural and
human environment from further exposure to the PCB substance
present in the soil.
39
VI. THE RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF
MAN'S ENVIRONMENT AND THE MAINTENANCE AJ-I'D
ENHANCEMENT OF LONG-TERM PRODUCT IV ITY
The immediate short-term effects on plant and non-human
animal life are restricted mainly to those animals which may
ingest the PCB contaminated soil or vegetation present along
the roadway shoulders . During the removal of the PCB con-
taminated soil from the roadway shoulder minor amounts of
soil in the form of dust particles could be translocated to
adjacent home gardens and agricultural field crops. However,
the use of dust control procedures will help to prevent any
significant contamination of these areas.
Utilization of approximately five acres of agricultural
land for the disposal site will result in a permanent loss
of this farmland. Upon removal of the PCB contaminated
soil, backfilling and seeding of the roadway shoulder activi-
ties involving maintenance, installation of utility lines
and driveway pipes will be permitted along the 211 shoulder
miles of roadway.
In summary the short-term effects involving the removal
and disposal of the PCB contaminated soil is not expected to
create conditions that will drastically alter the long-term
productivity of the surrounding plant life and non-human
animal life. The proposed action will contribute to the
long-term economic benefit of present and future residents
who are located adjacent to the roadway shoulders.
40
VII. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF
RESOURCES WHICH WILL BE INVOLVED IN THE
PROPOSED ACTION
Approximately five acres of agricultural land will be
indefinitely committed to containment of the roadway soil
contaminated with PCB industrial waste material . Removal
and disposal of the PCB contaminated soil will involve a
substantial commitment of resources including financial
expenditures for labor and materials. Although the labor
required to perform the proposed action is an irretrievable
resource benefits in the form of returning the roadway
shoulders to normal usage and removal of a potentially
hazardous industrial waste material from the roadside will
justify usage of the necessary labor and financial resources.
41
VIII. COMMENTS RECEIVED ON THE DRAFT STATEMENT AND RESPONSES
The Draft Environmental Impact Statement was circul~ted
and written comments were received from the Kerr-Tar Regional
Council of Governments and Sierra Club -Joseph Leconte Chap-
ter. Their comments on the Draft Statement have been consid-
ered in preparing the Final Environmental Impact Statement.
Their comments and our responses follow.
A. Kerr-Tar Regional council of Governments
1 . Comment:
Additional emphasis needs to be placed on the inte-
grity of the plastic liner.
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 water . Annual mowing should be a mini-
mum requirement.
b. The plastic liners along the side walls of the
proposed site offer the only barrier between
the disposed PCB waste and the surrounding
soil. What other measures does the State pro-
pose in order to mitigate any damage of or
decomposition of the plastic liner. (root
intrusion, damage by equipment, etc.)?
Response: (a) The United States Department of Agri-
culture, Soil Conservation Service was
contacted for their recommended procedures
to establish, support and maintain a vege-
tative cover on the PCB waste landfill site.
Their recommendations are included in Appen-
dix E. Their procedures and specifications
for a vegetative cover will be incorporated
into the-design of the PCB waste landfill.
(b) The proposed conceptual design for the
PCB landfill disposal site has been revised
to provide greater protection to the arti-
ficial liner. The final EIS contains a re-
vised conceptual plan for constructing the
landfill, see page 11. The revised plan pro-
vides a layer of material beneath and above
the artificial liner to protect it during
construction of the landfill and placement
of the PCB contaminated soil. A qualified
design consultant will be contracted to
prepare plans and specifications for con-
struction of the PCB landfill disposal
site. ·
42
2. Comment:
Half the waste is to be buried above current ground
level and thus be subject to event~al erosion or slump.
The Statement mentions flood diversion structures but
does not describe them or indicate how long they might
be expected to last.
Response: The purpose of the holding pond is to
divert surface runoff from the disposal pit area during
construction. The PCB disposal site is located above
the 100 year flood plain. -After the PCB landfill opera-
tion is completed no flood diversion structures are plan-
ned. Surface run-on at the site will be diverted by grad-
ing the vegetative cover for the PCB landfill to topogra-
phical lows along the perimeter of the landfill site.
3 . Comment:
The proximity of the water table and the bottom of
the sump is too close. This is of utmost concern since
the exact elevation of the water table has not been de-
termined, only estimated.
Response: Subsurface investigations through borings
and the study of hydrographs of wells in the vicinity of
the disposal site have given reasonable indication of ex-
pected high ground water elevations. The proposed separa-
tion of 14 feet between the waste material containing
PCB's and the high ground water elevation is within EPA
regulations. Maximum separation between the waste mate-
rial and ground water levels will be given careful con-
sideration during the design of the PCB landfill site.
4. Comment:
The plan allows numerous opportunities for human
errors in construction: installing plastic liners and
pipes, compacting the cl~y liner, driving trucks on top
of buried pipes and close to plastic side liners, and
close tolerance surface grading.
Response: The proposed conceptual plan for the PCB
landfill has been revised in the final EIS, see page 11.
The revised plan provides greater protection to the arti-
ficial liner and leachate collection system. As stated
in response to question 1 a qualified consultant will be
contracted to design, prepare construction plans and spe-
cifications and to see that the PCB landfill is built in
accordance with those plans and specifications.
5. Comment:
The site must not be subject to flooding or have a
hydrologic connection with the groundwater according to
p. 16 of the Draft EIS 11 Surface water discharge is to
43
Richneck Creek ... 40 miles separate the site discharge
area and the closest raw water intake." If a disruption
were to occur, the PCB ~aterial 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?
Response : Every reasonable precaution is being
taken in the desi~n of the PCB landfill to prevent dis-
charge to ground or surface water.
6. Comment:
This is not an adequate environmental statement.
More emphasis has been placed 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.
Response: The environmental impacts of the proposed
action are discussed in sections III, IV, V and VI of the
EIS. The impact of the proposed action on the air quality,
water quality, plant life, animal life, and potential ef-
fects on workers, motorist and area residents have been
identified and discussed in the EIS.
7. Comment:
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?
Response: Sections IV, V, VI, and VII of the EIS
indicated that the net economic impact of the pick up
and disposal will be positive for Warren County due to
the ability to utilize ·the presently contaminated shoul-
ders. The landfill will have absolutely no impact on
land use outside of the State-owned property; and there-
fore the economy of Warren County will not be affected.
This conclusion is supported by the fact that a major
poultry processing plant has recently decided to locate
in Warren County with full knowledge of the PCB disposal
plan.
8. Comment:
Reputable sources have disputed the State findings
on the availability of clayey material, further investi-
gation should be made.
44
Response: The procedures used in the selecting po-
tential disposal sites required that the land area and
subsurface soils met EPA landfill technical requirements.
The soils at the Warren County site have been evaluated
by State agencies and by a soils engineering f i rm on
different occasions. The North Carolina Department of
Tr=.nsportation, Division of Highways, Geotechnical Unit
and Department of Human Resources, Environmental Engi-
neers conducted in-place soil evaluations on September
18, 1978 and on December 6, 1978. A soils engineering
firm, Soil and Material Engineers Inc ., performed an
investigation and evaluation of soil conditions at the
Warren County site in February and June of 1979. These
soil evaluations and laboratory test results are in in-
cluded in Appendix B of the EIS. The soil borings and
laboratory tests indicated that most of the clayey mate-
rial is found in the soil surface to a depth of 4 feet
or more. The tests indicated that the material when
compacted to 95% standard proctor met or exceeded per-
meability requirements.
9. Comment:
The express will of the local government concerning
PCB disposal should be given more consideration by the
State government.
Response: The comments and views of the local
governments have been given careful attention. The EIS
incorporates many of the suggestions of the local govern-
ments.
10. Comment:
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 recom-
mended that the State's proposal be turned down and his
paper, A Review of the Proposal to Use Soils in the Afton
Community of Warren County, N. c. as a Disposal Site for
SoilsContaminated with PCB, still remains valid for the
most part.
Response: Dr. Charles L. Mulchi's questions about
clay type, depth of clay and ground water levels have
been addressed in sections I and II of the environmental
impact statement. The investigation and evaluation of
soil conditions at the Warren County site were conducted
by the State and by a soils engineering firm. Their in-
45
B.
dependent analysis of the in-place soil conditions con-
c luded the proposed site can meet EPA technical require-
ments for construction of a PCB waste landfill.
Si err a Club -Josenh Leconte Chapter
1. Comment :
Citizens Monitoring Committee
A committee of local citizens must be formed to mon-
i tor .the construction, operation and long term management
of the facility. Members of the committee must include
local officials, adjacent land owners, and leaders of the
community including those who may be opposed to the pro-
posed action. This will allow the affected community to
keep close watch on all activities concerning this pro-
ject. It must be in attendance during all activiti es,
especially the monitoring after closure of the landfill.
Response: The PCB landfill will be designed by a
qualified consulting firm . The consultant will monitor
the construction process and perform necessary quality
control testing to assure that t..~e landfill is built
according to plans and specifications. The North Caro-
lina Department of Human Resources will also provide
personnel to monitor and inspect the construction of the
landfill.
2. Comment:
Disclosure
All operations and monitoring data must be announced
to the local and statewide news media on a regular and con-
tinuing basis. This will keep the public informed of the
current status whether good or bad and will provide ac-
countability of the responsible state officials.
Response: Data resulting from the testing of soils
at the site and water monitoring data will be documented
and kept on file. This •information will be made available
to the news media and the public upon request .
3. Comment:
Leachate Treatment·
Treatment of leachate has been discussed in the DEIS.
However, no method of disposal of the treatment residue of
leachate after landfill closure has been described. An
approved EPA method of disposal must be provided for this
residue.
The decontaminated effluent of the leachate must be
tested before it is discharged. This effluent must not
be released until laboratory analysis has confirmed that
the PCB's have been removed. The DEIS must describe the
manner in which the effluent will be discharged.
46
Response: The Final EIS has been revised to reflect
this comment, see page 14.
4. Comment:
All possible legal and administrative actions must
be taken to insure the one time use of this site for the
disposal of the PCB contaminated soil as described in the
DEIS. The affected community needs every guarantee that
the proposed action is the only use ever for the site.
Response: The environmental impact statement ad-
dresses the removal of approximately 40,000 cubic yards
of PCB laced soil located along approximately 210 miles
of roadway shoulder and the disposal of the soil at a
selected site in Warren County. The State has no future
plans to use the PCB landfill site in Warren County for
disposal of additional PCB material and/or other hazard-
ous waste. The present administration has no authority
to bind future administration to restricted use of this
property as a one time hazardous waste disposal site.
5. Comment:
The proposed five (5) foot groundwater separation is
insufficient. Information in the DEIS shows that a much
greater separation is possible.
Page 17, paragraph 1 gives the maximum excavation
depth as 24 feet. Thus, by removing the thickness of
the liner and leachate collection systems, the landfill
will have a useable depth of 17 feet. Allowing for to-
pographic variation, a useable depth of 15 feet would
mean that the entire 40,000 cubic yards of contaminated
material could be stored in an area of 1.7 acres.
By increasing the landfill surface area to 2.9 acres
(as is shown in the N. C. Department of Transportation
boring (soils) study in the DEIS), the maximum excavation
depth would only be 14 feet -10 feet shallower than pro-
posed in the DEIS. This increase in area will increase
the groundwater separation to 15 feet -more than double
the proposed separation.
In the interest of maintaining environmental pro-
tection, the final design for the landfill must provide
greater groundwater separation than proposed. This can
be achieved at little or no increased cost and will pro-
vide a greater measure of security.
Response: EPA regulations require a minimum of 10'
separation between the PCB contaminated soil and the sea-
sonal high groundwater table. The predicted maximum
groundwater table is 312 feet or 32 feet below existing
land surface. The proposed PCB landfill design allows
47
a separation of 14 feet from the PCB contaminated soil
and the predicted maximum groundwater table. A decrease
in excavation depth will increase the ground surface area
of the landfill that is exposed to natural environmental
weathering conditions. The proposed landfill design seeks
a balance between separation of groundwater and ground sur-
face exposure to minimize environmental impacts.
6 . Comment:
According to Figure 5, Section I. D., the landfill
will not have a contiguous clay liner; the design fails
to provide a uniform container of equal specifications
for the bottom, sides and top. The DEIS provides no in-
formation to show that latterally moving groundwater or
that animals will not be a problem. In addition, there
is no information about the long term integrity of the
artificial liner.
The entire landfill must be encased in a clay liner
that is contiguous from the cap to the bottom including
the sidewalks. This contiguous liner must be construc-
ted to the specifications that are proposed for the bot-
tom in the DEIS .
Response: The proposed conceptual design of the
PCB waste landfill has been revised to reflect the above
comment, see page 11.
7. Comment:
The proposed cap design is insufficient to provide
for vegetal erosion control and to prevent future pene-
tration by surface water. The specifications on page 12
(10 mil artificial liner, 1.5 foot clay liner and 6 inches
of topsoil graded to a 2% slope) fail to provide an ade-
quate root zone for maintaining vegetation without an ir-
rigation system. Any vegetation established in such a
thin zone for roots will be very susceptable to drought.
Site maintenance must include fertilization and reseeding
of the vegetal cover.
Moreover, the cap is not thick enough to allow for
pedogenetic (soil forming) processes. The design pro-
vides for an almost inpenetrable bottom; it must provide
a no less penetrable cap. The chemical and physical forces
that could penetrate the landfill are most intense at the
ground surface. It is conceivable that normal climatic
events could easily penetrate the 2 feet of topsoil and
clay liner within a century. This scenario is made more
probable if a small area of vegetation dies and erosion
occurs.
The cap design must specify 2 feet of root zone
consistant with agronomic concepts and the same clay
48
liner plus artificial liner requirements as proposed for
the bottom in the DEIS . An agronomist-soil scientist
must supervise all surficial earth disturbances, vege-
tation and cap construction.
Response : The United States Department of Agricul-
ture , Soil Conservation Service was contacted for their
recommended procedures to establish, support and main-
tain a vegetati ve cover on the PCB waste landfill site .
Their recommendations are included in Appendix E . Their
procedures and specifications for a vegetative cover will
be incorporated into the design of the PCB waste landfill.
8 . Comment :
Revi sed Draft Environmental Impact Statement
We request that a revised DEIS be prepared which
incorporates our recommendations. This revised document
will allow al l agencies and the public to assess sub-
mitted comments on the proposed action.
Response: The final environmental impact state-
ment contains responses to the comments received on the
draft statement, see section VIII, of this statement.
Those recommendations that were considered reasonable
and feasible to implement have been incorporated into
the Final EIS. Comments received on the Draft EIS are
included in Appendix D of this statement.
TLW/FV/dk
49
APPENDIX A
PCB Spill Site Locations
and
Soil Sampling Results
..
SPILL SITI No. l
LOCAT!CNS:
1. SR 1004, Alamance County-From Bethel Church ?forth of Snow Camo to the r:~atham
County Line. Lengt~: 5.00 shoulder oiles.
2. SR 1004, Chatham County-From Al~nnnce County Line to SR 1346. Length: 2.22
snoulder miles.
3. si 1346, Chatham County-From intersection with SR 1004 to ~!C 87. Length: ll,16
shoulder miles.
4. NC 87, Chatham County-From intersection with SR 134~ Southerly. Length: appro-
ximately 1.42 shoulder miles.
Location of Sampling Sites within Spill Site No. 1
A. SR 1004, .lS mile South of SR 2352 pole ff5463 SPC 75
B. SR 1346, 0.5 mile East of SR 1335 in front of pole fl74'36
C. SR 1346, 51 yards West of Leroy Gowen mailbox-1 :11ile West of SR 1506
Sa:-:pling results are given in terms of mg/kg of Aroclor 1260 unless otherwise noted.
0-1 Inches
1-3 Inches
3-6 Inches
_S-f li1P/4£ A .S)/i!?I. e:.. g SA/l!PA£ c,,
• 11 SITE --it-g ¥JaB=73 U':'e C
20
1.9
32
140
4.1
2100
130
35
17t~K··--x7 ·~,.w~L = '3 .lll!' p ,, --, ~-' '\-;. ll1' . .ll.il. ..,.
I
llit _u;J. ,.
1.L"i
... . .,
1.0
,.,.,.~ .•
. ........ .:
\ "'R 'K .df/""
LlZZ #-# ~
\ 'fil ~,. '.l!..!.~ °"'""' ·.':"
SPILL SITE ~o. 2
LOCATIONS:
l. US 421, Chatham County-SR 2126 to Lee r.~~-nty Li ne. Length: 9.59 shoulder miles.
2. SR 1006, Chatha!:'t r.oun.ty-Bet-..·ee._ ~:C' 9()2 and ~:c 4'.!. Length: 3.46 shoulder ciles.
3. ~C 42, Cha~ham Cnunty-~rom Deep Ri•,er (tee County Line) to intersection with
SR 1006. Length: 4.56 shoulder miles
4. NC 902, Chathar.1 County-From S~. 1006 to Rocky Ri·-1er. Length: 9.M~ shoulder m:1:es .
5. NC 42, Lee County-From intersection with SR 1322 to Deep River (Chatham County
Line). Length: 4.52 shoulder miles.
Location of Sampling Sites within Spill Site ~o . 2
A. US 421, 1.6 mile South of SR 101() ~orth end of ,:,;uardrail 3"-6"
B. NC 42, 1. 5 miles t,W of SR 2306 in front of SE c,,rner of John Vaughn's pond
C. NC 902, 1.0 mile ~ortheast of SR 1141 directly across from telephone pole ~674
SPC 8
Sacpling results are
0-1 Inches
1-3 Inches
3-6 Inches
.. ~iven in terms of mg/kg of Aroclor 1260 unless othet"'.Jise noted.
. .5Al/:'P)-= A SA/J1PJ.E 8 .5~/Y!PI..£ c
SITE A SITE~ SITE G
2 .4
<1
< 1
18M
22
480
<1
• U!1
~(~
9
Lm
mi
-J.. \
. C 'lo
~I ., I
I ,.
1,
!Jll
i!.lli.-Oa.... 0 :
\ lj
/_)
1 1 ~,
0
· •. ~! ... o,.,..,
'
SPil.L SITE No. 3
LOCATIONS:
l. ~re 87, Lee County-From Harnett Co•.mty Line to VS 421. Length: Z. 1'4 shoulder
miles.
2. ~L:: 87, Harnett County-From Lee County Line to NC 27. Length: 5,311 shoulder
:niles.
J. ~ic '!.7, Harnett County··From NC 87 to SR 12.:'.:. L,~ngt!'l: 12 :no shoulder mi Ls .
Location of Sa~pling Sites within Spill Site ~o. 3
A. '.Jn Hwy. S7 approximately 1. l ~ile South from junction S7'.. 1203.
B. Hwy. 27 ').J ::tlle East of SR 1210 at T•,li::1 Oal~s.
C. Hwy. 8 7 0. J mile North of SR 12n3 at ulitily ·"!C•~ss 1128A at pine tree.
Sa~~ling results are given in :errui of m~/kg of Aroclcir 1260 unless other.,ise noted •
.5,,IITI PJ.. £ A 5 ,4;,,, f'J.. E /3 SA /lf..PJ. E ~
0-1 Inches
1-3 Inches
3-6 Inches
SITE 21
2400
110
110
6iTB B
7.6
SITE G
20()0
480
1S
---J ---'.'J I • --~ -~ : -:~ ~~ ~ .... ~ :f;"':'°
1.l
!.ill. 3,~,
I ~ \
)
i ... ~\...
~ I ~ -_.(
~I
I
SPILL SITE No. 4
LOCATIONS:
L NC 96, Gr:invill<?. Cou:i.t::-•-:'roc just )~orth of Cr.{ford to ~C 49. Le:-.c:::'c: 15 .2
shoulder 'r.!iles.
2. ~-l'C 49, Granville County-Fret:? ~re ~6 to Person Coun:y Line. Length: 1. 80
shculder miles.
3. NC 49, Person Co1..nt7-?:-oo ,;ran\".:..ile C;:.,u.1ty Line t:o S?.. 1515. i.enµ:t:-i: 4.24
shoulder miles.
Location of Sampling Sites W'ithin Spill Site ~ro. 4
A. 1. 6 mile South East of NC 49-Ad:!.ac~nt to Ca.roli:-la. Telephone 3"-6" Exe. Bound
B. 0.4 mi.!.e west of S?.. 1510 Surface
~. 0.5 ~ile East of SR 1509
Samr>ling result:s are 2i•1en in t:enns of mg/kg of Aroclor 1260 unless otherwise noted.
5,4/Jt,CJJ...E. A SA/11 pl..£ B 5AM PJ.£ c..
GtiL ft SITE C
1)-1 Inches ' , 2600 (1242) fi9 (1242) 6.3 (1242)
710 25 2.9
1-3 Inches 11 (1242) <1 (1242) <1 (1242)
2.1 < 1 ~1
3-6 Inches 18 (1242) <l (1242)
6.7 ~1
G N
' --7--,
w.
. ,,,. A ..
<_, •
i
I
• . I izn-40-:
}-------.
~--llli.J
~ I // .. -:.,
i •
: . ,., .. , .. ~ ', . f , ~~~1·
1 <..,_ .... ~
',, ' · _ __,,,---',
~
B i, ,, ,
~ ~~ ··-------
SPILL SITE ~To. 5
LOCATIONS:
1. ?TC 210, 1-Lunett C::it::--,~y-?ron Johnston County Line to City limits of Angier.
Length: 1.82 shoulder miles.
2. NC 210, Johnston County-Fr~m intersection with US 70 Southerly to Harnett
County Line. :•;c:th side only. Length: 17 .00 shoulder miles.
Location of Sampling Sites within Spill Sites No. 5
Nr.,
A. J~nction 210 andA50.3 ~ile Southwest 210 opposite GV Kings Driveway J
B. H,;.,y. 210 0.6 miles of junction with SR 1335 at RH Lassester's Hertford.
C. On Rwy. 210 l. mile Southwest junction SR 1010 Johnson County across Ulility
Pole 1147 d-/
Sampling results are given in terms of mg/kg of Aroclor 12~0 tmless othervise noted,
.5)/!IPJ...£ A >Ak.PJ...£ {3 ..5,4111PL£ C
3-M'!---.ilt-9H'f e 9'!ff e
0-l Inches 3600 94 (1242) 390 (1242)
' ' 850 4101')
1-3 Inches 12 3,3 (1242) 14 (1242)
30 55
3-6 Inches 14 < 1 (1242) 1.1 (1242)
6 5.5
---
S!>!LL SITE No. 6
LOCATIO!lS :
1. US 158, Warren County-Between :!aeon and Vaughan.
Length: 0.60 shoulder miles.
Location of Sampling Sites within Spill Site No. 6
A. NC 158, 1 mile West of SR 1325 Surface
B. NC P.wy. 158 NR Macon.
Sanpli..~g results are given in terns of mg/kg of Aroclor 1260 unless otherwise noted .
.5AMl'.L E. A $/liJt,f'J.. £ 1.3
0-1 Inches
l-3 Inches
3-6 Inches
' J
-----------------------
SITE A 9IT! B
70
2.0
190
8
S"-z, T' -----1.._
( -....
F ( T'
A
SPILL SITE No. 7
LOCATIONS:
l, NC 44, Edgecombe County-Froc SR 1409 East 0,2 ~iles.
Length: 0.23 shoulder miles.
Location of Sampling Sites within Spill Site No. 7
A. HYy. 44, .35 mile East of SR 1409
Sampling results are given in terms of mg/kg of Arcclor 1260 unless otherwies noted.
0-1 Inches
1-3 Inches
3-6 Inches
5AirJ Pi. E A .5 A/IJPJ,. ;_ 13 .SAi!!? ,( £. C
iITi A SI'ff B :!I!!! C
------------------
' J<1
L SITE No.
!,
~
(
(.
/1
!90.!
. 1
\
\ I
/
I I
~ ,.
<.i
. ·1 , " Y,
/ I l
'
-f ~t~ ... -....... ..-...... ~
m ~ ~-
T "".J.. ......... .......... ,,'\
•:B) -~--
!-!_~ ~~.•l..!.J!
, I
'J ' ..
..
\ \
,,.,
(,--
SP!LL S !TI No • 9
LOCATIONS:
1. No sit:e description li9ted by :)I"'!'.
Location of Sampling Sites within S;:,ill Site ~fo. ,.,
A. SR 1101, 0.4 mile ~7orth of :!;J"V. 4:!-ccmposite, :-.sst c f 5;{ 1rvn
B. SR 1001, 0.4 mile North of Hwy. 42-coffl'!'osit:e, ~est~£ ~u :00:.
Sam!)ling !'esults are given in t'!I"'!'IS of mg/kg of Aroclor 126') unless otherwise noted.
~ II ,Nl'1 ,7; .. _,7 ,,.--'. """"'' .,. .... :~ ...) /711/,~,.__J::. /''I' .>,",,,N!,,,·;._ !.j
SITE.\ ~
Ccn11pos : te < 1
. ,
SP ILL SITE ~fo. 10
.1... ~~c :.'3, '!;::;h C,,l"'.',t:-•-='-:-::i;::: r.:i.s l1'til'..~ ;.•,; · . .-u.:,on ::ou::t y Li.7.e. Len~th: 4.12
s,10•.Jl.c.er ;:;iles.
Location of Sc~pl~n; ~iC~3 wic~in Spill Site ~o. 10
A. NC Hwy. 58, .55 mile South of SR 1145
B. NC HTJY, 58, ES ' ~:orth of SR 1744
C. ~?CHwy. 58, 2:6' Sou::~ofSRl75f-
Sampling results are give~ in terms of
.SAlilPLE .-4'
mg/kg of Aroclor 1260 unless othervise noted.
.5,A/rlf)J.~ J3 5Al'r!PJ.£ e,
9 flf!= 9 SITE 8
G-1 Inc:ies 680 58 560
1-3 Inches < l 25
J-6 Inche$ ' , 1.2 < l 1.2
·..:.: ...•.. , ... .... .. ... ,-tE.. o. ~~
Iii{ -''< 'f
--◄~ ... ~--:
\,, _,, :,~ --.. _ ~ ---
... ,
SPILL SITE :;o. ll
l . ~re 97, ;,fat·e County-From Zebulon to Franklin County Line and ft'ol!I t:S f4 Bus. to
Zebulon. Len~th: 4.50 shoulder miles.
2. NC 97, 7:-anklin County-From Wal~e County Line to ~rash County Line. Length: 0.9()
shoulder miles.
3. NC 98, Eash County-From Franklin County Line to ~C 231. Length: 1.41 shoulder
miles.
4. ~:c 231, ~iash County-From NC 98 co S~ 1137. Length: (),94 shoulder miles.
5. SR 1.137, Nash County-From NC 231 to ;TC 97. Len~th: J. 43 shoulder miles.
6. ~C 97, ~Tash Countv-From SR 1117 to Franklin Counc:y Line. Len?th: 4. 39 shoulder
miles.
7. NC 98, Franklin County-From :iash County Line to ?unr. and approxiMtely 5 miles
west of Bunn. Length: 4.79 shoulder miles.
-r..ocation of Samplin~ Sites within Spill Site ~o. 11
A. 0.3 mile East of SR 2370 (NC 97)
. l
B. !'iC 97, 0.5 mile East of NC 231
C. NC 98, 0.5 mile Northeast of SR 1611
Sampling results are given 1n terms of mg/kg of Aroclor 1260 unless otherwise noted •
0-1 Inches
1-3 Inches
3-6 Inches
..5Al!fP1.£A SA/J!PJ..! 13 .5At1tPJ.Z. C-
&ITE 1•1 SITE B SIT! S
130
4.8
1.2
79
1.2
LO
110
1.6
. ,,,
ill1 • I. tU
--, -
I J I (.j 1 111 .
l.:,;: /J.J,. ~ , ,
,,,
?,,)ill
.!..!.Jti ........ ' '1wz.
... :_ '. 11"1 'I', zi.r ,, -"Ill ota"OiaC
...... 1.l..!i IUJ '" ~ EB i;:~ .. -. H .. ~
,0 ./.i; '-' 1 •1-•z ·-~-~ -~
SPILL SITE No. 12
LOCATIONS:
1. NC 96, Wake County-From 08 to Fran~lin County line, traces only. Length; 0 .03
shoulder ~iles.
2. No description for Franklin County segment.
Location of Sampling Sites W'ithin Spill Site !To. 12
A. Waka/Franklin County Line on NC North 96 (No PCB suspected at this point)-Composite
B. Wake/Franklin County Line on ~re East 96 (~o PC:E susl)ected at this. point)-Composite
Sar.J ling results are given in terms of mg/kg of Aroclcr 1260 i.mless otherwise noted.
SAm,::,J.E 1/, S A./J!Pl .E 8 s::i A sr:: J
Cor.tposite <. l < l:
. J
'
SPILL SITE ~o. 13
LOCATIONS:
l. t:c 53, Nash Cotmty-Froc. Franklin County Line ::o 3 miles ~forth of Nashvil!.e.
2 . NC 58, Franklin County-From Warren County Line to Nash County Line.
3. ~.c 58, Warren County-From intersection ..:ith NC 43 Southerly to Franklin County-
:oth sides. Length: 19.25 shoulder miles.
Location of Sampling Sites within Spill Site No. 13
A. NC 58, 0.2 miles from SR 1631 and 1.2 miles from SR 160R
B. ::c :{wy. 58, 2.0 r.iile South of SR 1649
C. Hwy. 58, 0.5 dle ~{crth of S'R. 1449
~,~pli~~ results are ~iven in terms of mg/kg of Aroclor 1260 unless other1:ise noted.
0-1 Inches
1-3 I:1ches
3-6 Inches
. J
S,41;1,,::JA. £. ~ ;A,ttP:.i.3 ;;";4mpJ. £ C
SITE A 9!!! 3 -SI!~ C
2500
210
J.4
<1 2100
41
1.5
SPILL SITE ~ro. 13 (Re-Sa!!!plc)
LOCATIONS:
l. ~TC 58, Nash County-From Franklin Ccur:ty Line to : r:iiles /fo r::~ of ~:.::::'1v~lle .
2. !'IC 58, Franklin County-From Warren Counc:y L:!.ne tc llash Count:,-Line.
3. ~TC 58, Warren Counc:y-From intersection with ~IC L,J Southerly to Franklin CoW1ty-
both sides. Length : 19.25 shoulder mi l~s.
Location of Sampling Sites within Spill Site No. 13
IL Hvy. 58,
D. Hvy. 58,
,.. Ewy. 58, C..
negative.
North of
200 yds.
200 yd:3.
Centerville.
North of side
North of sets
13-E take~ 2/2/70 to be usad for possihle location.
~13-D auxillary samply if 13-B series return
Sam!=ling results are given in terms of :ng/kg of Arocl ~1r 1260 t.mle:c;s othen,,ise noted •
0-1 Inches
• J
1-3 Inches
J-6 Inches
Composite
.SAll1f'J£ B
SITE ~
16 (1242)
160
~ 1 (1242)
1.9
, 1 (1242)
\"l
S' AtnpJ..£ D
Sf¥! !:l
86 (1242)
1100
S 4/tf ().. E. !:
!U't!! f
170 (1242)
1600
. -·· ----·-··------------------------------
SPILL SITE ~o. 14
LOC AT:JNS:
1. SR 1432 and SR 1<'<36, Frankli:1 Count~;-E'roni 1/2 ~i..'..e East of ~'oulton to a point
beyond Gupton, :~a~ traces to c~nterville. Length : 5.10 shoulder miles.
2. :iC 561, franklin County-From Nas:1 County Line to Centerville. Length: 4,30
shoulder t:iles.
3. :-JC 561, ::.:::;h C.:i1....1:y-From Franklfa County Line to Ealifax County Lir\e. Length: 0. 7
4. '!-TC 561, Halifax County-From S?. 1317 to Nash Coun t y Line. Length: J.S~ shoulder
miles.
S. ~C 43, Halifax Cn•..mt:,-:From Warren Cotmty Line to NC 561. Length: 0.65
shoulder '."'.liles.
6. ~!C 43, warren County-Froe. Liberia to H:ilifax C'.ounty Line. Length: 6 .40 shoulder
miles.
Location of Sampling Sites within Spill Site No. 14
A. SR 1436 at 0.1 t:dle ~fortheast of Sandy Creek Bridge
B. Rwy. 561 and SR 1447
C. Hwy. 43, 0.9 mle Southeast of 1512
Sampling results are given in terms of mg/kg of Aroclor 1260 unless otherwise noted •
0-1 Inches
l-3 Inches
3-6 Inches
.5Air. ::;,1._.5 A SA,,nJ?;._~ B SAMPA.£. L.
SIK A SITE :Z S!ll C
91
< l
< 1
240
< l
9.4 (1242)
42
i
'
\
..•
. / ..
\ ,w•~.: \
\ ' \
I ' \
S,_.a,
L,
'n '. ,.
Shoo:,, (\ • ---~~
(
'
:;~~•"r ·
l1ll f",,JunQ
""" -I ....
!l;
l.!1,9;
~¾ "" ·•.,:h
SP I!..L SITE :fo . 15
LOCATIC!'iS:
l. ~escription not listed.
Location of Samplin~ Sites within Spill Site :!o. 15
A. Hwy. 4 ,.lorth of SR 1315
Sampling t"esults are given in ter;,,s oE r:,g/kg of ,\roclor l'.!6() unless otherwise noted.
SAtttPA£.A
0-1 Inches
1-J Inches
3-6 Inches
. l
eITi ,\
120
1.6
LOCATIONS:
, -· ~C 4, Halifax County -Fror.:i S:-{ !.J H to SR 13'18.
L~ngth: 3 .13 shouid ~r ~il~s
Locacion of Sampling Sites ~ithi~ ~,.....; , ,
'-'!""··--Si:z ~:o. 15 (Formerly) 16
A. Rwy. 4 at SR 1309
S~pling results are given ln tc:.::s of :ng/kg of Aroclor 1260 unless othervise noted •
.54/Y/f'J...E A
~?!I!! A
0-1 r~ches 45
1-3 Inches < l
3-6 .,. . .. ncnes < 1
'
SPILL STI'E :;o. 15 (Formerly) 17
LOCATIONS:
1. SR 1308, fl.'1!.i.:a~,; County -From 0 .1 :::iile ~forth of S? 1309 to 1.2 .niles }Torth.
Len;th: l .lJ shoulder miles.
Lcc.:i::.:.on. of Sc1.~pli .. 1 ~ Sl::es wi thin Spill Sit:e )To. 15 (Forn:erly) 17
A. Pe~: s:!..!~ ~., , ~ ,'\':'I -J·'"'J ,
, , _.n miles of juncc:.on of P.wy . 4 and SR 1303
.,) . E..ls.:: ~:!."-e SR. 13')8, 1.6 miles of j1..nction of ~ . 4 and SR 1308.
Sampli.."lg results are given in terms of mg/kg of Arocl or 1260 unless othe~..rise noted.
5AIY!J?J.. £ A 5,4,n;:J...Z 3
SITE A Sitt-t 3
Compos ice 5.2 33
SP!L!. SITE No. 15 (?.e-Samol<?) 17
LOGATIONS:
l. SR 1308, ~..alifax County -F'!'c--=t ,1.1. mile Non~ o,' 5R 1309 to 1.2 miles ~lorth.
Length: 1.13 shoulder miles .
Location of Sampling Sites within Spill Sir:e No. 15 (For~erly) 17
' S:t 1308 1/4 . , from SR 1309 :-rorth side .. ·!..a m1_es
B. SR 1308 1/4 miles from SR 1309 South side
c. SR 1308 l.i) mil.? ~7ot"th of SR 130'? East: side of road asphalt covering
D. SR 1308 1.0 :nile ~:Orth of SF. lJIJ~ West: side of ?'.'oad 0-1"
Sampling results are given in ten~ of mg/kg of Aroclor 1260 unless otherwise noted.
5A-/1'1PI..EA SIJft1PJ.,£ t3 S/IIY!?.1..£ t:-rAirtPJ..E. !J
9!7E A gzmr J SITE C SITED
0-1 Inches 16 7.0 l.4 2.6 (1242)
76 ,
l-3 Inches s.s l l l (1242)
l • 1
3-6 Inches J.8 1 l l (1242)
S?!LL SI!~ No. 15 (FormeTly) 18
LOCATIONS:
1.. SI?. 1315, ~:-!lifax County -n.2 mile from ~re 4 to 1.1 mile East of bridge.
Lengt~: 1.13 shoulder ~iles.
Location of Sampling Sites ~ithln S?ill Site No. 15 (Fomerly) 13
.~. West side SR 1313 .1 r.iile junction of Hwy. 4 and SR 1315 composite sa1:;;:.e 0 "-1"
D. E~st side SR 1315 .1 mile junction of Hwy. 4 and SR 1315.
Sampling results are given in terms of ng/kg of Aroclor 1260 unless otherv-ise noted.
S~/Y! PLG ;,' Sl//7!,:JJ..E B
ii:rri'. ,\ . SITt ~
Compos it.: 200 6.6
'J
SPILL SI~ :1o. 15 (Re-S:1:nple) 18
LOCATIONS:
1. SR 1315, Halifax County -0.2 mile from ~C 4 to 1.1 mile East of hrid?~.
'Lengt::: 1.03 shoulder miles.
:.Ocati:m of 3a:.1pli:1g Sites within Spill Site ~;o. , C: C::'o!'T!'lerly) 19 Jo.J
A. SR 1315 East side of road
:3. SR 1315 West side of road
c. SR 1315 , . . 3 mile East of bridge
D. SR 1315, .3 mile East of bridge
Sampling results are given in terms of mg/kg of Aroclor 1260 unless otherwise noted •
.S"A/T7PJ..:3. A .S,.Jtt1?)£ t3 5Al>'.Pi..; ~ SA1>tPJ..,f 0
SITE n SITE 3 SITI! 9 SI'ffi B
0-1 Inches 13 18 (1242) l.3 5.3
190
1-3 Inches ~ l < 1 (1242) '( 1 ~ l
4.4 .,
3-6 Inches < 1 1.1 (1242) ""1 ..,:1
20
APPENDIX B
Laboratory Test Results
Soil Evaluation
Warren County, Pope Site
/
0
Soil sampling procedures to obtain soil materials for testing to determine
suitability for construction of impermeable soil liners.
Sampling locations were in the immediate area of soil borings 1, 2, 7, 3,
and 4 on the proposed Warren C~unty disposal site.
Sampling instrument was a 3½-inch diameter, closed bucket, standard hand-
operated soil auger.
The surface Oto 5-inch layer of the soil was removed to prevent the inclu-
sion of plant roots in the sampled soil materials.
An approximate total of 20 cores from all the different sampling locations
were obtained. Cores were obtained from the soil layer 5 to 30 inches
below the surface, composited and placed in a cloth sampling bag for trans-
port to the testing laboratory. Cores from the soil layer 30 to 72 inches
below the surface were composited and placed in a cloth bag. Fifty pounds
of each of the two layers were obtained.
I, William L. Meyer, certify that the above procedures were utilized to
obtain soil materials for laboratory analysis. The samples were obtained
on December 13,1978 and delivered to Mr. O. W. Strickland on December 13,
1978.
I, o. W. Strickland, certify that the soil samples were received from
w. L. Meyer on December 13, 1978, and transported to Soil and Material
Engineers, Incorporated, under the direction of Mr. Jerry Perkins on
December 14, 1978.
-tUt~ ;:/7)/.v~
William L. Meyer
Environmental Engineer
Solid Waste & Vector Control Branch
Sanitary Engineering Section
. L~) . ,/J/'j //"J Cb:'.' .z.u . .Le;.:.~.,,, 'i(.'"w. trickland, Supervisor
Solid Waste Management Unit
Solid Waste & Vector Control Branch
Sanitary Engineering Section
SOIL & MATERIAL ENGINEERS INC. ENGINEERING-TESTING-INSPECTION
3109 Spring Forest Road, Box 58069, Raleigh, N.C. 27658 Phone [phone]
January 4, 197'9
Department of Human Resources
Division of Health Services
Solid Waste Management Unit
P.O. Box 2091
Raleigh, North Carolina 27602
Reference: Laboratory Tests
Gentlemen:
On-Site Borrow Soils
North Carolina
Enclosed are test results of samples provided to
us by Mr. Jerry Perkins. Two test procedures were used. First,
the soils were compacted to a specified compaction criteria and
then permeability tests were performed on the compacted sample.
The test procedures were performed in compliance with the
following specifications:
1. Compaction -AASHTO*T-99 , Method A
*American Association of State Highway
and Transportation Officials
2. Permeability -U.S. Army Engineer Manual
EM 1110-2-1906 "Laboratory Soils Testing"
Appendix VII
( These test results represent true and accurate laboratory
permeabilities to the best of our knowledge.
Subscribed and sworn before
My Commission Expires:
August 17 , 1981
Very truly yours,
me this 4 day of Janu1ry, 1979.
~-~ /· J . : ( _!° /112·,/,,(ZZ ~ . /4. ,_. , ,, d
Notary
6017 Dixon Dr., Raleigh, N.C.
RALEIGH. N.C. • GREENSBORO, N.C. • SPARTANBURG. S.C. • ATLANTA, GA.· TRI-CITlES, TN.
TEST RESULTS
Maximum Test %
Sample No. Densit:r(Ecf) Densitf(;ecf) Com;eaction Permeability cm{_s ec
A 92.0 87.4 95 2.05xl0 -8
B 90 .2 85.7 95 2.38xl0-S
<'7 I j\
~/tH ~l(A./ It
~tt-.iyJl~ I!?
.,
--<~'f.ft-\.
(
December 21, 1978
.•."':--.-.::·_-. . . .. .,
·-~· ..
· .. \
\\ Department of Human Resources
Division of Health Services
Solid Waste Management Unit
P. 0. Box 2091
-··-· -• _j :-::' !1
. ~ :;
Raleigh, North Carolina 27602 __ ~..:,.:·~~:::
~ . -~,
-... ·......... . ..,-
Attention: Mr. Jerry Perkins ... ;".=:: -.
Subject:
Gentlemen:
Laboratory Tests
On-Site Borrow Soils
North Carolina
As authorized, Soil and Material Engineers, Inc.
has performed laboratory tests on soil samples delivered by
representatives of the North Carolina Department of Human
Resources on December 20, 1978. These tests included moisture-
density relationships (AASHTO T-99, Method A) and permeability
tests. Test results are attached. Permeability tests were
performed on remolded samples prepared at 95% compaction. Two (2)
tests were performed on each sample for comparison. The comparisons
are excellent. Sample A has a permeability of 2 .05 x 10-8 cm/sec
while Sample Bis 2.38 x 10-8 cm/sec. The maximum dry density for
Samples A and Bare 92.0 pcf and 90.2 pcf, respectively.
LR~i: mgm
Attachments
If you have any questions, please contact us.
Very truly yours,
SOIL & MATERIAL ENGINEERS, INC.
/! ~-e 4 a»:ll___ _
Lawrence R. Matthews , P.E.
Manager Construction Services
RALEIGH, N.C. -GREENSBORO, N.C. • SPARTANBURG, S.C. ·ATLANTA.GA.· TRI-CITIES, TN.
l-o
130
125
120
115
~ 110
u iii ::> u
a: UJ 0..
u, 105 a %
-~ -
I\
\
i\ -
,\
\ \
\
\ \
\
I
\
\
I
\
\
I\ \
\ \
\
\ \
\ \ \
\ I\ \
\ \ I\
\ \ \
\I
\I !--
~ I\
\
\
\
I I
e~ I
I
~
I
>-1-in 100 z
1M 0
>-c: 0
95
90
8 5
80
I I
I
_l I I
I
I
I ~ I
I
I -I
I I I !
0 .. 1--+-. I I I I I I I -·------7 -----1--r+J_l _I I I I !
~
\
\
I\
\ \
\ I\
' I\ \
\ \ I\
I\ I\ \
\ ~
\ \
\
\
\
,,v
/
. ii-. I
10 15 20
MOISTURE
SOIL B MATERIAL ENGINr-ERS IN" !:. l v. ,
COMPACTION TEST
JOB NUMBER -RG-730
JOB NAME Dent. of Hum,m P.escu:--02S
JOB LOCAT10N Raleigh. N:Jrth Cu·o l.
MOISTURE -DENSITY
RELATIONSHIP Sample A
METHOD OF TEST .1\ST!,! D-69S
MAX. DAY DENSITY 92.0 . e OPT. MOISTURE CONTENT 29.6
NAT. MOISTURE CONTENT
ATTERBERG LIMITS LL Pl
SOIL D€SCRIPTION Red-Brown SlL:ht lv
Micaceous Silty Clay
\
\
·\ \ CURVES OF 100% SATURATION FO?.
\ I\ SPECIFIC GRAVITIES EQUAL TQs
I\ \
\ \ r-,_ 2.80
I\ \ 2.70
\ \ \ 2.60
\ \
\ \ \
i\ ~
~ r\ I\
\ \ \
' I\ r\
i\. \ )\
\~ i\_l\
Vi\ F&\D_ / i\
)·' I -~~ ~ r\ /
l/ I " ~~ ~ / I I
I "''"' ~ ~
I I '\. ~ ~ I I',
I i'-... '\. '\
I ' " "i\.
I ' 1'\.j_~
-· --·-·filL ,-+----" 1 "\.J -+4= -~rs~. ---7----
··--·-·---"' "-,--'1"-J"-. T7-·,----·--1 1'-l"t ~-
25 35 40 45
CCNT£NT -PERCENT OF ORY •,.,-::-!GHT L75
------------------------------------'
SM -42
I-0 ~
u i5 ::,
(.J
a:
UJ a.
en 0 :z:
(I ::,
0 c..
I
>-r-
iii z w 0
>-a: 0
-------·-·· ---·-··----.
~ D
130 ..... -\ \
I
\ \
\ \
' 12 5 I \
I\ \
\
'
120 \
'
115 I I
110
105
100 I
95
90 I
8 5 I
---
80 ~~f~
"' 7'f,
10
I
\
\
\
\ \
\ ~
\ \
\ \
\ \
' \
\
\
\
I
I
I
I
I
--, ---7·
I
15
SOIL a MATERIAL ENG!Nr-ERS NC c:. , I .
COMPACTION TEST
JOB NUMBER RG-730
JOB NAME Deot_ of Ht!lT;.an Resource
JOB LOCATION Raleigh , North Caro
MOISTURE -DE~!S !TY
RELATIONSHIP Samnle B
METHOD OF TEST A.::, 1:,l D-698
s
lina
MAX. DRY DE:NSiTY 90 .2 \ OPT. MOISTURE CONTENT 30.7 \ NAt MOISTURE CONTENT \ \
\I ' ATTERBERG LIMITS LL Pl
\ SOIL CESC RIPTION Red-Brown Sligh t.lv
\ \ \ Micaceous Silty Clay
\ ' i\
\ \ \
\ I ' \
' \ \ I\
\ ' 1\
\ \ \
\ I\ \ CURVES OF 100% SATL:.''lATION FOR
i\ \ I\ SPECIFIC GRAVITIES EQUAL TO:
\ \ \
\ \ ~, 2.80
I I\ \ 2.70
\ '\ \ 2.60
\ \
\ \ \
\ ,,,,
\,., "\ ' \ I\ \
\ '\ I\
\. \ ' '\
'\ \ ' \ ,f\ ~ I \.
I/ ~"' \ ' '\
/ '\~ \
_,/ ":.". \.. '\. I ./ '\'.\_ " I'\. V I "\ ''t '\.
V "\ '\ I'.. ~ "\ \_
i'.. '\. ~
I'-"\J
"i'\." '\.. I ·---,---I -J-~~ -~~= ,-. -----:1--: ------r----_ _1··--= ---r
1 --~-T~ ----~i-+--,, '·-, ~----·-...._ ·-.. T I I I'\. 1 "l "l,
20 25 30 35 40 45
MOISTURE CONTENT -PERCENT OF DRY ','.-EIGHT
..
JAMES 8. HUNT, JR.
GOVERNOR
THOMAS W. BRADSHAW, JR.
SECRETARY
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
RALEIGH 27611
September 20, 1978
DIVISION OF.HIGHWAYS
MEMORANDUM TO: Mr. M.C. Adams, Maintenance Unit Head
FROM: W.D. Bingham, Head of Geotechnical Unit
SUBJECT: Investigation for Disposal Site for PCB (W.O. 4.5401101)
Attached are boring logs and sketch of a site we have investigated for
PCB disposal in Warren Cotmty.
The ~ite was drilled and sampled to a depth ranging from 28. feet to
41 feet. Twenty (20) samples were delivered to the Department of Transportation
Laboratory to 1:e tested for: Minus 200 material, Plastic Index, Liquid Limit
and pH values.
I! we can 1:e of further help in this matter please let us know.
WDB:nah
Attachments
werr
. \
' .. . N. C •. DEPAR'Il1ENT OF TRANSPORTATION
· Division of Highways
PCB . PIT BORir-'G Im
PROJECT 4.540llOl COUNTY Warren ___________ DATE 9-18-78
ROUTE _________ RES •. ENGINEER __________ PIT NO. PCB# 4
237--0001 6n Auger ~UIP. USED ____________ INVESTIGATED BY J .s. Britt
W /rock teeth
.
~ ffi DEPTHS. ~ &1 REMARKS: i.e. groundwater data H £XI F~e t p.. £XI ·DESCRIPTION OF MATERIAL 2~ FRCM TO ~~ moisture content; etc.
1 o.o 11.0 1-A Red-Brown Mica. -F~andy clay Dry
1 11.0 '30.0 1-B Brown Mica. Clayey silt Moist@ 20.0'
1 10.0 W.5 1-C Brown Mica·. Silty sand
·1 l..O. 5 1.i.1.2 Soft weathered rock_ Practical auger
refusal @ l;l.2'
.. Groundwater:
0 Hr.-Dry caved in @ 28. 5'
···-?-4 hours-caved in @ 28 .5 ,:
•.•
2 o.o 8.0 2-A Red-brown mica. fine sandy clay
2 8.0 38.0 2-B Brown high.ly mica. sandy clay silt Wet @ 30'
Groundwater:
0-Hr.-Drv caved in @ 35.0
24 Hr.-34.2
3 o.o 3.0 3-A Red-brown mica. -F-sandy clay Dry .
3 3.0 28.0 t.3-B Brown mica. sandy clayey silt Moist@ 19.0
Groundwater:
0 Hr. -Drv caved in @ 23. 5'
24 Hrs.-22.9 '
4 o.o 10.0 4-A Red-brown mica. -F-sandy clay · Drv
4 11.0.0 33.0 4-B Brmm mica. clayey sandy silt Wet@ 27.0'
Groundwater:
0 Hr. -Drv
24 Hr.-Dry
-
...
·-
. ·-
N. C •. DEPAR'Il1ENT QF TRANSPORTATION
· Division of Highways
PCBPIT BORn:G LCG
G-5
1-78
PROJECT __ 4_--_540_1_1_0_1 ______ COUNTY . __ w_ar_re_n ________ DATE 9-1~78
ROUTE RES.-ENGINEER PIT NO. _PC_B_#_4 ___ _
EQUIP• USED __ ..... 23,..,7,....,1)-...n .... o .... 1 ____ 6'_' _A_uge __ r_INV><'...STIGATED BY __ J_._s_._Bri_· t_t ________ _
W /rock teeth
..
~ai DEPTHS ;j~ REMARKS: i.e. grour.dwater data Hill li'eet · 0.. Ill DESCRIPTION OF MATERIAL 2~ ~~ moisture content; etc. FRCM TO '
i; 0.0 6.5 5-A Red-brown mica. -F--sandy clay Dry
W /auartz lenses
:; 6.S 25.0 r:;_B Brown mica. sandy silt .. Moist @ 25.0'
:; 2'5.0 11.0 'i-C Tan mica. silty -F-sand Wet@ 29.0'
Groundwater:
. . 0-Hr • -Dry caved in @ JO. 0'
24 Hrs.-Dry caved :in @ 30.0
-0.0 7.0 6--A Red.:::brown mica -F-sandy clay W/ Dry
quartz lenses •.
6 7~0 12.0 6--B Brown mica. sandy silt Dl"'V
6 12.0 33.0 6--C Tan mica. silty -F-sand Wet. @ 26.0 1
--'Groundwater:
0 Hr~ -Drv caved in @ 29.10
21.r. Hr. -drv caved in @ 29. 10
7 0 .0 10.0 7-A Red-brown mica.· -F-sandy clay Drv
7 10.0 20.0 7-B Bt-own..;.tan -F-sandy clay Moist@ 20.0'
7 20.0 33.0 7-C Bt-own -F-sandy silt Wet@ 25.0'
Grnundwater:
0 Hr.-dry cavec. in @ · 26. 7'
21.r. Hrs. ·TI-Mr ,...::i.ved ;_n @ 26.7ir .
8 o.o 9.0 ~A Red-brown mica-fine sandy clay Dey
8 9.0 38.0 8-B Bt-own mica. sandy silt Moist@ 26.0'
Wet, @ 10.0'
Groundwater:
0 Hr. -drv caved in@ 33.2'
21.r. Hrs. drv caved in@ 33,-
-ii'--,f';n.,. ---·-. ---..
'
-~.>)-
'•:::.
.· --·
..... :'!.?:::::.;:-· ......... ·.;::;.. -.~·:.:._·:,.;·~ -·----~~-..;... ___ ....;;.. _____ ..;... ____________________________ _
o::: , ,... ·•◄--, SR _1604 . 0.5 M ~LE s•:·.•·• .• ·~,.,.,.-~--• _., •• _. ___ . ·;···· •:.;. , • .,.., s-:--_.;.:_:.-
t/)
.. •· ~ . . 'i ;. "4' ~
SCALE
,, .-, ... _ .. -.. ~ -
1 = 1 0 0 · ·. . ... · . .-. · · .. . ....
. ;:'.';.::-..~·-..,;:-;.;:::\-/: •"' .:~-:.: . .-. :..._~ . .. ... . . ;-. ·~ ...
' . .
Rel.
NORTH
· Pen" . . M Ai T Form 503 11.1.u
DIVISION OF HIGHWAYS ;) ~ CAROLINA DEPARTMENT OF TRANS?ORTAT~
MATERIALS & TESTS UNIT .I ~w
SOILS LABORATORY SEP 25 1978
Proj. ------------------------------·---DEPARTMENT OF TRANSPORTATJON
DIWSION OF H.IGHWA~
GEOTE'CHNIC;t !J,~lf
REPORT ON SAMPLES OF _Soil_.f.or __ ~mty __ ft_pJi_ _______ ;_ _____ _
Project __________ _4,._540.ll0.1 _______________ County ____________ j/AITM ___________ Owner ________________ _
Date: Sampled __ J_-:~-~-:J~------------------------Received ---~--=!~_-:?~--------------Reported -~-2~_:-_7_8 ___ _
Sampled !rom _ PCB Pit _#4 _______________________ By _l• _ S. _ Britt ______________ _
Submitted by ____ J!!_P-!_-~!~~~------------~-----------------------19--~--Standard Speci!ic:ations
396732-396751 TEST RESULTS /).,;) -3.3'
Proj. Sample No. lA 1B
Lab. Snmple No. 396732 396733
Retaino!d J:4 Sieve ~:, - -
Passing :to Sieve % 100 100
Passing :40 Sieve '1c, 99 99
Pa!lsing :200 Sievo '1c, 74 54
,.. C.,.,.,,. Sa.nd-2.0 io
O O.!$ mm. Rrt.. :so % 4 g-
0
,: j f"lne Sand-4.23 to % 24 42 ~ ':i 0.05 mm. Ret. :210 ., .. .. ~ • Silt.-0.0$ 22 33 ~ :.; a~ tu 0.00~ mm. o/o I
2 --~ so 16 .. ·; ~ Clay-Z...a <'fo . a: th,.n 0.00$ mm . ,. .: J-uain,r . :: ;:.10 SiH• '1c, --
Pa.;1,in1C '1c, ::?00 Sit"'• --
L. L. 64 48
P. J. 34 NP.
AASHO •A-5(5) ·Classification A-7-5(20
Texture
St.:ition
Hole No. 1 1
Depth (!t.) 0 Ll . 11 30 to
oh 6.26 6.36
cc:: . }>1"• M. C. Adams
Air. W. D. Bingham
Soils File
. .
lC
396734
-
100
99
48
7
53
24
16
--
36
9
A-4(3) .
I
1
30
40.5
6.75
2A 2B 3A 3B 4A ' 396735 396736 396737 396738 396739
1 1 ---
98 98 100 100 100
96 95 99 93 98 . 74 63 78 70 77
7 11 3 . 7 4
21 30 22 29 I 24
24 33 29 42 24
48 26 46 22 48 . --------I-I-
64 47 58 I 53 58
36. 19 24 14 29
I ,
~-7--6(20)!A-7-Q(lO)A-7-5(lq)A-7-5( :)A-7-Q(l9
I
! i
2 2 3 3 14
0 8' 0 3 0
8 I 38 1 3 23' 10
6.53 6.35 6.43 6.29 I 5.98
)
,
Ref.
.. -. . .
NORTH CAROL!NA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
MATERIAI..S & TESTS UNIT
SOILS LABORATORY
Proj. ----------------------------------
Project __________ A • .5401J.0.l ______________ County --------------------------------Owner ________ ----.;_
Date: Sampled ------------------------------------Received ---------------------------Reported ___ _
Sampled from ___ :feu_..PiJ:_j/,A_ ___________________________ By ---------------------------·
Submitted by ---------------------------------------------19 ______ Standard Specifications
--') 396732-396751 TEST RESULTS ~;) ;;, ~
Proj. Sample No. 4B SA 5B SC GA 6B 6C 7A .
'
Lab. Sample No. 396740 396741 396742 396743 396744 396745 396746 I 396747
!Cetained :.i Sieve ., ,. -12 -l 7 2 --
. Passing tlO Sieve °lo 99 84 99 96 90 97 100 100
Passing ~40· Sien '1a 97 80 96 93 8~ 92 97 99 . I 81 Passim? ~00 Sieve °lo 64 62 64 48 65 59 50
.~ C,.an• Sand-%.0 to ~ 1).25 mm.. R.t .. :so "J'o 7 9 9 1 8 10· 11 2
0
C j Finl! Sand--0.!S to 36 20 33 51 23 35 47 14 " o/'o i: ~ 0.06 mm. Ret. ::70 .. . .. : ! • Silt-0.0S '1a 31 35 38 28 21 35 24 30 ;,. ~ ]~ to O.OOS mm. ~
"' ·c ;; .. C!ar-1-• "Ji, 2h ~,:;. 2n 1.d.. 48 20 18 54 . "' than O.OI).\ mm • ,.
C Puai11t1 • x :.so !>i~ °lo --------
Paaain• o/o
,_
:::oo s1--------
L. L. 41 62 45 28 64 43 34 67
P. J. 9 27 . 14 4 29 5 6 31
AASHO A-5(6) A-7-Sfl4 A-7-5(8) A-4(3) A-7-5(171) A-5( 5) .A.-4(3) !A-7-5(20) Classi!ic:ition ,
Texture
Station I I I
Hole No. J. ~ .Ii .Ii 6 6 6 7
Depth (!t.;} in n f; __ i:; 2 .li 0 7 12 7A
-,p,. ,, h ~J ? C.J 33, 7 12' 33
Ph 5.89 6.05 5.91 6.31 I 5.73 5.78 5.89 5.72
cc:
•
,
: seawsr~
Ref.
. . . .
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
MATERIAI..S & TESTS UNIT
SOILS LABORATORY
Pro~-----------------------------·---
....
M 6 T J,'onr
11-1-U
Project __________ 4 • .540.1101 _______________ County -----------------------------------Owner _________ _
Date: Sampled ---------------------------------Received ____ '." _____________________ Reported ___ _
Sampled from ___ PCB _Pit_#4 ____________________ . _ By -----------------------------
. Submitted by -----------------------------------------------------------19 ______ StandA&rd SJ)f!Cifieation,
396732""'396751 TEST RESULTS d.;) -j::, ' Proj. Sample No. 7B 7C SA 8B
' Lab. SAm!)le No. 396748 396749 396750 396751
Retained !4 Sieve ,:. ----
Passinir :10 Sieve "fo 99 99 100 100
Pa!lsinlf !40 Sieve "fo 97 97 99 97
67 55 80 . 58 Passing ~00 Sieve "fo
,o Caen• Sand-Z.O to ~ 0.25 mm. Rf't. !50 ~ 4 7 3 8 . I ...
" j fin• S-n6-4.:ZS to 38 . 45 20 43 ..! ~ 0.05 mm. R.-t. ::2'70 o/o .. • .. ~ ,. Silc-0.05 · 38 30 23 31 c:: :.; ~~ tn 0.00$ mm. efo
0 --~ .. ·;; ::II Clay-l'.A.s er., 20 18 54 18 . "' than 0.OOS ,.,,._ " C ruatna i tfo • ----;io s; ... ,.,
Pa .. inc-er., ----..,00 ~i•v•
L. L. 38 39 66 45
P. I. 8 8 23 4
AASHO A-4(6) A-4(4) A-7-5(17) A-5(5), Classifie:ition
I ! I Texture
Station
Hole No •. 7 7 8 8
De-pth (ft.) 10 20 0 9 .
-t't'\ 20f 111 gr 381 I
nh c:;_ 77 6 n1 _c:;_ 66 5.90
cc::
APPENDIX C
EPA Approval and Conditions
For the Warren County
PCB Disposal Site
------------. ---
lln•h•d St.ir,i~ t n,111onmcntJI Protcc:,011
Agency
Hpq,nu .?
].1~, Cc11 ,·tl.111d ~;,,.."! NL
;\11,inl,1 , i,\ 30300
/d.tlt,lll'-1 (:,";r,p.t r1 .. ,r:-:,,
.'.11•,·,1·,·,1; .. 01. ". 1:!11 { ,1ffl!,(',\
~,tll•lh f',1r1_1i,r•.1. ip11n••·,·.1~P
I\ 1•nl1.11 ~y
. ---------·---.. -----·-----------
June 4, 1979
4AH-RM
Honorab 1 e James [L llunt
Governor of ~orth Carolina
State Cap i to 1
Raleigh, North Carolina 27611
Dear Governor Hunt:
On February 17, 197.'3, the United St11tr.•; C11·/irorii:;cntJl P,ot·.:ctiG·
,\~ency ([P;\) published final rr~qulc1t io11:; in ti,:: F,_.,Jer,11 Pr.,1is:,'?r
(43 FR 7150-7164) on Polydtlnrinated P,i pi if;ll'/15 CPtDSJ,JTs-Gos,1_l_
and Marking. These re~rnl.1tion-; .,.,,•ri' ,1;::,:1 1,;!-'•1 by u,,_, r-l: '·"r,,~ '.1-.:•,1;-:~,.,r-
(43 FR 33918-33920) Oil /\u 1•'Jst L, 19 /i,;. 1::-:::,t.: r~;JtJlc1:.·i·o-1."s-pr~<./!i.iji ;~
the di spos.:t l of Prns J t i:111',' <_; i tr. nr, t ,,J,DrovPrl h·/ tho F.f'/\ ,1 f te r
/\cr-il 18, 1973, and these rrquli1tiow; tt0(!1J~n~ tlnt th -2 ov:r1 cr e:n •./Dr·
operJtor of il chc111ic;il 1·1<1sle L,ndfi i I w.•:·,! fur U1'! ,iL;,-o, .. il of r:'.;s
suh11iit infori;;ation in acconLinr:e v1it!1 Sr:'_'.t ion 7r;;_,;1, Cili_'n:ic,11 .!-.:_,:c
Landfills, to the Regional ,~d:ni nistr<1tDr ~rJr l'L:'li;»,-1.
in accordunce with the -3lJovc rrfr;ren,:P'.I 1(•r1ul :1Lior1s, ,1 f();-:r:.i; <1;J1:1:-
cation 1vas filed 1-1ith t!.is office duLcd 1;,!C':!:i>Qr l?, 197;'., ,::.:,1urstir;q
approval of a site in \·larren County, r:;irth Cc,rol ina v1i1ich 1•1 i 11 !1(•
01-med and opcr.:ited by the State of ::0rt:1 C.1,-01 ina and usr:d io1· '..i1Q
disposal of PCB contaminated soil frC1111 U1e nigh'f1a; sh oulders iri the
State and from the Fort Gragg 111ilitJry rr.scr-1,1tion. /\ pui)lic ht:iring
w<1s held in \·lc1rrenton, f~orth Carolinc:.i 011 Jan uary ,i, l'J79, fr.r ~•u b '.ic
input. Tne he<1ring record 1vac; held ur•en 1rnLil Ja1:u,:ir·y 12, 1970, for
c1dc.Jitio11al written public input into t!10. Jecision process.
Tile result of EPA's revie\'I is thJt t!1r nroposr~d site 1-1ill 11;et:t ,1li the
technical requirements for a cliemiCJl 1-1~'"-tc 1',rndfill JS 1·cquircd i11 ~
Section 76l.4l(b), when constructed in .:iccordance 1·-litl1 l!1(! enc1osl!d
conditions to 1:.his approv.:il except for the followinq:
(l) 761.4l(b)(l)(vi) "1\rtificial li1wr U1ickness 30 n1il. or
grea t1:r."
(2) 761.-1l(b)(2) "The site sli<1ll G,: <JL lcJst fifty fct:L f)-,J1i1 t:.he
11e,Jr2st grounJ\"1ater."
(3) 761.4l(b)(5)(iii)(J) "Chlor·ina~r'd 0rrpnics."
TIH~sr~ three n'11uircm0.nt::. ,1,·t: !tt:rr~l,v •.-:._:i •;, ci For UHl n.:tJsn11::; (i i ·;1.::1 i n
th1; enclosed tcch11ic<11 rc11i(11li. Yll1ir r<l':ue~t t.o ,,.,,ii-Jc t i1e k,1r:•1:~-~
rn11ection s 11st0.m underncc1U1 UH! li11r;r is denied ;·cir the rec::s ons
stc1tcJ in the enclosed !.e1.J1:1i cal rr•1:i0•.-1.
. 2-
Accordingly, the Worren County. No,·th C,;n;!;,,,, -;i~c r., 0:: .1'.·liled c1nd C;,Jcr:1tcj
by the State of North Carolina for tl1c J is,J:.; .. 1: ,.,F r'C'.., co .. ~:;,·1i:1Jt:::d !1 igr.\·iJY
shoulder soil is hereby approved Sl1iJ.icct : 1 ·.:,•: ;.:nci -J scd ,:r~nriit'.o~s c1s a
chemical \·1aste landfill as authorized ir! :.;(} t~f':-:, P,1r: 761. It is understood
by EPA and the State of North Carolina thJt t.i1is c1ppro 1,:i: is ba::2G 011 the
conceptual design only and thilt the fineil cnnst1·,.1eti0r. ol0r1s ,1nd ~pec i fi ca-
tions (if ,my) must be approved in 1"1riti:lt.J by ci1i~ office ;.)rior ta ·
the initiation of construction.
This approval is net to be construed to be apprr,v,1 fer incineration,
storage, marking or records and monitoring, '.i~ vii 11 continue to work
with you in any \·1ay 1ve can to expedite ::i puh 1 i c heu 1th oriented and
environmentally sound solution to the PCB problem in i·iorth Carolina.
Sincerely yours,
-~L(!_-~ ohn C. White t'
Regional AdministrJtor
Enr:losures
cc: Herbert L. Hyde, Secretary
NC Dept. of Crime Control
& Public Safety
KarsLJll Staton, Chief
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
... ~ ·----,-'-~---
/ _,,,~"
. f:--
Approval ccirid1tirrns for· the PG3 ui~posi.Jl Site O.,:,ed
And Operated by the St,1te of r1 orth Ci11·olinJ in
Warren County, ~lorth Carel ina on the Proo<:rty Desr:ribed.
in Governor Hunt 1 s Dec:::ir,ber 12 , 7()72 , i\pµl i::.3;:i0n a:.; 0 .-ff-:•j
by Carter C. Pepe .:ind Lin.:J 1.-i. f11 ;~c Found in De<:d ~c-:ik 278,
Pase 252.
A. General Requirements (a1l rc;Jorts sho:.:ld ~? sent to the Resional
Administrator, Attention: JaIT~s H. ScJrbrough):
1. Notify EPi'\ at least tv,o wee ks in ,dlv:.nc~ of the expected stor"t of
construction.
2. Notify EPA at least t ·,·10 ·.-~eeks in c:d v.:rnce of the initiation of disposal
of PCB waste at the site.
3. Send EPA the data which is r e1ui rcd ~Y 43 FR 761.4l(b)(5), monitoring
systems for baseline ar.ct Oi1 tne frequencies sp~cified.
4. !laintain records as .soecifi0.d in 4J F;~ 761,45(b)(3) as :appropriate
and submit 1·1ithin 90 9~ys afte r cl ,JS~r':.; of th,~ s ite to the P.egional
Administrator. ·
5. Advise EPA irrr.1edi,tely of An y c112n <J es, alterJtions or divergences
in the operationa l and managerial ~ol i cics and pr1cedures as out-
lined in the documents submitrr.d i,1 :;upport of 1:he application.
6. Report to EPA any instance of detection of PCBs through the r::onitor-
ing program um1ediately.
B. Technical Conditions of Approval:
l. 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 operation~ to provide and assure conformance
with the final plans. Such assur,rnce Shull be furnished to the
Regional Administrator .:1t the co:i1µletio11 of the proj ect vdth a copy
of »as builtH plans.
4. A record shall be placed on the rr·;')pr~rty deed i~hir:h stipul.:ites
the particulur boundary of the dis;:,i·~c1l ,W'.:,l .Jnd 1-,Jste contained
therein with the associc1ted 1-1aste r.lc ·✓JCions.
5. The State shall maintain an "u ll ·.,,~.1 1.11r•r" -1ccess rnarl i ndr:fi ,1itely
to pennit access to the si t e and to t',1cilitJte collection of samples
from r.;on i tori ng we 11:;.
l.
-2-
6. Waste wi11 be compacted us 1r:uch :s r rc1cticuble ,·lith tracked equipment to prevent settlement aft:;r closun~. ·
7. Appropric1te erosion control ~r.J sclres stic1ll be applied during excava-tion, fil1ing and after closure to mini~ize erosion.
6. Trucks us2d for hauling the waste ~u~t be covered.
9. The f inal ;,1a;iS ;:1nd speci ficJ.tLms (~ f Jny) sha11 be submitted to the Region<1l Adi.iini s.tr.:;tor (f\tte11tio11: J,rn1es H. Scarbrough ) and written approval received prior to the initiation of construction.
10. A leachJte collection system with a sum p and access which will allow pumping out of ~nv collected leachate is required above and below the clay liner .
J .
: I
' '' I
UNITED STATES ENVIRO! 1.\\ENTAL P!WTECTlm~ AGENCY
june 4, :.979
'I'ec:mical Revie·..; -C:e:uc3.l 1,•ia:..; :e LJJ-:t~f!l l r,...,r"
PCB Submitted cy :::e State of iforth car·ullna
TO, Jo::.'1 c. 'Nh.1te
Reg.ior.al Admirust.rator
~e State of Noe":h Ca.rollna submitted n.n apr,l ~cation for the app.rcval
of a disposal site in Wa.r.ren County, Nor-th Caro11ri.a on Dece11ber:-12, 1978.
The Technical .review has been pee-formed. Toe results of applying the
cz:-1ter1a found L11 FR 761.4l(b) to the a.ppltcn.tion are a::; follows:
(b) (1) Soils -The site is not in a "thick, c-elat:!.'1ely !m~em:~able
fonna.tion :uch as large-area clay par...::." Therefore, the soils are evaluat
on the following c.ritet"ia:
, ,
Required ?rooosed
(1) Soil liner thickness 3 ft. (cgnpacted) 5 ft. (canpa.cted)
(U) Per.neab111ty (cr.vsec) lXlo-7 or 6.8x10-8 or
(0.0000001) (0.000000068)
(1.µ) Percent SoU Passing 2, 30 75 Averoge
No. 200 Sieve
(iv) Liquid L1m1t 2, 30 51 Ave.rage
(v) Plasticity Index .?_ 15 18 Average
(vi) Artificial Liner 30 mil. None p.roposeo¥
1/ A waiver ·..cs requested Cot1 thls r-equir'anent. The prililat:/ Justification
for the waiver-was that the State wo11ld tm tead place a 10 mil. plastic
liner "umbrella" top on th~ lnndfi.11 coveC'ed by two feet or soil which
would be seeded with p;r-a:,s ani slopP-<i. 'n11s design wouln minimi~e ~
rainwatec-infiltration lnto the landrlll. 'lhis waivet1 c-equest soould
be approved.
-2-
(2) P:,:d:-clc;j' -':'r:e Gite 13 located on t;l:·=· c:--r::;t cf a rid~ clt l.::.:.!:1-
tude 36° 20' l3", longitude 7'0° U')' jo" .lJld ~.'.:i iJ.br)vc the 100 •:e'.lr
flood level. ':his is VBr-i fied by t'.:c (J -~~-(leolo-~tc;-iJ. ~tl'C''l<!~I ( :::r;e
let t er Clt,~:1 ::o•,e:..ber 29, 19 70, to ,!c::'t'.'/ -:. E'erk:m). T:--:e totc·:;.1 of
the waste Will not be 50 f~et above t:h~ :TOWJd',"1tr~r-. The r:I.1.n.1rnr:,
distance will be held t:i 10 f-=2 :.:. ai)<)ve th~ se.1.:or.al h.!;:..,h ~_rr-Jur.,ivr2.ter-
tab le. The S t:i te requested a 'ncli ve c :·,.) r t hl:, cc·:!. ::e ri or.. In r , ,., t ewing
the just1f1cat.ion of th~ ... ".l:.:1er, I h:-1•1r• <xnc l;..;.:::d t:-.at tr.e cl:v liner
1n the bottcm or t!"le t:-ench plu.:; tb: l t:ie r' on cop of t he \'la::;:e •,.,hich
W--....11 act as an umbrella for L'7f.iltr-:it~on pc-eventton, rlus t:-:.e ::a~hate
collection ::;ystern and sump above ?J,,i br~t,:w t!1e clay liner will
sufficiently protect p...:.bl.!.c heal th .2.r.1 th•~ 0rr.-1r-om:er.t fr-an ''un:-~asonable
r.sk of injury" as ::itipulatc-J by par·-~•~r·apil 761.lH (~.\(4). Ther-c.fore,
this waiver should be J.Poroved as r1~-i uc~tcd.
(3) Flood Pr-otcct1on -The application 3t2.tcs tr.at the dl ver-s:!.6n structures
will be designed to c!iveqn the 24 houc-, 25 year-runoff fr-an t i1~ active
p:>rtion of tte land.rlll.
I .
(4) Topo5rapr.y -The topo,_;r:-aph,•; .:1t the rropo:,0d s1.t~ ls low tr, rroier:1te.
The approva:. should be ~onditioned t o c·P.qulr~ all pr-actical ercx;ion
prevention re~-:.xes to be used.
(5 )(1) Monitor-1:'-o ::ys tenz
a. The application ::;t.J.tcs th.:lt !'1:l::cltn~ ·ht,1. ... 111 he col2.<:ctc·J
prior to f1nal. appr-oval. 1r.e c1ppr·oval sooul,1 be so conJi::::!.oned.
b. The application states that tr-:,~ sur-face ~tr,~ams and the P.:!"'cund-
water will be sa'T:pled r:onth.ly \HH' Lrn5 op,)c-acion. '.I"ne ap9rG1al
soould be so con:iitior.ed by t".!Cer-t'ing to paragr-aph 761.4l(t) (5).
c. Bi-annual r.on1tor1r.g will be Jone after:-closur~.
(11) Gr-ocndwate:-Monitoring Wells
The application states that ther-c , ... tll bP. co~tr-uct2d an:i lor,ated
as requiced. EPA staff sr:ould ver•lfy thi: location of these in
the f1eld.
(111) Water An.:llisis
The analysis for chlorirute.J hydr-oc.1.:·bons is t"equested to be
waived. The t"'eb"'Ulatioru:; were ·,,Tit;L!;!\ Cu r cu:urcrclal facilit.!.c!..:
which would be illsrxisiJ'\~; or ma.riy ciLt't\~!'1 .•nt ·.~::;tc:,, Slnce ?C3 1s
the only .,.,71.Ste .,.,hich •,,;111 h.e disf.•.>::, .. : ln thl:. :.ttP., there 1r. r,o
point to rn.)nitot"in;; for other-chlur•lJ1.'..i.t ;(j or:_:;-..ut.!.c:;. 1'hl.'.i .,.,...di V~r'
should be :i;::oroved.
-3-
(6) Leachate Collect1on
'!he proposed design does not show 2. k1.ch::i.te c8Eect:on. ::;ys ':-~:'1 un--:er
the liner 8..!3 required by t!1e retjul.:it 1 on. fl~cau::e er' the ,.;r,.:..:rvj•,:ater
pc-oxim1.ty :::.!1d tile demons tr~te<i public conl:~rn, I recanr.A":r:d that a.
leachate collection !:iystc:i ,;.nd s:1::m t:-~ '.:1..'it:J..11 ~,1 1l!':(ir:r tl:e ~o:.l llnec-
to monitoc· the .integrity of tt:c soll 1..Lne:r. In add!. t Lon, the leachate
collection system above t:1e sol.l llner :;;:r.Juld b·! c·equ 1.reJ wi:h t::::,J
appr-opriate :.;L..:rnp to pr-011ide tl10 ::--echa.'1~ :~rn ;:-.,i ;:i.11 o·t1 pu:'.'.[) ir,-; cut ot' ::J...'1;/
leachate collected to pre·1ent arw :,L_~:1.!. ncnnt: lwdr.'.'.ul'..~ hP.2.'1 t::.:Udup
on the clay liner. Thec-efore, this 1-.alver :;r:0uld noc he nnnro·.-•:'i.
(7) Ope~tions
The o~ro.tioro plan submitted 1:1 ~;,.,':l:.;.c',11~t.or1 wlth ':he exception of
the one foot of clean soil to he pl:1cd on to;:, or flrc.t lift c:· ,i2.ste.
This clean soil is to be u;;,"?11 to prcvP.nt the tr,.id:s fran t2k1.:-:.; c,1t
contwninated soil on the \•1heels. '1111::: one foot .:;honld be r ·~str'i8ted
to the middle 20 to 30 r~9t or th': tt'enc~1 rio as not to prol/ide a
shunt to the side walls j,ould any Wiltr·:i~icn occur. This c·::::~tric-:
tion w1.ll allow any 1nflltr::1.t1on to pr·ocPt:d co,..m thro,.u~"'l the ""'1Gte
to the leachate collection systen ·,.,rhich wculd lead it to the s~'7.p
for-pumping out.
(8) Supp:)rt:!.ng Fac111ties -The supp,rttili~ rac111tle3 A.re satisfactnr-J
as descr-1bed. No rrent1on ,,.,as rracte of lon:;-t~rm rralnten2nce o:· tr.e
access read. The approval should be cornJlticne<l to insure th .... t A.ll-
;:ea:cher accezs 1s rralnt;uned.
.Nr. Jerry C. Pc~kins, Head
GFU!.O,;ic• \L '1[ r:\ 1.'i'
1'. O. !..:ox 7.115/
P..ilci~h, t:c 27602
Solid lfasce and Vector Control llranch
Di'✓ision of Health S<.:rvlccs
t:. C. Dcpa.rcmcnc of Human Re:;ouL·cc.:;;
r. o. nox 27637
Ralcich, No:th Carolina 27611
D~ar Hr. Perkin!;:
The.: pro1,osed l'Ci) Ji~1>0!;,1l !,i.tc loc.ir1.:d in \:.,c:·,·n Cr,unt:y :1t ·L:t j !.tide.:
36°20'13", lonzitu<lc i'8°09'Sa", i~ al.,ovc the l Jll-yc.ir U .<JOd :•c:yc·:t.
The sttc i~ locac:.cd on a hilltr'op b~L11ecn !tic:,.icc~: Cr<'.1..·d, :incl one: c,f 1:.s
trihlltarlc!,. _I csti.m:.tc, bo.:;~•cl on flood 1,~cucds colJ.c?ctcd ,1t: :--cirLh
c.:wolin~1 r.trc.:?ms, th~t the 100-yr'.ar flood h:::f.~lit i:. not 1r.on: l!i,111 8 fa,!t
'1lJnv\! .1vcrc1~c t,.1c:cr level in tlw:;c cre,"'kB. Th·.! propo5~cl r;it<: ir.
:1ppro:,i.,.iatcly 80 feet above Lhczc crcc!:~ ;ind not !;ubjcct: to f..lo(lclinr,.
Sincerely you::::.,
4:--N. 11. Jacksu11, Jr.
/ llydrolo~bt
APPENDIX D
Comments Received on the
Draft Environmental Statement
--:--::.a ·
'-IEMSER UNITS
COUNT IE~
Franklin
Granville
Person
Vance
·Narren
Mi.JNICIP.&.L I TI ES
Bunn
Creedmoo,
Frankl ,n1on
Henderson
Ki!!rell
Louist>urQ
Mecon
MiddleourQ
Norlina
Oxford
Ro•lloro
Stem
s«a..■11
Warrenron
Youn9sv1lle
KERR -TAR REGIONAL COUNCIL OF GOVERNMENTS
P.O. Soa 709 23M ORAHG£ i TREET HENO ER.SON. H C ,7536
PHOHE , 9l 9i J?l ,1\0'1
Ms. Chrys Baggett
N. C. Department of AdministrJtion
State Clearinghouse
Room 504, Administration Building
116 W. Jones Street
Raleigh, NC 27603
Dear Ms. Baggett:
January 25. 1980
RE : Draft Environmental Impact
Statement for the Removal
and Disposal of Sotls
Contaminated with PCBs
Along Highway Shoulders in
Warren County
The Kerr-Tar Areawide Clearinghouse Review Committee has
completed its review of the above referenced draft EIS.
The A-95 Review Corrmittee does not concur with t he draft
Environmental Impact Statement per t'fie"following statements:
1. Additional emphasis needs to be placed on the integrity of the
plastic liner.
A. There is no proposal to maintain the surface free of trees whose
roots could penetrate the plastic top li-ner and create a
connection to surface water. Annual mowing should be a minimum
requirement.
8. 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.)?
2. Half the 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 concern since the exact elevati on 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
,..
~--··---~
Ms, Chrys Baggett
January 25, 1980
Page 2
how the high water table elevation was predicted. It appears :hat ~he highest
actual measurement taken from several Feb . 1, 19 79 bo rin1s at t he s ite
(306') was added to one-half of the maxir.1um normal r,round·,;ater fluctuation
in Warren -Co. (11') which gave a high •.va ter lev el of 312' (311 1/ rounded off).
Evidently this figure (312') was then subtracted from the ma xim u~ surface
elevation at the dumpsite (343') resultin~ in a 31' difference between the
ground level and the high water level. Since the study · .. as conducted
"during the middle portion of maximum seasonal fluctuatio•1", the water was
presumed to have already risen half as far as it was predicted to go whic h
resulted in adding half of the fluctuation. If this methodology or a similar
one was utilized in detenni n i 119 the high water 1 eve 1 , it wou 1 dn' t seem to be
too reliable. In addition, the lowest poi~t on the dump surface, not the
highest point, should probably have been ut i l ized in determining how much
working room would be available in relation to the ,jroundwater table. The
exact calculation utilized in detennining tile high groundwater level should
be clarified.
4. The plan allows numerous 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 1iners, and close
tolerance surface .grading.
S. The site must not be subject to f1ooding or have a hydrologic connection
with the groundwater according to p. 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. HO\v will the State
prevent this from ever occurrina?
6. This is not an adequate environmental impact ~tatement. More emphasis has
been placed 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 no t
exploring all possib1e environmental effects. the means to mitigate or
eliminate factors which could do hann 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.
10. Warren County hired a geologist, Dr . Charles L. Mulcl,i, who took his own
soil samples at the site and reviewed the State's plan. The En vironmenta l
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 tu Use So i ls
in the Afton ConJTiunity of Warren County, N. C. as a Disposal Site for Soi l s
Ms. Chrys Baggett
J~nuary 25, 1980
Page 3
Contaminated with PCB, still rema i ns vJ 1~d for the most ~J rt.
To stop PCB, you must keep it dry. :nis fo rmation becat..5e of the type of
clay and the low proporti on of c],y ~J othe r ty pes of soil, especially at
the lower levels, is not natura11y waterproof. James Scarboro ·1gh of the
EPA admits (Appendix C) that it ''is not in a 'thick , relatively impermeable
formation such as 1ara=-area cia v oans ' '. Li ners must be formed from earth
dug from the surface. -')f eight SJ.nipl ~s t ,~::en from t he top layers by th~
N. C. Dept. of Transportation, onl y three showed 50 percent or more cl ay
(Appendix B). The percent went down as they went deeper. To quote Or.
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 escaoi~g
materials in future years . The relati ve ly high sand content in these
lower regions suggest that moisture movement below the bur i al layer ·.-.ould be
very rapid and that there could be a risk of groundwater contaminations
resulting from leakage from the bur i al site ."
"A dependence on such means as artificial plastic liners and barriers of
soil less than SO 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 ir.
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,
Roy M. Williford
Planning Director
/ . \ I I : )
SIERRA CLUB ~ Joseph LeConte Chapter
... To rxfiort', ,,.,.joy '""'~rn<T1Je tht' 11atic,.'1 I ore1t1, Wtl/ff'I, wiuuf ,1 6114 wii,Jn-,uu ...
Burley Mitchell, Secretary
Department of Crime Control
& Public Safety
Raleigh, NC 27611
15 FabruarJ 1980
Subject, Removal and Disposal of Soils Contaminated With PCB's Along
Highway Shoulders In North Carolina -Draft Ellvironmental
Imoact Statement
Dear Secretary Mitchelli
Thank you for allowing us to submit our coffll11fJnts for your consideration
even though it is past. your deadline. As we stated in our January letter,
we needed this extra tillle to compile our statetaent.
We previously commented on the Draft Negative Declaration in January 1979.
Altho'4!;h many of the is3ues ve raised have been addressed, many subjects remain
that must be evaluated before the Sierra Club can assess the proposed action.
Sierra Club policy disapproves of landfilling of toxic or hazardous
111&terials in most cases. In this case, we agree with the determination of the
Administrator of the Environmental Protection Agency, Douglas Costle, in his
letter of 4 June 1979 to Gowrnor Hunt, "Aily hum.an exposUl"9 to PCB's is of
conc•m because of what is known about thia chemical." Disposal ot the
contaminated soil 1n a chemical waste and.fill that cOlllplies with the folloving
rec0Bm1endations will provide an interiJII method for protecting public safety
and health and for preserrtng our natural environment. We expect the state
to reMove the soil from the landfill and destroy the PCB's when an alternative
technology is developed.
RecOllllllendations required tor the construction and operation an:i for the
long term management ot the proposed chemical waste landfills
1. Citizens Monitoring COllllllittee
A c011111ttee of local citizena 111\1.St be formed to monitor the construction,
operation and long term management of the facility. Members of the committee
must include local otticials, adjacent and owners, and leaders of the oommunity
including those who uy be opposed to the proposed action. This will allow
the affected community to keep olose watch on all activities concerning this
project. It must be in attendance during all activities, especially the
monitorin~ after-closure ot the and.fill.
, 2. Disclosure ·
ill operations and 11t0nitoring data m~t be announced to the local and
statewide news l!l«ii• on a regular and continuing basis. This will keep the
public informed ot the cunoent st&tlll whether good or bad and will provide
accountability of the responsible state officials.
J. Leachate T:-:,a,t::imt
T:--eatment of leachate has been discussed. in the D~IS. However, no
method of disposal. of the treatment residue of leachate after landfill
olosure has been discribed. An appoved EPA method ot disposal must be
provided for thi.s residue.
Th" decont.i.minat.ed effluent of the leachate must be tastod l::efol"'II
it ia d11lh&rged. Thi.s efnuent 11u1t not be released. until laboratory
!.I.T'lalysis has confirmed. that the PCB's have been l"9moveo. The DEJ:S must
describe the m&Mer in which the effluent i.nll be discharged..
4. Restriction For Use Of Site
All possible legal and administrative actions must be taken to
insure the one tinle use of this site for the di.sposal of the PCB contaminated
soil as descrlbed in the DEIS. The at'feoted comnrunity needs eveey
guarrantee that the proposed action u the only use aver for the site.
The deed for the land mu.st contain a. covenant prohibiting the use
of the entire parcel for any other storage, treatment or disposal facility
for ha~ardou.s,. radioactive , or toxic material.,. Any lease for other
activities such as taming must oont&in these re.trictions.
The governor of the st&te must is.sue an executive order specifying
the restrictions for this site. Additionally, the administration must
seek special legi3lation from the 1980 session of the General Assembly
to restrict the use of the site to the prop:md action.
The state ll1U.st include these restrictions in its pendt application
request to the Regional Administrator of the Environmental Protection Agency.
The state must as~ure the citizens that all the loopholes for other uses
of this site are eliminated.
5. Groundwater Separation
The proposed. five (5) foot groundwater separation is insufficient.
In!o~tion in the DEIS shows that a much greater separation is possible.
Page 17, para.graph 1 gives the maximum excavation depth as 24 feet. Thus, by
removing the thickness of the liner and leachate collection syste~, the
landfill will have a useable depth of hZ feet. Allowing for topographic
variation, a u.seable depth of 15 feet would me&n that the entire 40.,000
cubic yards of contaminated material. could be stored in an area ot 1. 7 acres.
By increasing the land.till surface area to 2.9 acres (a.a is shown in
the N.C. Department of Tra.nsp<l'tation boring (soils) study in the DEIS), the
maxim~xcavation depth would only be 14 feet -10 fa.t shallower than
proposed 1n th• DEIS. This incl"'9aae in &1"'9& will inoreue the groumwater
separation to 15 feet -more than double the proposed separation.
In the interest of maintaining environmental protection, the final design
for the landfill 111Ust provide greater groundwater separation tha.n proposed.
This oan be achieved at little or no increased cost aod.. vill provide a
greater measure of security.
2
6. Land fill Sidewalls
According to Figure 5, Section I. D., the l&nrl!'111 will not have &
contiguous clay liner, the design fails to provide a unifoffl container
of equal ,peoification., f or the bottom, 51.du and top. The DEIS prov1.ri•s no
information to show that latterall,y moving Kroundwater or th.at ,1nir..a l a will
not be a problem. In addition, there i.s no in!o.M!lolticn ~bout:~~ long te?'ffl
integrity of the artificial liner.
The entire landfill must be encased in a clay liner that is conti?~OU5
from the cap to the bottom including the sidewalls. This cor.t i.;uo..:.s l iner
must be constructed to the ,pecifioations that are pro?osed f .Jr t ::e ':,ott c!!!
in the DEIS.
?. L&ndf111 Cap
The proposed. cap design is insufficient to provide for vegetal erosion
control and to prevent future penetration by ,urface water. The specifications
on pa~e 12 (10 mil artificial liner, 1,5 foot clay liner and 6 inche, of topsoil
i:i:raded to a ~ slope) fail to provide an adequate root ~one for maintaining
ve~etation without an irrigation sy:,tem. Any vegetation established in such
a thin zone for roots will be very su.sceptable to drought. Site maintenance
must include fertilization and reseeding of the vegetal cover.
Moreover, the cap is not thick enough to allow for ped.ogenetic (soil
forming) processes. The design provides for an almost inpenetrabla bottom;
it lllllst provide a no less penetrable cap. The chemical and physical forces that
could penetrate the landfill are most intense at the ground surface. It is
concievable that noz,nal olim&tic events could easily penetrate the 2 feet of
topsoil and clay liner rlthin a century. Thi.s scenario i.s made more probable
if a small area of vegetation dies and erosion occurs.
The cap design m~t specify 2 feet or root zone consistant with agronomic
concepts and the same clay liner plu.s artificial liner requirements as proposed
for the bottom in the DEIS • .A.n agronomist-soil scientist mu.st supervise all
surficial earth disturbances, reveget&tion &Bi cap construction.
e. Revised Draft Enviroamental Impact Statement
We r-equest that a revised DEIS be prepared which incorporates our
rftCOl!lfflendations. This revised. document ·"111 allow all agencies and the public
to assess submitted c0111111ents on the proposed action.
Adoption of our recommendations will as,1.st in providing greater protection
of the public and the environment from the hau.rds of PCB contamination. Th~k
you for considering these colllftenta.
Sincerely,
\ /
11}' ·/J --;.., ~ (' 'N \)),l 4 J "Y\. it . ~ c.eA.A.t. > 1 '
Wil.li.&Jll H. Doucette, Jr. 1)
Hazardous Waste Committee
~1vh ·t~-
David W. Levy J
Conservation Chairman
1428 Sedwiok Iii.
Durham, NC 2771J
( 919) .544-1187
J
APPENDIX E
USDA, Soil Conservation Service
Vegetative Cover Recommendations
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Mr. 0. W. Strickland, Head
Solid and Hazardous Waste
Management Branch
Environmental Health Section
Department of Human Resources
Post Office Box 2091
Raleigh, North Carolina 27602
Dear Mr. Strickland:
At your request, we have prepared, for inclusion in your final Environmental
Impact Statement (EIS), recommended procedures for the establishment, support
and maintenance of vegetative cover on the proposed PCB landfill disposal
site in Warren County. We feel that the treatment suggested will be adequate
for protecting the site from erosion.
We are pleased to be of service to you and the State of North Carolina in
this matter. If you have any questions regarding the reco11111endations, please
feel free to call me or James Canterberry, State Resource Conservationist
at 755-4375.
Si ncereiy,
. =:/ / /' I '-../ ~-/. Z:, wa'½~ c?"S,~~ 7
Jesse L. Hicks
State Conservationist
Attachment
cc: James Canterberry
ESTABLISHING AND MAINTAINING VEGETATION
WARREN COUNTY PCB LANDFILL
l. Ap piy a minimum of six inches of topsoil (12 inches is preferable) over the
compacted clay layer.
Topsoil -The material shall consist of natural surface soil; a loam, sandy
loam, clay loam, silt loam, sandy clay loam, or other soil su itable for
establishing vegetative cover. It shall not have a mixture of subsoil and
contain no slag, cinders, stones, or soil lumps, sticks, roots, or other
extraneous materials larger than one inch in diameter. Topsoil must be
free of noxious weeds as defined by the N. C. Department of Agriculture.
a. After the areas to be topsoiled have been brought to grade, and
iITJTiediately prior to dumping and spreading topsoil, the subsurface
or subgrade shall be loosened by disking or by scarifying to a
depth of at least two (2) inches to permit bonding of the topsoil
to the subsoil.
b. The topsoil shall be uniformly .distributed. Spreading shall be
performed in such~ manner that seeding can proceed with a minimum
of additional soil preparation and tillage. Any irregularities in
the surface resulting from topsoiling or other operations shall be
corrected in order to prevent the formation of depressions or water
pockets . Topsoil shall not be placed while in a frozen or muddy
~~"rlition, when the subgrade is excessively wet, or in a condition
~therwise be detrimental to establishing vegetative cover.
reasonably unifonn, lime and fertilize according to soil
absence of a soil test, apply two (2) tons of lime and 1,000
-10 or its equivalent per acre. Uniformly mix the lime and
o the top four (4) inches of the soil by ripping or tilling
e seeded. All land preparation should be done across the
te land preparation by smoothing the seedbed with a tandem
oth harrow, or other equipment.
' seeder is used, the area shall be cross seeded by applying eed in one direction and the other half at right angles to
:ction. When the seed are broadcast, a cultipacker shall be
entire area irranediately following seeding.
:ture
ispedeza
. I) and
le
:spedeza
i ed) and
Je
Planting
50 1 bs.
30 1 bs.
60 1 bs.
30 lbs.
Rates£'.'.Acre Optimum Planting Dates
February-April
August-November
--. •.. -
5. Mulching : Unweathered small grain straw or hay free from seeds of competing
plants. Spread at the rate of two (2) tons per acre.
6. Maintenance fertilizer and lime
a. Apply 500 lbs. of 5-10-10 per acre or equivalent in late winter or
early spring or amount recommended by soil test.
Apply in the fall if the Sericea is developing better than the fescue.
b. Apply one (1) ton lime per acre each thrae or four years or amount
recommended by soil test.
2