NCD980602163_19810413_Warren County PCB Landfill_SERB C_Preliminary Plans and Specifications including comments-OCR

North Carolina Department of
Crime Control~~
& Public Safety_
P.O. Box 27687 512 N. Salisbury Street Raleigh 27611 [phone]
James B. Hunt, Jr., Governor Apri 1 13, 1981
Sverdrup & Parcel
Consulting Engineers
2211 West Meadowview Road
Greensboro, North Carolina 27407
Attention: Mr. Frank B. Rainey, Jr., P.E.
Subject: Department of Crime Control & Public Safety
PCB Waste Disposal Site
Warren County, NC
Code 14900 -Item 1111-1990
Dear Mr. Rainey:
Burley B. Mttchell, Jr., Secretary
Attached you will find review comments from the following:
1. Region IV, US Environmental Protection Agency
2. Division of Highways, NC Department of Transportation
3. Solid & Hazardous Waste Man_agement Branch, NC Department
of Human Resources
4. Division of Environirental Management, NC Department of
Natural Resources & Comnunity Development
As you will note, the conments from the US EPA were only recently
received causing a delay on our part in submitting these to you.
Please advise estimated completion date of working drawings.
DEK:jj
Enc.
cc: Secretary Mitchell
Mr. Gene Roberts
Mr. Bil 1 Raney
Sincerely,
~· ~ ~-l~ David E. Kelly
Assistant Secretary
Public Safety
Mr. M.C. Adams✓
Mr. Bi 11 Myer
Mr. Page Benton
Mr. James Scarbrough
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DIVISION OF ENVIRONMENTAL MANAGEMENT
March 4, 1981
MEMORANDUM
TO: David Kelly, Assistant Secretary
Crime Control & Public Safety
FROM: L. P. Benton, Jr., Chief
Environmental Operations
SUBJECT: Review of Comments on PCB EIS
Warren County
As instructed, this Division has reviewed the comments on the above
EIS relative to groundwater levels at the proposed disposal site, with
special attention being given to the connnents from Warren County.
In conducting this review staff again visited the proposed disposal
site. The Division measures water level fluctuations at a monitoring well
located approximately two and one-half miles from the proposed site in
similar terrain. Records of water level fluctuations at this well showed
a range of four feet. The recently drawn set of preliminary grading plans
showi ng the exact location of the proposed storage pit was also reviewed.
Finally, four Department groundwater hydrologists wer e shown all of the
data and opinions received.
Based on the review of previously recorded facts, evaluation of the
preliminary grading plans for the disposal site, and consultation among
hydrologists with general knowledge of the area groundwater, staff con-
cluded that their review uncovered no additional information which would
refute the groundwater-water level part of the hydrology-topography
section in the final environmental impact statement.
cc: Ted Mew
Stan Taylor
c~(CEI
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UNITED STATES E N V IRON M ENTAL PROT ECTI ON A G EN CY
R E GI O N I V
345 CO U RTLAN D STREET
ATLANTA. GEO R GIA 30365
MAR 3 1 1981
REF: 4AH-RM
Mr. O.W. Strickland
Solid & Hazardous Was t e Management Branch
Departrrent of Human Resources
P.O. Box 2091
Raleigh, North Caroli na 27602
Dear Mr . Strickland:
EPA has received and reviewed the preliminary plans and specifications
for the Warren Count y PCB DisfX)sal Site, prepared by Sverdrup and Parcel
Consulting Engineers. A copy of the comrents is enclosed.
We must have a copy of the facility fX)st-closure care program. It should
include details on ground water monitoring, and t he collection and
rnanagernent of leachate.
Should you have any questions regarding this matter , please contact
Emilio Gonzalez or Don Hunter at [phone].
Sincerely yours,
f~!wrough , Chief
~si duals Management Branch
Enclosure
A'ITACfNENI'
The preliminary plans and specifications for the Warren County Disposal
Site has been reviewed as requested. The following are our corcments:
(a) The pipe used for rerroval of leachate from the leachate detection
system swnp should be buried in the compacted aggregate layer, and
not placed on top. The drawings and the specifications for landfill
construction do not seem to agree.
(b) The c l ay liner permeability must be 1 X 10-7 cm/sec or less. The
specifications does not make reference to this.
(c) We suggest a minimum 2% slope for the bottom grade of the disposal
pit.
(d) Vandal protection should be provided for the gas vent and t he
leachate collection pipes. lt>ne is provided as shown on drawing
number eight.
(e) Section 5.6 reads, "I f contaminated water is found i n the silt pond,
the sediments in the bottom of the pond will also be placed the
landfill prior to pit close out." The sediment should be analyzed
too, not the water only.
(f) Based on bore hole log data, it appears that less t han favorable
permeability conditions exits in the proposed holding pond area,
therefore, the holding pond should be lined to prevent any
contamination of the ground water.
(g) Ground Water Monitor ing -There has not been a detailed ground water
study at this site. Three borings intercept the water table and are
not adequate, in themselves to thoroughly character ize the
configuration of the water table below the site. Well nurnber one
probably can serve as the upgradient monitoring well. The problem is
adequately rronitoring all downgradient ground water zones . While ·
wells number two and three monitor ground water zones that are i n
fact downgradient from the disposal area as required, it appears t hat
another downgradient zone is left unmonitored. This situation is
defined in the following manner. Well number one is located on a
narrow east-west trending divide which terminates in a blunt
north-south trending face facing west. It is within this feat ure
that the disposal area is located. The indications are t hat there i s
definitely ground water flow north from the divide (rronitored by well
number two) and west from the face terminating the ridge (monitored
by well number three). There is also the str ong indication, based on
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topographic evidence that there is probably ground water flow south
from the disposal area. Unless it can be shown conclusively that
there is no ground water flow to the south beneath the disposal area,
a well to monitor any southward flow would be highly advisable. Its
location should be approximately 50 feet from the fence and near the
centerline of the landfill.
(h) The specifications call for only two feet of cement grout in the
annular space. EPA would like to see five feet of grout to anchor
the well more securely and to provide more isolation from the
surface. We would also like to see each well screened so that a
minimum of ten feet of the upper ground water zone can be sampled at
anytime (ten feet below seasonal low water table evaluation).
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STATE OF NORTH CAROLINA
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JAM ES 8 . HUNT, JR. DEPARTMENT OF HUMAN RESOURCES ........_--.iiltiMl1iilr" ILSON. M.D.
GOVERNOR
Division of Health Services
SARAH T. MORROW, M.D., M .P.H.
SECRETARY P. 0 . Box 2091 Raleigh 27602
MEMORANDUM
TO: Mr. David Kelly
Assistant Secretary
Public Safety
March 30, 1981
FROM: Mr . Bill Meyer, Environmental Engineer
Department of Human Resources
Solid & Hazardous Waste Management Branch
DIRECTOR
. . ., .... ..,_
SUBJECT: Comments on Sverdrup & Parcel Proposal For PCB Waste Di sposal Site
Warren County
1-Page lA-3 Add Department of Human Resources to Sentence l, 5.3
Define Contractor, Engineer and Owner.
2-Page lA-1 2. Coordination of Work. Add:
The State of N.C. will have a qualified engineer on site during
all construction activity to assist in coordination of work.
3-Page lA-4 Submittals DurinT Construction Add to 7.1:
The engineer shall submit copy of contractor submittals to the
State of N.C. for review.
Note: Required submittals should be outlined in contractor
specifications.
4-Page 28-1 Earth Work
(a) There are no specifications for selection of fills and backfills
except all fill material shall be subject to the acceptance of the
engineer.
There should be specifications on selection and excavation of
liner materials; placement in stockpile areas, preparation of stock-
pile areas, moisture control and sampling for laboratory of field
testing . The specifications should include standards established for
clayey materials suitable for soil liners on PCB landfills. (40 CFR
761.41 (b)(l) i through v)
(b) Page 28-2, 4.1 AAHSO T-180 Method Dor ASTM D 1557 Method D should
be evaluated for compaction st9,ndard. This would afford a safety
factor for engineering judgements on soil suitability for liner
construction .
(c) Page 28-3 Specifications for stockpile areas (preparation methods
for stockpiling) How are selected excavated materials selected?
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(d) Page 28-3, ~6~.l The surficial soils on site are eroded and the
surface foot may ~e suitable for final grading. It is suggested that
the su r face 611 or excavation to the minimum depth to exclude plant
roots and other organic material to be stockpiled for final grade .
It was noted during site evaluation that the highest soil clay content
was immediately below the soil root zone.
(e) Page 28-3, 4.5.2 Detail specifications on materials, methods and
tests fo r selection excavation, stockpile and protection (ie. moisture
content) of clay liner materials.
(f) Page 28-3, 4.8 Specify compaction test. The credibility of entire
project is based upon the clay liner and more specifically the per-
meability of the clay liner. It is essential that a combination of
f i eld/lab tests to determine density , moisture and permeability be
implemented.
It is sugg ested that AASH0 T 147-54 Method A or B; or ASTM D-2167,
1556 & 1557 be utilized on a 2000 ft 2 basis in addition to the lab
compaction tests on 10,000 ft 2 intervals per 6 inch lift.
*This point should be fully discussed and a decision made on the method
of testi ng a number of tests and lab selection as soon as possible .
5-Page 2C -l, 2. 1. l Specify stockpile of materials on plans, (methods
and materials)
6-Page 2C-l, 2C-2, 2C-3 An evaluation should be made of the alternative
of installating a gravity leachate removal system(s) as to the proposed
system.
7-Page 2C-2, 2.3.1 Specifications for compacted bridging fill on top of
artifical liner and liner protection materials. Depth of liner protection
layer should be a minimum of 1 foot.
8-Page 2C-2, 2.4.1 Specify liner soils from 40 CFR 761.4l(b) (1) i thru v.
Consider modified proctor for compaction standard.
9-Specify method of liner construction, i.e. constructed f l at, 3:1 slope,
etc. Evaluate alternatives for proposed construction on 3 to 1 slope,
i.e., excavate 1:1 construct 3:1, 4:1.
10-State test ing for moisture/density, compaction in liner construction
section.
11-P. 2C-3, 2.6-Specify method and degree of compaction of PCB soil mixture.
12-2.6.2
Should be modified to include construction of ramp into excavation to
prevent damage to side wall from dumping and placing PCB waste. A N-S
ramp (long axis of landfill) to allow dumping in the bottom excavation
should be considered. Ramp construction should be based on truck capability.
Ramp should be excavated for removal as the bottom 10-foot lift of waste is
placed insite. A second ramp should be constructed for the upper 10-foot
lift. This assumes that the waste will be placed into the site in 2-10 foot
lifts (lifts should be compacted on 2-3 foot sublifts).
13-Sequence of construction on covering the landfill. Evaluate proposed
sequence: bridging layer -

2

foot clay layer -PVC liner -protective
layer -

l

foot topsoil; versus: bridging layer -PVC liner -

1

foot PVC
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liner protection layer -2 foot clay liner -l foot topsoil. They may offer
better protection for PVC liner. Evaluate 10 mil versus 30 mil PVC liner
for landfill cover.
14-Page 2C-4 2.7.7 Evaluate increasing depth of final cover to 3,.,4, or 5 feet
utilizing excavated spoil. Evaluate increasing final slope to 3-5% in east
to west direction to reduce contact time for infiltration.
15 -Eval uate eliminating gas vent and utilizing upper leachate removal system
for gas venting (Predicted gas generation, diffusion pressure, etc .).
16-2F-3 PVC Liner -Specify distances of over lap and adh esives for all joints
of PVC liner.
17-Specifications (calculations) for sizing sediment basin (holding pond).
18-21-2, 3.1 Consider increasing topsoil depth (see comment 14) ..
19-21-2 Planting -If the site is completed in mid-summer a temporary vegetative
cover of a drought resistant grass (millet, milo, sudian, sudex) should be
considered, with permanent seeding to follow at optimum seeding season for
fescue and sericea.
20-Section 15A
Specify size of internal landfill sump, maximum anticipated or predicted
rainfall event, size and type of carbon for filtering PCB contaminated
water, rate of treatment capacility (what happens if 2 or 3 major rainfall
events occur).
Should the septic tanks be plastered or coated with sealant to ensure
water proofing.
The design should consider a gravity system for leachate collection
(lower leachate and upper leachate removal pipes extended through side wall
of landfill) and be tied (separately) to the sand and carbon filter system(s).
Valves (external) would control leachate flow to the sand and carbon system(s).
ENGINEERING DRAWINGS
Sheet No. 2
Borrow area proposed has not been tested for soil engineering properties.
What type of borrow materials will be obtained from this area. Areas to the
N and S of the proposed landfill location has been evaluated for soil engineer-
ing properties.
Sheet No. 3
Are the concrete monuments identified as permanent bench marks; if so, where
are they located (specifically located)?
Sh eet No. 4
Should include sections E-W & N-S to locate source and volumes of materials
to be excavated and stockpiled for various purposes, especially clay liner,
PVC liner protection, final cover s, etc.
Sheet No. 5
Calculations for si zing holding pond possibly sections since dam sections are
included here.
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Sheet No. 6
Should the final grading plan be modified to provide 3-5% grade along center-
line of landfill and establish several (2-4) control points (piped slope drains)
to reduce flow over 5:1 side slopes?
Sheet No. 7
Note in detail -should the tranks be plastered or further water-proofed,
siz~ type and volume of sand and carbon stated; sealing of pipe through side
walls (specs), at 125 gpm flow and the reduced volume for free board and sand
or carbon, there should be a control mechanism for liquid level to prevent
overflow. There should be a detail for containing the carbon below the inlet
pipe, as it will tend to float in the tank (e.g. removable screen).
Sheet No. 8
See comments concerning gravity leachate removal, sequence of top cover,
gas venting, top PVC liner thickness.
Evaluate all seal procedures, should the seal be l' or 2' and should the
seal extend up the sides of the PVC pipe.
Sheet No. 9
Cross section should include ramp section to allow placing PCB in bottom of
excavated areas.
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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
RALEIGH 27611
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J.~•.,r:S 8 . HUNT, JR.
::OV:::RNOR March 2, 1981 DIVISION OF HIGHWAYS
THOMAS W. BRADSHAW, JR.
SECRETARY
MEMORANDUM TO: Mr. Dave Kell:A
M. C. Adams ;er FROM:
SUBJECT: PCB Waste Disposal Site
Enclosed herewith please find comments on the subject
plans and specifications which have been submitt ed to me by
our Department of Transportation Construction Unit.
I submit these for cons i deration by the Consultant.
In addition to the comments made by the Construction Un it ,
I offer the following:
(1) I specifically would like to point out the importance
of the Construction Unit's comments concerning density.
I would strongly suggest the provisions require t h at
each densit y test pass a required 100% maximum density.
(2) In further reference to densities, due to the extreme
sensitivity of this pr oject, I suggest the provisions
go into further detail with regard to control of
moisture content. This should include a description
of moisture density curves to be developed for all
soils to be included as a part of the clay liner
and, also, a requirement that in the event opti mum
moisture is not present at the time a density test
is made, the soil will either be manipulated by
harrows, etc . for drying purposes, or moisture will
be carefully added and blended in with the soil material .
(3) I continue to question the backdumping of the
contaminated material over the side slopes of the pit.
This will cause a great deal of manipulation within
the pit area and could cause dusting and s pillage
problems.
...
Mr. Dave Kelly
March 2, 1981
Page 2
(4) I seriously question a contractor's ability to obtain
100% density on a 3:1 slope, particularly using a
vibratory roller. I suggest we investigate the
possibility of 5 or 6:1 slopes with vibratory rollers,
or the use of a sheepsfoot roller if steeper slopes
are required.
(5) In view of the comments made by the Construction Unit
and considering the sensitivity of the project ,
coordination required with DOT hauling operations,
and the need for absolute control by the Engineer,
I suggest we consider the possibility of a negotiated,
cost plus fixed fee type contract.
If I can provide any additi onal information , please let
me know .
MCA/pw
Attachment
cc: Secretary Thomas W. Bradshaw, Jr.
Mr. Billy Rose
Mr. Don Overman
Mr. Luther Berrier
Mr. Bill Rainey
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J AMES B. HUNT,JR.
GOVtRNOR
THOMN; W. B R/\DSH/\W, JH.
SECRETARY
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
RALEIGH 27611
Area Code 919 --733-2210
February 27, 1981 DI VISION OF HIGHWAYS
Subject: Waste Disposal Plans and Provisions -P .C .B.
MEMORANDUM TO: MR. M. C. ADAMS, MANAGER OF MAINTENANCE
Per your request, we are attaching a copy of our wri tte n
comments on the enclose d c ontract and plans . We could
go into much greater detail on some of o ur c oncerns , but
to be honest, we do not have the time to redesign and wri t e
specifications that we be lieve would be be t te r . Ma ny o f
the details in the contract and plans appear to be vague
and it appe ars to us as if the type of Co ntractor we normally
deal with will have a di fficult t ime deriving a reasonabl e
bid.
BGJjr:ppc
Attachments
Yo urs very trul y,
B. G.
HEAD 0
KINS, JR., P.E.
ONSTRUCTION
General:
Should not a Date of Availability and a Contract Completio n
Date be specified. It would also appear that some form
of liquidated damage might be wa rranted. Some type of
time extension provision should be included since to s ome
extent the Contractor's progress on a portion of the work
is dependent upon the actions of others, i.e ., the Department
of Tr ansportation.
In Section 4.3 on Page lA-3, the portion of the provlsion
concerning the Enginee r making recommendations on request
by the Contractor is an internal mechanism and should not
be included in a contra ct.
I n Section 8 on Page lA-4, t he provisions provide for
lump sum payme~ts and per diem unit prices. We would
suggest consideration be given to utilizing unit bid ite ms
for the work involved with ap propriate measurement and
p a yment provision for each bid item. This might result
in increased engineering costs to administer, but should
reduce contingency bidding by the Contractor since the way
the contract is drafted will require the Contractor to
protect himself by bidding overruns, plan alterations, etc.
I t appears many of the provisions in this contract are vague
and general in nature and I would expect a prudent Contractor
would protect himself and minimize his risks by including
contingency monies in his bids to an extent greater than you
would normally expect.
Section 2A -Clea ring and Grubbing
Subsection 2.1.2,Page 2A-l -Do not understand the
provision as wr itten. Is start of the contract the
date of award, the date of beginning construction, etc?
Contractor could not dispose of timbe r prior to taking
possession of the site. Believe intent is to have
timber removed prior to commencement o f grading operations.
Subsection 2.1.4 and 3.2 and 6, Page 2A-l, 2A-2 and 2~~4 -
Is material to be disposed of to be buried , covered, and
site seeded or just l eft out in open? Hard for Contracto r
to bid this item the way it is written .
Section 2B -Earthwork
Subsection 4.3, Page 2B-2 -Re commend a minimum requi rement
of density for each test, not an average.
Subsection 4.4, Page 2B-3 -A proof roller is not defined.
Is the intent t o proof roll t he slopes? What constitu tes
a soft spot? It would appear dif ficult for a Contracto r
to bid this work .
Subsection 4.5 and 4.5.1, Page 2B-3 -These two provisions
are vague and would appear to be difficult for a Contractor
to bid with a realistic estimate of his costs.
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Subsection 4.5.2, Page 2B-3 -What is defi ned a s clay?
How can t he Co ntractor bid his cos t o n this?
Subsection 4.7, Page 2B-3 - We question the value a nd
the feasibility of requiring a roller to operate on
the sand layer on the excavated slopes.
Section 2C -Landfill Construction
Subsection 2.1.2, Page 2C-l -Subgrade is not d efined nor
delineated on plans.
Subsection 2.2.1, Page 2C-2 -Need to indicate 197 8 Edition
of Standard Specifica tion s .
Subsection 2.2.2, Page 2C-2 -Refer to c omment on Subsection
4. 7.
Subsection 2.6.4, Page 2C-3 -Do not understand what the
ten foot cells are or will be used for. This may be an
obvious thing to those that normally do landfill construction.
Subsection 2.7.4, Page 2C-4 -The word "slope" s hould
be inserte d after the word "percent" in the 1st line
in order to b e clear as to i ntent.
Section 2D -Ground Water Monitoring We lls
Subsection 2.5, Page 2D-1 -We could not f ind a plan
detail indicating the g routing cf the top two fee t o f
annular space.
Subsection 2.6, Page 2D-1 -Is the information submitted
for approval or for informational purposes only? Could
make a difference in the way it was bid.
Subsection 2.10, Page 2D-2 -Can satisfactory be better
defined for the bidd er?
Section 2E -Chain Link Fence
Subsection 3.2.2, Page 2E-l and 3.2.4, Page 2E-2 -The .type
of material (steel) is not specified as it is in Subsection
3.2.3. Need to be consistent. Suggest posts length of
e ach type of posts be indicated.
Se ction 2F -Landfill Liners
Subsection 2.5.4, Page 2F-3 -Insert the words "by the
Contractor" after the word "available" in the 1st line
to clearly indicate who must make the arrangement for
the representative to be present.
Subsection 2.5.6, Page 2F-4 -Appears to be an unfinished
sentence in this paragraph.
Section 2G -Filter Fabric f or Le a c hate System Pr o tection
No comments
Section 2H -Soil irosion Control
Subsecti on 2 .2 , Page 2H-l -I f wa t e r must b e r eprocess e d
through the carbon filter , who does i t , how i s it done ,
and who pays for it?
Se ction 21 -Seeding
Subsection 2.2, Page 21-1 -Last s e nte nce should refer
to the current edition of Spec i fication s which is the
1978 Edition of the North Carolina Department o f
Tr a n sportation.
Sub secti on 4.3.2, Page 21-3 -Our expe r i ence with results
from using wood cellulose as a mulch has not bee n very
g ood except in early Spring and late Fall wh e n no mulch
might be just as productive. Suggest straw.
Subsection 5, Page 21-3 -Req uiring a g uaranteed stand of
grass is expensive . Might want to consider some other
approach.
Section 15A -Carbon Filter Sys tem
Subsection 3 .1, Page 15A-l -Pump not shown on p lans
that we can find. Suggest mo re de tails on pump .
Plan Comments:
Sheet No. 5
Our Utility Section of Design Units does not f e el the
design of the r e lief pipe with gate valve shown going
through the earth dam will work as designed. They
believe relief valve will blow off when water l e vel
in holding pond is significant. Co nnection of P.V.C .
pipe to riser pipe is q uestionable. Suggested design
be rechecked.
Sheet No. 7
Manhol e covers refe rred to in Sec tion A-A should be more
c learly defined as to what is required. Note refe r s to
pipe penetration through walls being sealed but does not
indicate what with.
Sheet No. 8
Gas Vent Detail -How many l" holes should be provided in
bottom 5 feet of pipe?
Cannot find where Specifications are given for type of
concrete intended to be used with details on this sheet .
Sump and Leachate Coll ection Pipe Detail -How far across
excavation does sump run?
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. ' ,'.• Suggest a plan view be shown that shows more detail and
the location of some of the i t e ms liste d on this she et.
We have not a ttempted to list every typographical error,
misspelling, etc. that we have faun~ nor attemp t ed to list
eve ry specification wording that we be lieve could be written
more clearly. Suggest the Consultant look back over the
s pecifications. Some of the design concepts that iny olved
the sump and l eachate system, g a s vent , we are not competent
to offe r opinions upon.
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