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HomeMy WebLinkAboutNCD980602163_19810526_Warren County PCB Landfill_SERB C_Administrative Action Addendum to Final Environmental Impact Statement-OCR.. ' -Ii .. Removal and Disposal of Soils Contaminated With PCBs Along Highway Shoulders In North Carolina ADMINISTRATIVE ACTION ADDENDUM TO FINAL ENVIRONMENTAL IMPACT STATEMENT STATE OF NORTH CAROLINA IN COMPLIANCE WITH ,uN 3 1981 :: fE · ,, THE NORTH CAROLINA ENVIRONMENTAL POLICY ACT Addendum to Final Environmental Impact Statement Removal and Disposal of Soils Contaminated With PCBs Along Highway Shoulders In North Carolina The Final Environmental Impact Statement (FEIS) was distributed on November 13, 1980. This addendum addresses comments submitted by Warren County on January 29, 1980 on the Draft Environmental Impact Statement (DEIS). Comments submitted by Warren County were inadvertently not responsed to in the Final EIS . Their comments which have been briefly paraphrased and our responses follow. The Warren County comments in entirety are attached. Warren County Comment: 1. Site Selection Response : a. Laboratory Procedures and Results "The 1 aboratory test results presented in the Envi ronmenta 1 Impact Statement, Appendix B, fail to satisfy the requirements stated in paragraph 716.4l(b). The test results were too few in number for the critical soil characteristics of permeability, liquid limit and plasticity index. Specifi cally, there were inadequate sample numbers and replications of samples to determine the mean and standard deviations for these key soil parameters both with depth and across the site in general ... 11 The engineering characteristics of the soil to be utilized in the construction of the proposed site meet the standards stated in 40 CFR Section 761.41(b). See N.C. DOT test results 9-22-78 project 4.5401101 Appendix B. See also the EPA technical review of chemical waste landfill for disposal of PCB contaminated soil submitted by the State of North Carolina, June 4, 1979 Appendix C. EPA 1 s review states that the site will meet all the technical requirements for a chemical waste landfill as required in 40 CFR Section 761.4l(b) (June 4, 1979 letter from EPA Region IV Administrator to Governor Hunt, Appendix C). The sampling and testing procedures to identify soil engineering properties are considered adequate and reasonable to determine permeability, liquid limit, and plasticity index. The specific tests for permeability were conducted under ASTM Standards by independent, qualified professional engineers. The proposed landfill construction project is an engineering project to m·anipulate or engineer existing natural soil conditions to conform to 40 CFR 761.41(b) standards . The true, natural or Comment: Response: Comment: inherent soil characteristics have been tested to indicate that the site can be engineered to conform to 40 CFR 761.4(l)(b) standards. b. Soils Map of Site 11 ••• In addition to the lack of definitive test results regarding permeability, no detailed subsurface map of the various soil layers found at the site has been prepared. This would have involved a systematic physical identification and characterization of the various subsurface horizons to determine which layers meet or exceed the stated requirements by the EPA for liner construction. Since the soil liner will be constructed from materials existing at the site, the present impact statements fail to identify the exact soil layers which do meet the requirements. The impact statement suggests that the construction engineer will 11 stockpi 1 e11 1 ayers of soi 1 s which visually appear to meet the necessary requirements and that these materials will be blended in a manner to assure the requirements are met. No feasible method is available for determining the adequacy of the blending operation ... 11 The soils on the proposed site have been sufficiently identified and tested to demonstrate the engineering capability for both soil characteristics and volume to meet 40 CFR 761.4l(b) standards (pp. 17 -18C Appendix B-C). The soil liner will be constructed of materials which were identified and tested to meet 40 CFR 761.41(b) standards under the direction of a soils engineer. The location of these soils are in the surficial or upper 5 feet. Bulk sampling, rather than sampling at 611 intervals, are standard ASTM and engineering procedures. A qualified soils engineer will select and supervise excavation of suitable soils for liner construction (p. 12.3). Any soil procedures including blending will be under the direction of a qualified soils engineer. Al so, see response to comment 1. d on page 4-, C. Clay Content and Definitions 11The critical features for retaining chemicals in place would be the clay content in the soils used in the soil liner. Clays are defined by both the International Society of Soil Science and U.S.0.A. classifications as solid particles of soil less than or equal to 0.002 mm in size (Soil Survey Manual, U.S.0.A. Handbook, No. 18, August 1951, p. 208). The impact statement does not identify the quantities of solids below 0.005 mm in size, which are fine silts. Since 761.41(b) states that 'the landfill site shall be located in thick, relatively impermeable formations such as large-area clay pans !andl !wl here this is not possible, the soil 2 Response: shall have high clay and silt contents ... 1 , it is paramount that these zones of clay enrichment be identified prior to construction. The clay content is the controlling factor in several critical soil parameters including liquid limit, plasticity index, chemical exchange capacity (CEC) and surface area ... 11 11 It is vital that the soil liner be constructed of soils 1 high in clay 1 to reduce the risk of chemical migration from the site. The very thin layer of clay enriched soil at the Warren County site would appear inadequate in .quantity to safely construct the soil liner. The reference of 1 mixing of soils 1 within the initial 01 -51 5 in the March 15, 1979, letter from Soil & Material Engineering, Inc., to Mr. Jerry Perkins appears an oversimplification in their estimate of the volume of 1 high clay 1 soil available for soil liner construction.11 The soil characteristics were evaluated under ASTM st~ndards for engineering purposes not USDA standards . The clay content of the evaluated materials were sufficient to meet 40 CFR .71(b) standards for permeability, liquid limit, and plasticity index. There is no standard for percentage of clay, type of clay and mineralogical content in the 40 CFR . 71(b) regulations. The letter to Mr. Jerry Perkins from Soil and Material Engineering is an estimate of professional soil engineers of the volume of clayey materials. Soil surface area characteristics effect soil engineering properties and these properties are included in 40 CFR .71(b) standards. Chemical exchange capacity (CEC and more appropriately identified as Cation Exchange Capacity) is involved with sorption of chemicals that have a positive change (cations) or have an area of apparent positive change. PC8 1 s do not exhibit a positive change and therefore would not be sorbed by CEC mechanisms. For this reason, CEC is not a valid parameter for PCB landfill standards. Surface area is a valid parameter and is considered in 40 CFR .7l(b) standards. Comparison of laboratory permeability results indicate that there is no significant difference in perme~~ility, with respect to exceeding the EPA standard of l. 0 x l 0 at 95% standard proctor, in the 0-2 1 , 0-4 1 (2/5&6/79) and 5-611 to 30 11 (12/13/78) surficial soils. All available data indicates a uniform, vertically and horizontally, 0-4 1 clayey layer that will exceed the required permeability. No special blending of clayey materials, other than mixing from excavation procedures will be required. It is realized that these materials were composited or bl ended for laboratory testing; however, the extensive field classification and laboratory testing identified these materials as significantly equivalent with respect to engineering characteristics and permeability. Therefore, it is reiterated that no blending will be required. 3 Comment: Response: There is approximately 12,000 yd. 3 of suitable liner materials (compacted permeability less than 1.0 x 10 CM/SEC) in the surfa3e 0-4 1 layer over the 2.0 acres to be utilized. There is 6,990 yd. in the surface 0-2 1 layer. Therefore the 611 to 3011 soil layer (after stripping of vegetation) will provide the most clayey materials and are of sufficient vol~me to construct the soil liner. There is approximately 25,000 yd. of available suitable liner materials in the area tested. d. Clay Type vs. Plasticity Index and Liquid Limit "One of the most disturbing and troubling apsects of the site selection process was the lack of interest and regard by both the State of North Caro 1 i na and EPA administrators in information concerning the lack of chemical activity and surface area of the type of clay found at the Warren County site. The limited quantities of clay found at the Warren County site appear to be predominately kaolinite clay. As shown in Figure 10, p. 28, Earth Manual (attached), soils with sandy clay, small amounts of clay, and kaolin clay have very low plasticity index and liquid limits, both key parameters as noted by EPA regulations 761.41(b)(l). Kaolin clay is 1:1 type crystal lattice material with very low chemical exchange capacity (CEC) and low surface areas for chemical adsorption of toxic substances ... 11 The 40 CFR regulations for soil characteristics do not include types of clays nor soil types based o~ clay mineralogy. After the vegetation and topsoil cover has been removed and stockpiled the exposed clayey material will be field classified and laboratory test (ASTM D-422 grain size analysis , ASTM D-425 liquid limit, ASTM D-424 plastic limit) will be performed . Prior to excavation of liner materials an area (approximately 150 1 x 150 1 ) immediately adjacent to the site will be stripped to the upper most clayey layer. The liner materials will be excavated and stockpiled in this area. In order to prevent the inclusion of unsuitable soils in the liner materials the stockpile area will be subjected to the same tests as the liner materials. This procedure will also supply additional volume of liner material if needed. Larger areas will be stripped and tested if required. Due to the relatively shallow location of the clayey mater- ials a self-elevating scraper will probably be used for excava- tion. Excavation will be in 4 to 611 increments (established by equipment limits) in successive layers until the required volume is obtained. The materials will be sufficiently blended by the beating action of the elevator paddles. Alterative excavation can be accomplished by stripping of 4 to 611 layers into windrows by motor graders or crawler tractors with pick up and transport to the stockpile area by elevating scrapers or front end loaders. 4 Comment: 2. Groundwater Response: Comment: 3. 11 The impact statement indicates that the base of the 1 eachate collection system will be a minimum of 7' above the water table for the site. The EPA regulations state that there must be a 50' separation; however, this regulation was waived for the Warren County site. Based on the previous discussions regarding the soils at the site, the EPA should not have been allowed to waive this very important regulation. This is especially true since there appears to be a great deal of uncertainty just where the 'mean high water table' for the area should be placed ... 11 A thoroughfare review of the groundwater analysis for the mean high water table in the EIS has been conducted. It has been determined that the analysis was conducted in a satisfactory manner and that none of the available hydrologic data and investigative reports from the area refute the reported water table levels and fluctuations. There is no known hydrologic data available which indicates the mean high water tab 1 e would ever reach the bottom of the landill. However, should on site water monitoring wells indicate that groundwater levels are approaching the bottom of the landfill, a groundwater control drainage system will be installed. With such a system in place, groundwater would be unable to rise to the level of the bottom of the landfill. PCB Landfill Design 11 The conceptual plan, Figure 5, for the landfill has several severe limitations. Perhaps the most critical faults in the design are the absence of a clay liner along the upper side walls and the outsloping of the sidewalls at an angle ratio of 3:1. This design is founded under the assumption that 'water movement through a 1 andfi 11 is always downward, thus the construction of a 1 i ner beneath the system to remove the water before a hydraulic head is allowed to develop would produce a site which would retain waste chemicals'. This assumption is demonstrably false with respect to the unlined, outsloped upper sidewalls, since at these locations the downward movement of water would leach PCB's directly out of the landfill. The other problems with this assumption are that chemicals may escape from the site through the lateral flow of moisture and by diffusion both laterally and downward. A clay liner along the sidewalls of the landfill would reduce the rate of lateral flow of moisture and waste chemical, but this will not stop the escape of chemi ca 1 s from the 1 andfi 11 site by diffusion processes, especially if the clay is kaolinite ... 11 5 Response: Comment: The landfill has been re-designed to include construction of both a clayey liner and artificial liner completely around the PCB soil waste material. Due to the sorpt ion of PCB on activated carbon and soil debris, the vapor pressor and solubility of PCB (see page 6 of EIS) is reduced below a rate that volitization or water migration would present a problem from diffusive movement. The leachate removal system within the landfill would capture any liquid generated for removal and treatment. The leachate detection system would indicate any movement from the landfill. Any detection of PCB movement from the site would require the implementation of remedial action by the State. The State will monitor the site and perform any necessary remedial action. 4. Moisture Control During Construction Response: 11The Environmental Impact Statement is very non-specific on how the construction engineers plan to control rainfall and excess moisture within the site at the time the soil liner is being constructed ... 11 11With an open pit of some five acres in size, rainfall on the soil liner may lead to inadequate compaction that will cause the liner not to meet the regulations. In other words, how do you 'dry out' several feet of clay enriched soil following several days of rainfall, especially in such a large area? It would appear that such problems as moisture control should be addressed more specifically in the impact statement. 11 During the excavation and construction of the outer portion of the di sposa 1 area, the contractor wi 11 be required to continually shape the excavated area such that storm drainage will be directed to sump areas. These areas will be immediately pumped free of water following precipitation. During the construction of the clay liner, the contractor will be required to compact the liner in layers not to exceed 6 inches in depth. The liner area will be continuously shaped to direct storm drainage to sump areas which will be pumped free of water following precipitation. Moisture-density tests will be conducted on each layer prior to placement of subsequent layers. If the clay material contains excessive moisture, the material will be aerated by harrowing, blading and/or scarifying until such time as optium moisture is obtained. Conversely, if the material does not contain sufficient moisture, water will be added by distributors and blended by harrowing, blading and/or scarifying until optimum moisture is present. 6 Comment: It is recognized that precipitation during this type of construction does present problems; however, under proper engineering supervision, these problems will relate to delays but will not affect the final quality of the constructed clay liner. 5. Alternative of Transportation to Existing Chemical Landfill Response: 11The Draft Environmental Impact Statement only mentions in passing the alternative of transportation to an existing chemical waste landfill. This alternative is dismissed on the basis of 'excessive cost' with the estimate that the cost would be $12,000,000. (pp. 25-26). Unfortunately, the State does not disclose its basis for estimating the high cost of disposal at an existing landfill ... 11 An estimate was prepared in the winter of 1980 to determine the cost of removal and hauling the PCB contaminated soil to an existing landfill in Alabama. A summary of the cost breakdown is as follows: PCB Haul to Alabama (1,400 miles roundtrip) Removal from Roadway Shoulder Roadway Shoulder Repair Total $6,400,000 200,000 250,000 $6,850,000 The total cost of $6,850,000 does not include the disposal fee which would be charged by the operator of the Alabama site. We disagree with EPA figure of two cents per pound. We are not aware of all of the factors upon which EPA relied to arrive at the two cents per pound figures contained in their support docu- ments. Factors which would explain the higher figure calculated by the State include (1) Increased fuel costs since EPA estimates were made (2) North Carolina will have to use small (4 yd.) dump trucks due to the pick-up method. Transportation by such trucks is not as cost efficient per pound as larger trucks. In addition, EPA estimates were based on transformers and capacitors which have a higher density and consequently can be transported at a lower cost per pound by taking advantage of maximum weight limits. (3) EPA estimate is based on a 400 miles average trip. The average round trip from the contaminated roads in North Carolina to the Alabama site would be approximately 1400 miles. 7 Comment: 6. Social and Economic Matters Response: 11 Sect i ans IV through VII of the imp act statement fail to address the major impact this landfill will have on the community in which it will be located, the value of the property adjacent to the 1 andfi 11 , and the extent of the injury from groundwater contamination, if and when it occurs. 11 Sections IV through 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 con- taminated s hou 1 ders. Once comp 1 eted the l andf i 11 wi 11 have no physical impact outside of the 142 acres of state owned property. The notoriety associated with the illegal dumping may cause unwarranted fears concerning the disposal site; however, these fears should subside once the site is recognized as being safe and secure. All of th~ existing land uses in the community will be able to continue. Even if there are unwarranted fears concerning the site, the same effect would result from location of the landfill in another area. The low population density, the existing land uses and the size of the buffer zone at the proposed Warren County site minimize the economic and soci a 1 impacts caused by unwarranted and sepculative fears. 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 the landfill is built according to plans and specifications. Every reasonable precaution is being taken in the design of the PCB landfill to prevent discharge to ground or surface water. Some of these precautions are (i) maximum separation between waste material and ground water levels (ii) the safeguard of having a compacted clay liner as well as an artificial liner, and (iii) the i nsta 11 at ion of a 1 eachate co 11 ect ion system both within and outside of the landfill. The landfill is designed to exceed the standards established by EPA for disposal of liquid PCBs. The PCBs in this case are already adsorbed onto soil particles and have been treated with activated carbon to further stabilize the PCB. Due to the extremely low solubility of PCBs, the adsorption of the PCBs onto soil, and the safety features of the landfill design; the possibility of PCBs coming in contact with water and moving through the 1 andfi 11 1 i ners into the groundwater are so remote as to be beyond reasonable speculation. Nonetheless, there will be a monitoring system which will detect any PCBs in the groundwater so as to enable the State to take whatever remedial action is necessary to protect the public. 8 • i . . , COMMENTS OF WARREN COUNTY ON DRAFT ENVIRONMENTAL IMP ACT STATEMENT OF THE STATE OF NOR'l'H CAROLINA OF REMOVAL AND DISPOSAL OF SOILS CONTAMINATED WITH PCB'S ALONG HIGHWAY SHOULDERS IN NORTH CAROLINA DATE: 1/29/80 Warren County offers the following comments on the Draft Environmental Impact Statement rrepared by the State of North Carolina in compliance with the North Carolina F.nvironmental Policy Act .on removal and disposal of soils contaminated ~ith PCB's along highway shoulders in North Carolina: 1. SITE SFLFCTION The technical requirements for a chemical waste land f ill to be used for the storage of PCR's according to EPA re0ulations stated in 40 C.F.R. Sec. 761.4l(b) are as follows: (1) Soils. The landfill site shall be located in thick, relatively i ~pe1·- meable formations such as large-area clay pans. Where this is not possible, the soil shall have a high clay and silt content and the following parameters: (i) In-place soil thickness, 4 feet or coMpactea so il liner thickness, 3 feet; -7 (ii) Permeability (cm/sec), ( 01 X 10 ; (iii) Percent soil passing no. 200 sieve,) 30; (iv) Liquid limit,") 30; (v) Plasticity index, ') 15; (vi) Artificial liner thickness,") 30 Mil. a. Laboratory Procedures a nd Results. The laboratory test .results presented in the Environmental Impact Statement, Appendix B, fail to satisfy the requirements stated in paragraph 716.41(b). ~he test results were too few in number for the critical soil characteristics of permeability, liquid limit and plasticity index. Specifically, there we re - 1 - inadequate sample numbers and replications of samples to deter- mine the mean and standard deviations f or these key soil para- meters both with depth and across the site in general. Anyone familiar with the field of soil science is fully aware that soils are highly variable in their chemical and physica l pro- perties and there is likewise variation associated with t h e procedures selected to estimate the ~agnitude of the v arious soil parameters, even among "standard methods". ".:'here are two pro- cedures listed to measure soil permeability in the 1974 e d ition of Earth Manual - A Water Resources Technic al Publication , 2nd Edition, U.S. Department of Interior. One procedure outlines a "constant head" approach to measure p~rmeability in a compacted soil; another procedure outlines a ''falling head" approach to estimate the permeability of a compacted soil. ~he "co nstant head" approach is by far the more accurate o f the two. The ''fall- ing head" approach requires one to "interpolate'' values from a graph in order to complete the calculations. It has been common experience that such "interpolations" o ften lead to larger e r ror components. The State unfortunately has chosen to use t he "falling head" method for this project. An o ther major factor concerning the test methods used to determine the perme a bility results was the fact that "remolded" samples were used in the "falling head" method. Such "remolding" assured a breakdown in native soil structure, and insured uniformity of moisture through- out the sample and the general creation of artificial conditions within the sample prior to measurement of the permeabil ity. - 2 - Had the sample been compacted as removed from the field, i.e., just as will be the case during actual soil liner construction, there is no doubt but what a different and probably far less acceptable set of values for permeability would have been obtained. There was no ieport of permeability values for undis- turbed samples. It is important to recognize and appreciate the wide variability ~hat is found in soils for these important parameters and to likewise understand that one can often bias the results by the creation of artificial conditions within the samples -even using "standard methods''. In conclusion, the per- meability data presented in the impact statement gives no evidence of the "true" permeability of the soil under actual field com- pacted conditions or the variation which most likely exists with depth or across the site in this critical parameter. b. Soils Map of Site. With the limited soils information prov ided in the impact report, it would be .a physical impossibility to construct a PCD waste themical landfill at the Warren County site and be 100% certain that the soil liner meets the requirements stated in paragraph 761.4l(b). In addition to the lack of definitive test results regarding permeability, no detailed subsurface map .of the various soil layers found at the site has been prepared. This would have involved a systematic physical identification and characterization of the various subsurface horizons to deter- mine which layers meet or exceed the stated requirements by the EPA for liner construction. The limited number of test borings at the site were "bulk sampled" with depth rather than at 6-inch - 3 - intervals. Mechanical analysis of the samples with depth into sand, silt and clay fractions would allow the construction of a detailed subsurface map indentifying those layers meetin g the minimum requirements. Since the soil liner will be con- structed from materials existing at the site, the present impact statements fail to identify the exact soil layers which do meet the requirements. The impact statement suggests t h at the construction engineer will "stockpile" layers of soi l s which visually appear to meet the necessary requirements and that these materials will be blended in a manner to assure the re- quirements are met. No feasible method is available for deter- mining the adequacy of the blending operation. It cannot be accepted that the blended product will be of such a quality as to satisfy the minimum liquid limit and plasticity index speci- fied by the EPA regulations, when the best soils at the site are only marginally within these limits. This procedure may be adequate for building a road or dam, but is much too unsafe or risky for the building of a chemical waste landfill on marginal soils. c. Clay Content and Definitions. The critical features for retaining chemicals •in place would be the clay content in the soils used in the soil liner. Clays are defined by both the International Society of Soil Science and U.S.D.A. classifications as solid particles of soil less than or equal to 0.002 mm in size (Soil Survey Manual, U.S.D.A. Handbook, No. 18,· August 1951, p. 208). The impact statement - 4 - does not identify the quantities of solids below 0.005 wm in size, which are fine silts. Since 761.4l(b) states that "the landfill site shall be located in thick, relatively impermeable formations such as large-area clay pans [and] [w]here this is not possible, the soil shall have high clay and silt con- tents . II . . , it is paramount that these zones of clay enrich- ment be identified prior to construction. The clay content is the controlling factor in several critical soil parameters including liquid limit, plasticity index, chemical exchange capactiy (CEC) and surface area. According to Baver (Soil Physics, Third Edition, John Wiley and Son), "The Atterberg constants are wiBely used in highway construction. The plasticity number or index in e ngineer- ing terms, is employed as an "empirical measure" of the suita- bility of the clay binder material in stabilized soil mixture ". The P.N. (plasticity number) = 0.6C (clay content) -12 for 0.005 mm particles and P.N. = 0.66C -10 for 0.001 mm particles. Thus, with these relationships, this illustrates that the soil liner has to be constructed with soil which always exceeds 45~ content of 0.005 mm material or 38% of 0.001 mm material. From material supplied by the Soil & Material Engineers, Inc., March 5, 1979, report, the soils in the O' -2' ~arginally meet the 0.001 and 0.005 mm soil requirements for plasticity index, but a sizable portion of the O' -4' and O' -6' would not meet the requirements. However, soils, such as that at the Warren - 5 - County site, which contain appreciahle quantities of mica may cause the plasticity index values to be higher than wo1 1ld be expected from the clay contents. These differences a re attributed to a greater surface and increased contact i n the case of plate-shaped particles. Therefore, the presence o f mica in the Warren County soils may have resu lted in the hig he r plasticity index values than should aGtually have been measured based on the clays content at the site. Again, the limited number of samples from the various soil horizons prevent any intelligent assessment of the mean plasticity index values or the variation in plasticity index values at the site . These results would strongly suggest that the amount of soil which would likely meet the requirements for a soil liner would be limited to the upper two feet of the soil. Therefore, the calcu- lations in the amount of soils at the site which would be suitable for liner construction may be grossly overestimated. Without more detailed subsurface mapping and ~echanic al analysis charac- terization, it is difficult to estimate the volume of soil It is of paramount importance that the 0.002 mm size for clays be the accepted standard for judging the a cceptabi l ity of soils for establishment of PCB waste chemical landfills. 3 Soil 0.005 mm in size would have a surface area for 1 cm of 2 soil equal to 6,283.2 cm 2 whereas a sqil 0.002 mm in size would 3 have 15,708 cm surface area within a 1 cm sample or over twice the surface area for retaining the PCB chemical. Likewise, the chemical exchange capacity (CEC) for 0.00 5 mm soil woul d be - 6 - about 11 milliequivalents (M.E.) per 100 gm of soil. The chemi- cal exchange capacity (CEC) for 0.002 mm soii would be about 19 M.E. per 100 gr. or over 1.5 X higher than the 0.005 mro soil (Baver, Soil Physics, cited above). These two important parameters, related to clay content, affect the retention of chemical substances in soils. It is vital that the soil liner be constructed of soils "high in clay" to reduce the risk of chemical migration from the site. The very thin layer of clay enriched soil at the Warren County site would appear in- adequate in quantity to safely construct the soil liner. The reference of "mixing of soils" within the initial O' -5'5 in the March 15, 1979, letter from Soil & Material Engineering, Inc., to Mr. Jerry Perkins appears an oversimplification in their estimate of the volume of "high clay'' soil avail ahle for soil liner construction. d. Clay Type vs. Plasticity Index and Liquid Limit. One of the most disturbing and troubling aspects of the site selection process was the lack of interest and regard by both the State of North Carolina and EPA administrators in information concerning the lack of chemical activity and sur- face area of the type of clay found at the Warren County site. The limited quantities of clay found at the Warren County site appear to be predominately kaolinite clay. As shown in Figure 10, p. 28, Earth Manual (attached), soils with sandy clay, small amounts of clay, and kaolin clay have very low plasticity index and liquid limits, both key paraweters as noted by EPA - 7 - .·, regulations 761.41(b) (1). Kaolin clay is 1:1 type crystal lattice material with very low chemical exchange capacity (CEC) and low surface areas for chemical adsorption of toxic substances. On the other hand, clays with 2:1 type crystal lattice have much larger surface area s, higher chemical exchange capacities, and much higher plasticity index and liquid limits. These clays are commonly referred to as "Montmorillonite" clay or "Bentonite" clay. From Figure 10, "Montmorillonite" clay, identified by nuJY1ber 10, had plasti- city indexes which varied from 55 to 140 and liquid limits which varied from 80 to 165. The "Bentonite", identified by number 13, had plasticity indexes which varied from 250 to 560 and liquid limits which varied from about 300 to 600. On page 35, the impact statement lists the average plasticity index as 9-21 and the liquid limit as 36-71 for the Warren County site, which is identical to line number 4 on Figure 10 listed for "kaolin clay formed from decomposed granite." From Figure 10, it is very evident that the EPA minimum r e - quirements of plasticity index) 15 or liquid limits) 30, and the position of the Warren County soil --i.e., similar to number 4 --should be considered as much too weak for the pro- tection of health from PCB. This is especially true for the soils at the Warren County site since there are a number o f soils in other areas of the state where 2:1 type clays are predominant. From the publication "The Soils of North Carolina'', - 8 - • I ._ • Tech. Bul. No. 155, by W. D. Lee (attached), the key soils which contain 2:1 type clays are Iredell (II.C.l), White Store (V.C.l), and Creedmoor (V.C.3). These soils are located across the Piedmont region of North Carolina and can be found in the areas identified by IM and WC on the attached map obtaine (~ from the above listed publication. Lee estima ted these two soil associations --i.e., IM and WC --covered some 790,000 acres. It would seem logical that the State of North Carolina could have located the 10-15 acres needed for a PCB landfill ~omewhere in this 790,000 acres. From the limited informa tion published regarding th~ sites examined by the State prior to selecting the Warren County site, it is difficult to deter- mine how many, if any, of the alternative sites were located within the areas shown on the attached soils map for North Carolina. Due to the high plasticity indexes and high liquid . limits for the 2:1 type clays, the areas designated on the· map are where the State should have concentrated its initial efforts for locating a landfill site. The site chosen by the State would qualify as one of the least desirable sites from the type and quantity of clay present at that location. From a transportation perspective, spill sites nos. 1, 2, 3, 4, and 5 are near regions designated by the IM and WC soils. From a health safety perspective, it would be far more cesirable to locate one or more landfills for PCB on the IM or WC soils than to select the Warren County site with soils which have clays with marginal plasticity index and liquid limit values. -9 - 2. GROUNDWl'TER The impact statement indicates that the base of the leachate collection system will be a minimum of 7' above the water table for the site. The EPA regulations state that there must be a 50' separation; however, this regulation was waived for the Warren County site. Based on the previous discussions regarding the soils at the site, the EPA should not have been allowed to waive this very i~portant regulation. This is especially true since there appears to be a great deal of uncertainty just where the "mean high water table" for .the area should be placed. As stated in the impact state- ment, the u. S. Geology and Groundwater Re sources show this table to be 47' below the surface, whereas the Soil & Material Engineers, Inc., suggest the static water table is 32' to 37' below the surface, but is estimated to vary 5' to 11'. The Soil & Material Engineers, Inc., assumed their February, 1979, samples were at the top of the range because there had been a 5 percent above normal rainfall for some time preceding the sampling. The initial samples for the site taken in September, 1978, normally the lowest period in the hydrology cycle for North Carolina, show moist soils at some 20' and wet soils a t 25 1 • Thus, the report fails to identify the actual high groundwater limit therefore, and this determination would b t' made after construction begins. Since the plasticity index and liquid limit of the soil is marginal at best, it is totally unsound to have such great uncertainty as to the location of the water table. Also, the EPA regulations direct -10 - ... that there must not be a hydrological connection b etween the landfill and the groundwater. This report fails to "prove" . that no such connection exists at the site. Therefore, to allow the landfill to be constructed 7' more or less ab ove a water table, about which there is great uncertainty as t0 its actual location, is greatly to exaGerbate an already risky operation. 3. PCB LANDFILL DESIGN The conceptual plan, Figure 5, for the landfill has s e v eral severe limitations. Perhaps the most critical faults in the design are the absence of a clay liner along the upper side walls and the outsloping of the sidewalls at an angle ratio of 3:1. This design is founded under the assumption that "water movement through a landfill is always d ownward, thus the construction of a liner beneath the system to remove the water before a hydraulic head is allowed to develop would produce a site which would retain waste chemicals''. This assump tio n is demonstrably false with respect to the unlined, outslop e d upper sidewalls, since at these locations the downward mov r:- ment of water would leach PCB's directly out of the landfill. The other problems with this assumption are that chemicals may escape from the site through the lateral flow of moi s ture and by diffusion both laterally and downward. A clay liner along the sidewalls of the landfill would reduce the rate o f lateral flow of moisture and waste chemical, but this will not stop the escape of chemicals from the landfill site by diffusion processes, especially if the clay is kaolinite. -11 - The diffusion process is governed by the laws of thermo- dynamics; chemicals will move from a zone of high chemical potential to a zone of low chemical potential. The high con- centration of PCB chemicals inside the landfill would be a major factor associated with a high chemical potential zone inside the landfill. The absence of PCB outside the landf ill likewise would cause a zone of low chemical potential. ~he chemicals will move from the inside to the outside of the landfill walls even with zero moisture flow. Once outside , the rate of PCB movement will greatly increase due to rapid moisture flow through the sandy subsoil. Other major routes by which the PCB's can be expected to migrate out of the l~ndfill include volatilization, uptake by soil microorganisms, transport with water, and possibly plant uptake. Contamination of the groundwater will soon follow if the landfill is only 7' above the water table (Marshall, The Physical Chemistry and Mineralogy of Soils, John Wiley and Son, 1964). The primary method for reducing the rate of che~ical diffu- sion will be to provide a thick barrier of clay enriched soil. The type of clay is also of critical importance since the surface areas and chemical exchange capacity (CEC) of the clay determines the adsorptive capacity of the clay. PCB nolecules adsorbed on the clay particles will tend to diffuse at a much slower rate, and 2:1 type clay would be far superior to 1:1 type clay in retaining the PCB molecules. -12 - The conceptual plan, noted in Figure 5 of the impact report, shows no means for moisture to flow from the snnd to the lower leachate collection system. As shown in Appendix B of the report, the native soils at the bottom of the landfill are extremely sandy with less than 20 % clays. Baver (Soil Physics, p. 111) states that soils that contain less than 20 % 0.005 mm sized particles 00 not exhibit plasticity. Thus, these soils below the landfill would be highly permeable and PCB which enters the lower collection system would tend to move downward rather than laterally in the sand layer. There should be a clay soil liner below the lower collection system to assure collection of the leachate. In fact, a double clay liner with a sand layer between the layers for the walls would substantially improve the safety of the landfill design. 4. MOISTURE CONTROL DURING CONSTRUCTION. The Environmental Impact Statement is very non-specific on how the construction engineers plan to control rainfall and excess moisture within the site at the time the soil liner is being constructed. The Soil and Material Engineers, Inc., were very specific that the samples of soil they tested for permeability had to exhibit about 29.6 to 30.7% moisture (optimum moisture contents) in order to compact to 95 % of maximum dry density of 90.2 to 92.0 pounds per cubic foot to -7 meet the ( 1. 0 X 10 cm/sec permeability regulation. These consultants made the further point that even 95% compaction will not meet the regulatory requirement; the suggestion is -13 - made that 100% compaction will have to be achieved in order to assure that the permeability standard will be attained. Since soils are typically 50% solids and 50% air and water , and water does not compact, a very low noisture con t en~ would be necessary to maintain the 100% compaction. As a practical matter, it will be nearly impossible to achieve 100% c ompaction under the field conditions that will be present during c on- struction. With an open pit of some five acres in size, rain- fall on the soil liner may lead to inadequate compaction that will cause the liner not to meet the regulations. In other words, how do you "dry out" several f eet of clay enriched soil following several days of rainfall, especially in such a large area? It would appear that such problems as rooisture control should be addressed more specifically in the impact statement. 5. ALTERNATIVE OF TRANSPORTATION TO EXISTING CHEMICAL LANDFILL. The Draft Environmental Impact Statemen t only ment ions in passing the alternative of transportation to an e xisting chemical waste landfill. This alternative is dismissed on t \e basis of "excessive cost" with the estimate that the cost would be $12,000,000. (pp. 2 5 - 2 6) . Unfortunately, the State does not disclose its basi s for estimating the high cost of disposal at an existing landfill. -14 - From materials prepared by the Environmental Protection Agency and filed with the United States District Court for the Easte rn District of North Carolina, it appears that the cost f o r trans- porting PCB contaminated materials to a chemical waste landfill site (400 mile average trip) wouia amount to two cents per pound. (Support Document for Proposed Regulations, p. 20). Because 40,000 cubic yards or approximately 86,400,000 pounds of con - taminated material are involved here, the e stimated tran s porta- tion cost would be $1,728,000. The closest adequate exist- ing chemical landfill site is near Emeile, Alabama. Th is land- fill has been in operation for some time, so no unique site expenditures would be involved with disposal of the PCB material from North tarolina. According to information obtained from the landfill operator, charges for disposing of the 40,0 00 cubic yards of PCB materials from North Carolina would be abou t $5,184,000. Hence, the total cost of transporting the material to and disposing of it at an existing landfill, apparently would amount to $6,912,000, substantially less than the $12,000,000 estimated by the State. Considering the extremely serious safety problems involved in use of the proposed Warren County site for PCB disposal, as discussed in this comment, the significant, but not extra- ordinarily, greater expense for transporting the PCB materials to an existing landfill site outside North Carolina, is easily justified by the additional protection afforded to the public -15 - health of our citizens. The State has estimated that disposal at the Warren County site would cost $1,580,000. Of this amount, $615,000 represents costs incurred in removal of the material from road shoulders, and would be incurred re- gardless of the disposal method chosen. The remaining $965,000 is specific~lly related to use of the Warren County landfill site. (Draft Environmental Impact Statement, p. 9). Thus, additional costs of $5,947,000 would be incurred i f the material were transported to the disposal site in Alabama. 6. SOCIAL AND ECONOMIC MATTERS. Sections IV through VII of the impact statement fail to address the major impact this landfill will have on the community in which it will be located, the value of the property adjacent to the landfill, and the extent of the injury from groundwater contamination, if and when it occurs. -16 - 2'3 [MffH M1\NUAL n-0 S,\NCY CLIIY, N0fllri(A5HII~ Nf.W IA(Xl(O. 100HCi) s,uv lC(SS, UNSAS·N(OAASKI\, I \6) CLAYEY lO(SS 'UIISIIS, r-{~) UoOLtN Ci.Al, OCCOMPOS(O GAI\NIT[,SINGAP_OA(, H\.0 KAO~l/1 CLIIY. A(SIOUAl S01l,Cllllf0Rt1111 .. 160 ,(i) ~llTY CLAY, SlllT lAK£ Of.Slit S(Ot►Wi!S,IJTAH. H(i) PORTCRVILl( CLAY "cxr11Ns1v(' lCAlC11JM I 1 1 1 1-t-t I I HIO(LLITE l 'CAllfOANIII. 140rl(d) 111\llOY~tTE CLAY, SANOY, rnACE OF tJ 11.Qt;Ti.<OAtlLONITE, CiUIIM, M/11111\NAS tSLANOS. I@ ?\Jl£ LU[ ~(011.l(HVi 1011\TOI.IAC[OUS ANO PVIJICE I, NORTll(RN CIILIFOAltlll. tt-l-~-hh"(--+---+-+-ir--1 X llOI 1@ MONIMOAll.1.0NrTE Cl.AT. SI.IGllTI.Y ORGANIC, ~ I m l .., H GUll~I, MlRIAHAS ISLANDS. --• ~H ~ I 10) ClAY,GLACIAL lllK( 0£POSIT,HOATlf 01\KOTA. . ► 100n1 ~?_) CLIIY,'EXPf.!ISIVt" ISOOIUW. \olONTMOAILLONtTEl : 1 GILi\ RIV(R VIILLt:Y, IIRl?OHA. ~ n@ OlNTONITC,WYOIJING AHO SOUTH ~ I OIIKOTI. ~ 0O1H-1 l ! I l 1 I l 6or I I I ,. I -► •'t -1---i ~4001 tv' I 7"1 40i -1 , I 20~ . ' r--1 i \.:_}; / .r o· . . o ,0 q:, GC V ' -;: "' .. :r, I I;_ 80 !UO 120 ·I. I O U I O L H,4 IT 2O?0""'0.--...L--,4-!-:o~o--'---,,..!.oo 1.IOUIO LIMIT 1'10 1~0 100 200 Figure 10.-Typlcal relotlonsh!ps between the liquid llmlt (LL) ;ind the plasticity Index (Pl) for various soils, 101-0-170. ,. 1n nddition to the conrse--gr:lined groups, the engineering use chart, figure S, indicates the enginecr:ng properties of fine-grnined soil groups. The c!cgree of consistency of n [me-grained cohesive soil can be deter-mined by its relative cons:stcncy, C., which defines the_ water content of the sd in rdation to t!1c liqllid limit and the plastic limit o( the same matc:ia'.. The eq~ntion for rdativc consistency is: C :::: JJL -w_= LL -w r LL-PL Pl . ( 4) !t is usually expressed :ls a percentage. A soil with relative consistency of O i~ :\t its liquid limit, nn<l a soil at lOO percent relative consistency is at its plastic limit. · 11. Porosity nncl Vohl Ibtio.-In_ the ev:lluntion ot a soil, one mny examine it either from the st;rndpoint ~f the nmount 9f solids contnine<l CHAPTER 1-PflOP[rmc.s or-SOILS . . .. , ... -~. in a ziven volume or from the stnndpoint of the rcmnining "°'~ . of the computations in soil mech:mics are simplified by consillet\ • voids rather than the solids. Two expressions, porosity al\d 'YOit~ . arc used to define the void space. The porosity, 11, is deiincd ns the~. expressed as tl percentage, of space i,, the soil m:ISS not occ\lpicd by th; so!ids (volume of voids) with respect to the total volume or the mas~ The void rntio, e. is defined as the ratio of the sp:,cc not occupied by th solid p:uticlcs (volume of voids) to the volume of the solid p:,rticks i a given soil mnss. The following equations express these relationships: V. e n=-=--V\ 1 + e v. " e=-=--v. l -11 where: Y1 = total voh1me, V,= volume of voids, nnd v. = volume of solids. (5 (6 Porosity ru,d void ratio ore mensurcs of the stntc or condition of soil structure. As porosity nnd void r:,tio decrease, the cnsinccrin properties of a given soil become more dependable with decreases i1 permeability and compressibili'.y and :m incrensc in strength. As porosit decreases, and consequently the voic! ratio decreases, it becomes mor difficult to excavate the material. At a given water conten_t it is ni:c.:cssar to incrense comp:ictivc elTort to obtnin :1 c.!ccrl·asc in porosity. J·lowi:vc1 similar properties mny be obtnined in different soils :1t widely differe11 conditions of porosity. Engineering properties of a soil tlo not var directly with its porosity; the relationship is generally compli:x. . 12. Specific Grnvjty.-In the irivestig:ition or a soil, the most ensi! visu;ilized condition involves the volume occupied by soil solids, V,. th volume occupied by soil moisture, V ..,, and the vol'.lme occupied by ai in the soil mass, V •. However, most measurements :ire more rcadi! obt;1incd by weight. To corrcl:llc w-:i~•!ll :-.ml volume, a factor ca!!~·, specific gr:wity is required. Spccilic gravity is l:dinl!d as the ratio betwCC! the unit weight of a sttbst:tncc nm\ the unit weight of wr.ter :H 4° C There arc sev~rnl dilfcrcnt t>·pcs of spcc:fii.: gravity in common use. Thos l!sctl by the Durenu of Reclamation arc: absolute spet:itic g,r:wity, ar-parcnt specific gravity, and several types of bulk specific gr:ivitics. Th•:s values nre obrninl.'.d by the method$ outlined in dcsign,ttion E-10. . The absolute specific gravity is determined by nnnlyzing the nmour. and kind of miner:il constituents present in the so!!, For this tc~t, :1' the coarse gm ins nre pulverized to nt le:lst Ii ncr than the No, '200 siev .; •: . . -. I. ' . -~----,,},.· '' :•: ... ~ -.. . -~, ..... . ··-.;, ··.:_···_:_1r··, I•,• •• I I-I i! n.-. · II t'i':/ I -I . _·J I . . Decomber, i 955 Tech. Bui. No.'115 The Soils o'f North CaroHna Their Formation, Identification and Use William D. Lee Associate Professor of Soils In Charge of Soil Survey North Carol:r.a Agr;cul1uro! Expcri:r;en~ Sta~ion r I' l· .. . . r t: '·; •. I I _.· . . . , . ~ f. _·: ; . ! ,. ~,-\r1 • I (' 1, ,. 'I. I, ''· ', · ll. Cray or light gray (A,), grayish•yellow or grayish•brown (A,, ,) friable sandy loam, or grayish•brown to yellowish•rcd sandy clay loam (A,, B,,) surface soils, occasionally gra,·clly; yellowish-reel upper (B,), and red<lish•brown or. reel lower (B,) cJ.iy subsoil which i~ streaked and splotched with yellow (and sometimes g-r,1y). The suhrnil is very firm when moist, plastic when wet, and very hard when dry. It swells on wetting an(I shrinks antl cracks on dryin~:. has ,1ro11~ nn·diurn ;111i.;ubr blocky structure; and may contain small a111ou11ts or mica a11d mTa\ion;tl sand grains. :\foderatdy deep to dec-p ~nil. Slopes '.!•:!·l',1/. .. 111mil\' :1.1:.:•:;, Rccl•Ydlnw l'odwli,·, i\1•1ili11g (\/a.Ala) l'a11cc (Tlw ,a11dy cL1y l11;1111 ,,11h prnh;tlily ;Ill' no,inl ph;1sl"S. '-cril"s i, c~sentially •·heavy Al'pli11~"'.) C. Soils with }'d/uw sui.J~oils I. Gray (A,.), grayi,h.lJrnwn (A,), and pale yellow (A,) very friable sandy loam \t1rf:1n· ,oils; p;:1,· y«·llow. yellow, 11r l,row11i,h.ycllow ,a11dy clay, clay loam, or clay upl'er ~ub,oil (B,) which is moderately firm to f,nn when moist, sli~htly pL,~tic when wet, and slii;lrtly hard when dry. The lower subsoil (B,) at depths or 2<i•:l·l inches below the soil surface is streaked yellow, lq~lll red, and ,omui111,·s gray, ,a!1dy cl;ty loam which is friable to moderately [irm ,vhcn moi,t, siightly Hi(ky \\':ien wet, and slightly hard when dry. The subsoil has medium moderate \Ub;111i-'.11lar blockv structure, and seldom m11tains an appreciable amount or mica. Deq, to ,moderately deep soil. Slopes l ·8%, mostly under :,% ............................................................... Durham Red·Yel.low Podzolic, Durham (Va.Ga) 2. Gray (A,) to very light gray (A,) sand, loamy sand, or loose sandy loam surface layer which is I to 3 inches thick; light yellowish•brown to pale yellow sand, loamy sand, or loose sandy loam (A,, ll,) which is moderately clerp lO very shallow over partly disintegrated rock. Rock outcrops and boulders arc common in places. Slopes 2•35%, mostly 4•12%. Soil is closely as~ociated with the Durham and Applini; soil series ·····-··········-····· Louisburg Gn·at Soil Group: Lithosol. Lauderdale (Va.Ab) 3. (Soils with yellowish suusoils of clayey Piedmont materials which have an overlay of sandy Coasral Plain materials) Gray or pale hrowni~h·gray sane!, loamy sand (A,) to pale yellow or pale brown loose sandy loa111 (:\,) ~urfa(c soils, orten gravel!)• and frequently 12·2·1 inches thick; yellow, yellow ancl brown, or brown clay, clay loam, silty clay loam, or silly day subsoil (B,). The subsoils may be Alamance, Durham, Granville, J Ickna, or I lermlon soil matcriah. :\focleratrly deep to deep soil. Slope range 2·10%, mostly 3•5% .................................. Cl,esterfie/cl Red•Yellow l'odwlic, Durham (Va.Ga) D. Soil with Yelfow am.I Gray sui.Jmil (Moderately well to somewhat poorly drained) I. Dark gray (/\,) to· gray (A,) rriauk s;indy loam to silt loam surface soils, ffde yellow sandy clay loam upper sul,soil (JI,,,) which is firm when moist, plastic when wt.:t, and Iran! when dry; arul 11H>ttlcd light gray. yellow, and )omclimcs light reclclish•lm,w11 s;1ndy clay to clay lower subsoil (B,) which i,-f1n11 wlH·11 t110:st, pL1\tir wlre11 wet, and hard tn very hard when dry . . ll\lX\cr;itl"ly deep soil. Slnpes (I •. J•;; .. mostly u11dcr 2%. Occupies 11early kvc:1 · ~ili<l11\ as "'llats" or luw sacldks or gt·ntle ,lopes around ,pri11g hc1cls ;ind "-drainagcways ···················r····-··············-··································-·· ................. Colfnx Great Soil Group: Planosol (Argip.in) Colbert (Va.J\Li) · The Colfax series is an intcrgrade with the Reel.Yellow l'oclzolic soils, the Low•Humic Cky soils, and the l'lanosols. It is about midw:,y in dr.1i11;1~e and color belwccn the well clrainecl Applin,i;-:incl Cecil series ;ind th1: J>CJurly drained \Vorsham series. Frequently it recci1·es SL'epagc w;1tl'r fro111 sunound. ing soils. (The Colrax series also inc:l11dcs soils ronnnl in ,in1iL1r po,itirn,, from the Carolina slates, 1l1c Tria.\sic sand,to111·,, and 111ic ;, grwi".) I·:. Soil with n111ch Gray in llrl' ,1d1rnil Fon11l'd of (I) r1:~id11al m;1teri;d in pL1n:, or ('.!) or locd colh1vial•:tll11vi;d lllatnials dl'rin·d rro111 n:,id111n11 of light•<"olon·d g1l<'is,, srlri,t, a11d g1a11i1c; uu:urs as flats or dl'presscd areas in 11pl;111d\, at the base or slopL's, around spring heads, or ;tlo11g streams 11ear the •source; and i\ sornewhat poorly to poorly drai11ed, often receiving-seepage wa1c-r fro111 surro1111di11g-soils. I. Gray (A,) to grayish•brown (A,) loo.se sandy !0;1111 tu frial,le silt loa111 rnr• face soils; mottled gray, pale yellow, and yello\\·ish•lirow11 clay ]0;1111 upper (B,, ,) subsoil which is fir111 when moist, plastic when wet, and hard wlren dry; and light gray to white clay lower (B,) su!J~oil whicl: i~ Ltintly 111ottlcd with yellow, brown, and olive gray and also is pLtstic wl1t:11 wet ;111d hanl when dry. Deep to shallow soil. Slopes 0•9%, mostly 1<1% .............. Jl'ors/t,1,r; Planosol (J\r~ipan), Guthrie (Pa.Ala, total acre-age is s11tall in each state.) (The Wor~ham series also incluc.!es soils formed in sirnilar positions from the Carolina slates, the Triassic sandstones, and mica i;neiss.) JI. Soils Derived from Daicdc Crystalline Hocks (mainly dic,1·itc, ~ublrro, din• base, hornb!cnde) A. Soils with Reel subsoils (B Horizons) I. Dark brown (A,), rcddish•brown (A. or A,) Criaulc cl,1y loam, or brownish. red firm clay (A,, H,,) surface soils; dark red (dusky red or m.iroon red) clay subsoil (B,) which is firm when moist, plastic when wet, ;md hare! when dry. The subsoil has moderate fine to c·oane rnb:i11g11lar blocky strnnurl', and is practically free of mica flakes or sand grain~. Deep soi! . .Slopl', :!•·JO~(,. mostly 1•12% ---·------··-·---···-···-··-······-···················-·•· . I )a11id.w11 Rcd•Yellow Podzolic, Davidson (Va•Ala) (The more_ clayey soils probably arc eroded plt:,ses) 2. (From a mixture of acid and b:1.~ic rocks, hut mostly h~rnblcnde gneiss and hornuknde schist): · Dark 1-:rayish•brown (A,), reddish.brown (A,, ,) friable )0;1t11, s;rndy lo.1m, or n:ddislt.i.Jrown clay loam surface (A •. n,,) soils; red to rcdd is!i.1Jrow;1 cbv loam or clay sui.Jsoil (B,) which is firm when moist, plastic wl1t:11 wet, a11d Iran! when dry. The subsoil has weak fine to llledi11m \1tli;111gular blocky struc:l11re, and contains some mica paniclcs ancl occasion;,! sand gr;1im. :'lfocleratcly deep or deep soil, but there arc many shallow areas. Slo!'L'S ~. •Ju•.~;,. mo~tly 3·12% ........................................ ................. ........... . .. .. 1.loyrl Rc:d•Ycllow Podzolic, Lloyd (\fa.J\la) (The redder lo:ims a11d an c:;1y !uam soils prou;ibly arc crodnl pli;1\es. Lloyd soils are ;1bo11t midway lil'lwt-c11 tl1<· D.1vidso11 a1,d C:l'c ii ,n i,·, i11 texturl', consiste11c;e, structure:, and colr,r.) B. Soil with i'l'lluwi.l!,./{cd or J:cr/di.1!, llrnw11 ~ubsoil J. l);i,k ~:ray or bl()\\"!1 rri:il,lc: lri;in1 I:\), dark 1cdcli,lr.liroll'11 r1i;1!,!v cl.1·.-!(J,,ill I~ 1 I I I I I I i ,! ~ ~ .·• (A• or A,), or tl.1y loam (A,, U,,) surface soils; ycllowish•rcd lo rc<l silty clay or clay upper (H,) subsoil which is firm when moist,· plastic when wet, and hard when dry; variable colored lower (1\a) subsoil, but chicOy strong brown silly clay or clay linely mingled with red, yellow, olive, and gray. 1'his layer is very pla~tic whrn moist and very hart! when dry. The upper· suhsoil has strong angular blocky struc1urc; the lower sul,soil is massive. Moderately deep or deep soil. Slopes 2•20%, mostly '1·12% .... Mulclenburg Red•Yellow Poclmlic, ~·[ecldenburg (Va•Ala, little in Ark) (The more clayey soils probably are eroded phases). C. Soils with }'eliowis!,.flmwn or Olive 11rown subsoils l. Gray (A,) grayish•brown to brown (:\,) loose sandy loam or friable loam, 10 very dark 1-,rray (A., ,) or ycllowish•brown (A,., n,.) lirm clay surface soils; brown, yc.:llowish•l1rown, olivc·brown, or pale olive clay subsoil (ll,) which is very lirrn when moist, very plastic when wet, and very hard when dry. Upon wetting the clay swelh, and upon drying it shrinks and cracks into rough an1-:ular blocks. l\[mlerately deep soil. Slopes 1•12%, mostly under 5% ··•·••······························•·································-·········································· Iredell l'.lanosol (Argipan), lreclell (\la.Ala) (ExceptinJ; a few Katten:d areas, probably all the sanely clay loam to clay soils arc crocled phases.) 2. C.rayi,h•brnwn (A,), lnow11 (A,) or dark •brown (A,, A,) friable loam to brown or yt:ilowish•brow11 friable clay loam (A,) surface soils; brown, ycl· lowi\h•brow11, or olive 1,rown friable loam to linn clay subsoil (B.). Shallow to moclcratcly deep soil. Slopes 1·20%, mostly 3·8% ·········-· ................. Zion Pl:tn;>sol (Arg1pan), Or;1ngc (Va, little in NC) (The clay loam soil.s probably are eroded phases. The soil is less firm ancl plastic than the lrcdell which it closely r"escmblcs.) D. Soil with much Grn)' in the subsoil Forn1l·d (I) of rcsiclu;d 111atcri;1l in place, or (2) of !oral c:olluvial•alluvial materials derived from re,iduum of clark•colorc<l rocks, as diorite, gabbro. Occurs as flats or clcprcssccl areas in uplands; at the base of ~lopes, around \prini.;-ht:;icls, or alonh streams near the source. It is somewhat poorly to poorly dr;1i11t·1I. C:r;,y (A,) fri:ii,ll' loa111, silt loam, or day loam surface soib which ;,rt: 111,,ttlnl ,,.it!, yl·ll<>wi,li-l>rown in t!ie ,11bs11rface (A,,.). The sul,soil is 111111tlcd gr;1y, ,,!in:, and )'l'llowish-l1ruwn clay which is firm ,vhc11 moist, plastic when Wt:1, and h;ml wlll'n dry. Deep 10 shallow soil. Slopes 0-12%, mostly under ·1% ...................................................................................... ...... .. .... /://11.·r/ l'L,nnsol (Ar~ip;1n), lrcclcll (Va, SC, Ga, little in NC)· Ill. Soil,; Derived from J\fixccl Adcl 11nd Bnsic Crystalline Rocks The rock formations arc principally granite and gneiss cut.by dikes or frequent intrusions of basic rocks as dioritc, gabbro, etc. The soils arc much less uniform \han tho,c of Groups I and II. :\. Soib with }'~l/r,;i,i.,lt.Jlrow11, Yellow and JJroum, or Stto11g /lrow11 subsoils I. Gray (A,), ~rayish•urown (A,), and pale yellow (A.) loamy sand to very frj. able sanely loam, or friable sanely clay lo;un (A,, B,,) surface soils; streaked or mottled light gray, yellow, brown, and reddish-brown sanely clay (B,) to rlay (1\,) ,ul,wil \\"hich is ftr111 when moist, plastic when wet, and hard when rlr~:. Th~· ,lii"oil has strong. medium sub;i11g11lar blocky strnnurc. Si.1b;nil c.iilur is very 11on•unirorm. Modcrntcly clccp to deep soil. Slopes l•I:>% mos1ly unclcr 8% -·················-·····-····-················-···································· /1,J,:nn l'lanoml (Argipan), Helena (Va•Ala) (The s;mdy clay loam soils probably arc crmh:d ph:,st~. Soil for111nl) mapped "smooth pha~e \·Vilkcs".) · · . 2. Gray (A,), pale yellow (A,) loose sandy loam or ycllm,·ish•bro,rn s:tndy cla~ loam to lirm clay loam (A., B,,,) surface soils; ycllowish•hrow11 to i>rnwr clay subsoil (R,) which is lirrn when m.oist, Ycry plastic when wet, ;111d li:1rc' when dry. :\[oclcrately deep soil. Slope~ 2-15%, mmtly under. 7','-~ ...... l·.'1101, l'la11osol (Argipan), Helena (Va•Ga) (Tltc sandy clay lo:1m to clay loam s·oils prol,ably ;ire crotlt"d plt;1sc,. Snic· originally called "basic Helena", 3. Gray (A,), pale yellow (t\,) loose sandy loam or hrownish•yl:i!ow s:ind) day loam to clay loam (!\,,, B,.) surface ,oik moulnl, ,trc;,kcd, or nr it:gatcd yellow, brown, an'tl rcddi,h•brown s.111c!y 10;1111, sandy clay lo:1111, 01 clay thin and l'Xtrclllely variable sulisoi\ (11.,) whicit is fri;tlilc to l"ir111 wltl'11 111oist, non•sticky to plastic when wet, ancl loo~e to h:inl wltcn dry. Sh:1!10" to very shallow soil. Slopes ·1-G0%, mostly l().'.!5% .... .. .. . ........ ll'il/;,•, Lithosol, Wilkes (Va-Ala) (In many places all the surface soil apparently h:" l>n·11 rc111mTd Ii, accde1·a1ed erosion: outcrops of rock ;ire co111111on. IV. Soils Derived from "Carolina Slate,:;" The "Carolina Slates" ·are finc•grainccl rocks of grayish c11lor. They occur i11 ; belt cxtcnding'·across the State (Fig. I), and comist of a grl'at sci io (,: l"()\c;111i, and sedimentary formations. Due to change~ brought about !iy prt·,s11n· ar:, folding-of the Earth's crust, some of these lorma1io11\ ha,-c ~bty stn:c111rn ;111< arc Cill!cd slates. All arc practically free o[ mica, ancl arc low in q11:n1z. Tiu soils formed from the slates are characteristically silty thro11gho11t thl'ir profiln A. Soils wi1h Reel subsoils I. C:ray (A,), ~r;1yish•yellow (A,) thin (2··1") triable silt loam or rcddish-ycllo\\ 10 reddish•brown silty clay loam (Ar, B,.) surface soils, oCGbin11;dlv ~r;1vcll: or slaty, but rarely containing-a noticeable a1111rn111 of ,;111d; n:ddi,h-hr11,,·1 10 n·d very smooth silty cby subsoil (ll,) whir!, is finn w!tcn 1111>i.,t. '\Ii, k' 10 sticky and slightly pl:tqir when \\'('t, ;111,l h:,rd wlrl"II d1y. Tl1<· ,111,,.,jl :,:, Wl':tk 111nli11111 •;u\j;1111.;11!:ir l,lorky str11rtun·, ;11:d i, free of "":i«·:d,k 111i,: pa11ic·lcs and sa11d gr;1i11,. ,\lodcr;11cly lk1·1, or il,TI' .,11il. .'il"i"··, '..'.-1',";. mostly 1•17% -··········-·······················••················•························•··. r ;,•nr_:;r:,,i/.1, Rcd•\'cllow l'oclzolic, Cecil (Va.Ga) (The silty clay loam soils probahly arc croclrd ph:1ses) '.!. (Fro111 cl;1rk•colorecl ma,siw: ,·olc:111ic rncks a,,ociatcd with Carolin;i Slatn) Brown (A,), reddish.brown (A, or A.) friable silt loam, or rcddish-brow11 t red silty clay loam (A,, B,.) surface soils: rl'd to dark red s1,10otl1 silty cla subsoil (B,) which is firm when moist, plastic when wet, ;111tl !tard whc11 dr: Tile subsoil has weak medium subang-ular lilocky strurt11rc, .111tl ;q>J>c:,r, ·t be free of mica panillcs and sand gr;1ins. i\lodcr;11t:I)' deep tt> ,1,-ep ,,)i Slopes 2·30%, mostly 4·12~'10 ·-•·········•······•·········· ....•.•...... .....•. /'i,:1/ Red•Ycllow l'odzolic, Davidson (NC, SC, Ga) (The silty clay lo;im ~oils probably arc erodl'll pha,c5) II. Soil with Ycl/01uislr•Bro1t•11 or Reddisl,.l/ror,,11 511bsoil I. l);1rk brown (:\,), bro\\'11 (.-\,or,\,) friabk ~ilt lo;1111, ur yl'l!.0wi,:1!,1111,11 ,iii ,# ~-clay loam (A., B,.) surface soils; yellowish.brown, reddish•brown, or brown•. ish•rcd silty clay upper (U,) subsoil which is firm when moist, plastic when wet, and hard when dry. The lower (lla) subsoil is streaked yellow, brown, and rcddish•ycllow silty clay loam. The subsoil generally has strong medium .subangular blocky structure, allhough in some soils the material is nearly massive. There are few or no mica particles and saml grains. l\Iodcratcly deep soil. Slopes J.JO%, mostly 2•7% ·······························-····················· F.fland Red•Ycllow Podzolic, :\[ccklcnl,urg (NC, SC, Ga) (The silty clay loam soils prouably arc eroded phases) C. Soil with Yellowish•Rcd or Red am/ Yellow subsoil I. Gray (A,), grayish•brow11 or g:rayish•ycllow (A,) friable silt loam or yellowish• brown silly clay loam (A.,, n,.) surf.tee soils, sometimes gravelly or slaty, hut rarely containing a 1101iccablc quantity of ~a11cl; rccldisli•ydlow (B,), yellow ancl red, or n:ddi~h•ycllow (ll,) very s111ootl1 s.ilty clay lo:1m or silty clay subsoil whic!1 is firm when· moist, "slick" to sticky ancl slibhtly pt1stic when wc1, and hard whc11 dry. The subsoil has moderate medium sub· angular blocky structun:, anil is practically free of mica particles ancl sand grains. Moclcrately deep to deep soil. Slopes 3•50%, 1,ut mostly :.,.JS% ·--••······-····· .·•····-······· ··············-········ ------··--·----·---·············-····-···· I-I ernd on Red.Yellow l'oclzolic, Appli11g (V:i•Ga) (The.silty clay lo:1111 soils probably.arc eroded phases) D. Soil with Ycl/orl' subsoil I. Gray (A,),. p;ilc .yellow (A,) friable and smooth silt loam surf:ice soils, often ;..:ravclly or sbty, and occasionally containing a small amount of fine sand; pale yellow (H,); yellow or urownish• yellow (B,) silt loam to silty clay loam ,11bsoil which is friable and very smooth when moist, "slick." lo sticky when wet, and slightly hard whcu dry. The subsoil has weak plate•like to fine ansul:ir blocky structure. Frequently there are fragments of slate throughout the profile. :vioderatcly deep lo shallow soil. Slopes 1•15%, mostly under 5% ··-··-·······-·-··-····-···--··-····-···-··-··--··-··························•········. Alamance Red·Yellow Po<lzolic, Durham (Va•Ga) E. Soil with Yellow, Rro111n, and Gray in the subsoil I. Gray (A,), pale yellow (A,) smooth silt loam surface -soils; pale yellow to yellow smooth silty clay loam upper (ll,) subsoil; yellowish•brown, pah: yc1low and brown, or brown streaked with gray silty clay lower (ll,) sub• soil, which is very firm when moist, very plastic when we.t, ancl very hard when dry. The lower subsoil swells on wetting and shrinks 011 clrying, crack· ing into irrq.;ular blocks. Moderately deep to shallow ~oil. Slopes 1·8%, mostly unllcr 1°/c, ................................................................................ Orange Planosol (Ari;ipan), Orange (Va•Ga) (Appears to be very erodible on slopes auove !!%) F. Shallow soil with Jlruwrz, Yel/0111isl,.Jlro11111, or Reddish•Yellow subsoil I. Brownish•gray (A,), pale yellow (A,), or brown (A,, ll,.) friable silt lo;un surface soils, usually containing fragments o[ slate; brown, yellowish•brown, rcddish•ycllow, or pale yellow friable silt loam to ~lightly plastic silty d;1y thin subsoil (H,) which contains some to many slate fragments. Shallow tu \•cry shallow $Oil. Slopes ·1··10%, mostly G•l5% ................................... Gu/d1l011 •-...., . Lithosol, Louisa (V,1•G.1) 1.~-lM>il with )Tilow and ~ray in s111J~uil, sec lMJ.;C GS -~,,i\ with 11111rh Gray i11 the sul,mil. ~cc p.i,.;e li\J ,, .......... ..... Colfax .... IVonham Y. Soils Derived from Sandstones and Shales of the Trh111~ic I•'ormntiun A. Soils with Red subsoils I. Gray (A,), pale yellow (A,) friable s.,ndy loam or silt lo:im, or rcd<li\h•brown friable to firm clay loam (A., B,P) 1urfacc: soils; red or .rccldish•brown \11100111 clay or silty clay subsoil (Il,) which is firm when moist, plastic whrn ,,-ct, ancl hard when dry. The subsoil h:is moderate 111edi11111 s11lia11;.;11br blnckv · ·HrucLUrc, and may contain small amounts of ~;111d grains and mic.i Jl;1kl',. J\focleratcly deep to deep soil. Slopes 2·2·1%, mo~tly 3·10% ..... ll',11/n/,mo Rccl•Ycllow Poclzolic, Cecil (Va•NC) (The clay loam soils probably ar.: eroded phase,) 2. llrownislq~ray (A,), brown (A,) [riablc fine sanely loa111 or \ilt lo,1111, or dark browni~h•rccl friable lo firm silty clay loam (,\,,, B,,,j surf.ice soils; d:1rk rnl (dmky reel or purplish-red) silty clay or clay .,1ill'ni! (11,) whirh is fir111 wlil'11 moist, plastic when wet, and hard wl,cn dry. Tlil' det'J' ,ulimil h;1s 11111tkr.1tt· fine subang-ular blocky structure, and u\ll:dlv i~ fn-c of ,:111d gr:1i11·, and mica flakes. Slopes 2•18%, mostly 3.5~,0 •......•............. ~.. ......•. .. .. ... /111,/:s Rccl•Ycllow l'oclmlic, Hucks (Pa, NJ, :\Id, Va; n:r\' little in :".C) (The ,il1y day lo;i111 soils probably arc eroclcd ph:,se,) 3. Brownish•gray (A,), brown (A,) friable silt loalll, or dark brownish•rcd fri• : ilblc to firm silty clay loam (:\,., ll,,) \urfacc ,oil~: dark red (purplish•n·d) silty clay or clay subsoil (B,) which is usually sh;,llow or very shall<lll'. Slol''"' 3·30%, mostly 6•18% ··-·-················································· ....................... ,,,.,,,, Lithosol, Penn (Pa, NJ, l\-Id, Va; little i.n ~C) (The silty clay lo:1111 soils probably arc eroded ii.:1:1scs) B. Soil with Yel/0111isl,.Jled or J/row11ish•Red ~uli,oil I. Grar, tight gray (A,), grayish.yellow, or ~rayi,Ji.[1ro1n1 (,\,) fri;1bh: ~and)' loam, or l>rownish•yellow sandy clay lo;1m (,\,,, l\,,,) rnrf;in: soil,: i1rnw11i,Ji. yellow (n1), yellowish•recl, rcdclish•brown, or ,tre;1ketl yellow a11d l,row11ish. red (H,) clay loam or clay subsoil which is fin11 1,·he11 moist, pl:istic ,,·hen wet, and hard when dry. The subsoil has moderate fine to medium ,uh• angular blocky structure, and may contain small .111101111\s of sa11d a11d mica flakes. Moderately deep soil. Slopes 2•~0%, mostly j.8% ... . . .. ,if n?<><i1111 Red•Ycllow Podzolic, Appling (Va.NC) (The s;;.ndy clay loam soils prol>al,ly arc eroded phases) C. Soils with Red to Reddish•Gray and Yellow (often l'arico/ored) ~ubsoils I. Gray (A,). brownish•gray or pale yellow (,\) frial,le silt loam I•) s;111dy loam s11rf:1cc .,,,ils, nr rcddish•brow11 10 rt·ddi,h•gr:,v I in11 clay loalll to pla\• tic day (,\,, B,,.) surface soib; v;1ricolored \tdhoil (I\,) which is domi11;111Ll)' n:cldish•gray or weak reel intcrminglcd "'ith sh:.t!cs of gray a11cl ~11111cti111e, yellow. The rnbsoil is clay or silty cl:iy which is very firm when moi,t. very plastic whrn wet, and very hard when dry. lt swells 011 weL1i11g, ;111d ~hrinks and cracks 011 dryin~ into strong medium a11gnlar l,lorky ,trntllll"l' part irks. The rcddcr•colorecl subsoils arc tougher ,,·hl·n 111ois1, more pl:isl ic when wet, and harder when dry than those with much ydlo11· and g1;1\'. :-.roclcr:11dy derp soil. Slopes :!·30<;{ .. mostly 3.1 :!~; ................ : l'/,i1,· .\/CJ1r l'bnmol (Argipan). White Store (NC, Va) (The cl;iy loam to cby soils probably arc eroded pl1;1Sn, a11d the ,oil ;11'1w:11s to he \'cry erodible) 2. I.ip,lit g1ay (A,), ydlowish•gray or yellcl\\"i)h•lir111,·11 (.-\,) frial1lc ,.,11cly 111;:111, or tnodnatcly firm reclcli,h hrow11 ~;rnd)' c-Lir i11:1111 t•r ,:l:i,• (.-\, .. 11.,,,) \11rf:1rl' 73 I • soils varicolored but mostly motllcd ttddith-gray, reddish-brown, and light gray clay or silty clay thin subsoil (B,) which is very firm when moist, ,•cry plastic when wet, and very hard when dry. Shallow to very shallow soil. Slopes 3-!15%, mostly 5-18% ·······-~---··-·-····-······-······-·········· Pir,/uto11 Lithosol, Litz (NC, Va) (The clay loam or clay soils probably arc eroded phases) 5. Cray to lii;ht gr,ty (A,), brownish•gray (A,), yellowish-brown (A1) loamy sand to loose sanely loam, oryellowish.1,rown sandy clay loam (A,, B,,) sur-• fare soils ortcn I :!·20 inches thick; light yellowish-brown to yellow friable samly clay loalu uppa ~11bsoil (B,), ·1-8 ind1es thick; yellow or yellowish-brown sanely clay middle suhsoil (B,), 8•18 inches thick, which is rriablc 1d1c11 moist, slightly plastic when wet, and hard when dry; and highly var-ie~atcd or mottled rcdclish-brow11, rcdclish•gray, ydlow, and gray clay lower sub5oil (B,) which is very firm when moist, very plastic when wet, and very hard wheu dry. The B, layer has weak medium subangular blocky structure; it swells 011 wcttin!-; and shri11ks ;ill(I cracks on dryiug. Moderately deep to deep soil. S!upcs 2-18''1,,, moMly 3·8% ..............................•............... Crutf111oor l'l;inosol (Fragipan),.Conway (Va-NC} (The sandy clay loam soih probably are eroded phases. The Creedmoor is essc11t.ially midway bctwt·t·11 llic White Store and the Granville series.) D. Soil with Yellow or Rrownisl,.}'ellow subsoil I. Cray loamy sand (A,). ycllowi~h•gr;ty (A,), pale yellow (A,) very friable sanely loam surface soil5; yellow to brownish-yellow sandy clay subsoil (B,) which is motlcratcly fir111 when moist, slightly plastic when wet, and h;ircl wilrn dry. The subsoil h;,s 1,·cak. crumb to weak fine mbangular blocky I ~tructurc, a ~rill)' feel, and sometimes contains small amounts of mica. Modcr:ttcly deep to deep soil. Slopes 2·12%, mostly under 6% ...... Granville Red-Yellow Pod,olic, Durham (Va, NC) E. · Soil with Yellowislt-Broc,111 or Urnwri s1.1bsoil I. Pak brown (A,), lirrnvni\li-ycllow (A,,•) loam surface soil; yellow, ycllowi,h-hrown, or brown silty day loam subsoil (H,) which is firm when moist, slightly plasti,: when wet, and sli~lnly hare! when clry. Modnatcly deep soil. Slopes 2•1:i%, mostly under I\% ....................................................... f.,11wl,1k Red·Ycllow l'odmlic, Lamd;de (l'a, NJ, Md, Va, very liuk ir1 NC) F. Soil~ wi1h w111c lO 1111rd1 Croy in 1hc subsoils I. Crav (A,), 1-;rayish•IJ1mrn (/\,) friable silt lo;im surfact' soil, which usually , 0111ai11, ~ome sh;,lc f1.1g11H·1Jls; gr;,y, 111<lltled with pall' yellow a11d p;1h: hrown, silly rlay loa111 lo ,Lry subsoil (II,) wliich generally has mmc to 111ud1 ,lr:rly 111;1tl'rial. Tire s11b,oil is firm when moist, plastic when wet, and h;ird wh,·11 dry. :'\lrnlcr'atcly 1kcp to shallow soil. Slopes 3-35%, mostly under I~';~, --·· Planosol (Fragip:111), Lehigh (l'a, NJ, Md, Va, very little in NC) ::!. Sec page G~ for .......... . 3. Sec pa;.;e fiH ror VI. Soils DeriH'cl from Quartz :\lica Schist and Related Rocks A. Soils wirh /{1'.1/ ~11bsoil-i l,cl,i~I, Worslta111 Colfax I. Gray (A,), brow11ish•~ray (A,) rriable fine sandy loam, or reddish-brown rrialile clay loam (,\., B,,.) ~urface soils containing considerable mica; reel-, tlish•brown tu reel friable tu rnodcratcly firm micaceous clay subsoil (13,) whirlr has a smooll1, :dmO\t grl':"y feel. \Viren dry the subsoil is h;ird, wht·n ,._. wet it is plastic. It has weakly developed medium platy structure. Modcr.itcly' deep or deep soil. Slopes 4-30%, mostly 6-15% ····--····-············-·· Statesville• Reel-Yellow Pod10lic, Cecil (Va, NC, SC) c" (The redder loam and all clay loam soils probably arc eroded phases, ancr• the soil appears to be very erodible. The series is essentially a "very mica-ceous Cecil".) 2. Cray (A,), grayish-brown (A,) friable sanely loam, or reddish-brown fri;1ble cl:ty loam (1\,. n,,,) surface soils containing much mica; yellowish-red, brownish.red, or reel frial,lc micaeeom clay loam ml,soil (B,), which is usually shallow or \'Cry slta llow. :slop<'s 3-:Fi1\,. 1:10.~1 ly 7• 18•_'.{, ....... : /,011i.ra Lic!roso!, Loui~a (Va.Ala) . (The clay loam soils probahl)' arc croclcd phases, bcc;1usc the soil appc:1rs to be very erodible) 3. Grayish-brown loamy sand (A,), yellowish-brown to light rcclcli~h•bruwn sar;dy loam (A,), or reddish.brown friable sar"ly clay loa111 (A., B,.) surface soils containing-flat CJllartz mica schist fra.~11H:11ts and some mica fl:1kes; reddish.brown tu lirow11 cl.ry lo:irn to clay tirr11 11p11LT (II,) sulisoil and reddish-brown to light red, often tinged with reddish-gray cby loam or clay lower (B,) subsoil which is friable to fir111 wlil'n rnuist and sli.~htly hard when dry. The subsoil has weak medium suliangular blocky to very weak platy structure, and contains much mica and flat angular fragments of schist. :'\-!oclcratcly deep to somewhat shallow soil. Slope., 2.,J0%, 111osrly (i.J_rj'X, Red-Yellow Pnclzolic, Cecil (Va-,\la) l\/,uliso11 (The sandy clay loan1 soils probabiy arc eroded p!1ase~) B. Soil with Yellowish-Red or Light Red suhsoi! :. Cr;1y (A,), grayish-brown (:\,), gr;1yi~h.ycllow (A,) fri:,ble s:1ndy loam sur. face soils co11tai11i11g-flat quanz 111ica schist fr.1.t:r11cnts arid some mira flak<'s; reddish.yellow clay loam upper (ll,) subsoil, strong brown clay loam or clay middle (fi,) subsoil, and yellowish•rccl tu light red clay loam or clay lower (H,) sub.5oiL The entire subsoil is friable to /inn when moist, sli~htly plaMic: when wet, ancl hard when dry. It has very we:1k pla1y structure. Throughout the profile the contc11t of 111ica aud fl:1t•:111~11lar fr;1g111cnts or schi,t \';1rics fro111 some to very much. Moderately deep tn .\Olllt'wl1a1 .,h;rllow soil. Slopes :!•20'¼,, 111ostly 5-l 2% ....................................... ............ ........ ...... Grou,:r Rcd•YclJow Podzolic, Appling (Va.Ga) C. Soil with Ydlowi.1/,.Jlrow" or Uedt/i.1/,.IJro1,•11 subsoil I. l\row11 (A,), brnwnish•ycllow (A,) friable loam, or yellowish.brown to red-dish•brown clay loam (A,., B,,.) smLrce soils; yl'llowi.~h•brown to rl'ddi~h-lnow11 day subsoil (JI,) wlrich is nrodcratcly lirrn when 111oisc, slightly pl;"tic when wet, ancl hard when dry. The sub,oi] has weak moderate s11b;111_~11lar to a11gubr blocky structure. Small rni,a 11:tkcs arc prl'\e11t in 11ws1 lnca1i,>11s, and in some pl:rccs numerous shale and st:ltist fr;igmcnts arc pre;c11l 011 tlrC' surface and throughout tire profile. l\rodcr;ttcly del'p soil. Slopes ·1-:i0'ii,, mostly 8·20% ·-·-······-·-······················-····--·----• ............................................... S11ny Recl-Yclluw l'odmlic, Cecil (Va, NC) (The day loam soils prol>ably arc crockd phases. This series i_,; ~bout mid-way between the Cecil series ant: lire l'ortl·r~ ,nic,) D. Soil with some Grny in the subsoil, sec p:1gc 6," ...................................... L'u/fax E. Soil with m11t:l1 Gray in the s11liv>il, sc·e p;1'.;e fj<). .................... ll'or.<11,1111 75 .1 < •