NCD980602163_19820401_Warren County PCB Landfill_SERB C_Application for Cooperartive Agreement Between the US-EPA and the State of NC for Ocnstruction of PCB Landfill and Cleanup of Contaminated Soil-OCR

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APPLICATION FOR
Cooperative Agreement Betv,een
The U.S. Environrnehtal Protection ,t\gency
And The State Of i'Jorth Carolina
For
The Construction Of PCB Landfill
And The Clean-Up Of
· PCB Contaminated Soil
. Along N.C. Roadways
· Using CERCLA Or 'Super Funds'
April 1982
APPLICATION FOR
COOPERATIVE AGREE MENT BETWEEN
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
AND THE STATE OF NORTH CA ROLINA
FOR
THF. CONSTRUCTION OF PCB LANDFILL
& THE CLEAN UP OF PCB CONTAMINATED SOIL
ALONG N. C. ROADWAYS
USING CERCLA OR "SUPER FUNDS "
April 1982
SECRETARY N. C. DEPARTMENT
OF CRIME CONTROL &
PUBLIC SAFETY
Heman Clark
ASSISTANT SECRETARY
David Kelly
Part I.
Part I I.
Part III.
Table of Contents
GENERAL ADMINISTRATIVE INFORMATION
A. Purpose of Project 1
B. Lead Agency 2
C. Summary of Budget Information 3
D. State Assurances 4
E. Contract Services 7
F. EPA Forms & Project Approval Information 8
STATEMENT OF WORK PROGRAM
A. Project Description
B. Backqround Information
C. Remedial Resoonse Plan
D. Remedial Resoonse Alternatives
E. Preferred Alternative
F. Project Management System
G. \fork Pl an
H. Project Safety Plan
I. Project Contingency Plan
J. Community Relations Plan
APPENDIX
16
26
32
39
41
44
46
57
60
61
,
PART I
GENERAL ADMINISTRATIVE INFORMATION
A. Purpose of Project
The State of North Carolina proposes to remove and dispose of
approximately 40,000 cubic yards of PCB (polychlorinated biphenyl) con-
taminated soil. The PCB contaminated soil is the result of deliberate
discharges from a passing truck of approximately 30,000 -35,000 gallons
of liquid waste material on to the roadway shoulders of North Carolina's
highways. The discharge of this industrial waste material containing
PCBs have been identified along approximately 210 shoulder miles of
roadways located in fourteen central and eastern piedmont counties of
the State.
The proposed action involves the mechanical removal of the PCB con-
taminated soil from the roadway shoulders and transportation of the PCB
contaminated soil to a disposal site for permanent storage. The disposal
site for containment of the PCB contaminated soil will be constructed
according to Environmental Protection Agency rules and regulations
governing the removal and disposal of PCBs. The disposal site is located
in Warren County approximately four miles south of Warrenton.
B. Lead Agency
The State has requested and EPA has agreed that the lead project
role should be taken by the State.
By the transmittal letter Governor James B. Hunt has designated the
N.C. Department of Crime Control and Public Safety as lead agency for
this project and has granted that agency authority to sign a Cooperative
Agreement with EPA.
The project officer for N.C. is:
WILLIAM W. PHILLIPS~
Special Assistant to the Secretary
N.C. Department of Crime Control & Public Safety
In accordance with PL 96-510 and by Executive order No. 12316, dated
August 16, 1981, the project officer for the U.S. Environmental Agency
is:
2
C. Summary of Budget Information
The estimated costs for the total remedial project is estimated to
be:
-Community Relations $ 20,700
-Landfill Construction & Engineering 450,000
-Sampling and Analysis (Pre and Post Pickup) 10,000
-Landfill Road Construction, Removal, l ,243 ,000
Transportation, and Deposition of Soil
-Shoulder Reconstruction 800,000
-Landfill Monitoring 20,000
-State l'roject Cost ttieu1 , ed bett~ee!'I .l82 ,693-
Jai::i-uary 1, 1978 and De ce11,ber 11 , t~80
-EPA SMRC-( 90~) 2,543,700
S~)
TiffAL ces-=r
t< £V t )!'O p l:tL
C ~NV tEYLS',4, f7G,J
3
'
ggz,633-
$2,826,333
f I tr/ r 2-Pl-1 uNtt
Gnwa;a.J {-(, T,'1 T ~m , ~
B ,_ u.., pH l LLI t°S
D. State Assurance
l. Cost Sharing
In the transmittal letter Governor James B. Hunt, Jr. has:
expressed his interest to enter into a cooperative agreement with EPA,
provided assurance that the state will share 10% of the project costs,
that a PCB landfill is ava i lable, and that the state will provide for
landfill monitoring and ma i ntenance requirements. North Carolina will
share 10% of project costs through project expenses incurred during
period January l, 1978 and December 11, 1980. Based on audit,if
additional match is required,the state will fulfill its responsibility.
2. Off-Site Treatment, Storage or Disposal Facility
During the fall of 1978, the State investigated ninety (90)
locations for a possible disposal site to accept the PCB contaminated
soil. A site in Warren County, North Carolina, was chosen by the State
as the best location for the PCB disposal. This site was purchased in
September 1979. North Carolina submitted an application to the Regional
Administrator for approval of the landfill under the Toxic Substances
Control Act (TSCA), 15 U.S.C. 2601, et seq. on December 14, 1981, EPA
approved the design of the Warren County site.
The consultant engineering firm of SVERDRUP & PARCEL has designed
the PCB landfill and will supervise construction. The Department of
Human Resources, Solid & Hazardous Waste Management Branch will insure
compliance with EPA TSCA approval conditions.
All PCB contami nated soil will be disposed of in compliance with
the EPA TSCA approval condi tions. Bids for construction of the landfill
have been received and a contract will be signed with the low bidder,
if bids have not expired, following the signing of the State/EPA Coopera-
tive Agreement and receipt of a letter of credit from EPA.
3. Operation and Maintenance
Contaminated PCB soil will be removed from the 210 miles of road-
way and hauled to the PCB l andfill disposal site. Sampling will be done
to determine the beginning and end of roadway excavation strips and adequate
post sampling to insure that PCB has been removed down to 49 parts per
million. No further monitoring activities are proposed on these roadway
cuts.
The PCB landfill wi ll be monitored by the Department of Human
Resources, Solid & Hazardous Waste Management Branch to insure compliance
with TSCA approval conditions. Monitoring activities will be covered by
existing state appropriations made to the Solid & Hazardous Waste Manage-
ment Branch. Site maintenance problems will be corrected by using state
funds and state personnel.
4
JAMES 8 . HUNT, JR.
GOVERNOR
Dear Mr. Jeter:
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27611
April 23, 1982
Attached is North Carolina's application for a cooperative agreement
requesting CERCLA or "Super Fund" assistance to clean up the 210-mile
PCB spil 1.
This application has been prepared by the North Carolina Departments
of Crime Control and Public Safety, Natural Resources and Community
Development, Transportation, and Human Resources. I have designated
the Department of Crime Control and Public Safety as the lead agency
for this project and Mr. Will iam W. Phillips, Jr., Special Assistant
to the Secretary of that Depa rtment, as the project officer.
Our state stands ready to pro vide its 10% share of the costs of clean-up
and has already purchased property to construct, monitor, and maintain
a suitable landfill under TSCA approval conditions.
We appreciate the excellent cooperation your staff has provi ded in the
past and look forward to a continuing close working relationship as the
program develops.
My warmest personal regards.
Mr. Charles Jeter
Regional Administrator
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Attachment
5
• f
A$SURANCES
The Applicant hereby agrees and certifies that he will comply with the regulations, policies, guidelines, and requirements
including 0MB Circular No. A-95, A-102 and A-87, as they ralate to the application, acceptance and use of Federal
funds for this Federally assisted projec!.. Also the Applicant agrees and certifies with respect to the grar:it that:
1. It possesses legal authority to apply for the grant; that
a resolution, motion or similar action has been duly
adopted or passed as an official act of the applicant's
governing body. authorizing the filing of the applica-
tion, including ·au understandings and assurances
contain,!d therein, and directing ar.d authorizing !he
person idantilied as tha official represc:ntali•,e of the
applicant to act in connection with lhe application and
to provide such additional information as may be
required.
2. II will comply with Tille VI of the Civil Rights Act of 1964
(P.L 88-352) and in accordance with Tille VI of that
· Act, no person in the United States shall, on the ground
of race, color. or nation origin, be excluded from
participation in, be denied the benefits of, or be
otherwise subjected to discrimination under any pro-
gram or activity for which the applicant receives
Federal financial assistance and will immediately take
any measures necessary to effectuate this agreement.
. 3.
,·
i It will comply with Title VI of the Civil Rights Act ol 1964
(42 USC 2000d) prohibiting employment discrimina-
tion where (1) the primary source of a grant is to
provide employment or (2) discriminatory employment
practices will resull in unequ~I treatment of persons
.-~ who are or should be benefiting from the grant-aided
activity.
4. It will comply with requirements of the provisions of the
Uniform Relocation Assistance and Real Property
Acquisitions Act of 1970 (P.L 91-646) which provides
for fair and equitable treatment of persons displaced
as a result of Federal and federally assisted programs.
5. It will comply with the provisions of the Hatch Act which
limit the political activity of employees.
6. It will comply with lhe minimum wage and maximum
hours provisions of the Federal Fair labor Standards
Act. as they apply to employees of institutions of higher
education, hospitals. other non-profit organizations.
and to employees of State and local governments who
are not employed in integral operations in areas of
traditional governmental functions.
7. It will establish safeguards to prohibit employees from
using their positions for a purpose that i!: or gi•1es the
appearance of being motivated by a desire for p:ivate
gain for themselves or others. particularly those with
whom they have family, business. or other lies.
E?A Fo,m 5700.33 (R .... 10-79)
6
8. It will give !he granter agency and the Comptroller
General through any authorized representative thE)
access lo and lhe right to examine all records, books,
papers. or documents related to the grant
9. It will comply wilh all requirements imposed by the ,
Federal ~ra.:tor agency concerning special require-
ments of law, program requirements. and other ad-
ministrative requirements. .,
10. It will insure that the facilities under its ownership,
lease or supervision which shall be ulilized in the
accomplishment of the project are not listed on the
Environmental Protection Agency's (EPA) list or Violat-
ing Facilities and that it will notify the Federal grantor
agency of the receipt of any communication from the
Director of the EPA O/fice of Federal Activities indicat-
ing that a facility to be used in the project is under
consideration for !isling by the EPA.
. t 1. It will comply with the flood insurance purchase · .•..
requirements of Section 102(a) of the Flood Disaster
. Protection Act of 1973, Public Law 93-234, 87 StaL
975, approved December 31, 1976. Section 102(a}
requires, on and after March 2, 1975, the purchase of
flood insurance in communities where such insurance
is available as a condition for the receipt of any Federal
financial assistance for construction or acquisition
purposes fonlse in any area that has been identiiied
by the Secretary of the Department of Housing and
Urban Development as an area having special flood
,hazards. -
12. It will comply with all applicable requirements of
Section 13 of the Clean Water Act Am~ndm~nts of
1972 (P,L. 92-500). if the grant is awarded 1.:nder any
grant authority of that Act, which provides Iha! no
person in the United Slates shall, on the ground of sex
be excluded from participation in. be denied the
benefits of, or ')e otherwi:;,~ subject to discrimina!io.,
under any p~ogram or zis:;,,ity under the . 1id Cl2an
Water Act Amendments ior which the applicant re-
ceives financial assistance and will take all necessary
measures to effectuate this agreement.
PAGE 12 OF 12
E. Contract Services
The State plans to use the EPA contractor to prepare the corrnnunity
relations plan. The State will let contracts for the construction of
the landfill, and technical assistance which may be required.
State personnel will manage the project, do pre and post collection
of samples, construct the landfill access road, remove contaminated
soil, do conmunity relations activities, transport and dispose of the
contaminated soil.
The State assures EPA that contracts will contain the necessary
safety plan to protect the health and safety of personnel involved as
well as the public. In addition, the state of North Carolina will con-
duct quality assurance evaluations to insure compliance with the safety
procedures provisions of the contract and carry out similar safety
requirements for all state personnel.
Contract Reporting Requirements
The actual removal of the contaminated soil is expected to be com-
pleted within six weeks of landfill construction. Because of the short
time involved, a report will be submitted by the State Project Officer
to the EPA Project Officer at the close of the first quarter. A final
report will be submitted within sixty days after close out of the land-
fill.
The initial progress report will contain as a minimum, the following:
Maps and drawings showing areas picked up
Sampling results
Work remaining to be accomplished
The final report will summarize the significant facets of the work
activity and, as a minimum will address:
Amount of material removal from roadways (cubic yds.)
Results of monitoring
Final sampling results
7
F. EPA Fonns & Project Approval Information
The N.C. State Clearinghouse is located in the Department of
Administration. Project reviews are conducted by the Clearinghouse
in accordance with 0MB Circular A-95. The Clearinghouse review follows:
8
.1.,v,to..u. \..u..1.1.vuua J"'\.-;,J \...lt!Uftngt'lOUSC
Office of State Budget and Management
116 West Jones Street Raleigh, NC 27611
[phone]
North Carolina A-95 Clearinghouse Review Statement
State Clearinghouse Ni.anber: Project Title/County: Cooperative Agreement Between EPA Date:
81-E-4900-5214 & N. C. PCB Project 04-22-82
>-unas Requested (estimate): Fundin& A&ency:
$ 2,568,055 U.S. Environmental Protection Agency
N.C. Dept. of Crime Control & Public Safety
512 N. Salisbury St.
Raleigh, North Carolina 27611
Attn: David E. Kelly
Please attach this form to your
application before submlttln& It
to the fundin& a&eney.
STA TE LEVEL REVIEW OF THIS PROJECT JS COMPLETE. As a result of this review, the following recommendation is
made: (You should _p_!~ceed to complete formal application for submission to appropriate federal agency. This statement
and its attachments~ be attached to your formal application.)
Project is consistent with state goals, policies, programs, and
fiscal resources and is recommended for further development.
Project is recommended for further development with attached
recommendations for strengthening it.
Project is recommended for further development if attached specific
and major changes are incorporated into project by funding agency.
Project is not recommended for further development based on attached
rationale
D 5. Project has been waived from.A-95 Review.
Additiona 1 Ccmments:
This project has been reviewed through the State and Regional
Clearinghouse process pursuant to the Statel.Environmental Policy
Act procedures and through the U.S. District Court. All comments
received were considered in the state's decision to go forward V.Jith
the project.
·· Clearinghouse Director
9
"
STATE AND LOCAL NONCONSTRUCTlON PROGRAMS
0M8 Ajlpro,,11 No 10-AO 110
•· MUMIU l . STATf •· NUMNI FEDERAL ASSISTANCE 2. ""I.I· Al'PIJ-
CANT'S CATION
1. TY'1! 0 l'ltWPLICATION Al'PIJ· I,. DATI y,.,, mo111fr doy IOENTI-I,. DATf y,.,, ''"'"'" ""' o, CATION FIU AUKlNID
ACTIOM ~ Al'l'LICATION 1, R? ii. 1h 1~? LI. Hi
//tlor• •~ 0 NOTlflCATIOII OF INTENT (Opt.) uo~ ,,..,,...,. 0 ll[l'ORT Of FEDERAL ACTION Blad ,_,
,. Ll!OAL Al'PIJCANT /UCIPIENT N th C l . Department of 5. FEDERAL tMl'I.OYH IDENTIFICATION MO.
I •. AN11c.t• ,.._ , or . a ro 1 na
Crime Control & Public Safety i,.o..-,,.-u ... ' 512 N.Salisbury Street 6.
I I I· I ~ IAI <. s--1,.0 .... ' PIO-•· MVMNI
4, City ' Raleigh •. c-• ., ,Wake GUM
"· TrTLI Comp re hens i ve Envi
I.S-' North Caro 1 in~. u,c...., 27602 /From onmental Response, Com Frdm1/
C h. C-,.,_ (Nam, Milliam W. Phillips, Jr.[phone] Cata/Of) sation & Liability Act ... • i,/,p~o•t No.) a 7.CITL! ANO OESCRll'TIO~ Of AP,llCANt S BIOtECT I. TYl'f o, A"'lJCANT/lECll'IENT I ~l)U l Cl:.KL ~ ooperat,ve greemen e ween EPA & N. C. for ~
,. __ -~--PCB Project using CERCLA Funds ---,_.....,., .....................
C-s...-,_ ..... , ...
w O.,trtct •-0-.., /Sp,ci/yJ: s See Remarks, Section IV D-'-1-Cloy •-s.---i a-_,.._ E•,,, app,opriai, Im,, [_7-\j -9. TYl'f o, ASSISTANCE l A-holcO.-0--
~ -5vpttlo•-G•-f-o,t,e, E•ttr oppro-rn
C-i-pri41t 1,11,r/1/
10. AlfA Of '110JECT IMrACT /Na,..,, of cititJ. cou~11,1. 11 . ESTIMATED HUM-12. TYl'f o, Al'P\JCATION llt Entire State Stous. tt(.) IEI OF l'USONS AX.,.._ c-1..;..-,_ •-""'-[:]
5 . tloB1~'o80 -·--0-,......, __ £•t,r opp,opriatt Ill/tr ~
13. PIOl'OSEO FUNDING U . CONGRESSIONAL DISTIICTS OP, 1'. TYl'f Of CHANGE /For 12 ~ a, 11 ,1
•· PfDCllAL s? .::11.1 7nn .00 •· A'1'\J(AlolT I,. rtlOJtCT A-IACrMMo.&e.-i ,_ O"-/Sp,ci/y/:
4th Statewide •-o-.... o.no.. N/A ~-APfUCAHT .00 C-1-.. ,.0,,,etio,,
c. STATf "' 16. P•OJECT STAU 17. ,_OJECT 0-OeoNM Ow.ti ...
.00 f -c-.ii.,; ...
DA~: ~f "'5"" 1ay O~TJON E•ttropprr>-I I I I 4. LOCAi. .00 Mont/ts priatt lm,,(J)
•· OTNfl .00 11. ESTIMATED OAT£ TO r,o, 1"0'1tlt day 19. EXISTING FEDERAL IOENTIFICA TION NIJMGEI
TOTAi. s?_i:;41 7nn IE SUIMITTEO TO ,. 82 4 16 f. .00 FEDERAL Af":ENCY ..,
20. FEOUAL AGENCY TO lfCEIVE REQUEST !Nam,. Cuy. Statt. ZIP cod,/ 21 . UMA.KS ADDEO u. s. EPA, 345 Courtland St., Atlanta, Ga. 30308 ~ y" o ...
! 22. •· Te th. ""' of MY know!~ Oftd t,.i;of, b. If reqvir-4 by OMI Ci,c..,,or A-9, tflt, o~t,4tcati0fl •o• ,wb.litt.d. pu""°"' to No IT• Rt,po,tM
THE 4-t-. lt1 f'trH, p,,,.oppiicotio"/ opp,ltCOf10t1 in1trvcti0ft1 ~-"· te ap,prop,iote deorfng~ ... ond o/1 ,....., ... et• ••· sponu otto.c~td
l,/ Am!CANT ere t,,,. Ofti9 con.ct. l+t,e OO<v,...., he, ,...-, D D ~ CEITlflfS ..._ tlv+y ov~,ocil br th• 90.-.,nint (1) N. C. Clearinghouse bo4y ef i+t.e e,-,pficaftf On4 tM oppliceAt D D 0: THAT ► wiN c~ with rite crtt~ cn1vrottU1 (2) ~ lf l+i• 0114,teM-e i, op11r•"-'· (3) D D
~ 2l. •. TYPfD MAMt AND mll w, 1 1 , am, w •
~SIGMAT~t -Al#f!J/1~ ~ C. DA TE SIGNED
CUTIFYING Phillips, Jr.,Special Asst. Ytar ''"'"'" day 1~ ; ,. "7•'l • t; 11tl'tlE• ll! Sf"4TAT!Vf ITL..-C'"--·---'--·-,,82 4 16
24. AGENCY 1-'J(Pi! -~~ ~ w-J Safety 7 25. Al'PIJCA-Yf'a, mo11!h day N. C. Department of Crime Control & Public TION
RECEIVED 19
26. ORGANIZATIONAL UNIT 27. ADMl"41STU TIVE OFFICE 28. FEDERAL Al'PUCATION
~ ID£NTIFICA TION
... 30. FEDERAL GIANT u 29. ADDRESS .. IOENTIFICA TION ► ~ ~ 31. ACTION TAKEN 32. FUNDING Ytar MOltl/t day J,. Ytar '"ontil doy
C ST.UTING .. 0 a. AWARDED •· 'fDfllAL s C .00 33. ACTI0"4 OA TE ► ,. DATE 1,
0: 0 I». lfJECTEO I,, Anl.lCAMT 35. CONTACT FOR ADDITIONAL INfOAMA• 34. Ytar INOlttA doy g .00 TION (No,n~ o,rd ltltpltont ,uunb#r) ENDING 1 0 c. IETUINEO ,01 C, STAT! .00 DATE 1,
! AMENOMENT ,. lOCAL .00 l7. REMARKS ADDEO
~ 0 d. DEFUIEO •· OTHO .00 OYN OM. .. u 0 a. WITHDRAWN :."( I. TOTAL s .00 ---,---31. •· h, toltiftf ob-o-w• octiOII, OIIY co•,....h r.ui•N frCM11 d..,;,..ho"M' w..-• "· FfDfllAL AGENCY A-95 ornOAL
nt11iderMI. If 09efte'1 '•IPOf'M i, dve _,,.c1., p,o•i1i.-1 ef Pllf't 1, OMI r,,·o,,., o,rd trltplto111 1to.)
f!OEIAL AGENCY Circvlo, A-9,. it Mu b.e11 o, i, Mt1t9 •od•.
A-95 ACTION
*State share filled thru credit2s°'of $282,633 available. ITANDAIID fOflll ◄24 ,.t.Q( 1 (R.-, ◄-77!
/l'rru-nt,,,-d f'y 0 .'-11 C,rc~/01 A-J()J
r-
pen
of
A)
r'AGE 1 OF 12
lEl
..
•
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PART II
Form Approved
0MB No. 158-ROT 10
PROJECT APPROVAL INFORMATION
Item 1.
Does this assistance request State, local, regional, or other priority
rating?
____ Yes X ____ No
Item 2.
Does this assistance request require State, or local advisory, educa•
tional or health clearances?
X ____ Yes ____ No
Item 3.
Does this assistance request require clearinghouse review in accord•
anoe with 0MB Circular A-95?
X ____ Yes ____ No
Item 4.
Does this assistance request require State, local, regional or other
planning approval?
____ Yes X ____ No
Item 5.
Is the proposed project covered by an approved comprehensive
plan?
____ Yes X ____ No
Item 6.
Will the assistance requested serve a Federal installation 7
____ Yes X ____ N,o
Item 7.
Will the assistance requested be on Federal land or installation?
____ Yes X ____ No
Item 8.
Will the assistance requested have an impact or effect on the
environment?
__ X __ Yes ____ No
Item 9.
Has the project for which assistance is requested caused, since
January 1, 1971, or will it cause. the displacement of any individual,
family, business, or farm?
X ____ Yes ____ No
Item 10.
Is there other related assistance on this project previous, pending,
or anticipated?
____ Yes
Item 11.
Is project in a Designated Flood Hazard Area?
---Yes
EPA. Form S700-33 (Rev. 10-791
X ____ No
X No
11
Name of Governing Body __ N_/_A ____________ _
Priority Rating ___________________ _
Name of Agency or N/ A Board ______________________ _
(Attach Documentation)
(Attach Comments)
Name of Approving Agency_N_/_A ____________ _
Date _______________________ _
Check one: State D
Local D
Regional 0
Location of Plan N/A
N/A Name of Federal Installation ______________ _
Federal Population benefiting from Project ________ _
Name of Federal Installation _N_/_A ____________ _
Location of Federal Land _______________ _
Percent of Project __________________ _
See instructions for additional information to be provided.
Beneficial impact due to removal of
contaminated soil.
Number of: N/ A Individuals, _____________________ _
Families ______________________ _
Businesses _____________________ _
Farms ______________________ _
See instructions for additional information to be provided.
N/A
PAGE 5 OF 12
\ if{) /VV/ ~ I ', !--3 ( C. u, cF F r-uf\i ,_.1.5 \ CLASS - A OBJECT CLASS CATEGORY BUDGET INFORMATION NORTH CAROLINA/ENVIRONMENTAL PROTECTION AGENCY COOPERATIVE AGREEMENT Activity Activity Activity Activity Activity Activity Activity Sub to ta 1 Activity 3 4 6 6A 7 8 9 ** ** ** ** Personnel $591,314 $ 8,000 $416,146 $1,015,460 Fringe Benefits Trave 1 $ 2,500 $ 6,500 $130,000 $ 5,000 144,000 Equipment Supplies 1,100 3,500 3,000 20,000 92,250 119,850 Contractua 1 l,600 $450,000 15,QQQ V 466,600 Construction Other 15,500* 478,686 12,00U 291,604 797,790 Total Direct Total ....... Charges N ,_,. Indirect Charges ** TOTALS $20,700 $450,00Q_ 1}__9_, 000:t> l , 203,000 $40,000 $800,000 $20,QOQ $2,543,700 $282,633 $2,826,333 (90%) ( 10%) ( 100%) ACTIVITY DESCRIPTIONS AND RESPONSIBLE AGENCIES: EPA NC Total /\ctivity 1 -Community Relations Program -N. C. Dept. of Human Resources 3 -Landfill Construction & Engineering .Supervision -N. C. Department of Crime Control & Public Safety 4 -Sampling and Analysis Prior to Contaminated Soil Remova 1 -N. C. Dept. of Natural Resources & Community Development 6 -Removal and Transportation of Contaminated Soil - N. C. Dept. of Transportation 6A -Access Road to Landfill Site -N. C. Dept. of Transportation 7 -Roadway Shoulder Reconstruction -N. C. Dept. of Transportation 8 -Sampling and Analysis at Landfill - N. C. Dept. of Human Resources 9 -Project related costs incurred by the State of North Carolina which have not been claimed as matching costs under any other federally sponsored project or program and which were incurred between January 1, 1978 and December 11, 1980. * ~elephone, Advertising, Equip~ent, ** See apendix for cost break-out
..... w -GRANT PROGRAM, FUNCTION OR ACTIVITY (a) 1. CERCLA 2. 3. 4. 5. TOTALS 6. Object Class Categories a. Personnel b. Fringe Benefits c. Travel d. Equipment e. Supplies f. Contractual g. Construction h. Other i. Total Direct Charges j, Indirect Charges k. TOTALS 7. Program Income ** *** PART Ill-BUDGET INFORMATION SECTION A-BUDGET SUMMARY FEDERAL ESTIMATED UNOBLIGATED FUNDS CATALOG NO. FEDERAL NON-FEDERAL (b) (c) (d) $ $ $ $ a: ~ ~ ·-· -" --rorm Approved 0MB No. 158-R0TT0 NEW OR REVISED BUDGET FEDERAL NON-FEDERAL TOTAL (e) (f) (g) $2,543,700 $ * s 2,543,700 $ 2,543,700 $ $ 2,543,700 SECTION B-SCHEDULE A BUDGET CATEGORIES *State Credits of $282,633 GRANT PROGRAM, FUNCTION OR ACTIVITY Previous 1Ytate Project Remedial Im-1P1 ementa ti on Costs*** s 799,654 ** $ 215,806 144,000 119,850 466,600 797,790* $ se,543,700 $ ~, 543,700 -.. --ment q□Tp -Use t-ee 11ase on U1v115 Cl r. A See appendix for cost breakout $282,633+ (3) $ $ $ 'di TOTAL (4) (5) s $ 799,654 ** 215,806 144,000 119,850 466,600 797,790* $ $2,543,700 $ $2,543,700 PAGE 7 OF 12 J ,. ' ~
SECTION B -SCHEDULE B -BUDGET CATEGORIES
6. Program Elements
* (1) FEDERAL
a. $
b.
c.
d.
e.
f.
g.
h.
i. Total Program Elements $ 2,543,700
j. STATE TOTAL $
* See page 12 for Detai 1 Cost Break-out
** State Credits of $282,633+
EPA Form 5700.33 (Rev, 10-79)
14
FUNDING
{21 NON-FEDERAL
$
$
$ **
(31
$
$
s
Form Approved
0MB No. 158-ROTTO
(41
MAN-
TOTAL YEARS
2,543,700
PAGE a OF 12
J •
' I-' CJ1 ..., ........ .... ,-_, SECTION C-NON-FEDERAL RESOURCES (al GRANT PROGRAM (b) APPLICANT (c) STATE (d) OTHER SOURCES 8. $ $ * $ 9. 10. 11. 12. TOTALS $ $ $ SECTION D-FORECASTED CASH NEEDS TOTAL FOR Isl YEAR 1st QUARTER 2nd QUARTER 3rd QUARTER 13. Federal $? ~41 1nn $ l . ?71 8!10 $ 1.271 850 $ 14. Non-Federal 15. TOTALS $ 2.543.700 $ 1,271,850 $ l ,271 ,850 $ SECTION E-BUDGET ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT FUTURE FUNDING PERIODS (YEARS} (a) GRANT PROGRAM {b) FIRST (C) SECOND (d)THIRD 16. Ill/ I\ $ $ $ 17. 18. 19. 20. TOTALS $ $ $ SECTION F-OTHER BUDGET INFORMATION (Attach Additional Sheets If NecessarvJ 21. Direct Charges: * State Credi ts of $282,633+ 22. Indirect Charges: 23. Remarks: -EPA Form 5700-33 (Rev. 10-79) PART IV-PROGRAM NARRATIVE (Attach per instruction) Form Approved 0MB No. 158-ROt 10 (e) TOTALS $ $ 4th QUARTER $ $ (e) FOURTH $ $ PAGE 9 OF 12
PART II
STATEMENT OF
WORK PROGRAM
A. Project Description
1. Roadway Spi 11 s
During the months of June, July, and August of 1978, approximately
35,000 gallons of oily liquids were intentionally discharged along the
shoulders of 210 miles of North Carolina roadways. (See location map and
table). Subsequent chemical analyses conducted by the state indicated that
the oily liquids contained polychlorinated biphenyls, PCBs. Further
investigation showed soils, in very narrow and shallow bands roughly 24
inches from the road edge, to be contaminated with PCBs at concentrations
as high as 4,000 ppm.
Temporary remedial measures were taken to contain the PCB compound
along the roadway shoulders. An application of a 10% solution of activated
carbon applied at the rate of approximately one gallon per square yard, then
followed by an application of liquid asphalt at the rate of approximately
one-tenth of a gallon per square yard were placed on the contaminated soils.
The activated carbon solution was utilized to bind the surface concen-
tration of PCB by absorption of the PCBs into the pores of the activated
carbon and retard dissipation into the surrounding environment. The liquid
asphalt was applied to eliminate dusting of the activated carbon and to reduce
run-off of the activated carbon caused by storm drainage. These applications
also served to delineate the contaminated areas.
16
' . . 1, .
17
0
LOCATION MAP
JIIJIIil PC 8 SPILLS
-L&Q&i ••• iilii~.-
TABLE
1. SR 1004, Alamance County -From Bethel Church north of Snow Camp
to the Chatham County Line.
Length: 5.00 shoulder miles
2. SR 1004, Chatham County -From Alamance County Line to SR 1346.
Length: 2.22 shoulder miles
3. SR 1346, Chatham County -From intersection with SR 1004 to NC 87.
Length: 11.16 shoulder miles
4. NC 87, Chatham County -From intersection with SR 1346 southerly.
Length: approximately 1.42 shoulder miles
5. US 421, Chatham County -SR 2120 to Lee County Line.
Length: 9.59 shoulder miles
6. SR 1006, Chatham County -Between NC 902 and NC 42.
Length: 3.46 shoulder miles
7. NC 42, Chatham County -From Deep River (Lee County Line) to
intersection with SR 1006.
Length: 4.56 shoulder miles
8. NC 902, Chatham County -From SR 1006 to Rocky River.
Length: 9.68 shoulder miles
9. SR 1146, Edgecombe County -From US 301 to SR 1135.
Length: 2.40 shoulder miles
10. SR 1135, Edgecombe County -From SR 1146 to SR 1143.
Length: 2.43 shoulder miles
11. SR 1143, Edgecombe County -From SR 1135 to SR 1141.
Length: 0.51 shoulder miles
12. SR 1130, Edgecombe County -From SR 1003 to NC 43.
Length: 1.33 shoulder miles
13. SR 1141, Edgecombe County -From SR 1143 to NC 43.
Length: 1.43 shoulder miles
14. NC 44, Edgecombe County -From SR 1409 east 0.2 miles.
Length: 0.23 shoulder miles
15. NC 43, Edgecombe County -From SR 1130 to SR 1131.
Length: 0.87 shoulder miles
16. SR 1003, Edgecombe County -From NC 43 to Wilson County Line.
Length: 3.38 shoulder miles
18
TABLE (Cont'd)
17. SR 1432 and SR 1436, Franklin County -From 1/2 mile east of
Moulton to a point beyond Gupton, then traces to Centerville.
Length: 5.10 shoulder miles
18. NC 561, Franklin County -From Nash County Line to Centerville.
Length: 4.80 shoulder miles
19. NC 58, Franklin County -From Warren County Line to Nash County
Line.
Length: 5.10 shoulder miles
20. NC 98, Franklin County -From Nash County Line to Bunn and
approximately 5 miles west of Bunn.
Length: 4.70 shoulder miles
21. NC 97, Franklin County -From Wake County Line to Nash County Line.
Length: 0.90 shoulder miles
22. NC 96, Granville County -From just north of Oxford to NC 49.
Length: 15.2 shoulder miles
23. NC 49, Granville County -From NC 96 to Person County Line.
Length: 1.80 shoulder miles
24. SR 1315, Halifax County -0.2 miles from NC 4 to 0.1 mile east
of bridge.
Length: 1.03 shoulder miles
25. SR 1308, Halifax County -From 0.1 mile north of SR 1309 to 1.2
miles north.
Length: 1.18 shoulder miles
26. NC 4, Halifax County -From SR 1314 to SR 1308.
Length: 3.13 shoulder miles
27. NC 43, Halifax County -From Warren County Line to NC 561.
Length: 0.65 shoulder miles
28. NC 561, Halifax County -From SR 1317 to Nash County Line.
Length: 3.58 shoulder miles
29. NC 87, Harnett County -From Lee County Line to NC 27.
Length: 5.30 shoulder miles
30. NC 27, Harnett County -From NC 87 to SR 1252.
Length: 12.00 shoulder miles
31. NC 210, Harnett County -From Johnston County Line to city limits
of Angier.
Length: 1.82 shoulder miles
19
TABLE (Cont'd)
32. NC 210, Johnston County -From intersection with US 70 southerly
to Harnett County Line. North side only.
Length: 17.00 shoulder miles
33. NC 42, Lee County -From intersection with SR 1322 to Deep River
(Chatham County Line).
Length: 4.52 shoulder miles
34. NC 87, Lee County -From Harnett County Line to US 421.
Length: 2.14 shoulder miles
35. NC 98, Nash County -From Franklin County Line to NC 231.
Length: 1.41 shoulder miles
36. NC 231, Nash County -From NC 98 to SR 1137.
Length: 0.94 shoulder miles
37. SR 1137, Nash County -From NC 231 to NC 97.
Length: 3.48 shoulder miles
38. NC 97, Nash County -From SR 1137 to Franklin County Line.
Length: 4.39 shoulder miles
39. NC 58, Nash County -From Nashville to Wilson County Line.
Length: 4.12 shoulder miles
40. NC 561, Nash County -From Franklin County Line to Halifax County
Line.
Length: 0.7 shoulder miles
41. NC 97, Nash County -From NC 58 west 1 mile.
Length: 0.35 shoulder miles
42. NC 58, Nash County -From Franklin County Line to 3 miles north of
Nashville.
Length: 4.11 shoulder miles
43. ~C 49, Person County -From Granville County Line to SR 1515.
Length: 4.24 shoulder miles
44. NC 96, Wake County -From 98 to Franklin County Line, to traces
only.
Length: 0.30 shoulder miles
45. NC 97, Wake County -From Zebulon to Franklin County Line and
from US 64 Bus. to Zebulon.
Length: 4.50 shoulder miles
46. NC 43, Warren County -From Liberia to Halifax County Line.
Length: 6.40 shoulder miles
20
TABLE (Cont'd)
47. NC 58, Warren County -From intersection with NC 43 southerly
to Franklin County -both sides.
Length: 19.25 shoulder miles
48. us 158, Warren County -Between Macon and Vaughan.
Length: 0.60 shoulder miles
49. SR 1407, Wilson County -From SR 1003 to SR 1002.
Length: 1.06 shoulder miles
so. SR 1419, Wilson County -.From US 301 to SR 1003.
Length: 0.87 shoulder miles
51. SR 1003, Wilson County -From Edgecombe County Line to US 301
Bypass.
Length: 4.76 shoulder miles
Total Length: 210.97 shoulder miles.
21
2. Disposal Site
The proposed disposal site is located in the northeastern North
Carolina Piedmont Plateau of Warren County, approximately four miles south
of Warrenton. (See Maps).
The proposed disposal site consists of approximately 142 acres of
which about five acres will be used for the actual disposal of the soil
contaminated with PCBs . The remaining acreage wi 11 serve as a buffer
zone for the disposal area.
Surface water discharges are controlled by the topographic position
of the land. The proposed disposal area occupies the crest of a gently
sloping upland ridge which has 70 to 80 feet of relief. Surface water
discharge from the site is toward seven draws located in a radial pattern
around the site. Two large draws immediately Northeast, and West of the
site receive the major portion of surface run-off. Exposed clayey
subsoils, topographic position and side slopes tend to minimize surface
water infiltration and maximize surface water run-off.
Surface water discharge is to Richneck Creek and an unnamed
tributary to Richneck Creek via draws around the site. Richneck Creek
discharges to Fishing Creek. The confluence of Richneck and Fishing Creek
is approximately 3 miles downstream and Southeast of the Warrenton raw
water intake. Stream classifications for Richneck Creek and Fishing Creek
in the discharge area is class C. Approximately 40 miles separate the site
area and the closest raw water intake.
U.S. Geological Survey Flood Records of N. C. streams indicate that
the 100-year flood elevation is not more than 8 feet above average water
levels in Richneck Creek and its tributaries. The site is 70 to 80 feet
above these streams and not subject to flooding.
Recharge of ground-water resulting from surface water i nfi ltrati on
and percolation if estimated to be low. There should be no significant
fluctuation in water table elevations beneath the ridge occupied by the
disposal site. All features on the site which enhance surface run-off
reduce ground-water recharge. Rapid run-off and the relatively small area
of gently shoping ridge crest minimizes the volume of precipitation
available for infiltration and recharge. The close proximity of 2 deep
draws for ground-water discharge and the relative low retention and water
storage capacity of deep subsurface weathered rock (silty sand and sandy
silt) indicates a low potential for build-up of any significant hydraulic
head or water table below the ridge. The net effect of constructing
impermeable barriers on the ridge crest and diverting any off-site surface
water will be to further reduce the potential for mounding of ground-water
below the site.
22
Subsurface borings perfonned during February 1, 1979 by the
consulting finn of Soil & Material Engineers, Inc. indicated a static
water level of approximately 303 1 to 306 1 in elevation or 37 to 32 feet
below land surface. The study conducted by the firm Soils & Materials
Engineers, Inc. was carried out during the middle portion of maximum
seasonal fluctuation of ground-water. The measured elevation of ground-
water in February, 1979, was 303 to 306 feet. Ground-water elevations
could be predicted to rise an additional 5 to 6 feet. The predicted
highest ground-water elevation would be 309 to 312 feet. Maximum surface
elevation in the disposal area is 343 feet. The highest predicted water
table elevation is 31 feet below land surface which would allow a maximum
excavation depth of 24 1 to remain 71 from the high water table elevations.
Construction of a clay liner would afford a 14 foot separation from the
high water elevation.
Surficial soils on the site consists of red-brown silty clays.
The top soil on the site is significantly eroded but where present extends
to a depth of 3 to 6 inches. Subsoils are clayey and silty and extend to
depths of 38 to 45 feet. In general, a gradual transition exist between
upper silty clays and deeper clayey silts. Observations of soil borings
on site indicate that the clayey silts which grade to fine sands is typical
of the Piedmont province. Detailed analyses of the soil materials were
performed by the N.C. Department of Transportation laboratory and Soil &
Material Engineers, Inc. The two laboratory analyses indicated an upper
layer of clayey soils ranging in depth from Oto 38 feet below land surface.
Soils at the 45 1 maximum drilling depth were classified as silty sands
and sandy silts.
Standard Engineering laboratory tests for maximum density at optimum
moisture and permeability at 95 to 100 percent maximum density were
perfonned on the soils. At 95% maximum density the permeability of 1.9 x
10-7 cm/sec and minimum penneability of 1.8 x 10-8 cm/sec. At 100% maximum
density no permeability was greater than 1.0 x 10-7 cm/sec .. The 8 acres
encompassed by detailed soil borings and analysis demonstrates that 50,000
to 75,000 cubic yards of clayey materials are available to construct highly
impermeable soil liners.
Landfill monitoring requirements in TSCA approval conditions will
be adhered to. See also landfill specifications for monitoring requirements.
23
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24
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B. Background Information
The first deliberate discharge of what was later identified as PCB
liquid materials took place the last week of June, 1978, on remote roads.
The discharge was investigated by personnel who secured liquid samples of
the material. The next discharge occurred on July 27 and July 29 on the
roadway shoulders on NC 58, north of Centerville in Warren County. This
discharge \'las reported by private citizens to the N. C. High\-1ay Patrol,
who alerted the Division of Health Services, Water Supply Branch. Water
Supply Branch personnel notified Division of Environmental Management,
Water Quality Program personnel in the Raleigh Field Office of the spills.
Raleigh Field Office personnel investigated the spill on July 31 as an oil
spill and on finding no oil ponded or evidence in surface waters, returned
to their office without taking further action.
On August 2, the Water Quality Operations Branch, Division of Environ-
mental Management, received a call from a Johnston County farmer concerning
a spill on NC 210 in front of his farm. Because of the description of the
odor and the effects on field workers being reported, a staff chemist was
immediately dispatched to investigate the spill and to take appropriate
samples. Grass, soil, and water samples were hand delivered to the Division
of Environmental Management Laboratory for analysis later that afternoon,
August 2. The same chemist who investigated the Johnston County spill
encountered a similar spill near Snow Camp, North Carolina on SR 1004,
Alamance County, while returning to his home. A sample 1-1as taken from the
spill area and hand delivered to the laboratory the following morning for
analysis.
On August 4, the Laboratory's Analytical Section Chief notified the Water
Quality Operations Branch that the material spilled in Johnston County
appeared to contain Aroclor-1260, a Polychlorinated Biphenyl (PCB)
substance. The Water Quality Operations Branch immediately notified the
Chief of the Emergency Response Branch, Environmental Protection Agency,
Region IV, of the laboratory's findings. After briefing the Director,
Division of Environmental Management, a meeting was called with representa-
tives of the Attorney General 1 s Office, the Department of Crime Control and
Public Safety, and Public Information representatives of the Secretary of
the Department of Natural Resources and Com111unity Development. A
notification to all enforcement officials was prepared and sent over the
Police Information Network system during the late evening hours of August 4.
A news release was prepared and sent to local newspapers for publication in
the Saturday morning newspaper. The same day, the iaboratory confirmed that
the material discharged in Alamance and Chatham Counties contained
Aroclor-1260, the same form of PCB material found in Johnston and Harnett
Counties. Also on August 4, the N. C. Highway Patrol delivered soil
samples obtained from Chatham County to EPA. The results of the EPA labora-
tory analysis were reported to the State Bureau of Investigation on August 8.
On August 5, Water Qual i ty Operations Branch met with concerned citizens
in Johnston County, investigated the spill areas in Johnston and Harnett
Counties, and conducted a door-to-door contact with people residing along
26
NC 210. Because of concern by some residents alon~ NC 210, the Division
of Highway, Department of Transportation was requested to cover the spill
with a layer of sand in order to suppress the noxious odors present. This
was completed in late afternoon August 5 and continued on August 6.
On August 6, the Raleigh Regional Office was directed to secure samples
of the spill area in Harren County to determine if similar material had
been deposited along NC 58. Because of the publicity bein~ given by the
newspaper and TV to the spills, the Fort Bragg Environmental Coordinator
requested the Water Quality Operations Branch to analyze material secured
from the spill at Fort Bragg to determine if similar material \'las spilled
on the military reservation. Because of the publicity, reports of spills
began coming in from many different sources such as Highway Patrol,
Depart~ent of Transportation Division Engineers, private citizens, and
others in nine additional counties. It appeared that most of the spills
took place in the evenings of August 1, 2, and 3. The Division of Environ-
mental Management Laboratory continued to work around the clock to verify
the material involved in the spills in the other counties.
On August 7, a preliminary conference v,as held with representatives
of the Division of Highways, Division of Health Services, Attorney
General's Office, and Public Information personnel. Specific information
gathering activities were spelled out and assigned to specific people. A
coordination conference was held with representatives of the Department of
Human Resources, Department of Agriculture, Attorney General's Office, the
Department of Transportation, Environmental Protection Agency, and the news
media, on August 10. A working session was held following the briefing to
news media to provide direction, identify responsibilities and initiate
specific actions concerning the spilled material. Advice was solicited
from the Environmental Protection Agency Office of Toxic Substances, the
National Center for Disease Control, Hevi Duty Electric Company, the EPA
Health Effects Research Laboratory, and various academic and private sector
personalities known as having expertise in handling this type of material.
On August 11, the EPA Health Effects Research Laboratory began ambient air
sampling at spill sites.
North Carolina State University was identified as having expertise in
detoxifying pesticides. The University was contacted to provide expert
advice and assistance. A proposal was submitted to the Governor for
temporarily deactivating the PCB materials to prevent its migration and to
neutralize any hazard to people coming into contact with the material on
the shoulder of the highway. The Governor provided directive authority to
proceed on August 15, 1978. An activated charcoal solution was applied to
the PCB contaminated roadway shoulders during the latter part of August.
On August 15, the Governor requested assistance from the President of the
United States. On August 17, a special EPA Coordinator was assigned to the
problem.
Cross sectional samples were
the magnitude of the penetration
the material at various depths.
of August 21-28.
taken at one-inch intervals to determine
into the soil column and the strength of
These samples were taken during the period
27
On August 28 and 29th, the Epidemiology Section of the North Carolina
Division of Health Services convened a meeting of national experts on PCBs.
Those in attendance included scientists from the Environmental Protection
Agency, National Institute of Occupational Safety and Health, National
Institute of Environmental Health Sciences, and the Center for Disease
Control. State personnel in attendance were from the Division of Health
Services, Natural Resources and Community Development, Department of
Agriculture, and the Department of Transportation. Industrial users of
PCBs were represented by a person from Carolina Power and Light. The
purpose of this meeting was to assess the immediate risks to the persons who
live along the spill routes and to discuss the safety of those persons
who \voul d be parti ci pati ng in the removal and storage of the PCB contami-
nated soil.
On September 6, 13, and 19 alternative methods of removing soil from
the roadway shoulders were conducted on noncontaminated sections of road-
way shoulders. When the soil removal procedures had been formulated, a
test removal operation was conducted. The test removal operation was
performed on October 5, 1978 on a one mile PCB contaminated section of
NC 58 near Inez in Warren County. The PCB contaminated soil obtained
during the test removal operation has been temporarily stored at a
disposal site in Warren County. The purpose of the test was to examine the
practicality of picking up the contaminated material as well as any
possible health or environmental effects. On November 6, test results
indicated that the pick up of contaminated shoulder material was not
harmful to the environment or personnel.
On September 29, 1978, Governor James B. Hunt's request for assistance
from the Federal Disaster Administration, Department of Housing and Urban
Development was denied. On October 4, North Carolina officials were
notified by the Federal Highway Administration, U. S. Department of
Transportation, that the request for emergency relief funds was denied.
During the month of December, a Draft Negative Declaration was
prepared pursuant to the North Carolina Environmental Policy Act. The
statement was sent to State Clearinghouse on December 21, 1978 for
circulation. Comments received on the Draft Negative Declaration requested
an EIS be prepared. Therefore, a Finai Negative Declaration was not
prepared.
On December 12, an application was filed with EPA for approval of the
Warren County site for pl a cement of contaminated PCB ma teri a 1. On
January 4, 1979 a hearing was held on the \iJarren County site at the National
Guard Armory.
During the period January 25-31, 1979 additional soil sa~ples were
taken by the Division of Environmental Management to substantiate the
location of the contaminated material and determine if any migration had
occurred. Test results indicated that the material was present and had not
migrated. On January 29, 1979, a meeting was held in Hashington, 0. C.
between representatives of the State of North Carolina and EPA officials to
discuss the current PCB regulations and to discuss alternative solutions.
28
On February 6, the State of North Carolina filed petition with EPA to
amend the rules under the Toxic Substances Control Act to allow considera-
tion of alternate methods of treatment.
On February 15, 1979, a test was run on a contaminated section of
NC 210 in Johnston County and on March 22, on a contaminated section of
SR 1004 in Alamance County to determine the feasibility of utilizing the
theory of PCB fixation with activated carbon.
On June 4, 1979, the EPA Administrator, Douglas Castle, ruled against
the petition of February 6 to change the regulations to allow consideration
of alternate methods of treatment. The Region IV EPA Administrator, John
White, on June 4, 1979 approved the State's application to construct a
landfill in Warren County for disposal of the PCB contaminated soil.
1. Definition of PCBs 1
PCBs (polychlorinated biphenyls) are a class of chlorinated, aromatic
compounds which have found widespread application because of their general
stabilities and dielectric properties. PCBs have been prepared industrially
since 1929 and are now produced in many foreign industrial countries.
The Monsanto Company's preparations of PCBs were termed "the Aroclors".
Production of PCBs ceased in the United States in mid 1977.
The outstanding physical and chemical characteristics of PCBs are their
thermal stabilities, resistance to oxidation, acid, bases, and other
chemical agents as well as their excellent dielectric (electrically
insulating)properties. These and other properties have led to numerous
uses of PCB such as dielectric fluids (in capacitors and transformers),
industrial fluids (use in hydraulic systems, gas turbines, and vacuum
pumps), and plasticizers (adhesives, textiles, surface coating, sealants,
printing, and copy paper).
PCBs were prepared industrially by the chlorination of biphenyls with
anhydrous chlorine, using iron filing or ferric chloride as catalysts .
The crude product was generally purified to remove color, traces of
hydrogen chloride, and catalyst which was usually achieved by treatment
with alkali and distillation. The resulting product was a complicated
mixture of chlorophenyls with different numbers of chlorine atoms per
molecule. (This fact is responsible for the physical state of PCB prepara-
tions). Most individual chlorophenyls are solid at room temperature
whereas commercial mixtures are mobile oils.
The most important physical properties of PCBs from an environmental
point-of-view are solubility and vapor pressure. The solubility of PCBs
in water is low and decreases with increasing chlorine content. Values
1Hutzinger 0. et. al., Chemistry of PCBs, CRC Pres
Cleveland, Ohio, 1974.
29
given by Monsanto are 200 ppb (parts per billion) for Aroclor 1242,
100 ppb for Aroclor 1248, 40 ppb for Aroclor 1254, and 25 ppb for
Aroclor 1260. Studies on the solubility of PCB in water are compli-
cated by the fact that these compounds are strongly sorbed onto various
surfaces. PCB has been shown to sorb relatively rapidly onto charcoal,
plastic, glass, and silt or soil particles.
PCBs have a high specific gravity (Aroclor 1260/1.500) and a
relatively high density (Aroclor 1260 weighs 13.50 lbs./gallons at 25°c).
Loss of PCB by evaporation is extremely slow, i.e. Arocior 1260 exposed
to 100°c for six hours would have an evaporation loss of Oto 0.1%.
PCBs are very stable at high temperatures. A temperature of 2000°c or
greater is necessary before these chemicals are destroyed.
In summary, PCB compounds have been manufactured and used in this
country since 1929. Their uses have varied from the manufacture of many
household products to industrial uses. PCBs are very stable heat
resistant compounds that are fat soluble and some are known to build up
in biological food chains. PCBs are relatively insoluble in water but have
strong absorption properties onto such materials as clay, soot, charcoal,
and grease. PCBs are found in a wide variety of substrates throughout
our environment.
2. Regulations Pertaining to PCB Spills
The Environmental Protection Agency has promulgated rules and
regulations pursuant to the Toxic Substance Control Act to protect the
environment from further contamination by PCBs resulting from improper
handling and disposal of PCBs. Disposal requirement for PCB contaminated
material are contained in 40 CFR 761.10 (a) (4) 1981. The regulation
initially defined PCBs to mean any mixture with 500 parts per million (PPM)
o-f P~B. This regulation was amended effective July 2, 1979. The amendment
in 40 CFR 761.1 (a) lowered the concentration of PCBs which are covered bv
the regulation from 500 ppm to 50 ppm (Federal Register, Vol. 44, Federal
Reaister 31542 May 31, 1979). The requlation reauires that soil and debris
co~taminated with PCBs -muit 6e dispos~d of eithei through incineration or in a
chemical waste landfill. Criteria for any such landfill are contained in Annex II to the
referenced regulations. Specific wording in 40 CFR Part 761.10 (a) (4)
is as fo 11 ows:
11 Soil and debris which have been contaminated with PCB as a
result of a spill or as a result of placement of PCBs in a
disposal site prior to the publication date of these regulations
shall be disposed of
(i) In an incinerator which complies with Annex I, or
(ii) In a chemical waste landfilL 11
30
The State of North Carolina petitioned the US EPA for a change
in the above disposal requirements for PCB mixtures in 40 CFR 761.10
(a) (4). North Carolina requested that the regional administrator be
allowed to approve methods of disposal other than incineration or
landfilling. The petition for rule change was denied by EPA on
June 4, 1979.
31
C. Remedial Response Plan
Remedial response activities for the PCB contaminated soil clean
up will consist of eight main components. These components deal with the
aspects of actual contaminated material pick up and subsequent road
restoration, landfill design, construction, and monitoring, laboratory
analysis and sampling and community relations during the response. A
more detailed description of these components follows.
1. Community Relations Plan
The state worked closely with representatives of EPA Region IV and
ICF, and EPA contractor, in developing the community relations plan for
the PCB cleanup. The large area involved in the PCB dumping (210 miles
in 14 counties), and the emotionalism and publicity that has since
surrounded the issue, dictated the development of an extensive and well-
thought-out plan for informing the public about cleanup efforts that will
take place. The community relations plan is discussed on page 61
2. Project Scheduling and Design
The state having followed a competitive bidding process will select
a qualified project contractor to prepare the landfill site, construct
the landfill, coordinate with the N. C. Department of Transportation
(DOT) to receive, place, and compact the contaminated soil and close
the landfill site properly. The contractor will be responsible to the
State's Consultant Engineer .for this activity. The State will also
monitor ground and surface water on 30-day intervals during project
construction. The N. C. DOT will be responsible for pick up and trans-
portation of the contaminated soil to the site and maintenance of the
access road.
The State will notify EPA two weeks prior to starting construction
on the project. All landfill construction necessary to provide for
receiving contaminated soil will require 50 days. Concurrent with initial
landfill construction, 4 groundwater monitoring wells and 4 surface water
monitoring stations will be established, sampled, and analyzed for
40 CFR 761.41 (b) (6) parameters. Prior to receiving contaminated soil, the
state will sample and analyze all groundwater monitoring wells and surface
water stations, and submit the base line data to EPA. Three samples, at
one week intervals, will be utilized to establish base line data. Additional
monitoring samples will be taken at 30-day intervals during construction
and submitted to EPA.
Two weeks prior to rece1v1ng contaminated soil, the state will notify
EPA of the date for starting pick up and delivery to the landfill site.
The contractor and N. C. DOT will coordinate to schedule receiving the
contaminated soil during a six week time frame.
Within 10 days after the contaminated soil is placed and compacted in
the landfill, final cover including an artificial liner and soil materials
will be applied.
32
w N ACTIVITY State notifies EPA of intent to construct State notifies contractor to begin construction Landfill construction State notifies EPA of intent ta dispose ~Pickup and disposal Dispose of on-site residue Construct final cover Complete site closure Pre-pick up monitoring Ground and surface water monitoring 0 14 ~ N.C. PCB PROJECT SCHEDULE 20 40 PROJECT D/0YS 80 100 120 50 14 42 t-i--i I l 0 20 50 50 \* I* \* * Ground and surface water monitoring schedule except for post clusion period
Completion of site construction will consist of erecting security
fencing, seeding for erosion control and general clean-up and will be
accomplished within 20 days after application of final cover.
Imnediately following site closure, the state will sample monitoring
wells and surface water for sub~ission to EPA.
The project will be completed in 144 days from initial site prepara-
tion to closure.
3. Landfill Construction and Engineer Supervision
The disposal site for the PCB contaminated soii is located on
approximately 142 acres of land in Warren County. The State of North
Carolina proposes to construct, operate and maintain throughout post
closure, the PCB landfill in accordance with plans approved with certain
conditions by EPA. (See EPA June 4, 1979 and December 14, 1981 letters .)
A general, sequential description of how the landfill will be constructed
follows:
a. An all weather access road will be built to allow site access
for necessary equipment and transport vehicles for landfill construction
and PCB contaminated material.
b. Soil erosion control devices will be installed/constructed to
prevent offsite sedimentation during entire construction phase.
c. Cleaning and grubbing procedures will be initiat~d to prepare
areas for excavation.
d. Ground water monitoring wells will be installed so that
background data can be accumulated while the rest of construction phase
continues.
e. Major excavation of pit area and subsequent stock piling of
soils will co~mence.
f. Preparation of pit area to receive contaminated soil will begin.
Installation of lower leachate collection system.
Installation of 30 ~il. PVC bottom liner.
Installation of 12 inch thick soil layer for PVC liner protection.
Installation and construction of 5 foot thick clay liner.
Installation of upper leachate collection system.
Installation of filter fabric to protect upper leachate
collection system.
Installation of carbon filter syste~.
g. PCB contaminated soil will be placed and compacted within the
landfill.
h. All contaminated materials from erosion control devices and
purgings from carbon filter system will be placed in the landfill.
33
i. The final cover will be constructed and the upper PVC liner
and gas vent will be installed.
j. Final soil erosion control procedures, including seeding, will
be performed.
k. The chain link fence will be installed to prevent access to
the landfill site.
1. General cleanup operations will commence.
4. Roadside Sampling
The roadside sampling activity will accomplish three objectives: (1)
verify that the State has adequately identified the beginning and ending
points of each contaminated road segment by sampling at the beginning and
end of each segment; (2) confirm that PCBs have not migrated from the
30-inch strip to be picked up by sampling each area where significant
erosion has occurred and (3) insure cleanup objective of 49 parts per
million is achieved. Nine tasks will be undertaken to accomplish this
activity. These tasks are described below along with the sampling
methodology to be utilized.
The State will develop a sampling plan 30 days before the removal of
contaminated roadway soil that is consistent with EPA guidance. Sampling
will be done to check for hot spots and to insure that contaminated soil
over 50 parts per million is removed. If necessary, the scope of work
will be amended to accomplish this objective.
a. Develop Monitoring Strategy
This activity will be carried out by two two-man teams and an
activity supervisor. One week is allocated to developing a work pian of
the work to be accomplished. Maps will have to be assembled and logistics
of the project laid out.
b. Acquire Supplies
Acquisition of supplies is identified as a separate task since it is
a critical path element in the timely completion of the project. Enough
supplies to take samples will be acquired. Each sample will be placed in an
individual jar and labeled. All samples will be taken with six-inch
circular metal cores or pipes. For composite samples, individual cores and
disposable gloves will be used for each part of the composite. Enough cores
and gloves will be acquired for individual cores. Maps will be acquired to
plot sampling locations and identify road segment boundaries. All supplies
will be acquired within 14 days of project start-up.
c. Sample End Points
A log book will be developed containing maps of each contaminated
road segment and a precise description of each starting and ending point.
This log book will contain all of the data available to the State on
starting and ending points.
34
The work plan will divide the contaminated segments into two groups
and each group will be assigned to a two-man sampling team. At each
starting and ending point the team will take a composite sample five feet
beyond the end point. Where the contamination begins at an intersection,
each corner along a possible direction of the spill will be sampled to
assure that the PCB discharge did indeed terminate at the intersection.
At each sample site a composite sample will be taken consisting of
three cores. The cores will be within the 30-inch strip perpendicular to
the road and equally spaced. Each core will be to a depth of 3 inches, and
the three cores will be composited. A clean core and clean gloves will be
used to extract each core. Each sample site will be marked by a small wooden
stake sunk level with the ground with survey tape nailed to the top. Each
sample will be sent to EPA for analysis. The sample location will be
described in the log book.
d. Erosion Site Survey
During the identification of the beginning and ending points of
each segment, each team wil l slowly drive the full extent of each segment
noting on maps areas of erosion. Each erosion area will then be classified
either sheet or channel erosion. An area of sheet erosion would indicate
erosion along a section of r oadway bank. Channel erosion would be analo-
gous to a point source or si ngle erosion gully.
The State has already surveyed roughly ten percent of the contaminated
highways for erosion. Based on this survey it has been estimated that
approximately 20 areas of channel erosion will be found and ten areas of sheet
erosion.
e. Erosion Area Sample
For channel erosion sites two samples would be taken. The first
sample would be a composite of three cores from observable deposition fans
at the bottom of the channel. The second would be a composite of three
cores of the area immediately downslope of the deposition where no PCB's
would be expected.
For sheet erosion, the extent of the deposition fan will first be
identified, then a representative composite sample of three cores from the
fan will be taken. Three additional composite samples will also be taken,
the first in an area downsiope of the fan, and the second and third at
either end of the sheet. These perimeter samples would also be taken
beyond the zone of expected migration in order to delineate the migration
area.
All laboratory analyses for both erosion and end point determination
will determine whether or not the concentration of PCB is greater than
49 mg/kg.
35
f. Evaluate Laboratory Results
All sample results of beginning and end points, as well as all
erosion sample results, will be reported whether or not the concentration
of total PCB 1 s is above 49 ppm PCB. If one or more of the erosion areas
show a PCB concentration above 49 ppm, each positive erosion area will
be further sampled to detennine the extent of the contamination. All
contaminated soil so identified in the erosion area will be removed to the
l andfi 11 •
g. Additional Sampling
The sampling activity tasks and budget include the potential for
taking additional composite samoles. These ~amples mgy include
additional erosion samples, if the estimates of number of significant
erosion sites prove to be low.
h. Past Pick-Up
Samples wi 11 be taken at the bottom of the 311 x 30" trench at
one of the pick up segments, selected by State/EPA personnel, and analyzed
prior to shoulder reconstruction to illustrate the absence of PCB
contamination below the pick up stripo Additional sa~ples may be taken
at any or all of the remaining segments for later analysis with shoulder
reconstruction not being delayed. If any "hot spots" are located,
additional samples will be taken to determine correct remedial action.
i. Conclude Activity
A final report will be prepared presenting all sample data and a
description of the project and areas sampled.
5. Lab Analysis
This proposal is based on the assumption that all laboratory
analysis and required quality assurances will be provided by the
Environmental Protection Agency and its contractors. The State's sole
role in sampling will be to ship properly prepared samples to a predesig-
nated location for analysis.
All analyses would be concerned only with total PCBs. The
erosion and beginning and end point sample results will be reported as
only whether or not the total PCB concentration of the sample exceeds
49 ppm.
36
6. Removal and Transportation of Contaminated Soil to Disposal Area
The proposed method of removing the PCB contaminated soil from the
roadway shoulders will consist of the following sequential steps:
a. The contaminated area will be thoroughly wetted down with
water, if necessary, in order to control dust during the
removal and disposal operations. This may not be required
during wet seasons, but on the other hand, may be required
as much as 24 hours in advance during extremely dry conditions.
This operation is recognized as extremely critical in the
total removal operation and will be stringently controlled.
b. The contaminated shoulder area will be trenched out to a
width of approximately 30" from the edge of pavement, and
approximately 3" deep by means of a motor grader equipped
with a specially designed blade to allow for the cutting
of a reasonable neat line trench, working with all motor
grader wheels on the pavement. The trenched out material
will be fed along the motor grader blade to form a windrow of
material located inside the edge of the pavement.
c. The windrow of contaminated material will be mechanically
picked up and fed into trailing dump trucks by means of an
Athey force-feed loader. This loader operation forces the
contaminated material onto a self-contained belt conveyor by
means of rotating paddles. The material is conveyed up the
belt and dropped into dump trucks. A specially designed canvas
shield will extend from the top of the belt down into the
dump truck bodies to prevent wind drift of the contaminated
materials.
d. The Athey loader is designed to scrape the road surface;
however, very thin amounts of residue will be left on the
road surface following the loader operation.
Depending on soil moisture conditions, this residue will be
either water sprayed back into the excavated trench or broomed,
by means of a tractor mounted rotary broom or a combination of
both spraying and brooming. Spraying will be performed by a
Hydroseeder with especially designed adjustable outlet nozzles
and the broom will be covered with a specially designed canvas
cover to minimize dusting and wind drift.
Once the contaminated material is deposited in dump trucks, the dump
bodies will be tightly covered with tarpaulins using elastic tie-downs.
Insofar as possible and practical, contaminated material wtll be hauled to
37
the disposal area along rural routes, avoiding highly congested areas.
Hauling of contaminated material will take place only during daylight
hours.
Vehicles equipped with mobile radio units will routinely survey the
haul routes for trucks with mechanical difficulty. In the event of
mechanical trouble, mechanics will be radio dispatched. (see also
Section I Project Contingency Plan.)
7. Shoulder Reconstruction
Reshaping of the disturbed shoulder area will immediately follow
the removal operation. Depending on the width and cross slope of the
existing shoulder, reshaping of the shoulder by a motor grader, or filling
in the excavated area with borrow soil material and shaping with a motor
grader.
The shoulder reshaping operation will be followed by erosion control
operations consisting of seed bed preparation, seeding, fertilizing and
mulching of all disturbed areas.
8. Landfill Monitoring
Four permanent groundwater monitoring wells will be constructed and
located North, South, East, and West of the landfill. The groundwater
wells will be monitored in accordance with 44 FR 761 .41 (8)(6) standards.
Base line groundwater quality will be established by sampling the ground-
water wells on one week intervals for 3 weeks. Groundwater Base line
groundwater qualfry will be determined during construction and prior to
receiving contaminated soil.
Four permanent surface water monitoring stations will be located to
determine water quality. Two receiving streams will be monitored,
Richneck Creek on the northern site perimeter and an un-narned tributary
to Richneck Creek on the southern perimeter. Two stations, one on each
stream, will be located up gradient from any site surface run-off event.
Two stations, one on each stream, will be located immediately down
gradient from the site and through which all flow from surface runoff events
will pass. Representative surface water and sediment samples will be
monitored at each station in accordance with 44 FR 761 .4l(b)(6) parameters.
Excluded from analyses are chlorinated organics other than PCB as indicated
in a letter to Governor Hunt from John White (EPA Regional Administrator)
dated June 4, 1979.
Twelve groundwater, 12 surface water, and 12 sediment samples will be
monitored for base line data.
Three sets of samples wil l be obtained from each ground and surface
water monitoring point on 30-day intervals during construction. Each set
will consist of l sample from each groundwater well and 2 (water and
sediment) from each surface wa t er station.
38
D. Remedial Response Alternatives
1. Alternative Method of Treatment In-Place
Tests were conducted to determine the feasibility of applying
activated charcoal as a means of achieving long term fixation and con-
tainment of the PCB material within the highway shoulders. The in-place
treatment consisted of applying activated charcoal on the contaminated
soil and then blending the activated charcoal material into the soil
column of the highway shoulder. The disturbed areas would then be
packed, seeded and reshaped. A continuous maintenance and inspection
program would be performed to insure that erosion and soil migration
did not occur.
A test was run on February 15, 1979, on a section of NC 210 in
Johnston County and on March 22, on a section of SR 1004 in Alamance
County. The test results indicated that vertical and horizontal mixing
was accomplished with the average concentration being below the
regulating requirement at that time of 500 ppm. The average concentration
along the test section is above the current requirement of 50 ppm
(amendment to 40 CFR 761 .10(a)(4).
During the test runs representative soil samples were taken by
EPA at the Research Triangle Park to conduct studies of possible health
effects. The EPA study which utilized rats for test purposes provided
evidence that the carbon fixation process was not adequate and would not
be an acceptable means of disposal.
Because EPA regulations prohibited in-place treatment the State
of North Carolina applied for a rule change to allow the regional
administrator to approve in place treatment. The EPA administrator on
June 4, 1979, denied the petitiion submitted by the State of North Carolina.
2. Alternative of Transportation to a PCB Material Incinerator
Three incinerators have been identified as having the capability
to destroy the PCB material through incineration. These incinerators are
located in New Jersey, Arkansas, and Texas. Additionally, transportation
and handling logistics would make this alternate cost prohibitive.
3. Alternative of Transportation to an Existing Chemical Waste Landfill
Consideration was given to transporting the PCB contaminated soil
to an existing chemical landfill located in Alabama. This alternative
was considered not feasible, because of limited transportation resources,
manpower requirements, and excessive cost of disposal estimated in 1980
at $12. million as well as the increased logistic problems.
39
4. Goodyear PCB Detoxification Process
Dr. R. H. Kline, scientist from the Research Division of the
Goodyear Tire and Rubber Company, was contacted to determine the
feasibility of applying the recently developed Goodyear PCB detoxification
process to the soil-PCB spill mixture in North Carolina. Dr. Kline
stated that the process was designed for PCB fluids, not absorbed PCB
and solid mixtures. The only way the Goodyear process could be applied
would be first extract the PCB from the soil mixture, and while extraction
and detoxification was possible that it is not practical nor economical.
5. No Action (Do-Nothing Alternative)
The no action or "Do-Nothing" alternative was not considered to
be a viable alternative because current EPA regulations require disposal
of PCB contaminated soil which has concentrations greater than 50 parts
per million. The rights of way of North Carolina highways are generally
used to provide driveway access to adjacent properties and to provide for
placement of utility distribution systems. In addition, highway shoulders
require periodic maintenance, enlargement and improvement to meet the
transportation needs of the public.
None of these right of way activities can be undertaken without
substantially increasing the risk of further distribution of PCBs in the
environment by disturbing the contaminated soil. Even without such use
of the rights of way, the normal usage of the highways will result in
some PCBs being distributed in the environment due to vehicles intentionally
or unintentionally being operated on the shoulders. It is felt to be in
the public interest to remove the PCB contaminated soil from the highway
shoulders so that the EPA regulations will be honored and so that the
highways can be put to full public use without further distributing PCBs
in the environment.
40
E. Preferred Alternative
1. Summary of Alternatives
One alternative considered for the proposed action consisted of
treatment in-place by applying activated charcoal on the contaminated
soil. Treatment in-place of the PCB contaminated soil is prohibited by
EPA regulations. Therefore, this alternative was considered not
feasible.
Another alternative considered was transporting the PCB
contaminated soil to a PCB material incinerator located out of State.
This alternative was rejected because of excessive costs.
The alternative of transporting the PCB contaminated soil to an
existing chemical landfill was considered. This alternative was
determined to be not feasible because of limited transportation resources,
manpower requirements and excessive cost of disposal estimated at $12
mi 11 ion.
The no action or 11 00-Nothing Alternative11 was not considered a
viable alternative because EPA has determined in the course of extensive
rule-making proceedings that PCB contaminated soil in concentrations of
50 parts per million or greater should be disposed of in landfills. For
these reasons its removal and safe disposal is in the public interest.
The State of North Carolina proposes to remove and dispose of the
PCB contaminated soil in a specially constructed disposal landfill that
is located on approximately 142 acres of land in Warren County.
Approximately 90 sites located in twenty counties of the State
were evaluated as potential disposal sites for the PCB contaminated soil.
A set of general guidelines and EPA technical requirements were utilized
in the evaluation and selection of disposal sites.
2. Summary of Environmental Impact and Adverse Environmental Effects
The proposed action to remove and dispose of approximately 40,000
cubic yards of PCB contaminated soil will result in some adverse environ-
mental effects. Approximately five acres of agricultural land utilized
for the disposal pit will be taken out of production for an indefinite
period. No significant environmental effects are anticipated to result
from the removal and disposal operations. Test results during trial
removal operations show no levels of airborne PCB vapor or dust that ex-
ceeded the NIOSH proposed criterion of 1 microgram/m3 or added significant
quantities of PCBs to the total atmosphere levels. Dust control measures
will be utilized during the removal of the soil to help reduce the PCB
laden dust particles.
The disposal pit will be constructed to completely contain the
PCB contaminated soil. There will be no hydraulic connection between the
PCB contaminated soil and surface water or groundwater. Installations of
wells and leachate collection systems will allow monitoring of the disposal
site.
41
The removal of the PCB contaminated soil from the roadsides will
have a positive effect on the environment by substantially diminishing
the availability of the PCB substance to people as well as plant and
non-human animal life. The roadway shoulder and surrounding environment
will be restored to normal usage.
See the State's Environmental Impact Statement for a more detailed
discussion.
3. Description of Removal and Disposal Action
a. Soil Removal
Shortly after the PCB spills occurred, measures were taken to
contain the PCB compound spilled along the roadway shoulders. An
application of a 10% solution of activated carbon applied at the rate of
approximately one gallon per square yard then followed by an application
of liquid asphalt at the rate of approximately one-tenth of a gallon per
square yard were applied to the roadway shoulders where the PCB spills
have occurred.
The activated carbon solution was utilized to bind the surface
concentration of PCB by absorption of the PCBs into the pores of the
activated carbon and retard dissipation into the surrounding environment.
The liquid asphalt was applied to eliminate dusting of the activated
carbon and to reduce run-off of the activated carbon caused by storm drainage.
These applications also served to delineate the contaminated areas.
The PCB contaminated soil would be removed from the roadway shoulders.
b. Need for the Proposed Action
Polychlorinated biphenyls are highly stable compounds that will
remain unchanged in the environment for a very long time. PCB will
biologically magnify in food chains and accumulate in the fatty tissue of
both humans and animals. The long term effects of human and animal
exposure to low levels of PCBs are not clearly documented; however, studies
using laboratory animals have shown potential chronic effects such as
cancer induction, pigmentation, and behavioral changes. The PCB contami-
nated soil may become translocated into adjacent agricultural crop lands
and may have an impact on agricultural cash crops such as tobacco, feed
and forage, and crops for human consumption, The State of North Carolina
considers the removal of the PCB contaminated soil a necessary action to
insure the protection of the natural and human environment.
In addition to the above reasons for removal of the PCB contaminated
soil, the North Carolina Department of Transportation must periodically
reshape shoulders and ditches adjacent to state highway system travelways
in order to maintain safe egress for the traveling public and to maintain
proper cross slopes for storm drainage. While these operations are closely
followed by necessary erosion control measures to stabilize the loosened
soil, there nevertheless follows a period of time during which the shoulders
and ditches are susceptible to erosion. In addition normal deterioration
of the highways caused by traffic, climate and age will require future
42
modifications to the contaminated areas including resurfacing and
possible widening and realignment of the highway facilities. All of
these operations would tend to redistribute the contaminated soil in
a manner which would be very difficult if not impossible to control.
The presence of PCB contaminated material along state highway
system routes has caused the Department of Transportation to disallow
all encroachment requests along those roadway shoulders which involve
activities requiring excavation or redistribution of the soil structure.
This has included placement of utilities and commercial and private
driveway pipes. These activities involving the roadway shoulders are
necessary in order to provide needed services to property owners located
adjacent to PCB spill areas.
43
F. Project Management Plan
The overall coordination/management of all the remedial projects
relative to the cleanup of PCBs dumped along North Carolina highway
shoulder shall be the responsibility of the designee of the Secretary
of the North Carolina Department of Crime Control and Public Safety.
(see I-B Lead Agency) Said designee shall serve as State Project
Officer (SPO) and will utilize an inter-disciplinary team with repre-
sentatives from the Governor's Office, Attorney General's Office,
Department of Human Resources, Division of Health Services, Department
of Natural Resources and Community Development, Division of Environmental
Management and the Department of Transportation, Division of Hi gh\-1ays.
The general areas of responsibility of the other state agencies shown
on the "Management Plan" are as follows:
l. Governor's Representative -to keep the Governor and the
appropriate members of the Governor's Office updated on the project
and to relay guidance from the Governor to the State Project
Officer.
2. Attorney General's Representative -to serve as legal advisor to
the State Project Officer.
3. Controller's Office, CC&PS -to receive and disperse all funds
(state or federal) allocated to the project and prepare fiscal
reports as required, as well as serve as fiscal advisor.
4. Department of Transportation -to remove, haul and deposit in the
landfill the PCB contaminated soil from the highway shoulder, and
to reconstruct said shoulders.
5. Department of Human Resources -to oversee the construction and
operation of the landfill, and to develop and carry out a Public
Information/Community Relations Plan.
6. Department of Natural Resources and Community Development -to
coordinate all sampling along the spill sites, including the
actual pick-up of samples and delivery to vendor for analysis.
44
+::> I U1 Pick-Up l ---I DOT Governor's Representative Attorney Gen. Renresentative I Landfi 11 I I Inspections Vendor ---OHR I Construction Vendor MANAGEMENT PLAN Overal 1 Coordination CC&PS I Sampling I I Pi ck-Up NRCD ---I NRCD Analysis Vendor CC&PS -Department of Crime Control and Public Safety DOT -Deoartment of Transoortation OHR -Department of Human Resources NRCD -Department of Natural Resources and Col'Tilunity Develooment Budqet Controller I Public Infomation/ Community Relation I Community Relations Vendor ---OHR Public Information OHR
G. Work Plan
TABLES FOLLOW
46
WORK PLAN Activity: Community Relations Name of Project: N.C. PCB Clean Up Activity:_l _____ _ ~Jork Yrs: O Funds: ( $000) 20. 7 SCHEDULE TASK NO. DESCRIPTION OF PLANNED TASKS OUTPUT START COMPLETE l -A Notification of Officials Letter 0 On Going l -B Press Conference Media Briefing On Going On Going l -C Press Release Press Rel ease On Going On Going l -D Care Line Hot Line On Going On Going l -E Informational Packet Packet On Going On Going l -F Public Service Announcements Announcement On Going On Going ~l -G Site Tours Meetings On Going On Going l -H Mailing to Residents Letter On Going On Going l -I Final Report Report On Going On Going & I ! r
r WORK PLAN Activity: Project Scheduling Name of Project: N. C. PCB Clean-Up Activity: 2 -------Work Yrs: o Funds: O --~-------TASK NO. 2 - A 2 - B 2 - C DESCRIPTION OF PLANNED TASKS Complete State Sampling Plan State notifies EPA two weeks prior to initiation of project construction State notifies contractor to initiate project construction (minimum 5-day notification) State implements pre-pickup monitoring 2 - D !Contractor initiates site construction OUTPUT Plan EPA Notification Contractor Notification Pre-Sampling Construction of Site t2 -E !contractor installs groundwater monitoring wells I Installs Wells 2 - F !State establishes surface water monitoring stations 2 - G · !State samples ground and surface water 2 - H !State submits ground and surface water monitoring data to EPA Identified Sampling Data Submitted 2 - I !State notifies tPA of intent to initiate pick up I EPA Notification and disposal phase 2 -J !Contractor completes construction of landfill I Landfill ready 2 -K !State starts pick up and disposal phase 2 -l !State monitors ground and surface water 2 -M ~tate submits ground & surface monitoring data to EPA Pick-Up Sampling Data Submitted START -14 5 0 0 0 7 35 36 50 50 58 95 SCHEDULE COMPLETE 0 0 64 124 7 14, 21 , 28 35 92 58 95
' PROJECT SCHEDULING (continued) ACTIVITY 8 jr~K NO. SCHEDULE DESCRIPTION OF PLANNED TASKS OUTPUT START COMPLETE i ! 2 - N Final cover construction completed 103 ! ' 2 - 0 Site closure initiated l 04 124 t i i 2 -p Site closure completed Site Closed 124 ! :\ 2 -Q State monitors groundwater and surface water Sampling 124 i 2 - R Landfill project completed Erid 124 I ·t 2 - S State submits ground and surface water monitoring ' data to EPA Data Submitted 130 2 - T CERCLA Project completed 130 I +'> 'I.Cl ! I '
Landfill Construction Activity: & Eng. Supervision WORK PLAN Name of Project: ......:N~C~P~CB:::__.::C:..;.l.::;..ea=n...:..-....::.U=p ______ _ 3 Activity: ______ _ Work Yrs: Contract Funds: ( $000) 450 ---------------------------------------------------------------------------------------------------TASK NO. I DESCRIPTION OF PLANNED TASKS ~ 3 - A !Access road construction 3 - B !Soil Erosion Control devices installed/ constructed 3 - C !Clearing and grubbing procedures 3 - D Groundwater monitoring wells constructed 3 - E !Excavation and stock piling 3 - F !Landfill construction to receive contaminated soil 3 - G !Install Lower leachate collection system 3 -H !Install 30 mil. PVC botton liner 3 - I . !Install 12 inch soil layer for PVC liner protection 3 -J [onstruct 5 foot thick clay liner 3 - K 3 - L 3 -M Lnstall upper leachate collection system Install filter fabric for leachate system brotection nstall carbon filter system OUTPUT Access site Prevent erosion Site Cleared Sampling capability Pit Construction Ready to receive Contaminated materials 3 - N ~lacement and compaction of PCB contaminated soil !PCB material landfilled I 3 - 0 ~lace carbon filter system and contaminated bediment from erosion control devices in landfill START 0 0 0 0 0 0 51 86 SCHEDULE COMPLETE 50 50 50 7 50 50 92 92
PROJECT SCHEDULING (continued) I· .! jh1>.SK NO. DESCRIPTION OF PLANNED TASKS ii 3 -p Construct final cover and install upper PVC i! liner and gas vent '.ff i 3 -Q Perform final soil erosion control procedures I including seeding i 3 -R Install chain link fence I I 3 -S General Clean-up I U1 I-' I i I ACTIVITY B SCHEDULE OUTPUT START Finish construction 93 Close site 104 Prevent access 104 Final activities 104 COMPLETE 103 124 124 124 I I -' 1 :1 J I! i ' !l
WORK PLAN Activity: Sampling Name of Project: N.C. PCB Clean-up Activity=--=------TASK NO. I DESCRIPTION OF PLANNED TASKS 4 -A I Develop monitoring strategy and procedures 4 -B !Acquire necessary supplies. 4 -C I Identify and sample beginning and ending points of all contaminated road segments j'r;. -J)E; Survey a 11 s i gni fi cant erosion sites 4 -tf Sample all erosion areas !<-n4 -11Co Evaluate ·1aboratory results N 4 -~H If necessary conduct additional sampling 4 -IJIJ Conclude activity ~4-])I; l}')( {{1)P fo'(1_ --r ,,('), c.-:t-.l. ;1'''-'~l-l"-l Cr ,_:;NT, :':<-IL.-X 1 (,• · k0d ~ Lp I ' '" /-) I) I,, j \J 4 3 (;/ ' "! ( }..o f WorkYrs: 1.0 Funds:($1,000): 10 Work Plan Supplies Map 81 Samples Map l~ork Pl an Samples OUTPUT Report and Recommendation 39 Samples Final Report 5r.>M,7L/Nl-\ r (. r::, L tc... , ,-...;(., START 0 0 8 8 28 44 56 56 C SCHEDULE COMPLETE 7 14 21 21 42 55 106 l 09 107 I
WORK PLAN Activity: _________ _ Lab Analysis Name of Project: N. C. PCB Clean-up Activity: ______ _ 5 Work Yrs: Contract Funds: ($1,000): 0 SCHEDULE TASK NO. DESCRIPTION OF PLANNED TASKS OUTPUT START COMPLETE 5 - l Submittal of roadside monitoring samples to EPA for analysis by EPA contractors. Sample Results 8 l 06 <.J7 w -r-
WORK PLAN Activity: Removal, Transportation & Name of Project: N.C. PCB Cleanup Disposal Activity: 6 -------\,Jork Yrs: 50 Funds: ($000) $1,243 TASK NO. c..n +:> r 6-A 6-B 6-C 6-D 6-E 6-F 6-G DESCRIPTION OF PLANNED TASKS Const. Landfill Access Road Pre-Sample-Test to determine beginning and ends of strips (210 miles) Wet down contaminated soil from 210 miles Remove contaminated soil from remainder of 210 miles, feed to edge of pavement Mechanically pick up windrow of contaminated material from pavement, load on trucks Broom or spray pavement residual in cut Transport contaminated soil to landfill OUTPUT Road Access Identify beginning and ends of strips Dust control Remove test strip soil Load Clean up pavement Transportation of soil to landfill SCHEDULE START COMPLETE 0 42
WORK PLAN Activity: Shoulder Reconstruction Name of Project: N.C. PCB Cleanup 7 Activity: ______ _ ~Jork Yrs: 30 Funds: ( $000) $800 SCHEDULE TASK NO. DESCRIPTION OF PLANNED TASKS OUTPUT START COMPLETE i 7-A Reshape shoulder or fill in excavated area Filled in excavation 0 and reshape (210 miles) area ! 7-B Seed, fertilize and mulch disturbed area Erosion control 42 I for erosion control (210 miles) l I (J1 (J1 : ,
!f ['+ ~ '· WORK PLAN :.J Activity: Landfill Monitoring Name of Project: N.C. PCB Cleanup Activity: ______ _ 8 ~Jork Yrs: O Funds:($000) 20 SCHEDULE TASK NO. DESCRIPTION OF PLANNED TASKS OUTPUT START COMPLETE 8-A Contractor installs groundwater monitoring Wells Installed 0 7 wells 8-B State establishes surface water monitoring Station Locations 0 7 stations Identified 8-C State samples ground and surface water Samples collected for 7 14, 21 , 28 baseline data 8-D State submits ground and surface water Submission of Baseline 35 35 monitoring data to EPA Data to EPA 8-E State monitors ground and surface water 58, 88 58, 88 l1l during placement of materials in landfill CJ) 8-F Data submitted to EPA 65, 95 65, 95 8-G Submission of records to EPA as per 40 CFR Data submission to EPA 95 185 761. 41 (b) ; 8-H State samples surface and ground water twice a Perpetual sampling year I ,..
H. Safety Plan For Remedial Action
The purpose of the project safety plan is to provide adequate health and
safety protection for the workers involved in the pick-up and deposition of
PCB contaminated materials. It is not felt that any special precautions will
be necessary to protect the general public except to keep them away from the
operational areas.
Since the PCBs have lain on the roadside for over three years it can be
assumed that they have assimilated to the available soil particles and
activated charcoal applied for just such a purpose. The containment of the
PCB materials depends upon controlling the bulk soils to be picked up and
fugitive dust. Air quality studies conducted by the State during a trial
roadside pick-up indicated that fugitive airborn PCB particles were far below
recommended NIOSH standards providing that dust suppression measures, as out-
lined in the remedial response plan, were followed. It is concluded then that
respiratory equipment and special clothing will not be necessary for the DOT
roadside clean-up crews. This is based on October 5, 1978 tests and letters
dated October 24, 1978 and October 30, 1978 from EPA that follow.
Protective disposal clothing including boots will be made available to
State employees who want to use them . These will be disposed of i n the
l andf il l .
Fugitive PCB airborne levels at the disposal site can only be speculated
upon but it can be assumed that they would be appreciably higher than those
measuf~d at the roadside pick-up trial . Article 61 (Safety Regulations) of
the contract document for the construction of the PCB waste disposal site
specifies that the contractor "shall adhere to the rules,. regulations, and
interpretations of the North Carolina Department of Labor relating to Occupa-
tional Safety and Health Standards for the Construction Industry (Title 29,
Code of Federal Regulations, 1926, published in Volume 39, •Number 122, Part II,
June 24, 1974 Federal Register) which are hereby incorporated in these require-
ments.11 It is the contractor's responsibility to see that his labor force is
adequately protected. Any State employee located at the landfill during the
disposal operation should have comparable protection.
A 11 workers wi 11 be informed of the ci rcumstanc.es under which they
are to work. This should include the potential r-isks involved if any,
and the fact that steps have been tak~n to minimize all risks as much as possible.
Any worker with a skin rash should be excluded from the clean-up operation. •
This is to avoid confusion if symptoms of PCB contamination (skin rashes) do
occur following the completion of the project. ·
Decontamination· of equipment and vehicles will not be necessary.
57
UnileO :.,tJl f'S
Environmental Prote~t,on
Agency
OEPA
r{,·qrpil ,l
3.J S Cnurllun d S 11 ~t NE
AIIJnlJ GA 30301
1\l.1i>arna. (jror q1<1, Flor tdJ,
M,ssissipp,, North Carolina,
Soulh Car olina. Tennessee.
KPntucky
October 24, 1978
Honorable James B. Hunt, Jr.
Governor of North Carolina
Raleigh, North Carolina 27611
Attention: Ms. Barbara Buchanan
Dear Governor Hunt:
EPA has completed preliminary analysis of samples collected at the
October 5 pilot test of the pickup of the PCB contaminated roadside material.
Our first impression findings are:
-Pretest worker PCB blood levels were within the normal range of
the general population.
-Indoor and ambient air levels were less than 0.1 ug/m3
-Worker breathing zone air levels were less than 1 ug/m3
which is the NIOSH proposed work place standard.
These findings show that air pollution was controlled under the
conditions of the pilot test dig such that the workers and nearby population
were adequately protected.
We are now completing the data analysis and expect to have the final
numbers available soon.
cc: David E. Kelly
Sincerely,
/ David R. Hopkins
Special Assistant to
the Regional Administrator
·:~ U.S. GOVERNMENT PRINTING OFFICE: 1Q78 --746-732 /1304
.-. ' . ; . ~-... -· .' ,.· '""' ,· ...
-
-
;._
,..
Uni:ed State s
Environm e ntal Protectl!Jr'
Agency
&EPA
October 30, 1978
Mr. David E. Kelly
Regr0n .J
14~ Courtldnri StrPLI N [
At!Jnt.1 (j 4 ,0308
Assistant Secretary for Public Safety
North Carolina Department of Crime Control
and Public Safety
Post Office Box 27687
Raleigh, North Carolina
[)~
Dear M~y:
27611
,\l,1IJ;11n;1, Georqrci. Fl,Jr ido.
M:,'.,••;srpp,, No rth r .. ,,r,1,na.
.;u,_,tb C1tru lin,J, Tflrw~~see.
l<'.,•n tur,ky
The EPA-Health Effects Research Laboratory has completed the
analysis of the air samples collected by the North Carolina
Department of Human Resources Division of Health Services during
the October 5, pilot test of PCB contaminated soil removal. The
data is today being sent directly to Pat Curran of Dr. Hines staff.
Review of this data confirms our earlier opinion that the NC-DOT
workers wearing protection were not exposed to hazardous air levels
of PCB during the test. We will be happy to discuss the data further
with you at any time.
David R. Hopkins
Special Assistant to the Regional Administrator
·.': ll.S. GOVER NMENT PRI NTING OFFI CE: 1978 · -746-732/1304
SEC "i::Tt',ri f'S OH=ICE
N. c. D!:;Jl. of Crime Control
Pu b!ic Safety
I. Project Contingency Plan
DOT vehicles equipped with mobile radio units will routinely survey
the haul routes for accidents or mechanical difficulties. Reporting of
problems will be by radio or phone. In the event of a wreck or mechanical
trouble a DOT stand by crew will be dispatched.
Emergency procedures include immediate removal or cover of spilled
soil with tarps, for later removal, by trained DOT crews. The Highway
Patrol would be called to secure the area in case of spill. NRCD
employees would sample to insure contaminated soil down to 50 parts per
million PCB are picked up.
If a spill occurs near a stream special precautions would be taken
to insure that surface water would be diverted around the spill.
60
. )
J. Community Relations Plan For Remedial Action
This community relations plan outlines activities to be conducted during
a Superfund remedial action to clean up PCB spills alongside 210 miles of
roadway in North Carolina . Under the terms of a cooperative agreement with
EPA, the lead in this action will be assumed by the North Carolina Department
of Crime Control and Public Safety. Other agencies of the State will contri-
bute to the implementation of the response action . The schedule of activities
in the plan is closely matched with the technical project schedule, which
calls for a completion of all work within 181 days of initiation.
A. Background and Key Issues
1. History
In the summer of 1978, approximately 35,000 gallons of oily
liquid were intentionally discharged from a truck along the
· shoulders of 210 miles of roadway in 14 North Carolina counties .
Subsequent analysis indicated that the liquids contained poly-
chlorinated biphenyls (PCBs). Soil along the roadways was found
to be contam i nated with PCB.s .
To contain the PCBs temporarily, roadway shoulders were
sprayed with a solution of activated charcoal and liquid asphalt .
Subsequent testing has not indicated any significant migration of
PCBs from the roadside soil, or any groundwater contamination.
The individuals responsible for the discharges were later appre-
hended and convicted, and the state has filed a $12 million civil
lawsuit to recover damages from the spill.
The roadways along which the discharges took place are located
in 14 rural counties in the east-central part of North Carolina.
Despite the sparse population of the areas in which the dis-
charges took place, public interest in the incident initially was
high. Press coverage was widespread through the state (the case
later was repeatedly cited in the national press to demonstrate
the need for Superfund legislation). A public meeting held
shortly after the discovery of the contamination attracted hundreds
of people and grew fairly heated. North Carolina's governor stated
his intention to have the PCBs cleaned up as quickly as possible.
Several people blamed health problems upon exposure to PCBs but the
problems that were reported, upon investigation, were not found to
be symptomatic of PCB exposure.
Public interest in the roadside discharges soon shifted to a
proposal for a landfill to dispose of the contaminated soil, a
point discussed below.
The State of North Carolina considered a number of alternatives
for resolving the problem, but was restricted to the following
approach. The stretches of roadway where the discharges took place
have been grouped into 15 sites. A 3-inch deep and 30-inch wide
61
...
trench will be dug in the roadway shoulders to remove soil con-
taminated with PCBs. The contaminated soil will be trucked to
a landfill that will be constructed solely for the disposal of
this material, sealed when the clean-up is completed, and moni-
tored. The proposed di spo sal site in Warre n County con sists of
aP1J}!1'oxi mat ely t4'2 ac res, fi ve acres of which will be used for
the landfi 11.
The clean-up operation will be the first action taken on
the contaminated roadsides since 1978, apart from spot sampling
and testing. Despite high visibility, the operation will not
look much different from ordinary roadwork, and workers will not
need to wear protective tlothing. ·
2. Key Issues
The following issues, which we~e taken into consideration
in designing the community relati ons program, are likely to have
some effect on the conduct of the remedial action .
a. Opposition to landfill in Warren County --The proposed
disposal site is strongly opposed by some residents of Warren
County as well as by the county commissioners, who brought an
unsuccessful suit against the state to prevent the site from
being used for the disposal of contaminated soil. Many com-
munity leaders also have joined in the opposition . There
have been threats of civil disobedience when the landfill
construction begins .
The landfill site is on state property in a remote area of
Warren County, which is rural and sparsely populated.
b. Truck traffic and routes --The proposed project schedule
calls for hauling up to 40,000 cubic yards of soil from five
simultaneous roadside pickup operations, at a rate that will
send 25 trucks per hour to the disposal site. The high volume
of truck traffic is likely to cause concern among residents of
the 14-county area about the routes used and the safety pre-
cautions being taken.
c . Coordination with clean-up of a federal facility --The clean-
up of the contaminated roadside at Fort Bragg, a federal mili-
tary facility, will not be part of this reponse action.
Negotiations are underway, however, to use the Warren County
landfill t o dispose of contaminated soil from Fort Bragg. The
community relations effort may have to extend to Fort Bragg
and involve Army officials.
8. Objectives of The Community Relations Program
The overall objective of the community relations program is to
provide public inf ormation, as a remedial alternative already has
been selected and was previously subject to public review. Sufficient
62
advance information will be given to local officials, citizens, and
the news media to prevent any surprises that could cause unnecessary
friction. All information will be clear, detailed, and accurate~ so
that misconceptions about the remedial action will be minimized.
Means will be available by which to bring inquiries or concerns to
the attention of government officials, so that clean-up work is
conducted in the manner most acceptable to local officials and the
affected citizens.
More specific objectives are as follows:
1. Give advance notice to county officials of roadside clean-up .
schedules.
2. Ensure that citizens are well-informed about safety precautions,
truck routes, and related matters.
3. Provide the news media with accurate information.
4. Ensure that there is one person ultimately responsible for answer-
ing inquiries and speaking on behalf of the state.
C. Community Relations Techniques To Be Used
1. Press Conference
2. Notification of County
Officials
3. Press Releases
63
To announce the award of funds for
the PCB clean-up, and initiation
of the project. Presentations by
top state and EPA officials. A
media question and answer period
will be included as a part of the
press conference.
Mail or telephone notification of
the clean-up to county commissioners,
county managers, and health directors
in the 14-county area prior to the
press conference announcing the clean-
up. The N.C. Association of County
Commissioners also will be notified
in advance of the press conference.
A second notification approximately
one week later will contain schedules
for roadside work in each county and
proposed timetables for the clean-up.
To provide the news media with the
detailed and accurate information on
the clean-up. These will be issued
when the roadside clean-up is completed
in each county, and when the entire
remedial action is completed. Addi-
tional releases will be issued, if
needed, to inform the general public
about other aspects of the clean-up.
4. 11 Careline11 To ensure timely response to public
i nqui ri es. The existing 11Care line 11
toll-free telephone system in the
Department of Human Resources will be
used, and the toll-free 11 Careline11
number will be widely circulated.
5. Public Service Announcements --To inform residents of scheduled road-
side work, methods of clean-up, etc.
Short taped notices for radio and TV,
and display advertisements in state
newspapers will be used whenever
necessary.
6. Informational Packet
7. Site Tours
A series of fact sheets to be given
to county officials and to the media
as a source of detailed information
about the clean-up.
Times will be arranged during which
the press and county officials can
visit roadside clean-up projects in
each county, and observe the landfill
under construction in Warren County.
This will enable the media and county
representatives to observe the clean-
up firsthand, and have their techni-
cal questions answered. This method
also will ensure safety by controlling
access to construction areas.
8. Mailing to Interested Citizens
In Warren County --To ensure that citizens who have in-
d1cated special concerns about the
landfill are given complete and undis-
torted information. The information
packet wi ll be included in information
mailed to these citizens.
9. Final Report
D. Work Plan and Schedule
Activity
Notification of Officials
Press Conference
Press Releases
11 Careline11
Informational Packet
Public Service Announcements
64
1982:
A summary of the community relations
program will be submitted to the U.S.
E.P.A. upon completion of the project.
May June July Aug. Sept. Oct.
(Ongoing)
(Ongoing)
prepared
(Ongoing)
,-
ACTIVITY
Site Tours
Mailing to Residents
Final Report
E. Staffing Plan
Date
1982:
ACTIVITY
5/12
5/13
Notification of Officials
Press Conference
l 0/5, 10/30 Press Releases
(Ongoing) "Carel ine 11
(Ongoing) Public Service
Announcements
Inf ormati ona l Packet
5/30, 7/30 Site Tours
5/24 Mailing to Residents
10/30 Final Report
65
May June July Aug. Sept. Oct.
Ji_ prepare at completion of project
STAFF RESPONSIBILITY WORK HOURS
Bryant Haskins (OHR) 40
Bryant Haskins,
Russ Edmonston (CC&PS), 35
G. Kenna (EPA)
B. Haskins, R. Edmonston, 40 Cy Lynn (DOT) , G. Kenna
B. Haskins, R. Edmonston 40
B. Haskins, 40 R. Edmonston
B. Haskins, R. Edmonston, 40 E. Breckling (OHR)
B. Haskins, R. Edmonston 24
B. Haskins, E. Breckling 20
B. Haskins 8
PART II I
APPENDIX
JAMES B. HUNT, JR.
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
RALEIGH 27611
GOVERNOR
DIVISION OF HIGHWAYS
W ILLIAM A. ROBERSON , JR. March 19, 1982 ~~~ SECRETARY 'l!J ~fir! ( -.
' '-'.J ...... ;
. ~;Ir
.. ti~ l ,9 >, ~!!//
MEMORANDUM TO: ~ 'e¾.©;;,_~'!; ~-:' Mr. David K~lly · . ~" 1-fi;(?,)f,0 <
FROM:
~wt ~(2¥:.-
111 C Ad ."'411;,,..~rq,;;•;_fC~ 1· • • ams ... -·<e>". ,
SUBJECT: -
~~f~
Estimated Cost of PCB Removal, Haul and
Disposal; and, Reconstruction of Shoulders
Per your request, our Department of Transportation submits
the following estimate to perform the subject work along 211
shoulder miles of state highway system routes contaminated by PCB: ~ .
(1) Removal, Haul and Disposal
(2) Reconstruction of Shoulders
Total
$1,200,000
800,000
$ 2,000,000
Removal, Haul and Disposal -This work includes the
removal, haul and disposal of material removed from
the shoulders in a strip 3" deep, 30" wide.
Attachment No. 1 represents a personnel and equipment
crew size daily cost necessary to perform the required
work based upon an average weighted haul distance of
65 miles and a 10-hour per day work schedule. This
mileage was computed based upon length of individual
contaminated sections and map mileage froo these
segments to the proposed landfill in Warren County .
We have estimated a daily production for t h is crew
to be 315 cubic yards or 2.1 shoulder miles. This
includes a 20% factor for swellage due to vegetative
materials. This would require a total theoretical
cost of $767,000. We have also estimated our crews
would be required to stay out overnight approximately
75% of the time requiring a cost of approximately
$130,000.
66
Mr. David Kelly
Harch 19, 1982
Page 2
Therefore, the theoretical cost of performing the
work would be $897,600. In consideration of
equipment breakdown time and daily weather conditions,
we estimate this crew to work at approximately 7 s~:
efficiency. Accordingly, the estimated cost is
$1,196,800, say $1.2 million.
Reconstruction of Shoulders -Attachment No. 2
represents a crew size daily cost necessary to
reconstruct the shoulders. It is estimated this
crew would be required to work the same schedule
and would requi re the same time frame as the removal,•
haul and disposal crew.
Accordingly, the theoretical cost of reconstruction,
based on 101 workdays is $383,800. We have also
estimated that approximately 1.5 million square yards
of shoulder area and borrow material area would have
to be seeded and mulched. Our cost records indicate
this cost to be approximately $0.15/sq. yd. or
$225,000 . . i We have estimated this crew to work at approximately
~5% efficiency resulting in a total estimated cost
of $811,700 say $800,000.
If I can provide any additional information, please let
me know.
MCA/pw
Attachr:lents
cc: Mr. Billy Rose
Mr. Frank Coleman
67
Attachment No. 1
REMOVAL HAUL AND DISPOSAL
CLASSIFICATION
1 -MCL IV
2 -MCL II
3 -MO IV
3 -MO II
3 -MO I
4 -GUW
35 -Truck Drivers
PERSONNEL
HOURLY RATE
$ 11. 24
8.97
9.15
7.80
6.88
6.29
6.40
·k + 20% Additive
* Payroll Additive plus overtime
TYPE
2 -Motor Grader
1 -Athey Loader
1 -Tractor w/Broom
35 -24,000 GVW Trucks
1 -Pickup Truck (radio)
1 -Dozer
2 -Hydroseeder
1 -Lube Truck
1 Traffic Barrier
+ Fuel
EQUIPMENT
HOURLY RATE
$ 11.10
14.60
5.00
5.00
2.62
17.00
7.20
8.20
1.72
To t al daily Personnel and Equipment Cost
MCL -Maintenance Crew Leader
MO -Machine Operator
GU~~ -Genera 1 Uti 1 i ty Worker
68
$ 7,600
DAILY COST
$ 112.40
179.40
274.50
234.00
206.40
251.60
2,240.00
$ 3,498.30
699.66 S 4,197.96 say $4,200
daily
DAILY COST
$ 222.00
146.00
50.00
1,750.00
26.20
170.00
144.00
82.00
17.20
$ 2,607.40
750.00 s 3,357.40 say $3,400
RECONSTRUCTION OF SHOULDERS
PERSONNEL
CLASSIFICATION
1 -MCL IV
2 -MCL II
4 -MO IV
2 -MO II
2 -MO I
10 -Truck Drivers
4 -GUW
TYPE
2 -Pickup Trucks
4 -Motor Graders ,
1 -Hydroseeder I
1 -Pneumatic Roller SP
1 -Athey Loader
1 -Front End Loader
1 -Tractor Broom
10 -24,000 GV\J Trucks
HOUR.LY RATE
$ 11.24
8.97
9.15
7.80
6.88
6.40
6.29
+ 20% Additive
EQUIPMENT
+ Fuel
HOURLY RATE
$ 2.25
11.10
7.20
8.58
14.60
11.50
5.00
5.00
Attachment No. 2
DAILY COST
$ 112.40
179.40
366.00
156.00
137.60
640.00
251. 60
$1,842.60
368.52
$2,211.12 say $2,200
DAILY COST
$ t~s. oo
444.00
72.00
85.80
146.00
115.00
50.00
500.00
$1,457.80
150.00
$1,607.80 say $1,600
Total daily Personnel and Equipment Cost $ 3,800
69
-.. -----I.----.
North Carolina Departmen t oP
Crime Control ~
& Public Safe ty
512 N. Salisbury Street P. 0. Box 27687 Raleigh 27611-7687 [phone]
James B. Hunt, Jr., Governor
Mr . Charles Jeter
Regional Administrator
Environmental Protecti on Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr . Jeter:
April 16, 1982 Heman R. Clark, Secretary
As you are aware, North Caroli na is currently preparing an application for a
"Super Fund 11 grant for the purpose of removing and disposing of PCB contaminat ed
soils al ong North Carolina highways . If the grant is awarded , North Carolina will
be seeki ng credit for out-of-pocket State funds expended between January 1 , 1978
and December 11, 1980 pursuant to Section 104(c)(3) of the Act .
The purpose of this l etter is to request a cred i t verification by E.P.A. I
have been des ignated as fiscal officer for t his pr oject and will be responsible for
provi ding the documentattbn supporting t he State 's expenditures . Attached is a
gross accounting of State expenditures totaling $286,862 during the applicable
peri od . These were pr oject related costs incurred whi ch have not been clai med as
matching costs under any other federally sponsored project or program. Since it
is our understanding that the State cannot be r ei mbursed fr om the Fund for credit
in excess of our matching share , I have not listed other substantial expenses
incurred in investigating the dumping; locating, purchasing and designi ng the land-
fill site; prepar ing t he environmental i mpact statement; defendi ng l awsuits; and
other administrative ma tters . Please contact me concerning arrangements for t he
audit .
As you are aware, the State is anxious to proceed with the project as quickly
as possible . It i s our understandi ng that the credit verification need not be
compl eted before the award of a grant; nonetheless, we i✓Ould like to ge t the rr.atter
resol ved i n a timel y fashion so as to enable us to undertake necessary fiscal planning.
Pl ease do not hesit ate to contact me at t his add ress or telephone number (919)
733-2193 if you should have any ques t ions or need any additional info1~mation .
Attachment
cf : /41 Hanke -EPA Atlanta
Kitty Taimi-EPA Washingt on
Sam Morekas--EPA Washington
70
Si ncer ely,
7:?~---c\ A.\_:~L=.:
Raymond A. Lichtner, CPA
Controller
e
NORTH CAROLINA/ENVIRONMENTAL PROTECTION AGENCY COOPERATIVE AGREEMENT
PROJECT EXPENSES INCURRED BETWEEN JANUARY 1, 1978 AND DECEMBER 11, 1980
Personnel }
Fringe Benefits
Travel
Equipment
Supplies
Contractual
Construction
Other
Total Direct
Indirect Charges
TOTALS
NOTES :
.I
''
ACTIVITY
A
$ 29 ,587
100
13,174
1,275
$ 44,536
ACTIVITY
B
$ 60,359
552
35,912
144 ,172
1,331
$242,326
$242,326
TOTAL
652
49,086
llf5 ,447
1,731
$286 ,862
$286,862
Activity A represents project expenses incurred by the N.C. Department
of Na t ural Resources and Community Development for laboratory sample
analysis . Personnel costs were $24,907 and fringe benefits were $4 ,680 .
Activity B represents project expenses incurred by the N.C. Department
of Transportation for initial remedial measures, demonstration projects
and test pic~s. Approved standard labor rates fer personnel comingle
salary and fringe benefit costs. Equipment amounts are for documented
charges based on usage rates.
71
i
~ .. :3':k~'.T':'f!!ll!i ... PiiM!.P~'owr~-,~~.!-':-lt.~~.:-.~"ln:f~~~~-------...
•·v ·; B. Hunt, Jr., Governor
Ms . Linda Washington
PM 216
North Carolina Departme nt of
Crime ControJ ..-rii
& Public Safett 7'
512 N. Salisbu,y Street I'. 0 l3u, ::!/t',87 l?uleigli :D61 I /bj/ "/ 1'11 11, .
May 7 , 1982
Grants Administration Di vision
Environmental Protection Agency
L10l M Street , SW
Washington , DC 20460
Dear Ms . Washington:
'; )'·,)
I n response to Kitty Taimi's and Al Hanke 's r equest , we are attaching work
sheets to show how we arrived at the cost figures on pages 12 and 13 of the N. C.
PCB Clean Up Applicati on. Figures reflected on page 13 are totals taken from the
break out by agency found on page 12. Since the origi nal cos t f i gures were compu ted
by different agencies with costs involved , we have developed the attached work s heets
t ha t way.
Attachment "A" is for -
Activity 1 and 8 (Department of Human Resources )
Attachment 11 B11 i s for -
Activity 4 (Depar tment of Natural Resources and Community Development)
Attachment "C" i s for
Activity 6, 6A, and 7 (Department of Transportation)
We hope this more detailed break out of costs meets your requirements . The
cost figures are estimates . Reimbursement will be by documented expenditures.
WWP ,Jr ./kp
Attachments
cf: Kitty Taimi
Al Hanke
i/~l y J.~ J .
Wi lliam W. Phillips , Jr .
Project Officer for N.C. PCB
Super Fund Application
Attachment "A"
Worksheet for Activity
Community Relations Program
Travel -$2500
This figure uses the state rate times the number
of vehicle miles and subsistence days.
10390 miles @ 18¢ = $1870
18 days @ $35 = 630
Total $2500
Travel would be from Raleigh to 14 PCB spill counties
and to landfill site in Warren County -(see pages 63-65
of application for list of work activities)
Supplies -$1 , l 00
This figure includes materials needed for press releases,
public service announcements, mailing to residents,
information pack ets and printing.
O.ther Costs -$15,500
This figure includes monies for:
phone services (long distance calls,
"Careline") -$5,500
advertising-$9,000
(display ads let people know when clean up takes
place)
equipment -$1,000
(document clean up with camera work)
See pages 63-65 of application for list of work activities.
Attachment "A" (continued)
Worksheet for Activity 8
Travel
Sampling and Analysis at Landfill
$5,000
Included is vehicle travel from Raleigh to
Warren County landfill to monitor construcion
of the landfill and pick up samples.
(see page 38 for list of work activities)
20972 miles@ 18¢ = $3775
35 days @ $35 = $1225
Total $5000
Contractural $15,000
This money would cover costs of running analyses
for:
-36 samples to determine base line data
-36 samples (every 30 days during landfill
construction, 120 days)
144 samples
(total 180 samples analyzed '9 $75 each)
(see page 38 for list)
Attachment "B"
Worksheet for Activity 4
Sampling and Analysis
Supp lies -$3 ,500
This cost is to cover the material needed to collect the samples from
the spill area. Some of the supplies needed incl ude: sampling tools ,
sample containers and gloves .
Travel -$6 ,500
This cos t is to cover the travel and s ubsblcnce cost for t r avel from
Ra leigh to the fourteen (14) PCB counties t o collect the samples for
analysis . The cost is estimated to be as f ollows:
travel: 16,666+ miles @ .18¢/mile
subsistence: 100 man -day @ $35/man-day
$3,000
3,500
$6,500
See pages ]Lf-36 of the App lication for list of work activity.
.Attachment "C"
JAMES B. HUNT, JR.
GOVERNOR
WILLIAM R. ROBERSON, JR.
SECRETARY
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
RALEIGH 27611
May 7, 1982 DIVISION OF HIGHWAYS
MEMORANDUM TO : Mr . William ~~~t}ips
M. c. Adams pt1b' FROM:
SUBJECT: Application For Cooperative Agreeme nt
Between The U. S . Environme ntal Protection
Agency And The State Of North Carolina -
PCB Removal and Disposal
Per telephone coversation with Mr. Emil Breckling, I am
submitting below additional details r elative to our Department's
cost estimate for the removal and haul of PCB contaminated material
and the r econstruction of shoulders. These estimates are refe renced
t o Page 12 of the Application.
(1) Activity 6 -Remova l and Transportation of
Contaminated Soil -
(a ) Personnel $591,314 -As indicated on Page 68
of the Application, we have estimated daily labor
cost to be $4200. On the basis of t he estimate d
daily production rate s e stimated on Page 66 and
67 of the Application, it is estimated o ne crew
would be required t o work 134 days to complete
the project. The theoretical labor cost i s there-
fore $4200 X 134 days or $562,800. The discrepancy
between the Application and the theoretical amount
is in r ounding of f the total estimate of $1.2 mil l ion .
(b) Trave l -$130,000 -This ite m i ncludes only per
diem expense and does not include any "travel"
to and from work site or o ther incidental travel .
On Page 66 of the Application we have estimate d
the work crew will b e required to stay away from
home 75% of the work time or 75 days. Estimated
cost is therefore 51 persons X 75 days X $35/day =
$133,875. The discrepancy between theoretical
amount and estimat ed amount is the result of
Mr. William Phillips
May 7, 1982
Page 2
rounding off the total cost to $1.2 million.
(c) Supplies -$3000 -This is the es timated amount necessary
to equip the crew with boots , gloves, r espirators and
coveralls as required. We plan to use 5 working crews
or 256 personne l. The average estimated cost per employee
is therefore $11.72.
(d) Others -$478,686 -This e xpense r e lates t o equipment rental
and fuel cost. On Page 68 of the Applicatio n we have
estimated a daily cost of $3400. On the basis of the
es timated daily productivity rate shown on Page 66 and 67
of the Application , it i s estimated one crew would be
r equired to work 134 days t o complete the project . The
theoretical estimate and fuel cost is therefor e $3400 X
134 days or $455,600. The discrepancy between the theoretical
amount and Application amount is in rounding off the $1.2
million e stimate .
The e s timated total equipment r e ntal and fuel cost is
further broken down as follows:
Labor Parts & Supplies De preciation Fuel Amount
$75,637 $136,147 $86,983 $179,919 $478,686
(2) Item 6A -Access Road To Landfill Site
Labor
$2400
Our forces have b een unable to perform any preliminary
engineering on this project because of legal and local
community concerns. Accordingly, our estimate of $40,000
to construct one-half mile of access road is based upon
historical data on similar construction by State forces.
This is based upon a 20' travelway with a 10-inch com-
pacted stone base course.
With respect to "Supplies", this estimate is based on
approximately 3500 tons of aggregate base course at a
unit price of $5.71 per ton.
With respect to "Others", this estimate is related to
rental of State-owned construction equipment and fuel
cost broken down as follows:
Parts & Supplies Depreciation Fuel Amount
$4320 $2760 $2520 $12,000
Mr. William Phillips
May 7, 1982
Page 3
(3) Item 7 -Roadway Shoulder Reconstruction
Labor
(a) Personnel -$416,146 -As outlined on Page 69
of the Application, we have e stimated daily labor
cost for reconstruction of shoulders to be $2200.
On the basis of productivity rates estimated on
Pages 66 and 67 of the Application one crew would
be r equired to work 134 days to complete the project.
Accordingly the personnel cost is estimated to be
$2200 X 134 days or $294,800.
The balance of the personnel cost (121,346) is
related to seeding, mulching and other n ecessary
erosion control work. We have estimated that 1.5
million square yards (210 shoulder miles at 12 1
wide including borrow area) will have to be treated.
This equates to an estimated cost of $0 .08 per
square yard.
(b) Supplies -$9?.25 0 -This is the estimated cost of
seed, mulch , lime and fertilizer to seed and mulch
approximately 1 ,5 million square yards at a unit
cost of $0.06 per square yard.
(c) Other -$291,604 -This estimate d cost relates to
r e ntal of State-owned equipment and fuel expense.
As outlined o n Page 69 of the Application, we have
estimated a daily cost of $1600 for reconstruction
of shoulders. On the basis of productivity rates
estimated on Pages 66 and 67 we have es timated 134
orew days will be required to complete the work.
Accordingly , the estimated cost is $214,400.
The balance of equipme nt rental and fue l cost ($77,204)
is related to the seeding , mulching _and o ther necessary
erosion control work to be performed -over approximately
1.5 million square yards. This equates to $0.05 per
square yard .
Equipment rental and fuel cost is further broken down
as follows:
Parts ,& Supplies Depreciation Total
$54,301 $97,741 $62,446
Fuel
$77,116 $291,604
The request for additional details was not very specific, however,
we have attempted to provide that information as we interpreted the
Mr. William Phillips
May 7 , 1982
Page 4
r equest. Please be assured t hat our Depart me nt stands ready to
pro vide any additional informati on or c larification that may be
required.
MCA /ph
cc : Mr . Billy Rose
Mr. Frank Coleman
Mr. Jim Med lin
~ (,
North Carolina Department of 'C---r)v' I __ .) -~-7, 0 '-;
Crime Control .,,,.,a
& Public Safety
512 N. Salisbury Street P. 0. Box 27687 Raleigh 27611-7687 [phone]
James B. Hunt, Jr., Governor
Mr. Al Hanke
Environmental Scientist
EPA Region IV
Remedial Action Section
345 Courtland Street, NE
Atlanta, GA 30365
Dear Al:
May 25, 1982 Heman R. Clark, Secretary
Attached are rev1s1ons requested in the PCB Clean up application.
Please substitute these four pages for pages 3, 57, 61 and 62 in
the application.
WWPj r :jj
cc: Kitty Taimi
~~~ ~ ..
William W. Phillips, Jr. I(
Assistant to the Secretary
Office of Emergency and Remedial Response
Enc.
'
C. Summary of Budget Information
The estimated costs for the total remedial project is estimated to
be:
Community Relations
-Landfill Construction & Engineering
-Sampling and Analysis ( Pre and Post Pickup)
-Landfill Road Construction, Removal,
Transportation, and Deposition of Soil
-Shoulder Reconstruction
-Landfill Monitoring
$ 20,700
450,000
10,000
1,243,000
800,000
20,000
$2,543,700
Revised per 5/18/82 telephone conversation between
Kitty Taimi and Bill Phillips
3
r .
H. Safety Plan For Remedial Action
The purpose of the project safety plan is to provide adequate health and
safety protection for the workers involved in the pick-up and deposition of
PCB contaminated materials. It is not felt that any special precautions will
be necessary to protect the general public except to keep them away from the
operational areas.
Since the PCBs have lain on the roadside for over three years it can be
assumed that they have assimilated to the available soil particles and
activated charcoal applied for just such a purpose. The containment of the
PCB materials depends upon controlling the bulk soils to be picked up and
fugitive dust. Air quality studies conducted by the State during a trial
roadside pick-up indicated that fugitive airborn PCB particles were far below
recommended NIOSH standards providing that dust suppression ·measures, as out-
lined in the remedial response plan, were followed . It is concluded then that
respiratory equipment and special clothing will not be necessary for the DOT
roadside clean-up crews. This is based on October 5, 1978 tests and letters
dated October 24, 1978 and October 30, 1978 from EPA that follow~
Protective disposal clothing including boots will be made available to
State employees who want to use them. These will be disposed of in the
l andfi 11.
Fugitive PCB airborne levels at the disposal site can only be speculated
upon but it can be assumed that they would be appreciably higher than those
measured at the roadside pick-up trial. Article 61 (Safety Regulations) of
the contract document for the construction of the PCB waste disposal site
specifies that the contractor "shall adhere to the rules,. regulations, and
interpretations of the North Carolina Department of Labor relating to Occupa-
tional Safety and Health Standards for the Construction Industry (Title 29,
Code of Federal Regulations, 1926, published in Volume 39, Number 122, Part II,
June 24, 1974 Federal Register) which are hereby incorporated in these require-
ments.•• It is the contractor's responsibility to see that his labor force is
adequately protected. Any State employee located at the landfill during the
_disposal operation should have comparable protection.
A 11 woi:-ker:s will be informed of the ci rcumstanc.es under wli.i ch they
are to work._· This should ihcl:ade .the potential risks tnvo1ved if .any,
and the fact that steps ·have been tak~n to miriimtie all risks as much as possible.
Any worker with a skin rash should be excluded.from the clean-up operation.·
This is to avoid confusion if symptoms of PCB contamination (skin rashes) do
occur following the completion of the project.
Decontamination· of equipment and vehicles will not be necessary.
57
r .. • f . .
J. Community Relations Plan For Remedial Action
This community relations plan outlines activities to be conducted during
a Superfund remedial action to clean up PCB spills alongside 210 miles of
roadway in North Carolina. Under the terms of a cooperative agreement with
EPA, the lead in this action will be assumed by the North Carolina Department
of .Crime Control and Public Safety. Other agencies of the State will contri-
bute to the implementation of the response action. The schedule of activities
in the plan is closely matched with the technical project schedule, which
calls for a completion of all work within 181 days of initiation.
A. Background and Key Issues
·1. Hi story
In the summer of 1978, approximately 35,000 gallons of oily
liquid were intentionally discharged ·from a truck along the
shoulders of 210 miles of roadway in 14 North Carolina counties.
Subsequent analysis indicated that the liquids contained poly-
chlorinated biphenyls {PCBs). Soil along the roadways was found
to be contaminated \'lith PCB.s.
To contain the PCBs temporarily, roadway shoulders were
sprayed with a solution of activated charcoal and liquid asphalt.
Subsequent testing has not indicated any significant migration of
PCBs from the roadside soil, or any groundwater contamination.
The individuals responsible for the discharges were later appre-
hended and convicted, and the state has filed a $12 million civil
lawsuit to recover damages from the spill .
The roadways along which the discharges took place are located
in 14 rural counties in the east-central part of North Carolina.
Despite the sparse population of the areas in which the dis-
charges took place, public interest in the incident initially was
high. Press coverage was widespread through the state {the case
later was repeatedly cited in the national press to demonstrate
the need for Superfund legislation). A public meeting held
shortly after the discovery of the contamination attracted .hundreds
of people and grew fairly heated. North Carolina's governor stated
his intention to have the PCBs cleaned up as quickly as possible.
Several people blamed health problems upon exposure to PCBs but the
problems that were reported, upon investigation, were not found to
be symptomatic of PCB exposure.
Public interest in the roadside discharges soon shifted to a
proposal for a 1 andfi l l to dispose of the, contaminated soi 1, a
point discussed below.
The State of North Carolina considered a number of alternatives
for resolving the problem, but was restricted to the following
approach. The stretches of roadway where the discharges took place·
have been grouped into 15 sites. A 3-inch deep and 30-inch wide
61
... ... .,
trench will be dug in the roadway shoulders to remove soil con-
taminated with PCBs. The contaminated soil will be trucked to
a landfill that will be constructed solely for the disposal of
this material, sealed when the clean-up is completed, and moni-
tored. The proposed disposal site in Warren County consists of
app~oxiniately l 42 acres. fiv·e acres of which wi 11 be u·sed for
the i andfi 11. ·
The clean-up operation will be the first action taken on
the contaminated roadsides since 1978, apart from spot sampling
and testing. Despite high visibility, the operation will not
look much different from ordinary roadwork, and workers will not
need to wear protective tlothin~.
2. Key Issues
The following issues, which were taken into consideration
in designing the community relations program, are likely to have
some effect on the conduct of the remedial action.
a. Opposition to landfill in Warren County --The proposed
disposal site is strongly opposed by some residents of Warren
County as well as by the county commissioners, who brought an
unsuccessful suit against the state to prevent the site from
being used for the disposal of contaminated soil .. Many com-
------munity leaders also have joined in the opposition. There
have been threats of civil disobedience when the landfill
construction begins.
The landfill site is on state property in a remote area of
Warren County, which is rural and sparsely populated.
b. Truck traffi·c and routes --The proposed project schedule
calls for hauling up to 40,000 cubic yards of soil from five
simultaneous roadside pickup operations, at a rate that will
send 25 trucks per hour to the disposal site. The high volume
of truck traffic is likely to cause concern among residents of
the 14-county area about the routes used and the safety pre-
cautions being taken.
c. Coordination with. clean-up of a federal facility --The clean-'
up of the contaminated roadside at Fort Bragg, a federal mili-
tary facility, will not be part of this reponse action.
Negotiations are underway, however, to use the Warren County
landfill to dispose of contaminated soil from Fort Bragg. The
community relations effort may have to extend to Fort Bragg
and involve Army officials.
B. Objectives of The Community Relations Program
The overall objective of the community relations program is to
provide public information, as a remedial alternative already has
been selected ~nd was previously subject to public review . Sufficient
62