NCD980602163_19820521_Warren County PCB Landfill_SERB C_Impact Study 1980 & 1982-OCR

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.;:,'" ~,S' ~ ft t> ~ ~ W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ·
\ ct ~4 '\' 1"4lPF101~C, REGION IV
MAY 211982
34!5 COURTLAND STREET
ATLANTA. GEORGIA 303e!S
FINDING OF NO SIGNIFICANT IMPACT'
To All Interested Goverrrnent Agencies and Rlblic Groups:
In accordance with the procedures for irrplementing the requirements of
the National Environmental Policy kt, an Ehvironmental A<5sessment has
been performed on the following proposed EPA action:
APPLICANT:
PROJECT:
PROJECT Nll-ffiER:
LCCA'I'ION:
ESTIMATED EPA SHARE:
ESTIMATED STATE SHARE:
ESTIMATED 'lOTAL:
PROJECT' DE'roUPl'ION:
lt>rth carolina Division of Crime
Control & Public Safety
Remedial l\ction to Clean up PCB
Contaminated Soils
NC 81-E-4900-5214
Raleigh, North Carolina
$2,568,055
$ 285,339
$2,853,394
The intent of this project is to clean up approximately 40,000 cubic
yards of PCB {polychlorinated biphenyl) a::>ntaminated soils located along
the shoulders of 211 miles of North Carolina roactways. 'Ihe proF,Osed
renedial action will accomplish the removal of contaminated soils from
along fifteen segments of highway and the placement of these soils in a
PCB disposal site in Warren County, lt>rth carolina. 'Ihe disF,Osal site
has been api;:roved by EPA pursuant to the Toxic Substances Control Act
(TSCA), 15 U.S.C. §2601, et~-
The soils will be excavated, transported, and landfilled under tightly
controlled conditions. A sanpling program will be implemented during the
course of the reiooval operation to assure that significantly contaminated
material has been rezooved. 'lhe landfill will also be IOOnitored on a
regular basis.
'I'here is a serious need to dispose of the contaminated soils, since PCBs
are very stable COIIp)unds that will remain unchanged in the environment
for an excessive amount of time. Studies using laboratory animals have
shown potential chronic effects such as cancer induction, pigmentation,
and behavioral changes after ingesting PCBs. Accordingly, the reason for
the reiooval of the PCB contaminated soils to a secure landfill is to
prevent the future redistribution of the soils which could increase the
chance of PCB exposure to humans and animals.
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'Ihe environmental review, based on 4 O CFR Part 15 00, has indicated that
no significant adverse environmental irrpacts will result from the
proposed remedial action. 'ltle act ion is necessary to protect public
health, welfare, and the environment and has been designed to mitigate
all potential hazards associate d w.i.th the ?CB contaminated areas. Air
and water quality monitoring conducted d uring a trial run of the soil
rerroval procedures showed no adverse impacts . Measures to control
fugitive dust emissions, erosion and s eciinentation are expected to
mitigate potential adverse i.npacts. Transportation of the excavated soil
to the landfill s i te has been p lanned t o avoid po?,Ilated areas, to
minimize traffic disruption, and to safely handle any accidents involving
haul trucks. 'lbe landfill site was selected after careful consideration
of nurrerous potential sites. 'Itle landfill is designed to provide secure
containment of the contaminated soils. Sampl ing will be conducted to
detect any unexpected leachate from the landf ill and to monitor the
groundwater and surface water qualit y at the landfill site.
'Ihe proposed action was selected aEter ca,~eful evaluation of all viable
alter natives. 'Ihe action has been shown to be environmentally sound and
cost effective. Therefore a decision has been made not to prepare an
Environmental Impact Statement (EIS). 'l his decision was based on a
caref ul review of the State prepared l:IS, Warren Cbunty PCB Waste
Disposal Site Engineering Design, the regulatory program files for the
North carolina PCB spill strip i ncident, t he documents referred to in the
Environmental Assessment prepared t-y EPA a nd other suH?()rting data. All
of these documents, along with the Ehvironmental Assessment, are on file
i n the EPA Region IV office ~here they ar~ available for public scrutiny
upon request. As a convenience, a copy c f t he Ehviroronental Assessment
is attached for your review.
Corranents concerning this project may be 3ubmitted for consideration by
EPA. If you wish to make a corrnnent 1 you sh.)uld write imnediately to:
us Environmental Prob~ction A•9ency
Mr. Al Hanke, Proj ect Manager
Emergency & Remedial 1-<esponsE Branch
345 Courtland Street, NE
Atlanta, Georgia 30 365
or t elephone 404/881-2643.
2?fiU cna~r (
Reg ional ~~trator
El ,closure
ENVIRotM:NTAL ASSESSMENT
A. PROIB:T IDENI'IFICATION
APPLICANT:
PROJFX:T:
PROIB:T NlMBER:
LOCATION:
ESTIMATED EPA SHARE:
ESTIMATED STATE SHARE:
ESTIMATED 'IOTAL:
B. SUMW\RY OF ENVIRON-1EN'mL REVIEW
1. Project Description
North Carolina Division of
Crime Cbntrol & F\lblic safety
Remedial ktion to Clean up
PCB Contaminated Soils
NC 81-E-4900-5214
Raleigh, North Carolina
$2,568,055
$ 285,339
$2,853,394
'!tie State of N::>.rth Carolina proposes to rerrove and dispose of
approximately 40,000 cubic yards of PCB (polychlorinated biphenyl)
contaminated soil. 'lbe / PCB contaminated soil is the result of
deliberate discharges of ap,E:t:oximately 30,000-35,000 gallons of
liquid waste material from a passing truck onto the roadway shoulders
of North Carolina's highways. '!tie discharge of this industrial waste
material containing PCBs has been identified along ap:EroXirnately 211
miles of roadway shoulders located in fourteen central and eastern
piedroont counties of the State, as shown in the attached location map.
'll1e proposed action involves the mechanical removal of the PCB
contaminated soil from the roadway shoulders using road graders and
conveyer systems to load dump trucks which will transport the
material to an ap,E:t:oved disposal site.
DJring the fall of 1978, the State investigated ninety (90) locations
for a possible disposal site to accept the PQ3 contaminated soil. An
area in Warren County, N::>rth Carolina was chosen by the State as the
best location for the PCB disposal site. In December 1978, North
Carolina submitted an application to the EPA Regional .Administrator
for approval of the landfill under the Toxic Substaoces Control Act
('ISCA), 15 U.S.C. §2601, ~ ~-On June 4, 1979, EPA approved the
conceptual design of the Warren County site. A 142-acre tract which
included the five-acre larrlfill site was then acquired by the State
in August 1979. '!be final Plans and Specifications for the site were
approved December 14, 1981.
The landfill will be constructed with major emtxi aS'is on the
protection of surface water and groundwater from potential
contamination from the material buried in the site. 'Ihe design
incorporates artificial and clay liners below the landfill to prevent
hydraulic connection with groundwater and on top of the larrlfill to
prevent infiltration of rain and surface water, as shown in the
attached diagram.
'I.here will also be leachate collection systems installed above and
below the bottom l iner to remove any l eachate, and this system will
be monitored monthly. 'll1ere will be groundwater monitoring wells
installed around the site which will be sampled on a monthly basis
during operation or for a period of one ~ear, whichever is shorter,
and then semiannually after closure. Surface streams located
downgrade from the site will be monitored monthly during operation of
the site and semiannually during the post closure period.
The proposed pr oject will be conducted in two phases. 'Ihis approach
will facilitate the prompt and adequate removal of contami nated soils
and permit a smooth transition to final closure of the 1 andfill up:m
conpletion of the project.
Phase I activi ties will include f foalization of the detailed soil
r eiroval plan which will be irrplernented using one spill strip. All
cleanup operations, from pre-sanpling to backfilling the road
shoulders, will then be conducted on this strip. Cbnstruction of the
landfill and access road will also occur during Phase I.
Phase II will consist I of cleanup activities, from pre-sampling to
backfill, on the remaining spill s trips and may run concurrently
until all spill strips have been addressed. 'Ihe total project is
projected to be completed in four to t ive months.
2. Purpose and Need
Th e purpose of this project is to rem::.ve and dispose o f apµ-ox irnately
40,000 cubic yards of PCB (polychlorinated biphenyl) contaminated
soils to a secure landfill. Polchlorinated biphenyls are highly
s table conpmnds that will remain unchanged in the environment for a
v ery long time . P03 will biologically magnify in food chains and
2ccu."lU.ll ate in t he fatty tissue of bo co hu.'11:llS and animals. Studies
;J sing laboratory animals have shown pc.;centi al chronic ef.:ects such as
cancer induction, pigmentation, and b~havioral chai1ges after
i ngestion of PCBs. Tne PCB contaminated soil could become
translocated into adjacent agncultur.21 crop l ands and may have an
i rrpact on agri cultural cash crops s uch a s tobacco, feeci and for age,
and crops for buman consunption.
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The State of ?lk>rth Carolina considers the remval of the PCB
contaminated soil a necessary action to insure the protection of the
natural and human environment.
In addition, the North Carolina Department of Transportation must
periodically reshape shoulders and ditches adjacent to state highways
in order to maintain safe ingress and egress for the traveling public
and to maintain proper cross slopes for storm drainage. W1ile 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 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 oontaminated soil in a manner which would be
very difficult if not inpossible to control.
3. Alternatives Considered
The preferred alternative is excavation of the contaminated soil with
transport to a secure in-State landfill, followed by reconstruction
of the highway shoulders. All the remedial options considered in
addition to the preferred one are described below:
a. In-Place Treatment
At one time the State prqposed to treat the PCB contaminated roadside
soils in-place by admixing with adsorptive and stabilizing
materials. Accordingly, early in 1979 the State petitioned the EPA
Administrator under _Section 21 of TSCA to modify Section 761.lO(b) of
the PCB Disposal and Marking Regulation (40 C.F.R. §761.10 (b)) to
allow the EPA Regional Mministrator discretion to approve disposal
of PCB contaminated debris or soil in ways other than by incineration
or in chemical waste landfills meeting EPA requirements.
In June 1979, the Administrator disapproved the State petition to
allow in-place treatment because there were no known environmentally
acceptable disposal alternatives other than EPA-aP};Coved chemical
waste landfills and incinerators. Several other inplace treatment
alternatives were later explored:
(1) Q>odyear PCB Detoxification Process
'ltie Research Division of the Goodyear Tire and Rubber Conpany
has developed a PCB detoxification process; however, the pr-ocess
is designed for PCB fluids, not absorbed PCB and solid mixtures.
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b.
\
'!be only way the Goodyear process could be applied would be to
first extract the PCB from the soil mixture. Wiile extraction
and detoxification is possible, it is neither practical nor
econanical.
(2) Franklin Research Institute Process
A process for the destroction of PCB 's in-place, developed by
the Franklin Research Institute in Philadelphia, PA, involves
canbining the contaminated soil with a reagent (sodium
polyethylene glycolate) which in turn would gradually break down
Pa3's. However, the process has been demonstrated successfully
only under laboratory conditions and has yet to become an
accepted method •
Ex:cavation and Transportation to a PCB Material Incinerator
Three incinerators have been identified as having the capability to
destroy the PCB material through incineration. 'Ihese incinerators
are located in New Jersey, Arkansas, and Texas. Incineration at sea
is also available. H:>wever, transportation, harxUing logistics, and
incineration fees make this alternative econanically prohibitive (in
excess of $200 million) •
c. Excavation and Transportation to an Existing Out-of-State
Chemical Waste Landfill
Consideration was given ;to transporting the PCB contaminated soil to
the nearest existing chemical waste landfill, located in Alabama,
which is approved to accept P(B wastes. '!his alternative was
considered infeasible because of limited transportation resources,
manpower requirements, and excessive cost of disposal (estimated at
$15 million), as well as the increased logistical problems.
d. No Action (Ib-futhing Alternative)
'I'he no action or "Do-Nothing" alternative is not considered to be a
viable alternative because 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 irrproveirent to meet the transportation
needs of the public. These activities would cause continued
dispersal of the PCB contaminated material to the environment.
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e • Excavation and Transportation to a Specially Engineered PCB
Landfill Located In State
The preferred alternative involves the excavation of the P<l3
contaminated soil, transportation to, and disposal of the soil in an
EPA approved landfill, followed by reconstruction of the highway
shoulders.
Several methods for excavating the contaminated soil fran the spill
locations were examined including: trenchers, pulverizers, vacmnns,
and road graders. During a trial run conducted in October 1978, the
use of road graders with a conveyor belt bulk loading system was
determined to be a technically sound and cost effective excavation
method. Dlring the fall of 1978, the State investigated ninety (90)
locations for a possible disposal site to accept the PCB contaminated
soil. An area in Warren County, North carolina was chosen by the
State as the best location for the PCB disposal site. In Decerrber
197 8, the State sutmi tted an application to the Regional
Administrator for approval of the landfill under the Toxic Substances
Control Act ('!SCA) , 15 u.s.c. §2601, et ~-Qi June 4, 1979, EPA
apµ:oved, with certain conditioos, the conceptual design of the
Warren County site. The final Plans and Specifications for the site
were approved with certain conditions on Decenber 14, 1981.
f. Sunmary of Alternatives
'Ihe alternative selected is the excavation of the contaminated soil
from the spill strips ~or transport to an in-State, specially
engineered PCB landfill which will be regularly monitored. 'Ihe
excavated strips will be backfilled with clean soil and reseeded. An
Envirorurental Impact Statement (EIS) has been published by the State
which describes the removal process and landfill operation.
N:>ne of the in-place alternatives can be implemented without
substantially increasing the risk of further distribution of PCBs in
the environnent by disturbing the contaminated soil. Even normal
usage of the highways would result in some PCBs being distributed in
the environment due to vehicles intentionally or unintentionally
teing operated on the shoulders. '!he incineration alternative and
the alternative of reiroval to an out-of-State existing chemical waste
landfill are l:::oth logistically irrpractical and cost prohibitive. It
has been determined to be in the public interest to reIOOVe the PQ3
contaminated soil from the highway shoulders to a secure landfill so
that the highways can be put to full public use without further
distributing PCBs in the enviroment.
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4. Impacts of the Proposed Project on the Environment
A review of the potential environmental impacts involved in the
rerooval of contaminated soil from the roadside spill sites leads to
the conclusion that there will be a net positive and beneficia l
impact on the environment. A sunrnary of this review follows:
a. Air Q.Iality
Potential fugitive dust emissions from the excavation o f the spill
strips will be controlled by initially wetting the road shoulders and
by use of especially designed water spray nozzles in conjunction with
tractor mounted rotary brooms. D.lring the pilot soil removal study
c onducted in October 1978, air quality was monitored and the results
s ha.ved no significant increase in ambient air concentration of PCBs
d uring the test rerooval and disposal operations. 'Ihe presence of
PCBs in the air was not found to exceed the NIOSH (National Institute
o f Occupational Safety and Heal th) proposed criterion for workplace
air of one microgram per cubic meter, even directly above the spill
sites. Ambient air monitoring was also conducted in seven houses or
other structures along the test removal route. 'Ihe resulting data
from the domicile monitoring showed no levels above O. lD micrograms
per cubic meter, which is well within the proposed NIOSH criterion
for workplace air. Accordingly, it is felt there will be no
s ignificant impacts upon air guality which would adversely affect
personnel engaged in the clean-up operation, area residents, or
passing rootorists.
I b . Water Quality and Quantity
(1) Spill Strips
A short-term water quality impact may occur as a result o f a
very small amount of soil particles contaminated with PCBs being
left in cracks and crevices on the surface of the highway.
'Ihese particles, which are not returned to the shoulder and
incorporated into the soil coll..nnn, may be carried duri ng
rainfall events into drainage channels, ditches, and streams .
Wind could pick up the s oil p articles as dust and create some
migration of particles into adjacent fields. Monitoring results
of the test pickup demonstrate that concentration of PCBs
contained in the soil remaining in cracks and crevices of the
pavement s urface would not be significant.
'l'est results of the wash water utilized in t he clean-up
operation indicate that t here i ~, an extremely weak concentration
of PCB in solution that will be readily absorced by t he soil
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aloog the roadside. Sane pockets of PCB contaminated soils
could possibly remain adjacent to the pavement and these soils
could migrate into the environment through soil erosion.
l:bwever, this amount of PCB material is not expected to be
significant. '!he entire pickup operation will be monitored to
insure that the volume of the contaminated soil residual is
minimized.
Continuous monitoring of selected areas of the spill strips has
indicated that vertical migration of PCB in the soil column has
not occurred, which indicates that groundwater will not be
affected by the soil removal process.
(2) Disposal site
The disposal site has been engineered to protect both surface
water and grourrlwater quality by utilizing nrultiple liners,
leachate collection systems, and erosion control measures and
devices. The grourrlwater resource in the landfill area is not
actively utilized. '!he recharge area is very localized and
limited to the ridge upon which the landfill is to be
constructed. Groundwater flow would be to the south,
potentially energing in outcrops at the base of the ridge and
discharging into the surface streams.
'!be artificial and clay liners have been engineered to prevent
infiltration and exfiltration from the site, thus precluding any
hydraulic connection/ between the PCB contaminated soils and
surface water or groundwater.
If any leachate is generated, it will be withdrawn by the
leachate collection and renoval system as frequently as
necessary. Surface waters will be protected by sedimentation
basins during disposal operations and any PCB contaminated
sediment will be placed in the landfill prior to closure.
Water quality monitoring of the site will be conducted before,
during, and after the construction and operation phases. After
the site is closed, the leachate collection systems will be
roonitored roonthly and the surface waters semiannually. 'Ihe site
will be monitored as long as required by EPA regulations, and if
any system failure ocx::urs, necessary corrective action will be
taken by the State of North Carolina.
The disposal site design provides for stringent environmental
isolation of the PCB contaminated soil; therefore this facility
does not present an unreasonable risk of injury to public health
and the environment.
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c. Envirornrentally Sensi t ive Ar eas -Floodpl ains, Wetlands, etc.
There are no environmentally sensiti ve areas along the roadside spill
right of way. 'Ihese areas have previously been distur t:ed by the
initial road construction and perpetual maintenance being performed
by highway and utilities work crews. 'lbere are no known
envirormentally sensiti ve areas in the vicinity of the disposal site.
d. land Use
'Ihe existing land uses in the vicinity of t he landfill are classifi ed
as rural. The rural areas are comprised of forest, agricultural
land, residential land and, to a lesser extent, industrial land.
e. Biological Resources
'.Ih e PCB contaminated soil is currently accessible and could be
contacted by animals which may be present on the contaminated
r oadside • ., Removal of the soil from t he roadside and its disposition
in the proposed landfill will eliminate its availability to plant and
nnimal life. At the landfill site the contaminated soil will not be
exposed to plant and animal life due to the fact that it will be
totally encased in a plastic lining which will be covered by at least
l . 5 feet of soil. In addition, the entire landfill will be enclosed
i nside a chain link fence which will be maintained in good order as
l ong as post closure monitoring is required. 'lbere are no sensitive
b iological resources which will be disturbed or lost as a result of
construction o f the landf/ill.
Since the actual soil removal operation simulates the normal
Department of Transportation maintenance work along roadways, no
a dverse effect s on the plant o r anirral l ife are expected to result
t rorn the excavation and grading. 'Tue excavated area will be
b ack-filled with soil removed from t he ditch area or trucked in from
a non-contaminated area, and wi ll then be r eseeded. 'Iheref ore, t his
o peration repr esents only a t emporary disruption of the plant 1 i fe
a long these roadways.
Another potent ial irrpact that must be considered i s that of
d isplacement of P\....""13 contaminated soil to t he adjacent area during the
removal operati on . Previous l aborato~y testing by the No r t h Caroli na
Department of Agriculture duri ng the test removal operation found
mi nute am:>unts of PCB on plant fol iage up to several hundred ya cds
distant al ong these roadways. Th is atmospheric translocation is
presumed to be v ia PCB laden d ust o r a erosol spray. 'The areas unc er
consider ation a re all rural, and therefore the possible cont aminati on
o f home gardens and agricultural field crops must be considered.
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With adequate dust control s as derronstrated during the test removal
operations in Warren County, there would be no significant
contamination of crops. 'lbe levels of PCB expected to be found on
such crops would not preclude the usage of these crops. Therefore,
there appears be no short or long-term adverse effect on biological
resources by either the roadside spill site excavation or the
lamfill operation.
f. Archaeological and Historical Resources
'Ihe North Carolina Department of Olltural Resources, Division of
Archives and History has reviewed the disposal site for potential
effects on cultural resources. There are no structures of
architectural importance in the disposal area. 'lbe disposal site was
also reviewed for potential effects on archaeological resources. It
was concluded that there is little likelihood that any archaeological
or historical resources will be affected by the proposed disposal
site. Similarly, there is little likelihood that any archaeological
or historical resources will be affected by the roadside shoulder
excavation process as these areas have already been disturbed by the
original road construction and the normal maintenance procedures of
highway and utilities work crews.
g. Noise
'Ihere will be .some tenp:>rary inpact from equipment noise to
residences located along the roadside shoulder excavation route.
However, this should not; be in excess of noise created by routine
roadside shoulder maintenance/reconstruction activities. There will
be no significant noise impact from the operation of the disposal
site as it is located upon a five-acre section within a 142-acre land
parcel which serves as a buffer zone.
h. Energy Consurrpt.ion
There will be no long-term corrmitment of energy to this project. 'lbe
short~term energy expenditure will primarily be in the form of fuel
for the excavation and transportation equipment.
i • Aesthetics
'Ihere will be a short-term impact upon the aesthetics of the highway
strips during the excavation and reconstruction of the roadside
shoulders. 'ltlis operation will not create any irrpacts in excess of
normal roadside shoulder maintenance. D..le to the buffer zone and
restricted access to the landfill area, no significant aesthetic
inpact will result from the landfill excavation. At closure of the
lamfill, grass will be planted on top of the landfill to minimize
any long-term aesthetic inpact.
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J. Transportation and Co ntingency Planning
I t is not anti cipted that t he removal and hauling operations will
c r eate any major traffic d isruption. '!tie PCB spills are
predominately along rural rout es with relatively low traffic countse
'r'h e removal operation will be quite similar to shoulder and ditch
maintenance operations routinel y carried out by State maintenance
c r ews. These personnel have consider able experience in the handling
o f traffic under these conditions.
One-way traffic will be maintai ned throughout the reroval process at
the sites. Pdvance warning signs in accordance with the Manual
Uniform Traffi c Control Devices and flagmen will be employed.
Errergency vehicles will be given imnediate ingress and egress through
t he areas, and local school officials will be kept posted as to the
location of current work areas.
Ha ul trucks will be dispatched f rom t he reiroval area at approximate 5
minute intervals providing adequate passing distance for following
motorists. The haul routes will also be routinely monitored by
ve hicles equipped with nobile radio units which will survey the haul
r outes for accidents or mechanical difficulties. Reporting of
problems will be by radio or fhone. In the event of a wreck or
mechanical trouble, a DOT stand-by crew will be dispatched.
In the event of a wreck, emergency procedures would include inmediate
removal or cover of spilled soil wit h tarps, for later removal, by
t cained DOT crews. '!tie /Highway Patrol would be called to secure the
area in case of a spill. State employees would sanple 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
i nsure that surface waters are not adversly affected.
k. Public He alth
Based on the NIOSH standard o f 1 microgra.rrym3 of PCB in air, t here
i s no reason to believe that temporary exposure, if any, would create
a health hazard to motorists who may drive past a clean-up operation
or to any resident who lives along a spill r oute. 'I.he NIO SH standard
i s based on t he expected working 1 ife o f an e mployee, i . e . , f or ty
hours per wee k during a lifetime. 1vit hin t his t i.me frame , any
e xposure a motorist or area resident would experi ence woula be
:i nsignificant.
1•1h ile no adverse effect is expected among the personnel involved in
clean-up operations, personal protective wear will be furnished to
v.orkers directly involved with the reITDval and disposal operation.
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In summary, no adverse heal th effects on the workers, motorists, or
persons living along the spill sites are expected to occur during
cleanup.
5. Probable Adverse Impacts Which cannot Be Avoided and Mitigative
.Measures
'Ihe proposed rem::>val and disposal of 'the PCB contaminated soil from
the roadway shoulder will have some adverse effects on the
environment. Several short-term impacts along with mitigative
measures have been described and are summarized as follows:
IMPlC'l'S
a . Sedimentation and Erosion.
b. Inconvenience and annoyance
due to truck loading and
equipnent operation.
I
c. Airborne particulate materials
in the form of fugitive dust
may leave the spill sites.
MITIGATIVE MEA5URES
Rmof f during excavation and
landfill construction will be
prevented by using appro-
pr iate priate control
measures such as sedimen-
tation traps and water
diversion and retention
structures.
Trucks and loading equipnent
will be scheduled to prevent
traffic congestion and
disturbance of residents
living along the spill sites.
The State will be required
to implement measures for
control of fugitive dust (see
section 4a.) •
'Ihe roc>st significant long-term effect at the disposal site will be
removing approximately ten acres of land from agricultural production
for an iooefinite period of time to be used for disposal of PCB
contaminated soils. An additional 132 acres will be utilized as a
buffer zone around the disposal pit. 'Ihe disposal of the PCB
contaminated soils at the Warren County site will restrict any other
land use within the fenced area of the proposed disposal site.
6. '!he Relationship
Envirorunent and the
Productivity
Between Local
Maintenance and
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Short-term Uses
Enhancement of
of Man's
long-term
\
The short-term uses of the project are represented by the excavation
of PCB contaminated soils along 211 miles of roadside and the
transportation of excavated material to the disposal site. 'l."'he
disposal site will be dedicated to the long-term use of containing
the contaminated soils. Construction of the disposal site will
result in an alteration of the physical environment, whereas the
excavation of roadside will be tellp)rary and will not result in any
change.
'Ihe only long-term environrrental loss of the project will be the loss
of ten acres of potentially agricultural land. 'ltiis loss is not
considered significant and will be mitigated by the beneficial
aspects of the project.
7. Any Irreversible and Irretrievable Commitment of Resources
Approximately ten acres of agricultural land will be indefinitely
corrmitted to containment of the roadway soil contaminated with PCB
industrial waste material. Removal and disposal of the PCB
contaminated soil will involve a substantial commitment of resources
including financial expenditures for labor and materials. Al.though
the labor required to perform the proposed action is an irretrievable
cornnitment of resources, benefits in the form of returning the
roadway shoulders to normal usage and removal of a potentially
hazardous industrial waste material from the roadside will offset
this corrmitrnent of the necessary labor and financial resources.
8. Summary of Agency Con~ideration and Public and .Agency Cbnsultation
a. Documents Considered and Public Partici,eation Efforts
The Final EIS enti tied "Removal and Disposal of Soils Cbntaminated
with PCBs along Highway Shoulders in North Carolina" prepared by the
State of North Carolina and the .Addendum to the Final EIS have been
thoroughly reviewed and considered and are incorporated by reference
into this Environmental Assessment (FA) • 'Ihe Draft EIS was
distributed to government agencies through the A-95 Review Process
and to interested persons and groups and announced in the furth
Carolina Environmental Bullen tin issued January 7, 19 00. The Final
EIS and Addendum to the Final EIS contain responses to the comnent.s
received on the Draft EIS.
'The following supplemental documents have been reviewed and
considered and are incorporated by reference into the EA:
(1) 'Ibxic Substances Control Act ('l'SCA), 15 u.s.c. 2ffil et~-
(1976). Section 6(e) of TOCA re~uires the /l.dministrator of EPA
to promulgate regulations for, among other things, the disi::osal
of "PCBs."
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(2) PCB Disposal Regulations, 40 CFR Part 761. 'Ihese
regulations authorize EPA to grant approval for use of Pa3
disposal sites. 'Ihe regulations were the result of the following
steps. Proposed regulations for marking and disposal of PCBs
were published on May 24, 1977 (42 Federal Register 16564).
Also at this time, a support document was made available to the
public containing the basis for the proposed regulations. Four
days of informal hearings were held in Washington, D. c., to
allow for public corrments on the proposed regulations. Numerous
written sutmissions to the rulemaking docket were also
received. Final regulations were published on February 17, 1978
(43 Federal Register 7150, amended, 43 Federal Register 33918,
August 2, 1978) • Further amendments were proposed on June 7,
1978 (43 Federal Register 24802) • '!en days of public hearings
were held in Washington, DC, from August 21 to September 1,
1978. On September 22, 1978 (43 Federal Register 43048), EPA
published a notice of the opportunity for cross-examination and
extended the reply ccmnent period to October 10, 1978. Oller two
hundred carments were received. 'Ihe final regulations were
published on May 31, 1979 (44 Federal Register 31514).
(3) Letter, Governor James B. Hunt, North Carolina, to John c.
White, Regional Mministrator, EPA Region IV, Decentier 12, 1978,
with attached application. In these documents the State of
North carolina applied for EPA approval pursuant to TOCA for the
Warren County waste landfill.
(4) Letter, John C~ W'lite, Regional kiministrator, EPA Region
IV, to James B. Hunt, Governor of North Carolina, June 4, 1979,
with attached Approval O:>rrlitions. In this letter EPA approved
the conceptual design of the Warren County disposal site as
meeting the requirements of 40 CFR 761.41, with the exception of
three items which were waived in accordance with 40 CFR
761.41 (c) (4). This approval followed a public hearing held in
Warrenton, North carolina, on January 4, 1979, to receive
written ccmnents. Written cooments by interested parties were
also accepted. Following the hearing, the State was directed to
engage in further soil sanpling and testing at the site. 'Ihis
information was submitted to EPA on March 8 and 20, 1979.
(5) letter, Charles R. Jeter, Regional ldninistrator, EPA
Region IV, to James B. Hunt, Governor of North carolina,
December 14, 1981. '!his letter gives approval to the plans and
specifications of the Warren County, North Carolina site, as a
PCB waste landfill as authorized by 4 O CFR Part 761, subject to
attached conditions.
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(6) Warren County v. State of North Carolina, 5 28 F . Supp. 276
(E.D.N.C. 1981), and '!wi tty v. State of N:>rth carolina, 527 F.
Supp. 778 (ENOC 1981) and t he full Administrative Record in both
cases. In these two court cases, Warren Cbunty and several
adjoining property owners, respectively, brought suits to
prevent the use of the Warren County site as a disposal site for
the PCB contaminated soil. A Federal district ccurt granted
swrmary judgment in both cases for the State of N:>rth carolina
and the U.S. Environmental Protection Agency.
Public Objections to the Project
The most relevant objections to the project concerned the landfill
site selection process and were voiced by the ~r r-'lar Areawide
Clearinghouse Review Committee and the Jose:fh LeConte Chapter of the
Sierra Club. These groups sutmitted written carments on the draft
State EIS. .Additionally, Dr. Charles Mulchi, a consultant for Warren
County, sut:mitted a statement raising several concerns at-out the
project. His carrrents included the following concerns:
(1) the amount and type of clay soil available at the Warren
County site to be utilized in the soil liner construction;
{2) the failure of the State's proJ?Osed design to meet the EPA
50 ft. regulatory requirement for proximity to groundwateq
(3) the lack of a t eachate collection system beneath the burial
site; and
(4) the absence of the required artificial liner below the clay
liner.
The following are resJ?()nses to these corranents::
Concern (1)
A resanpling of the clayey soils at the Warren County site
i ndicated that the uwer six (6) feet of soils met or exceeded the
required parameter for permeability based upon sufficient conpaction
o f the soil. The type of clay is not of concer n as long as the soil
mechanics parameters are met or exceeded. It was again established
that there was an adequate vo l ume of clay available for the project
located at or in areas adjacent to the site which would meet the soil
mechanics parameters.
Concern (2)
'Ihe requirement that the bottom o f the waste cell must be located
a t least 50 ft. from grourrlwater was waived. EPA reasonabl y
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determined that sufficient protection from contamination of the
groundwater would be provided by the clay liner under the contaminated
soil, the leachate collection systems above and below the liner, and the
10 millineter plastic liner on top of the site. 'lhe bottom of the cell
containing the contaminated soils will be at least 10 ft. above the
seasonal high groundwater table. Moreover, groundwater monitoring wells
must be constructed at the site. EPA will verify their locations. 'Ihese
wells will allow periodic testing of groundwater to determine whether
contamination has occurred. '!he State is required to inmediately report
any detection of PCBs through monitors to EPA.
Concern (3)
EPA denied the State's request for waiver of the leachate
collection system due to the proximity of the bottom of the waste
cell to the groundwater and public concern about possible groundwater
contamination. 'Ihe site approval requires leachate collection
systems to be installed both above and below the clay liner.
Concern (4)
The landfill construction requirement that a 30 millimeter
artificial liner be installed atove, below, and along the outside of
the clay liner was waived. EPA maintains that rainwater infiltration
into the landfill would be sufficiently minimized by use of a 10
millimeter plastic liner on top of the site. 'Ihe State will also use
a 30 millimeter liner on the sides and bottom of the landfill.
In addition to the ·above concerns, numerous conments were received by
mail and at the January 4,11979, public hearing held on the project.
'Ihese conments included a recorrmendation to leave the contaminated
soils alone, as well as concerns about property values, accuracy of
the technical presentation and trustworthiness of State and EPA
officials.
'Ihese and all concerns voiced by the public were taken into
consideration by EPA in evaluating the final project design.
c. Comments Received from State and Federal Agencies
All State agencies with regulatory or review responsibilities were
heavily involved in the drafting of the EIS and in the siting and
aesign of the landfill. .Accordingly, there were no formal corrrnents
from State agencies on the project.
EPA, acting under the mandate of CEOCLA, is the Federal agency
charged with the responsibility for carrying out the herein described
remedial action project. No cormients have been received at this time
from other Federal agencies.
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9. Reasons for Concludins There Will Be No Significant Impacts
North carolina and EPA have established the cleanup of the P03' s
dunped along the highway shoulders as the State's highest priority
for action under the Superfund (CEICLA) program.
Toe remedial action alternative was selected after careful evaluation
of all other alternatives, and it will have the least adverse impact
upon health and the environment.
EPA and the State of North carolina have weighed all the concerns
voiced by the public on this project, and in conjunction with
technical and other information submitted, have reasonably concluded
that there will be no unreasonable risk or impact to health or the
environment. 'Ihe project will greatly benefit the 5 million citizens
of the State by minimizing the potential for public exposure to the
c ontaminated soil by rerooving the soil to a secure landfill which
•.vill be regularly monitored.
I
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Al.A
0
LOCATION MAP
1110111 PC 8 SPILLS
10 20
SC.a!.( OF MILES
'
i, . LAND FILL -CROSS-SECTION -GAS VENT r.-:7-" f Ii. _.J,r -·--· -~-~~II LlLL/:; •.. ff.~.f .. _~)-.7-~/.~.·;~ ... -..... ~--·~ --COMPACTED SOIL a PCB MIXTURE _____ y NOT TO SCALE \ \....._ .. ---------·•:::;:;:;:;:;:;:;~;:;~;~;:;:;:~=~~:;:;:~~~~~~ill~:;:;~;:~:~:;~:;:::~· WATER TABLE \LEACHATE REMOVAL \'LEACHATE D)]:ECTION -✓ vi· ;1~ '( . ,, ) t f ( f .~ 'f y l-' t ·. II f ).:, \ \ ---·-----0 TOP SOIL \ -----.. : LEACHATE COLLECTION SYSTEM fl &ARTIFICIAL LINER. PROTECTOR ~ ARTIFICIAL LINER El CLAY L 1,VER ~ NATURAL EARTH --ORIGINAL GROUND SURFACE \
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. NE
ATLANTA. GEORGIA 30365
OFFICIAL BUSINESS
POSTAGIE ANO FEES PAIO
U.S EHVIRONMENTAL P7'0TECTIOti AGENCY
(PA-33&
F'lnST CLASS
...
FEB 18 1983
J:01r. ',iilliam w. Pt:illips, .Jr.
A.ssistm-.t to SecretarJ
n.c. D<:purtment of Crime control
.=i.nd ?w:,lic Sa(ety
P.O. Box '27687
R.:tleigh, NC: 27611-7667
Denr Hr. Phillip:::
on Fe-brUciry 17, 1983, ar. J£11Iles a. s~rt:reiugh of my staff inspecte.J the
narren County PCB lancifill with Hr. 'l'om r<arnr..i.Ski from Mr. Strickland's
ort1Ge. ·:;.'lie erosicn arid sediment coritrcl m~.:i.sures taken by Herth
c.:.roli1lli have the lanc:fill in a good condition pen<ling decent veath~r for
ccntJletion. However, \.i:t i'!re concer.ic--,:J at:cut the fact tlwt North carolina
bas not installed the per ... 'lan,mt lea\..il<lte rer.oval sy;stem nor is· a
t~St~craty remov~l syste~ t-<!ing used.
As the res,ulator; ag~n<.-y for PCB L:mdf ills under the '.i'OXic SUbstances
control Act, we oost ask you to Lt-Jaec.'U.atel}' take action to renove and
pror...erl.t treat, etcre l1%id/cr '1is-f)Ose uccumulated leachate tram the
lilnc.lfill. Plea~ respond to Mr. Scarbrough as to whut action you are .
tu~ing by Pebruar~i 2!i, 1983.
YOlir early attention and action will be appreciated.
~inccrely :1ours,
C.harlee R. Jeter
Regicnal Administrator
C ..• '-'. Mr. O. W. Strickland, Hea<l
Soli<l & Hazardous i;aste Management Bra1~ch
N. C. De2t. of Ht:wiln ~soun .. "es
bee: Al Hanke
Bill Andreen
Doug Mccurry
JAMES SCARBROUGH:dg/3016
4-RC 4-RC
Hanke Andreen
4AW-RM
Hunter
6161Z 2/18/83
4AW-RM
Mccurry
4AW-RM
Scarbrough
4AW
Devine
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