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HomeMy WebLinkAboutNCD980602163_19900116_Warren County PCB Landfill_SERB C_EPA correspondence re approval, 1979 and 1981-OCR'Jifttl 11 'o - 4APT-PT Mr. William Meyer Director REGION IV 345 COURTLAND STREET. N .E. ATLANTA. GEORGIA 30365 North Carolina Solid Waste Management Division P.O. Box 27687 Raleigh, North Carolina 27611-7687 Dear Mz:_,. Meyer: Please find enclosed a copy of the December 14, 1981, letter sent to the State of North Carolina from the Environmental Protection Agency {EPA), Region !V's, former Administrator, Charles R. Jeter. This letter served as the final EPA approval for the Warren County, North Carolina chemical waste landfill. A review of the "Final Approval Conditions" section indicates that this permit document needs to be updated to present stan- dards. A permit revision process will be initiated by our Toxics Section to ensure that the landfill approval is in con- junction with all current PCB landfill regulations. These standards are found in the Code of Federal Regulations, Title 40, Section 761.75. At this time, we expect to have an updated permit issued for the Warren County site by the end of this fiscal year. If you have any questions or comments on this matter, please contact Carin DeBenedictis at (404) 347-3864. Sincerely, Richard D. Stonebraker Chief, Pesticides & Toxic Substances Branch Enclosure .. _ .• . -. -·· uJ~Co -DEC 14 1981 Honorable Jaires b. Hunt Governor of oorth Carolina , State Capital l<a..leigh, North Carolina 27611 tear Governor Hunt: On June 4, 197S, Re<;icn IV gave conceptual approval, with certain ccnaitions, to the \\arren County, North Carol.in.ii, site as a chemical w-c:.Ste landfill c:.s authorizea in 40 CFR, .Part 761. OnE! of t:t.e conciticns was that the Sta~e $ci:lr~t final plans and si:,ecificaticns to this office for approval, in writing, prier t.e the initiation of construction. These F,,lans ar..c sf,'ECifications have been sutmi.tteci ana are .hereby a_pproved subject to the enclose:i conditions. rfE corrmeoo you ant the many im..'Olved fer your dedication to reaching a final solution to this envir~ntal problem baseo on the tecnnclogy as it E:Xists tod.:(f. I:t: we can be ot further assistance, please let rne knew. Sincerely you.rs, /s/ Charles R. Jeter Re.gionat Administra~0r Olar les R. Jeter .i.tegional Administrator .l:.nclosurE: cc: t-lr. burley B. M1tcht:il, Jr., ~retary, l-.orth Carolina Le_partnent of Crime Control and Putlic Saiety Raleigh, North Carolina. O.W. Sc.ricklana, Bea<:: ~lid & Hazaraous Waste Z.:.anageI!'ent Branch f.nviror.:mental i:l.€-alth Section Der-c.runtnt of. human .k.esources Division of heuth Services Raleish, North Carolina Dr. Sara furrow Lepartrrent of Human ~sources Livision of health Services Raleigh, l.orth Carolina . -.-. Final Approval Conditions for PCB Q1emical Waste Landfill in Warren County, North Carolina, owned and to be operated, closed and post closure cared for by the State of North Carolina on property formerly owned by Carter C. Pope and Linda w. Pope, found in Deed Book 278, page 252. I. Reference June 4, 1979 approval letter signed by John .C. White A. General requirement numbers 1, 2, and 5 remain in effect. B. Technical condition numbers 1, 2, 3, 4, 6, 7, and 8 remain in effect. Condition numbers 9 and 10 have been satisfied. II. Additional conditions of this approval are: A. Leachate collection will be monitored monthly and collected leachate disposed of properly, if required (761.41 (b) (7)). Records will be maintained on file at a designated State office. B. The operation plan will be followed, as approved (761.41 (b) (8) (ii)). C. Records will be maintained and submitted to the Regional Administrator within 90 days of closure (761.41 (b) (8) (IV)). D. The fence, gate, and access road shall be maintained in good working order as long as post closure rroni~oring is required. E. Report to EPA Region IV any instance of detection of PCB' s through the monitoring program immediately. F. Designate a State departmental person who will be responsible for operation and for post closure rrontioring prior to initiation of construction {761. 41 (c) (5)). G. Notify EPA Region IV 30 days prior to transferring responsibility for operation or any change in ownership (761. 41 (c) (7)). H. Monitoring Program 1. General The parameters for ground and surface water monitoring for this program are found at 40 CFR (761.41 (b) (6) (iii) (A), (B) and (C)). Samples should be collected and analyzed in accordance with EPA approved procedures. 2. Ground Water a. Background -Each well must be sampled at least three times and the data submitted to Region IV prior to any disposal. A minimum of one week should elapse between sampling. At each sampling a minimum of t\-.0 replicate measurements for each value or concentration should be- made. /U .. b. During Operation -During operation or for a period of one year, whichever is shorter, all wells must be sampled rronthly. c. Post Closure -Each well must be sampled on a semiannual basis. 3. Surface Water 4. a. Background -EPA Region IV will designate surface water sampling locations. These locations will include, at a minimum, two (2) sampling points per surface water bcdy (one upstream and one downstream). Each of these points will be sampled each time the background samples are taken for ground water quality. b. During Operation -Each of the designated surface water sampling points will be sampled rronthly during operation of the facility. c. Post Closure -Each of the designated surface water sampling points will be sampled on a semiannual basis during the post closure period. Changes in Program Upon a determination by the State or EPA that containment has failed, the sampling frequency of either ground or surface water sampling may be rrodified. EPA may also require the installation of additional rronitoring· wells and an expansion of the list of rronitoring parameters. 5. Well location and screened elevations shall be coordinated with EPA Region IV in the field or by telephone as appropriate. I. Undisturbed samples of the soil liner will be taken and the laboratory permeability determined and submitted to EPA Region IV prior to any disposal (1 sample per 25,000 square feet of liner). {/ '4, -••• ;: ,-... -.:.-t, United States Environmental Protection Agency June 4, 1979 4AH-RM Region J 345 Courtland Street NE Atlanta GA 30308 Honorable James B. Hunt Governor of Horth Carolina State Capitol Raleigh, North Carolina 27611 Dear Governor Hunt: Alabama. Georgia. Florida. Mississippi, North Carolina. South Carolina, Tennessee. Kentucky On February 17, 1978, the United States Envi ronmenta 1 Protection Agency (EPA) published final regulations in the Federal Register (43 FR 7150-7164) on Polychlorinated Biphenyls (PCBs), Disposal and Marking. These regulations were amended by the Federal Register .(43 FR 33918-33920) on August 2, 1978. These regulations prohibit the disposal of PCBs at any site not approved by the EPA after April 18, 1978, and these regulations require that the owner and/or operator of a chemical waste landfill used for the disposal of PCBs submit information in accordance with Section 761~41, Chemical Waste Landfill~, to the Regional Administrator for revi~w. · In accordance i..;ith the above referenced regulations, a formal appl i- cation was filed with this office dated December 12, 1978, requesting approval of a site in Harren County, North Carolina·which will be ovmed and operated by the State of North Carolina and used for the disposal of PCB contaminated soil from the highway shoulders in the State and from the Fort Bragg military reservation. A public hearing was held in Harrenton, North Carolina on January 4, 1979, for public input. The hearing record was held open until January 12, 1979, for additional written public input into the decision process. The result of EPA's review is that the proposed site will meet all the technical requirements for a chemical waste landfill as required in Section 761.~l(b), when constructed in accordance with the enclosed conditions to this approval except for the fellowing: ( l ) 7 G l. 111 ( b ) (I ) ( v i ) " [\ rt if i c i 2 1 l i:: u-h i c L '.7 :: :; s 3 0 mi l. •J!' ~Jr'.:i1 Ler." (2) 76l.41(b)(2) "The site shall be at least fifty feet from the nea,re$t_ ground1·1ater.11 (3) 761.4l(b)(5)(iii)(d) 11 Chlorinated Organics." These three requirements are hereby waived for the reasons given in the enclosed technical review. Your re~uest to waive the leachate collection system underneath the liner is denied for the reasons stated in the enclosed technical review. -2- Accordingly, the Warren County, North Carolina site to be owned and operated by the State of North Carolina for the disposal of PCB contaminated highway shoulder soil is hereby approved subject to the enclosed conditions as a chemical waste landfill as authorized in 40 CFR, Part 7610 It is understood by EPA and the State of North Carolina that this approval is based on . the conceptual design only and that the final construction plans and specifica- tions (if any) must be approved in wr.iting by this office prior to the initiation of constructiono This approval is not to be .construed to be approval for incineration, storage, marking or records and monitoringo We will continue to work with you in any way we can to expedite a public health oriented and environmentally sound solution to the PCB problem in North Carolina. Sincerely yours, . -2~i?.M~ ohn.C. White Regional Administrator Enclosures cc: Herbert L. Hyde, Secretary ~C Depto of Cri me Control & Public Safety t11rshai l Staton, Chief Sanitary Engineering Section Division of Health Services NC Depto of Human Resources Jerry Perkins, Head Solid Waste & Vector Control N.C. Depto of Human Resources & Division of Health Services .. Approval Conditions for the PCB Disposal Site Owned And Operated by the State. of North Carolina in Warren County, North Carolina on the Property Described in Governor Hunt's December 12, 1978, Application as Owned by Carter C. Pope and Linda W. Pope Found in Deed Book 278, Page 252 .. A. General Requirements (all reports should be sent to the Regional Administrator, Attention: James H .. Scarbrough}: l. Notify EPA at least two weeks in advance of the expected start of construction .. 2. Notify EPA at least two weeks in advance of the initiation of disposal of PCB waste at the site. 3. Send EPA the data which is required by 43 FR 761.4l(b)(5), monitoring systems for baseline and on the frequencies specified. 4. Maintain.records as specified ·in 43 FR 76l .. 45(b)(3) as appropriate and submit within 90 days after closure of the site to the Regional A~mini stra tor. 5. Advise EPA irrrnediately of any changes, alterations or divergences in the operational and managerial po1icies and procedures as out- lined in the documents submitted in support of the application. 6. Report to EPA any instance of detection of PCBs through the monitor- ing program immediately .. B. Technical Conditions of Approval: 1. The one foot of cover to be placed only on the middle 20 feet to 30 feet of the first lift of waste to preclude shunting any infil- tration to the side walls. · 2 •. A soils engineering finn shall be employed to provide quality control during the construction of the clay-silt liner. 3. Engineering expertise shall be provided by the State or a consulting firm on-site during all operations to provide and assure conformance with the final plans. Such assurance shal I be' fo,·i1i siied to t ;1:3 Rcgion.J.l Ad;;1i nistrator at the c cHi1 pletion o f th:: prnje:t \·lith c:1 copy of "as bui It" plans, 4. A record shall be placed on the property deed \·thich stipulates the particular boundary of the disposal area and waste contained therein with the associated waste elevations. 5. The State shall maintain an "all weather" access road indefinitely to pennit access to the site and to facilitate collection of samples from monitoring wells. 6. Waste will be compacted as much as practicable with tracked equipment to prevent settlement after closure. 7. Appropriate erosion control measures shall be applied during excava- tion, filling and after closure to minimize erosion. 8. Trucks used for hauling the waste must be covered. 9. The final plans and specificati.ons (if any) shall be submitted to the Regional Administrator (Attention: James H. Scarbrough) and written approval received prior to the initiation of construction. 10. A leachate collection system with a sump and access which will allow pumping out of any collected leachate is required above and below the clay liner. . . . . ! UNITED STATES ENVIRONMENTAL PROTECTION AGENCY CATE: June 4, 1979 suaJECT: Technical Review -Chemical Waste Landfill for PCB SUbmitted by the State of North carolina FROM: Chief, Residuals Management Branch TO: John C. \mite Region.al Adrn:1.nistrator 'lhe State of North carolina submitted an application for the approval of a disposal. site in Warren County, North carolina on December-12,-1978. '!he Technical review has been ~rfonned. The results ·or applying the ~riteria found in FR 761.41(b) to the application are as follows: . -(b)(l) Soils -The site is not in a "thick,·relatively 1mpenneable formation such as large-area clay pans." 'lherefore, the soils at'e evaluat. on the following criteria: Required Prooosed (i) Soil 1.ir1er thiclmess 3 ft. (canpacted) 5 ft. ( canpacted) J , . (ii) Penneability (cm/sec) mo-7 or 6.ano-8 or (0.0000001) (0.000000068) (i:µ) Percent Soil Passing .?_ 30 75 Aver--cge No. 200 Sieve (iv) Liquid Limit .?_ 30 51 Average (v) Plasticity Index .?_ 15 18 Average (vi) Artificial Liner 30 mil. None proposect!-1 1/ A h'3.iver was t'equested for this requirement. The prirnary justification for the ·.-:2.i ve r v.-as that tl:e St .J.tc i•:ou.ld in3 t ead pl:,1.ce a 10 ::tll. pla s t ic line r '\1rrb rel l .'1 n top en t he lar::1f1l 1 co1(~.:-'•c:-1 by t_;-,•10 !.\:·2t of: soil ·.;h l ch would t•= s ,::,:-J:::·J \rl th i;r;.1.::;s an:~ slor,=i· '111:..: d:.::-3 1.:';n i·:,)it::I :r:.::1Lrnl::-:-c ,"':.2';/_ ra.im;2.ter 1.rl'LLt r·a t i on into t he l 2.11d:'1ll. ':.h is \·ru.1· .. -f:t' t'i:.'qt,;-::St s ::.):J.ld be approved. IPA l"o.-m 1J20·6 (R.-.. 3-76) -2- (2) Hydrology -The site is located on the crest of a ridge at lati- tude 36° 20' 13", longitude 78° 09' 58" and is above the 100 year flood level. This is verified by the U.S. Geological Survey (see letter dated November-29, 1978, to Jerry C. Perkins). The bottan of the waste will not be 50 feet above the groundwater. The min:1nrur:-i distance will be held to 10 feet above the seasonal h1gh groundwater- table. The State requested a waiver for this cclterion. In reviewing the justification of the waiver, I have concluded that the clay liner 1n the bottan of the trench plus the liner on top of the waste hnich ~'ill act as an t.lIT'brella for infiltration prevention, plus th: leachate collection system and su~p above and below the clay liner will sufficiently protect public health and the environnent fran "unreasonable risk of injury" as stipulated by paragraph 761.41(c)(4). Therefore, this waiver should be approved as requested. (3) Flood Protection -'Ihe application states that the diversion structures. will be designed to divert the 24 hour, 25 year runoff' .fran the active 'pot't~on of the land.fill. j : (4) Topography -The topography at the proposed site:is low to roderate. 'Ihe approval should -be conditioned to require all practical erosion prevention rceasures to be used. (5) (i) Viocltorir.g Sys tens a. 'Ihe application states that baseline data will be collected prior to final approval. The approval should be so conditioned • ... ' b. 'Ihe application states that the surface streams and the grcund-· water will be sampled m:mthly during operation. The approval · sr.£iuld be so conditioned by ro--ferring to paragraph 761.41(b)(5). -c. Bi-annual rronitoring will be done after closure. (11) Groundv-,ater Monitoring Wells 'Ihe. application states that these vill be constructed and located as required. EPA staff should verify t:ie l01~ation of these in the field. (111) Water Analysis 'Ihe analysis for chlorinated hydrocarbons is • requested to be waived. The regulations were written for canrrercial facilities which would be disfX)sing of many different wastes. Since PCB is the only waste which will be dispJsed in this site, there is no point to rronitoring for' other chlorinated organics. This waiver should be aooroved. -3- (6) Leachate Collection 'Ihe proposed design does not show a leachate collection system unde~ the liner as required by the regulation. fucause of the groundwater prox.1mity and the demonstrated public concern, I recanmend that a leachate collection system and sump be installed under the soil liner to monitor the integrity of the soil liner. In addition, the leachate collection system above the soil liner soould be required with the appropr-iate sump to provide the rrechanism to allow pumping out of any leachate collected to pr-event any significant hydraulic head buildup on the clay liner-. Therefore, this waiver should not be approved. (7) Operations The operations plan submitted is satisfactory with the exception of the one foot of clean soil to be placed on top of first lift of waste. This cleari soil is to be used to prevent the trucks fran taking out contaminated soil on the wheels. This one foot should be restricted to the middle 20 to 30 feet of the trench so as not to provide a ,shunt to the side walls should any infiltration occur. 'Ihis restric~ tion·wlll allow ariy infiltration to proceed down through the waste to the leachate collection system h'hich would lead it to the sump for pumping oJ.t. "'· (8) Sup;x.:.;rtir..g Facilities -The sup.r:orting facilities are satisfactory as described. No mention \•,-as ITE.de of long-term rraintenance of the access road. Tne approval smuld be conditioned to insure that all- weather access is rraintained.