NCD980602163_19961029_Warren County PCB Landfill_SERB C_Reponse to Bill Meyer's 29 Aug 1996 letter to US-EPA-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4APT-TS
Mr. William L. Meyer
Director
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
Division of Solid Waste Management
State of North Carolina Department of
Health and Natural Resources
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Meyer:
This is in response to your letter dated August 29, 1996,
requesting information on the process and time frames for
obtaining U.S. Environmental Protection Agency (EPA) approval (s)
to conduct Research and Development (R&D) studies on
detoxification of Polychlorinated Biphenyl(PCB) contaminated soil
buried in the Warren County PCB Landfill. You also asked for the
EPA's opinion on the State's plans for temporary storage of PCB
contaminated soils excavated from the landfill.
As explained in your letter, North Carolina plans to acquire
the requisite quantity of soil for the R&D studies by using
standard or modified well drilling methods. Two to three bore
holes will be drilled through the existing landfill cover to the
desired depth. The bore holes are to be constructed and
completed in a manner that will maintain the integrity of the
landfill cover and liner systems. You wanted to know what
administrative process EPA would use to authorize this work and
approximately how long it would take for EPA to issue approval
for this work.
EPA believes the best way to administratively handle the
Warren County PCB Landfill detoxification project is to approach
it in two stages~ Stage one will cover the R&D studies. Stage
two will cover the post-R&D period, which may involve a full
scale treatment process to detoxify the contents of the Warren
County PCB Landfill; or repairs and improvements to the
monitoring and containment systems at the existing landfill.
EPA envisions a relatively simple and short approval process
for stage one. Once the State has submitted detailed plans for
soil excavation to EPA, we will review the plans and prepare a
letter of approval to modify the December 14, 1981, PCB disposal
approval for the Warren County PCB landfill. The approval letter
will stipulate conditions under which the State may remove and
manage a limited quantity of soil for the R&D PCB detoxification
studies. Depending on the extent of landfill cover system damage
Recycled/Recyclable• Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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during soil removal work, EPA may also stipulate interim cover
requirements. We estimate that it would take no more than 30
days to issue the approval letter after we receive a detailed
description of North Carolina's soil excavation plans.
Stage two covers the post-R&D studies period. There is no
way to define the scope of and schedule for the stage two
permitting or approval process until North Carolina makes a
decision on the future disposition of the Warren County PCB
Landfill following completion of the R&D studies.
Issue number two raised in your letter concerned the State's
plans for storage of the excavated soil while awaiting shipment
to the facility or facilities where the ·R&D studies will be
conducted. The soil removed from the landfill would be placed in
55-gallon containers and these containers in turn would be placed
in 85-gallon over pack drums. The containers would be stored
within a secure area of the landfill site for no more than 30
days before shipment to a PCB commercial storage facility. EPA
concurs with North Carolina's proposal for storing the PCB
contaminated soil.
In your third and final question, you wanted to know how
long it would take to issue a permit or an approval for the
following three types of PCB disposal methods:
1. Alternative disposal methods which are mobile or are of
identical design to be used in more than one EPA Region.
2. Research and development methods disposing of> 500 lb
PCB-containing material.
3. Research and development methods disposing of s 500 lb
PCB-containing material.
The disposal method described in number 1 is a full scale
commercial unit. Multi-Regional or mobile PCB disposal
operations are approved by EPA Headquarters. The approval
process for a full scale alternative disposal method may be
lengthy and complex. This is due to the need to conduct
extensive testing at pilot and/or full scale to demonstrate that
the level of PCB destruction achieved by the proposed alternative
method is equivalent to that achieved by incineration. R&D
approvals for methods for disposal involving~ 500 pounds of PCBs
are generally issued by EPA Headquarters. Time required for
processing approyals in this category varies depending on several
factors not the least of which is the current work load of the
staff member assigned the project. Our best estimate is that
approval would take three months to a year. Regional EPA offices
handle the third category of disposal approvals. If the
application was complete and involved a familiar disposal method,
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it might take Region 4 between 30 and 90 days to issue a R&D
approval, assuming all other work assigned to the Region 4 permit
writer was of lower priority.
If you have any questions about this response or would like
to discuss some of the details of the projects, please do not
hesitate to call Craig Brown of my staff at [phone].
Sincerely yours,
(~~~~ [~~id -
Toxic Substances Section