NCD980602163_19970211_Warren County PCB Landfill_SERB C_EPA authorization to the State to conduct intrsuive sampling and testing work-OCR

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• ..::."'' ~ ("u', UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f ~• .,.1 REGION 4 ~ Si),tz W ATLANTA FEDERAL CENTER
\ o.: 100 ALABAMA STREET, S.W.
1,~t PA01~0~ ATLANTA, GEORGIA 30303-3104
4APT-TS
Mr. William L. Meyer
Director
Fm l l l9 S7
Division of Waste Management
Department of Environment, Health
and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Meyer:
Subject to the limitations and conditions set forth below,
this letter provides U.S. Environmental Protection Agency (EPA)
authorization to the State of North Carolina to conduct intrusive
sampling and testing work within an approved polychlorinated
biphenyl (PCB) disposal facility, the Warren County PCB Landfill
(WCLF) located in Warren County, North Carolina. By this letter
EPA is also granting approval to North Carolina to expand and/or
replace the existing groundwater monitoring network at the WCLF.
The proposed sampling investigation and the proposed changes
to the monitoring network are part of an ongoing effort by the
State to address concerns raised by the Joint Warren County/State
PCB Working Group about the WCLF. Plans for the sampling
investigation and new monitoring wells were described in two
separate letters, each dated February 5, 1997, from Mr. Michael
Kelly, Deputy Director of the North Carolina Department of
Environment, Health and Natural Resources, Division of Waste
Management (DWM) to Mr. Craig Brown of EPA Region 4's Toxic
Substances Section.
Intrusive saumling Investigation
SM&E, Inc., at the request of DWM has prepared a document
entitled •Draft Work Plan for Excavation, Handling and Storage of
PCB Contaminated Soils From the Warren County PCB Landfill.• The
draft Work Plan, dated February 5, 1997, was reviewed by EPA.
The draft Work Plan provides a detailed description of the
procedures SM&E will use to drill soil borings at two locations
in the WCLF. Drilling into the landfill will be performed in two
steps using hollow stem augers. The borings will penetrate the
landfill cover (including the top liner) and the entire thickness
of land filled PCB contaminated soil at each location. The
borings will be terminated at the top of the five-foot thick clay
(bottom) liner, at an approximate depth of thirty feet from
ground surface. After obtaining sufficient soil for testing, the
two boreholes will be completed as six-inch diameter recovery
wells.
Recycled/Recyclable• Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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The landfill cover system includes a 10 mil thick PVC
membrane l±ner overlying a two-foot thick compacted clay liner.
After the recovery wells are installed, SM&E workers will
carefully excavate the cover soil to expose the PVC liner near
the recovery wells. SM&E will then remove a five-foot by five-
foot sample of the PVC liner at each of the two locations for
laboratory testing. A liner installation contractor under SM&E's
direction will then patch the PVC liner and replace the cover
material.
Undisturbed soil samples obtained during the investigation
will be properly packaged and sent to off-site laboratories for
testing as they are collected. The remainder of the PCB
contaminated soil samples collected during the investigation will
be used in the PCB treatability tests. Soil for treatability
tests will be placed into drums and stored temporarily on-site at
WCLF within the fenced landfill area. Investigation derived
waste will also be placed in drums and staged inside the fenced
landfill area until removed for disposal. The maximum amount of
time drummed PCB soil samples and waste will be stored on-site is
thirty days.
Conditions for Conducting the Sarm;>ling Investigation and on-site
waste Management
North Carolina may implement the February 5, 1997, draft
Work Plan prepared by SM&E subject to the conditions (changes)
outlined herein. Required changes to the draft Work Plan were
conveyed to SM&E during a telephone conversation, between Craig
Brown of EPA and Walter Beckwith of SM&E on February 6, 1997.
EPA expects SM&E will prepare a final Work Plan that meets these
conditions before field work is initiated.
1. Management of Investigation Derived Waste:
(a) Non-PCB Waste: Solid waste consisting of used personal
protective clothing, well material packaging, and other trash
that has not contacted or has had only superficial contact with
PCB contaminated soil may be disposed of as non-PCB waste
provided it is segregated from PCB waste or PCB-derived waste.
(b) PCB Waste: All excess drill cuttings, unused soil
samples, equipment decontamination fluids and other investigation
derived waste that has been in contact with PCBs or derived from
PCB waste shall be placed in approved PCB storage/shipment
containers that are marked and dated in accordance with 40 CFR
§§ 761.40 and 761.65. PCB Wastes may be stored in containers at
the WCLF within the fenced landfill area for no more than 30 days
from the date that waste is first placed into the containers.
PCB waste shall be disposed of in accordance with the PCB
disposal regulations at 40 CFR § 761.60.
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2. Drilling Equipment Decontamination: After completion of
the two boreholes at the WCLF and before leaving the site,
drilling equipment shall be decontaminated as described in the
draft Work Plan except that the equipment shall be rinsed with a
10 percent isopropanol solution following the high pressure or
steam wash and before the final tap water rinse. To confirm that
drill equipment is PCB-free, at least one rinse blank sample
shall be collected from a clean (decontaminated) randomly
selected auger flight and tested for PCBs. Organic free water
shall be used to generate the rinse blank(s).
3. Reporting: North Carolina shall provide EPA with a copy
of a report documenting the results of the sampling investigation
to be prepared by SM&E at the conclusion of the investigation.
New Monitoring Network
North Carolina plans to construct fifteen new groundwater
monitoring wells at and near the WCLF. Three of these wells will
be constructed off-site and are to serve as background wells.
Subsequent to completing installation of these new monitoring
wells, North Carolina shall submit to EPA, a scaled map (or maps)
showing the locations of the new wells and a well construction
report. At a minimum, the well construction report shall
indicate formation materials penetrated by each well, well casing
material, well screen location, placement of sand pack, and
annular space sealants, and surveyed elevations of the top and
bottom of each ori-site well. If the new wells are to replace or
supplement the existing monitoring network at the WCLF for use in
semi-annual monitoring as required by the PCB disposal approval
for the WCLF, North Carolina shall also submit to EPA a written
description of its well sampling procedures.
Please advise EPA of any changes in North Carolina's plans
for the sampling investigation or well installation effort at the
WCLF. Should you have any questions concerning this letter, you
may contact Mr. Craig Brown of my staff, at [phone].
cc: Walter Beckwith, SM&E
;;~y;µ
Winston A. Smith
Director
Air, Pesticides and Toxics
Management Division