NCD980602163_19971202_Warren County PCB Landfill_SERB C_Letter from Mike Kelly to Craig Brown-OCR

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
Mr. Craig Brown
US Environmental Protection Agency
Pesticides & Toxics Branch
Atlanta Federal Center
100 Alabama Street. S.W.
Atlanta. Geonzia 30303-3104
De:ir CraiQ:
December 2. 1997
.-\s you are ::l.\rnre. the State of \."onh Carolina. Di\·ision or \\·asre \1anagement (D\V?\,f)_ in
conjunction \\·ith the Warren County PCB \\·orking Group and their Science Advisors. have been
doing a considerable amount of work at the PCB landfill in Warren County for the past several
months. Work has centered around installation of new monitoring wells, placement of nvo
extracri"on wells in the landfill itself, extraction of soils from the landfill fo r testing, extensive site
im·estigarion and a pilot scale detoxification study.
The detoxification studies \Vere done on soils taken from the landfill. Excess soils from the
placement of the extraction \veils in the landfill and the accompanying rinse water and waste.
were sent to l'tah for disposal. Four 85 gallon o\·er-pack drums. eJch containing four 5 gallon
buckets of soils from the landfill. were sent to ECOFLO. a fully permitted hazardous \\·aste
management company in Greensboro, NC. who also has a permitted PCB storage area.
Tvvo of the 85 gallon over-packs were shipped to companies and used during the detoxification
pilot studies, and the remaining two are being stored, at our request, at ECOFLO's facility in
Greensboro. These containers are being held for additional testing on other detoxification
technologies at a future date, should it be necessary.
The Working Group is currently putting together a pl~n to seek funding from the Nonh Carolina
General Assembly to detoxify the PCB landfill. The Legislature \vill convene in May of 1998
for a "shon session". We should know by July 1, 1998, if funding will be available for
detoxification. We anticipate that the General Assembly may ask us to pursue additional
detoxification technologies to determine if less costly technologies exist. There have been
numerous inquiries frotn companies interested in the detoxification process, and some have
requested soils-to test at their own expense.
P.O . Bo x 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity AHirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
The Working Group and Science Advisors have selected the BCD process for detoxification, and
funding for this technology is what will be presented to the General Assembly. We are
concerned that a major funding issue such as detoxification may have to wait until the General
Assembly convenes for the "long session" during which the next budget will be written and thus
the DWM be required to pursue other options during the interval.
As you can imagine, it was very expensive to extract soils from the landfill, put in extraction
wells, replace the cap area disturbed and dispose of the resulting waste. The total for all of this
work was over $60,000. We would prefer not to have to do a similar exercise in order to retrieve
more soil in the future.
The Code of Federal Regulations, 40 CFR Part 7 61.215, requires exception reporting for PCB
waste in storage that is not sent to a disposal facility within 9 months of the "in storage" date,
thus allowing the disposal facility 90 days to properly dispose of the waste before the one year
maximum storage time is reached. The two drums remaining at ECOFLO were placed in storage
in March of 1997. Analys is of the soils taken from the landfill for PCB's did not show any
concentrati ons greater than 500 ppm. No PCB's measured in soil from the landfill have exceeded
900 ppm.
\Ve fo rmally request that the EPA consider the remaining drums of waste ( estimated to be less
than 400 pounds) as in storage for research and development purposes. specifically for future
detoxification studies, and that an exemption of one year be provided to the state and ECO FLO,
similar to exemptions given in CFR Part 761.80, Subpart E. Should the state determine that the
materials not be needed for further testing, we will immediately notify ECOFLO to proceed with
the necessary disposal.
Thank you for your consideration in this maner. You may call me at 919-733 --1-996. extension
203 . if you have any questions.
Copy: Mr. William Meyer, DWM
Mr. Cary Lester, ECOFLO