NCD980602163_20030926_Warren County PCB Landfill_SERB C_Non-Hazardous Waste - Kernersville NC-OCR

Sep-29-03 09 :59am From-CWM CUSTOMER SERVICE
I
WM
September 29, 2003
Shaw E & I.
Bill Gallagher
200 Horizon Cente•· Blvd.
Trenton, NJ 08691
Phone: [phone]
Fa:x: 252-257-4218
2056528289
CONFIRMATION LETTER
T-597 P.02/03 F-745
WASTE MANAGEMENT
'fmdle Treatment fildlity
Hi;.:hway 17 N., Mik M~rkcr !63
l'.0. Bnx 5 3
Emelle, /\L .>5459
(205) 652-972 l
Waste Management is pleased to confirm that your Special Waste has been approved for disposal at our
Piedmont Landfill located in Kernersville, NC subject to the terms of the Disposal Service Agreement.
GENERATOR
WASTE NAME
PCB (<50ppm) landfill deb1·is
Disposal Price;
Tranportation:
Fuel Surcharge:
SPECIAL HANDLING:
SALES REP:
Warren County PCB Landfill
PROFILE APP. DATE
CU9637 09/26/2003
$25.00rTon
Same
Based on Current Fuel Prices
Manifest Loads, No Free Liquids
PO#l96761 Must Appear on Each Invoice
Steve Miller
*\}' ASTE PRICED AS PROFILED -INVOICED AS RECEIVED
EXPIRATION
09/26/2004
The price is, however, subject to change by WM of Piedmont as described in our Disposal Service
Agreement.
Thank you for this opportunity to be of service. If you should have any questions please feel free to call
me at [phone].
Sincerely, . ~~
2
.. '
Ssp-29-o3 IO:OOam From-CWM CUSTOMER SERVICE
l="P.OM ; SHAW-ENV I R, I NC L c,,..r-,,: ':l , N\-,.. ..,,.., "-', 2056528289 T-597 P 03/03 F-745 a.---...-.
-'·'.( I •
2056ti25Zlf9' X· P.Oi!/02 MSS
?~OflLc CU9637
. EXPnu.-noNDATE~ u-~ o:1,i:
RECERT.IFJCATION DATE:_·_·-·---~----
E,E~RJIEICA 'rION OE QENERATQR,'S WAST£ PR.dEILE. SHEET
A. GE,NE.RALJNfORMATION: ' .
·1 _ Generaror Narne; WARREN COUNTY PCB LANDFILL __ Lb!.Ple~R. 2. Add1·ess~zoo HORJZON GENTER RL'(P__IEfilil..~~';::Q8~6:1;9~J~-:-. -..,,.,----'-----~--
3. Technic:il c:omact_PATRJCLA BACKUS~ Title: PCB Lh,NP.EJLL PROJECT MANAQER 4. Telephone:_252·257·171 J ____ Fax #;_252•257-4218 _________ ~--•-""
B. JltLLING INFORMATION -OPTIONAL ( MAIL WASTE MANAGEHENT INVOJCES TO h
l, Company Narnc:,_~----------~-----------------
·:L Address:.~--------------~---------~----·3 ; Contac:r: ____________ ~ _ _..lltle:·_ ------~--------~-4 . Telephone: P,0.# __________________ _
5. Llst any $peciaI brJilnJ requlremenut_" -----------:-=~~~=-=--;-~,---::--,,-.,....,.~ 6. Dlspi;:,saJ Pric:~/Unic: ____________ ~_+ additional cost per "Schedule of Fees'" ·· • -
.B,ECERTJfJ~I9N INFORMATION: · Waste Name; PC~ LANDFILi. DE8R1S ANO THERMAL TREATMENT WASTE PRODUCTS , :· 1
•
Have you obrilned any Jaborilr.ory analysis .of th~ waste within the pas; year?-=-=,...... __ Yes ✓ No·
Have you cnanged the ra~ m~terialr. used in the waste generating process Q&..tba waste g~ncratlng p~es,
itself?~ __ Yt:.s_-'v ____ No · · ·
Is the laboratorY analysis anct/or ot~perdnent infonnation previously submitted still representative of the
wa'fOO 11s pres~ndy' t{en.:!nted'i' )-L._, Yes~__.,.~_NQ .
If you have answered fil to question 2 or 'Z lls,ed above, please att.ic:h doc:umi,ntatJon explaining your TeSPOnse.
D. REC,ERTIFICATIQN SIATWE,NT:
· By signing tlHs form, -che Generator hereby certifies;
Toe informarloi, provided in thl.s document, the attached Wasw Me1nagernent Oenerator':, Wa~ Profile Sheet,
i'lr,d .:di other :i'CP.ched documents contain crue and ' a'ta.1rare desc::rlptions or mis waste matert-111. ATI new
lnformal:ion raprdll'lg renown or SUlipec~d ha?ards ln ihe po!!SeS~Gn of the generawr has been dlsdosed. The
generator hereby certifies thiS waste ls not a "Hazardous w~~re" · as derJned W USEPA or canadl.an federal
~gulation .ind/or-the siatefpt•oytnce .ind this waste do~ not contain regT.tlated radioacttve material or regulated
concentrations of PCB's. · · . · . ·
X, s1cnan1re: ~~ £ ~G),,...-<::: Tide Pee, l-a.nd.,::. LI +>r-ajed M~y
· N.:ame (TYpe or Print) · Pe,:t:.vic. iC11.. M. Ba..c..k.Uc& Oate._q __ ,(...;~;.,.,_:.S.__,-/~o...::.3=-------
, l .
Condltions/Precautlons;._---1---'·--·--'"7"'~--.,-~---------------~--
WMI R~viaw/Approval: ~ .· Z:~ J
• 1 ' . .'• .
3
. , Sep-24-03 02:36pm From-GWM CUSTOMER SERVICE 2056528289 T-478 P.02/02 F-595
PROFILE CU 96 3 7=--=====-===--===-
EXPIRATION DATE: __________ _
RECERTIFICATION DATE: ------------
RECERTIFJCA TION OF GENERA TOR'S WASTE PROFILE SHEET
A. GENERAL INFORMATION:
1. Generator Name: WARREN COUNTY PCB LANDFILL='/:--N:-::=--=:Cc=::D-=:EN~R~==oo----"'=-'=-=~=~=-
2. Address,__200 HORIZON CENTER BLVD TRENT~~J~0~8~69'=1"=---====--===a~------
3. Technical Contact PATRICIA BACKUS Title: PCB LANDFILL PROJECT MANAG_E-',R~==--=
4. Telephone:_ 252-257-171 3 ____ Fax #: [phone] ____________ _
B. BILLING INFORMATION -OPTIONAL ( MAIL WASTE MANAGEMENT INVOICES TO ):
1 . Company Name: -----------------------------2. Address: -----------------=--------------3. Contact: _____________ ~_Title: ________________ _
4. Telephone: ____________ P.0.# _________________ _
5. List any special billing requirements: ----------~,,...--,--------------6. Disposal Price/Unit: ______________ + additional cost per "Schedule of Fees"
C. RECERTIFICATION INFORMATION:
1. Waste Name: PCB LANDFILL DEBRIS AND THERMAL TREATMENT WASTE PRODUCTS
lJ 2 . Have you ob~ined any laboratory analysis of this waste within the past year? ____ Yes -✓~--N-o-
)\ 3. Have you changed the ra,-, materials used in the waste generating process OR the waste generating process
1 / ltself? ___ Yes_---'v'---_No
J<: 4. Is the laborat0ry analysis and/or o~e_y pertinent information previously submitted still representative of the V waste as presently generated? _ ___..~'----Yes ____ No
"' 5. If you have answered YES to question 2 or 3 listed above, please attach documentation explaining your response.
D. RECERTIFICATION STATEMENT:
By signing this form, the Generator hereby certifies:
The information provided in this document, the attached Waste Management Generator's Waste Profile Sheet,
and all other attached documents contain true and accurate descriptions of this waste material. All new
information regarding known or suspected hazards In the possession of the generator has been disclosed. The
generator hereby certifies this waste is not a "Hazardous Waste" as defined by USEPA or Canadian Federal
regulation and/or the state/province and this waste does not contain regulated radioactive material or regulated
concentrations of PCB's.
X:. Signature: "-/J~ /;; ~~~ Tide
Name (Type or Print) Pc.c_:l:.v i c:. i o.... M.. Bo...c.J::.l,(.J!.
Conditions/Precautions:
Pee L..a..n d +.· l l Pr-oj ec.--t Md V"
Date q / :LS/ o3
------------------------------
WMI Review/ Approval: ------------------
2
""
Sep-24-03 02:36pm From-GWM CUSTOMER SERVICE 2056528289 T-478 P.02/02 F-595
PROFILE CU9637=""'====-=~==aa
EXPIRATION DATE:
RECERTIFICATION DATE; ·----------
RECERTIFICATION OF GENERA TOR'S WASTE PROFILE SHEET
A. GENERAL INFORMATION:
1. Generator Name: WARREN COUNTY PCB LANDFILL.='/'-:-'-'N=C=D=EN,_,__R,_,===-~=--==~=--'=___,~
2. Address: 200 HORIZON CENTER BLVD TRENT~-_._J~0~8=-69-=1~~'="""""---======----,=----c----
3. TechnicaiCont:ac:t PA TRICIA BACKUS Title:. PCB LANDFILL PRO] ECT MANAG_E~R___,==--=
4. Telephone:_ 252-257-171 J ____ Fax #: [phone] ____________ _
B. BILLING INFORMATION -OPTIONAL ( MAIL WASTE MANAGEMENT INVOICES TO ):
1. Company Name: _____________________________ _
2. Address:. ____________________________ _
3. Contact: _____________ -=---=--Title: ________________ _
4. Telephone: ____________ P.0.# _________________ _
5. List any special billing requirements: __________ ---:--~-c-----~:-:----,--,--~---------~
6. Disposal Price/Unit: ______________ + additional cost per "Schedule of Fees"
C. RECERTIFICATION INFORMATION:
1. Waste Name: PCB LANDFILL DEBRIS AND THERMAL TREATMENT WASTE PRODUCTS
l) 2-Have you obtained any laboratory analysis of this waste within the past year? ____ Yes -✓~--N-o-
.A 3. Have you changed the ra-" materials used In the waste generating process OR the waste generating process
1 / ltself? ___ Yes_-'v'--_No
X:: 4. Is the laboratory analysis and/or o~~pertinent information previously submitted still representative of the
\/ waste as presently generated? _ __.~'------Yes ____ No
'\ 5. If you have answered YES co question 2 or 3 listed above, please attach documentation explaining your response.
D. RECERTIFICATION ST A TEMENT:
By signing this form, the Generator hereby certifies:
The information provided in this document, the attached Waste Management Generator's Waste Proflle Sheet,
and all other attached documents contain true and accurate descriptions of this waste material. All new
information regarding known or suspected hazards In the possession of the generator has been disclosed. The
generator hereby certifies this waste Is not a "Hazardous Waste" as defined by USEPA or Canadian Federal
regulation and/or the state/province and this waste does not contain regulated radioactive material or regulated
concentrations of PCB's.
X., Signature: ~~ £ ~ Title
Name (Type or Print) PA.."CY ic i0\.. M. 80...c.l:.1..t-:B.
Condltions/Precam:lons:
Pelo L.a-n d +.· l J -:Pr-oj ee--f MB v
Date q / ;z,s/ o3
-------------------------------
WMI Review/ Approval: _________________ ~
2
I I ,.
WASTE MANAGEMENT GENERA TOR'S WASTE PROFILE SHEET
PLEASE PRINT IN INK OR TYPE
Service Agreement on Fi!e? DYES XJNO
OHaza;dous X]Non-Hazardous 0TSCA
Profile Number: WM
Renewal Date:
cu· 9637
i I
-~A.· Waste Generator Information-------•· ---'---··--·-·····-----··· -----------·. ---· __________ ,-..
1. Generator Name: WatTen County PCB Landfill 2. SIC Code:
3. Facility Street Address: Box426.Route4 4. Phone: .[phone]
5. Facility City: Warrenton. NC 6. Stme/Province: North Carolina
7. Zip/Postal Code:
9. County:
27589 8. Ge(1eratorUSEPNFederallD#: NCR000J37802
WatTen 10. State/Province ID ii North Carolina
11 . Customer Name:
13. Customer Contact:
15. Billing Address:
NC Deot. of Nat. and Env. Resources 12. Customer Phone: [phone]
Bill Galla!!her 14. Customer Fax: [phone]
Shaw E&I. 200 Horizon Center Blvd .. Trenton. NJ □Sqme as above
.: B.· Waste Stream Information .
1 . Description
a. Name of Waste: PCB landfill debris and thermal treatment waste oroducts
b. Process Generating Waste: PCB contaminated soil is excavated from a landfill. The excavated soil is
.. treated in a thermal desorber to remove the PCBs. The concentrated PCBs will either be treated
on site or sent to off site incineration The treated sail is returned to the landfill
I C. Color d. Strong odor e. Physical state @ 70°F f. Layers g. Free iiquid range
(describe): X ISolid □Liquid □Single Layer 0 to 0 %
Brown. black None □Gas □Sludge X Multi-layer
~ white, gray □Other h. pH: Range
4 to 10
i. LiquidFlashPoin~: O<73°F 073-99°F O100-139°F O140-199°F □2:200°F XNotapplicable
j. Chemical Composition (List all constituents [including halogenated organics, debris, arid UHC's) present in any concentration and submit
representative analysis):
Constituents Concentration Range Constituents Concentration Range
Used PPE 0 to 80 % PCB
Concrete 0 to 60 % Soil
Air and water treatment carbon 0 to 50 % Trash (olastic. bottles. etc.)
Crushed rock 0 to 90 % sand and soil
-••••••-Mlrml::J.IJ.:1 ■■111\1 ■m1ih'"'t ,11,~,-,1~--1~::i;;a1•1111L:/~
k. D Oxidizer D Pyrophoric D Explosive D Radioactive
O Carcinogen D Infectious O Shock Sensitive O Water Reactive
1. Does the waste represented by this profile contain any of the carcinogens which require OSHA
notification? (list in Section B.1.j) ........................................................................................................................................ ..
m. Does the waste represented by this profile contain dioxins? (list in Section B.1 .j) ............................................... ..
n. Does the waste represented by this profile contain asbestos? .................................................................................... .
If yes............................................................................................................................ · 0 friable D non-friable
o. Does the waste represented by this profile contain benzene? .................................................................................... ..
If yes, concentration ________ ppm
Is the waste subject to the benzene waste operations NESHAP? ............... : ............................................................. ..
p. Is the waste subject to RCRA Subpart CC controls? ...................................................................................................... .
If no, does the waste meet the organic LOR Exemption? ................................................................................ , ........... ..
If no, does the waste contain <500 ppmw volatile organic (VO)? .............................................................................. ..
Volatile organic concentration __________ ppmw
q. Does the waste contain any Class I or Class. II ozone-depleting substances? ........................................................ .
r. Does the waste co11tain debris? (list in Ssection B.1 .j) ........................................................................................... ..
0 to 49 oom
0 to 80 %
0 to 25%
0 to ?<:i%
□YES XNO □YES XJNO
□YES X.JNO
□YES XNO
□YES X:NO
□YES XNO
X. YES □NO
X YES □NO
□YES XNO
XYES □NO
2. Quantity of Waste
Estimated Annual Volume 180 X Tons □Yards □Drums O Other (specify)
3. Shipping Information
a . Packaging:
X;Bulk Solid; Type/Size: 20 yard roll off □Bulk Liquid; Type/Size:
□Drum ; Type; Size: __ OOther:
b. Shipping Frequency: Units 2 Per:)(Month Oauarter □Year Done time []Other
c. Is this a U.S. Department of Transportation (USDOT) Hazardous Material? (If no, skip d, e, and f) ...... □YES X NO
999·21 17
.
W ASTE M A N AGEMENT GENERA TOR'S WASTE PROFILE SHEET
PLEASE PRINT IN INK OR TYPE
d. Reportable Quantity (lbs.; kgs.): e. Hazard Class/ID #:
f. USDOT Shipping Nam!3:
g. Personal Protective Equipment Requirements:
h. ·rransporter/Tran~fer Station:
, c.: Generator's Certification. Please check a ro riate res onses, si n, and date below. · . • · .
1. Is this a USEPA hazardous waste (40 CFR Part 261)? II the answer is no, skip to 2 ............................................................... .
a. If yes, identify ALL USEPA listed and characteristic waste code numbers (D, F, K, P, U)
□YES XNO
b. If a characteristic hazardous waste. do underlying hazardous constituents
(UHCs) apply? (if yes, list in Section 8.1 .j) ....................................................................................... . □YES ONO
c. Does this waste contain debris? (if yes, list size and type in Chemical
Composition -8.1 .) ............................................................................................................................. . □YES ONO
2. Is this a state hazardous waste?....................................................................................... ......... . ............................................ ...... DYES X NO
identify ALL state hazardous waste codes
3. Is the waste from a CERCLA (40 CFR 300. Appendix B) or state mandated clean-up?............................................................. . X YES ONO
If yes, attach Record of Decision (ROD), 104/106 or 122 order or court order that governs site clean-up
activity. For state mandated clean-up, provide relevant documentation.
4. Does the waste represented by this waste profile sheet contain radioactive material, or is disposal
regulated by ihe Nuclear Regulatory Commission?.. ... ............ .................................................................................................... O YES XI NO
5. Does the waste represented by this waste profile sheet contain concentrations of Polychlorinated
Biphenyls (PCBs) regulated by 40 CFR 761? (if yes, list in Chemical Composition -B.1.j) ........................................................ 0 YES X NO
a. If yes, were lhe PCBs Imported into lhe U.S.?..................................................................................... □YES □NO
6. Do the waste profile sheet and all attachments contain true and accurate descriptions of the waste
material, and has all relevant information within the possession of the Generator regarding known or
suspected hazards pertaining to the waste been disclosed to the Contractor.?............................................................................. X YES □ NO
;
7. Will all changes which occur in the character of the waste be identified by the Generator and disclosed
to the Contractor prior to providing the waste to the Contractor?................................................................................................... X YES □ NO
X Check here if a Certificate of Destruction or Disposal is fequired.
Any sample submitted is representative as defined in 40 CFR 261 • Appendix I or by using an equivalent method. I authorize WM to obtain a
sample from any waste shipment for purposes ol recertification. If this certification is made by a broker, the undersigned signs as authorized
agent of the generator and has confirmed the lnfonnation contained in this Profile Sheet from-information provided by the generator and additional
information as it has determined to be reasonably necessary. If approved for management, Contractor has all the necessary permits and
licenses for the waste that has been characterized and identified by this approved profile. ~~O?~ Certification Signature:
Name (Type or Print): Patricia M. Backus Company Name:
Title: PCB Landfill Project Manager
NCDENR Date: 9/..s/o z_ X Check if additional information is attached. Indicate the number of attached pages --=2 __ _
i OJWMManagement'sDecision, ,;.-..: .. , ·" '· •·;:•>, ..... · -... ·' ·. · .•;. -. ' · FORWMUSE·ON~V
1.
2.
3.
Management Method D Landfill D Non-hazardous Sol1d1f1cation
D Hazardous Stabilization O Other (Specify)
Proposed Ultimate Management Facility:
Precautions. Special Handling Procedures, or Limitation on Approval:
4. Waste Form _______ 5. Source
Special Waste Decision ............................................................................................................. .
D 81oremediation 0 Incineration
6. System Type
D Disapproved
Salesperson's Signature: ___________________________ _
□Approved
Date:
Division Approval Signature (Optional): Date:
Special Waste Approvals Person Signature: Date:
999·2117
' '
North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michaei F. Easiey/Govetnor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
September 5, 2002
Mr. Steve Miller
Waste Management
1675 Allen's Crossroads Rd.
Four Oaks, NC 27524
Dear Mr. Miller:
MA
NCDENR
Tha.11k you for including me in your meeting with Shaw Environment a.'ld L'lfrastructure, our contractor
for the PCB Landfill Detoxification Project, concerning the disposal of material from the project at your
Emelle, Alabama, facility.
Yon requested that I supply information concerning the history of the landfill and the state mandate for
the remediation project.
History of the Landfill
In 1982 the State of ;North Carolina constructed a landfill pennitted under the Toxic Substances Control
Act (TSCA) in Warren County. The purpose of the landfill was to contain soil that had been
contaminated by the illegal spraying of liquids containing polychlorinated biphenyls (PCBs) along over
210 miles of road in North Carolina. The contaminated roadsides, designated as the PCB Spills, were
listed on the National Priorities List and the removal of the contaminated soil and placement in the
iandfiii was the remediai action approved by the U. S. Environmentai Protection Agency (EPA) under the
Superfund program.
Before soil removal, the roadsides were sampled to determine the extent of contamination. Based on the
analyses, the shoulders of the roads were trenched to a width of approximately 24"-30" from the edge of
pavement, and approximately 3" deep. This plan was designed to remove all of the contaminated soil
along with a small amount of uncontaminated soil. Sampling also identified the contaminant as a mixture
similar to Aroclor 1260.
Construction of the landfill began on June 21, 1982. Placement of contaminated soil into the landfill
commenced on September 15, 1982 and was completed on November 17, 1982. The soil was excavated
from the roadsides and transported directly to the landfill by the North Carolina Department of
Transportation. Truck identification and weight was closely monitored. The North Carolina Department
of Public Safety provided around the clock security. The total volume of contaminated soil was estimated
to be 40,000 cubic yards. The only additional materials placed in the landfill were 50 truckloads of
cement kiln dust purchased from a vendor in New Hanover County. The kiln dust was placed in the
northeast comer of the landfill to absorb excess moisture due to extremely heavy rains during the
construction. After all the roadside material was received, the landfill was closed. Construction was
completed on July 14, 1983.
1646 Maii Service Center, Raieigh, North Caroiina 27699-i646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us I
Mr. Steve Miller
August 23, 2002
Mandate for Remediation
Over 90 sites in 20 counties were evaluated as possible landfill locations with six sites chosen for
extensive investigation. The Warren County site was selected as the location for the new landfill because
it "demonstrated the least restrictions and the greatest degree of protection of the public health and
environment" However, many in the community felt the county was the selected because it had a
predominantly minority population and was one of the poorer counties in the state. Residents and civil
rights leaders vehemently protested the construction of the landfill with over 4-00 arrested. That
community activism is considered the "watershed event" that brought the environmental justice
movement to the national level."
The Governor of North Carolina at the time, James B. Hunt, Jr., wrote a letter to the citiz:ens of Warren
County promising that the state would "push as bard as it can for detoxification of the landfill when and if
the appropriate and feasible technology is developed." Landfilling was the only TSCA-approved disposal
method for contaminated soil at that time of the spills. A study conducted in the mid-1980s concluded
that no detoxification technology was available and that the landfill was "state-of~the-art."
Despite assurances that the landfill was well-constructed and approved for construction by EPA and that
monitoring has not indicated the movement of contaminants beyond the landfill, the citiz.ens living nearby
remain concerned about the possible health impacts now and in the future.
Following Governor Hunt's return to office in 1993, a Joint Warren County/State PCB Landfill Working
Group (Working Group) consisting of community members, environmental activists, and representatives
from the Department of Environment and Natural Resources (DENR) was established. The Working
Group with the assistance of independent science advisors selected Base Catalyzed Decomposition as the
best and safest process for the site.
The General Assembly of North Carolina supported their decision by mandating the use of Base
Catalyzed Decomposition for the remediation in Session Law 1998-212, Senate Bill 1366 and directed
DENR to oversee the project.
If you require additional information or have questions, please call me at [phone] ext 308.
Sincerely,
Patricia M. Backus, P.E.
PCB Landfill Project Manager
cc: Mike Kelly, DENR
Gary Duke, Shaw E&I
Bill Gallagher, Shaw E&I
J im Cloonan, Earth Tech
Sep-24-03 02:36pm From-CWM CUSTOMER SERVICE 2056528289
WASTE MANAGEMENT
P.O . BOX 55
HWY . 17 @MILEMARKER 163
EMELLE, AL 35 459
T-478 P.01/02 F-595
PHONE: [phone] OR 2 05 /652-8155
FAX: [phone] OR 205 /652-8102
FAX COVER SHEET
Bill Gallagher/Shaw E & I.
252-257-4218
PHON!:1 NLIMBL!l:
Recertification for ClJ963 7 /PCB ,S0ppm
Debris
!-'ROM:
Carol Weldon
TOTAL NO. 01: PAGES INCLUDING c ovf;tl;
cf
09/24/03
Please have your customcr complete section C.2, 3 & 4, sign and fax back to (205)-652-8289.
If you have any quescions, please call (800)-652-5755 or my direct line (205)-652~8186.
1
WASTE MANAGEMENT
March 17, 2003
Mr. Bill Gallagher
Shaw Environment & Infrastructure, Inc.
Warren County PCB Landfill
Route 4, Box 426
Warrenton, NC 27589
Re: Non-TSCA Soil
Mr. Gallagher:
Waste Management is pleased to provide you with pricing for the waste streams listed below. The prices
presented herein are estimates, pending profile review and approval.
Based on the information available, the following summarizes our quotation:
WASTE DESCRIPTION
Bulk Non-TSCA PCB Soil
WM FACILITY
Waste Management -Piedmont Landfill
9900 Freeman Rd.
Kernersville, NC 27284
DISPOSAL CHARGES
$19/Ton
TRANSPORTATION CHARGES
$17.25/Ton
20-Ton Load Minimum
$75/Demurrage
Notes:
Warrenton, NC
Subtitle D Landfill
Priority Load Rate (25 Cu. Yd. End-Dump)
After 1-Hour Free Loading
All pricing is contingent upon the review of the Generator's Waste Profile Sheet.
All services are subject to a variable monthly fuel surcharge, based upon the US Department Of Energy
Fuel Price Index.
Necessary documents will be forwarded to you and must be completed and signed by an authorizing
signatory of the generator. Upon acceptance of this proposal, please contact me at your earliest
convenience for the paperwork required to begin the approval process.
Upon review of the completed waste profile and review of available analytical data (if requested), the final
extended price will be good for sixty (60) days. Ifnot accepted in the allotted time, all pricing will expire.
Waste Management appreciates this opportunity to serve the Shaw E&I. Should you have any questions or
need additional information, do not hesitate to call me direct at 919-207-2166 or our Customer Service
Center in Emelle, AL at 800-652-5755.
Sincerely,
WASTE MANAGEMENT, INC.
Steve E. Miller
Steven E. Miller
Account Manager
Cc: Carol Weldon, WM-Emelle
attachments
NOTE BY GARY DUKE, SHAW E&I, 03/19/03:
I spoke to Steve Miller at 0930 today to confirm that the 25 cy end dumps quoted are articulated tractor
trailers, they are. I told him there might be problems with getting them access to the area of Mt. Tilley. He
said that if we requested in advance of actual shipping they could get their transporter to provide triaxle
and/or quad axle straight body trucks at the same price. He said that with the extra axles those trucks CAN
legally haul at least 20 tons over the road, most can actually carry about 22 tons. I consider this is to be a
very important consideration for reasons cited below.
First is that they propose to use 25 cy end dumps. Those are articulated trucks which we could not get
anywhere NEAR Mt. Tilley without MAJOR road building, right now they would tend to jackknife and
overturn at the turn around Mt. Fuji, especially coming back down the hill fully loaded. We have talked
about the need to improve the road back there but were thinking of some ABC stone spread by our dozer to
get tandem or triaxle straight body dump trucks such as KPH uses back there. Building a road for
articulated tractor trailers multiplies the road effort and cost, even if we have space to put in curves of
adequate radius around Mt. Fuji and for a turnaround at Mt. Tilley, which I am not sure of but seriously
doubt. If the move of Mt. Tilley occurs so late that all or most of Mt. Fuji is gone that would solve one
problem but means we would be building (and removing?) this big, heavy road from areas along the landfill
that would otherwise be almost complete with regard to grading and restoration, so the cost of that rework
would have to be factored in.
Second point is that even ifwe built the "highway", it's unlikely that we could often get articulated
dumps all the way back to Mt. Tilley, loaded, cleaned and out in an hour or less, so the demurrage charge of
$75/hr would kick in, adding about $3.75/ton to a 20 ton load and raising their "real" transportation price
from $17.25 to $21.00/ton.
The only practical way I see to use articulated trucks would be to use Kenny's dumps to relocate the soil to
go offsite to a new stockpile area just east of the parking lot, then load the offsite articulated trucks from
there. That reduces the road building from "interstate grade" back to what we originally envisioned, and
should about eliminate the demurrage. The problem, of course, is that it adds another onsite rehandling step,
which off the top ofmy head will probably add back at least $2-3/ton, so again Waste's "real" transportation
cost would likely exceed $20/ton.
Steve Miller's e-mail transmitting this quote to Bill Gallagher included the following message:
Please note I have requested an extended "hold" period on
these prices (up to six months). I will advise when I receive verification.
Jul-23-07 OB:37A KP HAWKINS
....... 1111111••1.•
Phone [phone]
Fax [phone]
PROPOSAL SUBMITl'ED TO: Shaw E & I, Inc.
200 Horizon Center Blvd.
Trenton, NJ 08691
Attn: Mr. Gary Duke
257 1026-t-
P.O. BOX 129
MACON, NC 27551
March 17, 2003
We will haul soil from the Warren County PCB Landfill to the upper Piedmont Environmental
Regional Landfill in Person County for a cost of$IS.OO per ton.
We will haul soil from the Warren County PCB Landfill to t'1e Piedmont Landfill in Kernersville,
NC for a cost of$20.00 per ton.
We will provide the loading at the Warren County PCB Landfill for a oost of$2.00 per ton.
This proposal is good for 30 days. We reserve the right to renegotiate the price after this period
based on fuel cost.
If any portion of the contract price is collected by or throu~h an attorney-at-law after maturity,
the purchaser-agrees to pay reasonable attorney fees equal 10 15% of the outstanding balance.
Acceptance of Proposal: The above prices, specifications and conditions are satisfactory and are
hereby accepted. 1ne above contractor is authorized to do the work specified. If acceptable, sign
and return one copy.
Customer's Signature Title Date
We appreciate the opportunity to SCfVC you,
/tutd'" //~{ f J
KPH Trucking/Landscaping. Inc_
P.01
·' :AfW\ ,....,,. __ Sou~h_Co Enterprises, Inc. PO Bof 35871, Greensboro, NC 27425 -----------------1-(336) 882~8000 ---------......,.;.~--...__, w~rrr,,,,, G ,.,,""f V }')c.i let.tel.//)/ Date:_/_._l,._.2,.....,,.../ ___ -Q""'-'<------Client: Location: __ W_g~rr_tt_,11~t-~_~_____,,~1 _A/._7_,t: ___ .___..j __ -'---_________ Drop; __ _ Pickup: Detention Time (Jo.b Site) Start: I 3 .'00 Stop: 3 :.z.o Equipment No: Materials: Truck: 1.,/C,ot./ ~inet(Y/N):~v _____ _ Trailer: /? f o '-I Bows (#): __ J ____ _ Container: -----------------Tarp (Y/N):~a../ ____ _ Condition of Equipment/Materials: 2 • Destination: /J,'e wto1-t7 La P! '/,// Weight: Heavy_?_ OK __ _ Location /(ernPr,;v,'//e • ,U,{ Manifest #: _ ___,.'/._..h ..... ~~I_C.'---~-Detention Time (Destination) Start: _____ _ Stop: ------------Comments: *Customer accepts responsibility for overweight ticke · or citations. · DriverSignature . ~vi:;~ ClientSignature_·~ £)~ ~
.> 0 -} cf 't d J ,-<J -0 f .i j ? ~ / t f ~ ~ :f ...) r ~ _,;I ,; rJ ,> ~ ! (; 1. ii' ..J l(t ,..I ~ " r-.,,0 51 ~ 1} 1 t 1 ~ r 1 s ~ t. ,,, ,, () i:) I' V ~ r 45. ~ ? ~ 11 ~ ~ ~ ~ (iJ ~ ~ "' r f ~ J e --ti I Z ~ f' ~ 9 ~ '-'t rt> rD 11, ct 3 ~ ~ ~ 1:,1 V (_ /I i t -') ~ >< 'ii~"' C> , , ~,,, ~ Ii' i(' ? ro _., ,'J',~,~ "' I 3 ~,, ,,, ... ' p ~ QJ C ,, 1,,, .. ~ • ~ ) l ~ ,'ff ~ r' ~ '•••·· Ci r ~-3 -F ? , ~ ~ (> ~ --... -t a::
~ NON-HAZARDOUS WASTE MANIFEST
WASTE MANAGEMENT If waste is asbestos waste, complete all Sections. 7 If waste is NOT asbestos waste, complete only Sections 1, 2, 3, 4 and 5.
SECTION 1 GENERATOR INFORMATION (generator to complete)
' a) Generator's Name: j) Generating Location (Name):. r
--
b) Generator's Address: ' ' . k) Address: ----. -·------,.
c) Generator's Representative: ' I) Telephone Number: ( )
r1
d) Telephone Number: ( ) __
!') WASTE MANAGEMENT PROFILE#: c,_1-fj, '3 q
f) Common Name of Waste: m) Asbestos ONLY -D Friable; □Both; --%friable --% non-friable
g) Description of Waste: n D Non-friable; □NIA TYPE OF !;;ONTAINERS
h) Disposal Volume: nl Type of Containers: [I] TR -TRUCK
__ Tons Cubic Yards __ Other DM -METAL DRUM --DP -PLASTIC DRUM
i) Number of Containers: BA -BAG
BB -6 MIL. PLASTIC BAG o) I hereby warrant the above named material is the same material as represented on the Special Waste Disposal Application BC -12 MIL. PLASTIC BAG identified by the above Waste Management Code and such material was delivered to the transporter on the shipment date referenced below. ~ ~ " ~ ...-,..c; .,, , I ,;
Generator's Authorized Agent Name (prinVtype) Signature of G;nerator's Authorized Agent Shipmeni Date I
SECTION 2 TRANSPORTER 1 SECTION 3 TRANSFER FACILITY -(Complete if applicable)
a) Transporter's Name: ,, , a) Transfer Facility's Name:
b) Transporter's Address: . b) Transfer Facility' Address: -
c) Telephone Number: ( ) ~ ,· c) Telephone Number: ( )_.
d) Vehicle License No./State: ii. ( •[ ~ i; A (. d) VehiclP. License No./State:
e) Trailer or Container No.: ;/ . e) Trailer or Con:ainer No ..
f) Name of Transfer Facility's
f) Name of Driver (prinVtype) . ' Authorized Agent (prinVtype)
g) I hereby warrant that the above named and described material was received g) I hereby warrant that the above named and described material was received
from the generator on the date referenced below. from the transporter on the date of receipt referenced belov,.
Signature of Driver Date of Receipt Signature of Transfer Facility's Authorized Agent Date of Receipt
h) I hereby warrant that the abo e named and described material was delivered h) I hereby warrant that the above named and described material was delivered
without incident or contamination on the date of delivery referenced below. to the transporter without incident or contamination on the date of delivery
referenced below.
Signature of Driver Date of Delivery Siqnature of Transfer Facility's Authorized Aqent Date of Delivery
SECTION 4 TRANSPORTER 2 • (Complete is applicable) SECTION 5 DESTINATION (Disposal Facility)
a) Transporter's Name: a) Disposal Facility's Name: PIEDMONT LANDFILL
b) Transporter's Address: b) Disposal Facility' Address: 9900 Freeman Rd. • Kernersville, NC
c) Telephone Number: ( ) c) Telephone Number: ( 336 ) 595-6677
d) Vehicle License No./State: d) Mailing Address: P.O. Box 1109
e) Name of Disposal Facility's
e) Trailer or Container No.: Authorized Agent (prinVtype):
f) Name of Driver (prinVtype) f) The material delivered by the Transporter has been received at the Disposal
Facility.
g) I hereby warrant that the above named and described material was received on the date of receipt referenced below. Signature of Disposal Facility's Authorized Agent Date of Receipt
g) The material delivered by the Transporter has been rejected for disposal at
Signature of Driver Date of Receipt the Disposal Facility.
h) I hereby warrant that the above named and described material was delivered on the delivery date referenced below. Signature of Disposal Facility's Authorized Agent Date of Rejection
Signature of Driver Date of Delivery Signature of Driver Date of Reiection -SECTION 6 ASBESTOS (operator to complete)
"Operator" is defined as the company which owns, leases, operates, controls, or supervises the facility being demolished or renovated, or the demolition or renovation operation or both.
a) Operator's Name: " c) Telephone Number: ( )
b) Operator's Address:
d) Recommended special handling instructions and additional information:
e) Operator's Certification: I hereby warrant and declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and domestic law, regulations, ordinances, orders, rules and/or standards.
Operator's Name (prinVtype) Signature of Operator's Authorized Agent Date
f) Responsible Agency
Name and Address: GSM-9-30
FORM #111-005
GENERATOR
North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
September 5, 2002
Mr. Steve Miller
Waste Management
1675 Allen's Crossroads Rd.
Four Oaks, NC 27524
Dear Mr. Miller:
NCDENR
Thank you for including me in your meeting with Shaw Environment and Infrastructure, our contractor
for the PCB Landfill Detoxification Project, concerning the disposal of material from the project at your
Emelle, Alabama, facility.
You requested that I supply information concerning the history of the landfill and the state mandate for
the remediation project.
History of the Landfill
In 1982 the State of North Carolina constructed a landfill permitted under the Toxic Substances Control
Act (TSCA) in Warren County. The purpose of the landfill was to contain soil that had been
contaminated by the illegal spraying of liquids containing polychlorinated biphenyls (PCBs) along over
210 miles of road in North Carolina. The contaminated roadsides, designated as the PCB Spills, were
listed on the National Priorities List and the removal of the contaminated soil and placement in the
landfill was the remedial action approved by the U.S. Environmental Protection Agency (EPA) under the
Superfund program.
Before soil removal, the roadsides were sampled to determine the extent of contamination. Based on the
analyses, the shoulders of the roads were trenched to a width of approximately 24"-30" from the edge of
pavement, and approximately 3" deep. This plan was designed to remove all of the contaminated soil
along with a small amount of uncontaminated soil. Sampling also identified the contaminant as a mixture
similar to Aroclor 1260.
Construction of the landfill began on June 21, 1982. Placement of contaminated soil into the landfill
commenced on September 15, 1982 and was completed on November 17, 1982. The soil was excavated
from the roadsides and transported directly to the landfill by the North Carolina Department of
Transportation. Truck identification and weight was closely monitored. The North Carolina Department
of Public Safety provided around the clock security. The total volume of contaminated soil was estimated
to be 40,000 cubic yards. The only additional materials placed in the landfill were 50 truckloads of
cement kiln dust purchased from a vendor in New Hanover County. The kiln dust was placed in the
northeast comer of the landfill to absorb excess moisture due to extremely heavy rains during the
construction. After all the roadside material was received, the landfill was closed. Construction was
completed on July 14, 1983.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
Mr. Steve Miller
August 23, 2002
Mandate for Remediation
Over 90 sites in 20 counties were evaluated as possible landfill locations with six sites chosen for
extensive investigation. The Warren County site was selected as the location for the new landfill because
it "demonstrated the least restrictions and the greatest degree of protection of the public health and
environment." However, many in the community felt the county was the selected because it had a
predominantly minority population and was one of the poorer counties in the state. Residents and civil
rights leaders vehemently protested the construction of the landfill with over 400 arrested. That
community activism is considered the "watershed event" that brought the environmental justice
movement to the national level."
The Governor of North Carolina at the time, James B. Hunt, Jr., wrote a letter to the citizens of Warren
County promising that the state would "push as hard as it can for detoxification of the landfill when and if
the appropriate and feasible technology is developed." Landfilling was the only TSCA-approved disposal
method for contaminated soil at that time of the spills. A study conducted in the mid-l 980s concluded
that no detoxification technology was available and that the landfill was "state-of-the-art."
Despite assurances that the landfill was well-constructed and approved for construction by EPA and that
monitoring has not indicated the movement of contaminants beyond the landfill, the citizens living nearby
remain concerned about the possible health impacts now and in the future.
Following Governor Hunt's return to office in 1993, a Joint Warren County/State PCB Landfill Working
Group (Working Group) consisting of community members, environmental activists, and representatives
from the Department of Environment and Natural Resources (DENR) was established. The Working
Group with the assistance of independent science advisors selected Base Catalyzed Decomposition as the
best and safest process for the site.
The General Assembly of North Carolina supported their decision by mandating the use of Base
Catalyzed Decomposition for the remediation in Session Law 1998-212, Senate Bill 1366 and directed
DENR to oversee the project.
If you require additional information or have questions, please call me at [phone] ext 308.
Sincerely,
Patricia M. Backus, P .E.
PCB Landfill Project Manager
cc: Mike Kelly, DENR
Gary Duke, Shaw E&I
Bill Gallagher, Shaw E&I
Jim Cloonan, Earth Tech
VtC]!;u
WASTE IIIIANAGEMENT GENERATOR'S WASTE PROFILE SHEET
PLEASE PRINT IN INK OR TYPE
Service Agreement on File? DYES XJNO
D Hazardous K] Nori-Hazardous 0TSCA
Profile Number: WM
Renewal Date:
cu· 9637
I I
1.
3.
5.
7.
Generator Name:
Facility Street Address:
Facility City:
Zip/Postal Code:
Warren Countv PCB Landfill 2. SIC Code:
Box 426. Route 4 4. Phone: .[phone]
Warrenton. NC 6. State/Province: North Carolina
27589 8. Generator USEPNFederal ID#: NCR000137802
9. County: Warren 10. State/Province ID.~ North Carolina
11 . Customer Name:
13. Customer Contact:
15. Billing Address:
NC Deot. ofNat. and Env. Resources 12. Customer Phone: [phone]
Bill Galla2:her 14. Customer Fax: [phone]
Shaw E&I. 200 Horizon Center Blvd .. Trenton. NJ □Same as above
1. Description
I
a. Name of Waste: PCB landfill debris and thermal treatment waste oroducts
b. Process Generating Waste: PCB contaminated soil is excavated from a landfill. The excavated soil is
treated in a thermal desorber to remove the PCBs. The concentrated PCBs will either be treated
on site or sent to off site incineration The treated soil is returned to the landfill
C. Coior d. Sirong odor e. Physicai staie @ 70°F f. Layers g. Free iiquid range
(describe): X ISolid □Liquid D Single Layer 0 to 0 %
Brown. black None □Gas □Sludge X Multi-layer
~ white, gray □Other h. pH: Range
4 to 10
i. Liquid Flash Point: D <73°F 073-99°F D 100-139°F 0140-199°F □~ 200°F X Not applicable
j. Chemical Composition (list all constituents [including halogenated organics, debris, arid UHC's] present in any concentration and submit
representative analysis):
Constituents Concentration Range Constituents . Concentration Range
Used PPE 0 to 80 % PCB
Concrete 0 to 60 % Soil
Air and water treatment carbon 0 to 50 % Trash ( olastic. bottles. etc.)
Crushed rock 0 to 90 % sand and soil
. TOTAL COMPOSITION MUST EQUAL OR EXCEED 100% .
k. D Oxidizer D Pyrophoric D Explosive O Radioactive
O Carcinogen O Infectious O Shock Sensitive D Water Reactive
I. Does the waste represented by this profile contain any of the carcinogens which require OSHA
notification? (list in Section B.1.j) ........................................................................................................................................ .
m. Does the waste represented by this profile contain dioxins? (list in Section B.1.j) ................................................ .
n. Does the waste represented by this profile contain asbestos? .................................................................................... .
If yes............................................................................................................................ Otriable O non-friable
o. Does the waste represented by this profile contain benzene? ..................................................................................... .
If yes, concentration ________ ppm
Is the waste subject to the benzene waste operations NESHAP?. .............. : .............................................................. .
p. Is the waste subject to RCRA Subpart CC controls? ..................................................................................................... .
If no, does the waste meet the organic LOR Exemption? ............................................................................................. .
If no, does the waste contain <500 ppmw volatile organic (VO)? ................. , ............................................................. .
Volatile organic concentration _________ ppmw
q. Does the waste contain any Class I or Class If ozone-depleting substances? ........ , ............................................... .
r. Does the waste contain debris? (list in Ssection 8 .1.j) .. . ... ......... . ......................... .
0 to 49 oom
0 to 80 %
0 to 25%
0 to ?"i¾
□YES XNO
□YES XJNO
□YES XJNO
□YES XNO
□YES X: NO
□YES XNO
XYES □NO
X YES □NO
□YES XNO
XYES ONO
2. Quantity of Waste
Estimated Annual Volume ----=-1 =-80"-------X Tons O Yards O Drums O Other (specify)
3. Shipping Information
a. Packaging:
X 'Bulk Solid; Type/Size: 20 yard roll off □Bulk Liquid; Type/Size:
□Drum ; Type; Size: __ □Other:
b. Shipping Frequency: Units 2 Per:XMonth Oouarter □Year D one time Cl Other
c. Is this a U.S. Department of Transportation (US DOT) Hazardous Material? (If no, skip d, e, and f) .... □YES X NO
999-2117
\
VVJ:!M
WASTE MANAGEMENT GENERA TOR'S WASTE PROFILE SHEET
PLEASE PRINT IN INK OR TYPE
d. Reportable Quantity (lbs.; kgs.): e. Hazard Class/ID#:
f. USDOT Shipping Nam(:): -------,-.. ___________________________ _
g. Personal Protective Equipment Requirements:
h. Transporterffransfer Station:
f:CJ Generator's Certification: Please ·check·a ·ro riate res onses; si n;and'date below. ~, ···· ; .... , .,,._:· ": > ·· · .i ;, . : .-. ,\:· ._; -
1. Is this a USEPA hazardous waste (40 CFR Part 261)? If the answer is no, skip to 2 ............................................................... . □YES XNO
a. If yes, identify ALL USEPA listed and characteristic waste code numbers (D, F, K, P, U)
b. If a characteristic hazardous waste, do underlying hazardous constituents
(UHCs) apply? (if yes, list in Section 8.1.j) ....................................................................................... . □YES ONO
c. Does this waste contain debris? (if yes, list size and type in Chemical
Composition -8.1.) ............................................................................................................................. . □YES ONO
2. Is this a state hazardous waste? ................................................................................................................................................... .. □YES XNO
identify ALL state hazardous waste codes
3. Is the waste from a CERCLA (40 CFR 300, Appendix 8) or state mandated clean-up?............................................................. X YES ONO
If yes, attach Record of Decision (ROD), 104/106 or 122 order or court order that governs site clean-up
activity. For state mandated clean-up, provide relevant documentation.
4. Does the waste represented by this waste profile sheet contain radioactive material, or is disposal
regulated by the Nuclear Regulatory Commission?........................................................................................................................ . DYES XI NO
s. Does the waste represented by this waste profile sheet contain concentrations of Polychlorinated
8iphenyls (PC8s) regulated by 40 CFR 761? (if yes, list in Chemical Composition -8.1.j) ........................................................ 0 YES X NO
a. If yes, were the PC8s imported into the U.S.?..................................................................................... DYES D NO
6. Do the waste profile sheet and all attachments contain true and accurate descriptions of the waste
material, and has all relevant information within the possession of the Generator regarding known or
suspected hazards pertaining to the waste been disclosed to the Contractor.? .. _. ............................................................ , ........ .-... X YES D NO
7. Will all changes which occur in the character of the waste be identified by the Generator and disclosed
to the Contractor prior to providing the waste to the Contractor?................................................................................................... X YES D NO
X Check here if a Certificate of Destruction or Disposal is fequired.
Any sample submitted is representative as defined in 40 CFR 261 -Appendix I or by using an equivalent method. I authorize WM to obtain a
sample from any waste shipment for purposes of recertification. If this certification is made by a broker, the undersigned signs as authorized
agent of the generator and has confirmed the information contained in this Profile Sheet from information provided by the generator and additional
information as it has determined to be reasonably necessary. If approved for management, Contractor has all the necessary permits and
licenses for the waste that has been characterized and identified by this approved profile.
·W~lh~ Certification Signature:
Name (Type or Print): Patricia M. Backus Company Name:
Title: PCB Landfill Project Manager
NCDENR Date: '1/...s/o z_
X Check if additional information is attached. Indicate the number of attached pages -=2'----
1. Management Method D Landfill D Non-hazardous Solidification D Bioremediation D Incineration
2.
3.
D Hazardous Stabilization D Other (Specify)
Proposed Ultimate Management Facility:
Precautions, Special Handling Procedures, or Limitation on Approval:
4. Waste Form 5. Source 6.
Special Waste Decision ........................... .................... ... ................................ ................................... . ............ ..
Salesperson's Signature:
Division Approval Signature (Optional):
Special Waste Approvals Person Signature:
999-2117
System Type
□Approved
Date:
Date:
Date:
D Disapproved
North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
September 5, 2002
Mr. Steve Miller
Waste Management
1675 Allen's Crossroads Rd.
Four Oaks, NC 27524
Dear Mr. Miller:
NCDENR
Thank you for including me in your meeting with Shaw Environment and Infrastructure, our contractor
for the PCB Landfill Detoxification Project, concerning the disposal of material from the project at your
Emelle, Alabama, facility.
You requested that I supply information concerning the history of the landfill and the state mandate for
the remediation project.
History of the Landfill
In 1982 the State of North Carolina constructed a landfill permitted under the Toxic Substances Control
Act (TSCA) in Warren County. The purpose of the landfill was to contain soil that had been
contaminated by the illegal spraying of liquids containing polychlorinated biphenyls (PCBs) along over
210 miles of road in North Carolina. The contaminated roadsides, designated as the PCB Spills, were
listed on the National Priorities List and the removal of the contaminated soil and placement in the
landfill was the remedial action approved by the U.S. Environmental Protection Agency (EPA) under the
Superfund program.
Before soil removal, the roadsides were sampled to determine the extent of contamination. Based on the
analyses, the shoulders of the roads were trenched to a width of approximately 24"-30" from the edge of
pavement, and apptoximately 3" deep. This plan was designed to remove all of the contaminated soil
along with a small amount of uncontaminated soil. Sampling also identified the contaminant as a mixture
similar to Aroclor 1260.
Construction of the landfill began on June 21, 1982. Placement of contaminated soil into the landfill
commenced on September 15, 1982 and was completed on November 17, 1982. The soil was excavated
from the roadsides and transported directly to the landfill by the North Carolina Department of
Transportation. Truck identification and weight was closely monitored. The North Carolina Department
of Public Safety provided around the clock security. The total volume of contaminated soil was estimated
to be 40,000 cubic yards. The only additional materials placed in the landfill were 50 truckloads of
cement kiln dust purchased from a vendor in New Hanover County. The kiln dust was placed in the
northeast corner of the landfill to absorb excess moisture due to extremely heavy rains during the
construction. After all the roadside material was received, the landfill was closed. Construction was
completed on July 14, 1983 .
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
. • Mr. Steve Miller
August 23, 2002
Mandate for Remediation
Over 90 sites in 20 counties were evaluated as possible landfill locations with six sites chosen for
extensive investigation. The Warren County site was selected as the location for the new landfill because
it "demonstrated the least restrictions and the greatest degree of protection of the public health and
environment." However, many in the community felt the county was the selected because it had a
predominantly minority population and was one of the poorer counties in the state. Residents and civil
rights leaders vehemently protested the construction of the landfill with over 400 arrested. That
community activism is considered the "watershed event" that brought the environmental justice
movement to the national level."
The Governor of North Carolina at the time, James B. Hunt, Jr., wrote a letter to the citizens of Warren
County promising that the state would "push as hard as it can for detoxification of the landfill when and if
the appropriate and feasible technology is developed." Landfilling was the only TSCA-approved disposal
method for contaminated soil at that time of the spills. A study conducted in the mid-1980s concluded
that no detoxification technology was available and that the landfill was "state-of-the-art."
Despite assurances that the landfill was well-constructed and approved for construction by EPA and that
monitoring has not indicated the movement of contaminants beyond the landfill, the citizens living nearby
remain concerned about the possible health impacts now and in the future.
Following Governor Hunt's return to office in 1993, a Joint Warren County/State PCB Landfill Working
Group (Working Group) consisting of community members, environmental activists, and representatives
from the Department of Environment and Natural Resources (DENR) was established. The Working
Group with the assistance of independent science advisors selected Base Catalyzed Decomposition as the
best and safest process for the site.
The General Assembly of North Carolina supported their decision by mandating the use of Base
Catalyzed Decomposition for the remediation in Session Law 1998-212, Senate Bill 1366 and directed
DENR to oversee the project.
If you require additional information or have questions, please call me at [phone] ext 308.
Sincerely,
Patricia M. Backus, P.E.
PCB Landfill Project Manager
cc: Mike Kelly, DENR
Gary Duke, Shaw E&I
Bill Gallagher, Shaw E&I
Jim Cloonan, Earth Tech