NCD980602163_19950714_Warren County PCB Landfill_SERB C_Bill Meyer letter to Stewart Perry, EPA Region IV requesting information-OCR

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr ., Governor
Jonathan B. I lowos, Secretory
William L. Meyer, Director
Stewart Perry
EPA Region IV
345 Courtland St., NE
Atlanta, GA 30365
Dear Mr. Perry:
July 14, 1995
SA
DEHNR
The Division of Solid Waste Management appreciates your participation in the Warren
County PCB Landfill meeting with the co-chairs of the working group and state representatives.
I would like to request any regulatory information, policy or guidance documents
concerned with the following issues:
1. Process for modification of existing TSCA chemical waste landfill permit to allow
excavation, removal, back fill and closure of the landfill.
... 2. Limitations, restrictions on the amount of materials that can he removed for utilization on a
pilot scale R&D detoxification project. Are waivers available for the 500 lb limitations for
R&D projects? If no waivers to the 500 lb R & D limits are available, what is the process for
approval to exceed this amount.
3. What approval is applicable to a pilot scale R&D project utilizing Dase Catalyzed
Dechlorination (BCD) technology for PCB (<500ppm) contaminated soils?
4. If PCB ( <500ppm) contaminated soils are stored prior to and during the implementation of a
R&D pilot scale project, what standards are applicable?
5. The state intends to proceed with up to 3 simultaneous pilot scale projects involving 3
different methodologies for BCD. At what point should the state submit information to TSCA
for approval? Will approval be required for each project?
P.O. Box 27687. Rr1lnigh. North Corolirifl 27611 -7687 Tel0phon0 ? 1 ·~ .'Jl ,1'7'}6 r AX? I? 715 3605
An E<111ol Oppnrt11nily Affirmativo Ac-:llon Fmr,loyor
6. What is the difference in applicability of PCn regulations on R&D projects and proposals for
final approval for an alternative methods for destroying PCB? For example if all 3 R&D projects
fail to meet the 2ppm PCB standard for exclusion, then no proposal for alternative technology
will he submitted for consideration. It is not clear to the Division how these two processes are
addressed in the 40CFR 761 regulations.
I appreciate your efforts to respond to these issues at your earliest convenience.
William L. Meyer, Director
&£J
Division of Solid Waste Management