NCD980602163_19990302_Warren County PCB Landfill_SERB C_Nontice of Non-Compliance from TSCA, 1985 - 1999-OCR

I'
l ~VA i MCDENR .,
JAMES B. HUNT JR.
;t GoVERNOR
:t WAYNE MCDEVITT
' SECRETARY
WILLIAM L. MEYER
DIRECTOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
March 2, 1999
Ms. Carol L. Kemker, Chief
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Ms. Kemker:
DIVISION OF WASTE MANAGEMENT
Thank you for your letter of December 2, I 998, regarding the PCB landfill
in Warren County, North Carolina. The State of North Carolina has come into
compliance with the Notice of Non-compliance (NON) issued to it by the EPA on
August 28, I 997.
Upon receipt of the NON, the state immediately began to monitor for all
parameters required in the permit. In addition to our monthly monitoring, we are
doing the required semi-annual monitoring, and have completed the upgrade on the
leachate collection system in order to facilitate continuous pumping.
On Tuesday, February 16, 1999, Ms. Pat Backus and I met with Mr. Craig
Brown and Mr.Winston Lue in Atlanta. Ms. Backus is a chemical/environmental
engineer hired by the division as the project manager for detoxification of the
landfill. We presented data we had collected on water levels in the landfill as well
as rainfall and barometric pressure data. This information helps confirm that water
is not entering or leaving the landfill.
The current leachate system is functioning properly. Low yields of water
during pumping is a result of the water content of the landfill being at or above the
fi eld capacity of the soil, and the sump is recharged slowly.
We have installed a Slider landfill pump in the 6-inch sloped riser from the
sump. This is a pneumatic driven pump capable of delivering 9.5 gallons per
minute at 200 feet of head. The pump will have an automatic control that turns it
on and off based on changes in the water levels in the sump. Conventional flow
meters will not record the amounts of leachate pumped because of the surging
effect, however, we are investigating other means of measurement. Currently, we
plan to pump the water through the sand filtration and carbon absorption tanks. I
have enclosed copies of the lab results from the January sampling for both the
influent and effluent as it was pumped from the landfill and run through the
filtration system. The PCB levels are well below drinking water standards.
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE 919-733·4996 FAX 919•715·360S
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Ms Carol L. Kemker
March 2, I 999
Page 2
Our future plans depend on the results of pumping. If we see an increase in the amount of
water we are able to pump from the landfill as a result of continuous removal, we may install
additional pumps in the extraction wells that were installed in the landfill in 1997. We would also
look at the feasibility of purchasing a new filtration system and holding tank for the filtered
leachate in order to spray irrigate it back on the landfill if sufficient quantities of water are
removed.
Thank you for the deferral of the requirement to place a new cap on the landfill . Based on
our data from the past year, it is not necessary to redo the cap at this time, particularly as we
continue our plans for detoxification.
Analytical results for sampling events are being verified by me and other staff, and placed
in our permanent files here in Raleigh. They may be reviewed anytime or copies supplied to you
as requested . I also will notify the EPA if any changes occur in the various parameters being
monitored .
We look forward to working with Mr. Craig Brown and Mr. Winston Lue during
detoxification
Copy Mr. William Meyer
Ms . Pat Williamson
Ms . Pat Backus
Mr. Craig Brown
·---------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4APT-TS
Michael A. Kelly
Deputy Director
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
D_EC O 2 1998-
North Carolina Department of
Environment and Natural Resources
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Dear Mr. Kelly:
Thank you for your Septe:nber 1, 1998, letter requesting a
six-month extension on completion of improvements to the leachate
collection system at the Warren County Landfill (WCLF) and
submission of design plans to upgrade the landfill's cover
system. These items were required under the terms of the notice
of non-compliance issued by the U.S.-·-Environmental Protection
Agency (EPA) on August 28, 1997.
North Carolina requested the :ext:?sion in anticipation of
the North Carolina General Assemb~----s1,ftpproval of Governor Hunt's
request for funds to begin detoxifi,ca~ion work at the WCLF. In a
telephone conversation on November J:18, 1998, between you and
Craig Brown of my staff, you informed EPA that the budget
recently approved by the General Assembly included $2 million to
start detoxification. EPA also learned that the North Carolina
Department of Environment and Natural Resources, Division of
Waste Management is hiring a full-time engineer to oversee near-
term improvements to the WCLF leachate collection system and
manage the WCLF detoxification project.
This is encouraging and welcome news on the WCLF project.
In light of the State's continuing commitment to proceed with
detoxification of polychlorinated biphenyl contaminated soil at
the WC.LF, EPA is granting Nortl-1 · Ca:tolh1a the requested six-month
extension until February 28, 1999, to complete upgrade/repairs to
the leachate collection system. EPA is also granting North
Carolina an indefinite extension on submission of design plans
for landfill cover system improvements. Deferral of improvements
to the cover system at the landfill is contingent upon the State
demonstrating continued progress toward design and construction
of a soil detoxification system for the WCLF.
Soon after the new WCLF project engineer joins your staff,
we would like to invite him to meet with EPA staff members who
will be reviewing North Carolina's application for an alternative
method of disposal approval. Such a meeting will facilitate
Internet Address (URL) • http://www.epa.gov
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communication between our agencies and ensure a smoother approval
application process. Please contact Craig Brown of my staff if
you would like to arrange such a meeting. Mr. Brown may be
reached at [phone].
Carol L. Kemker
Chief
Pesticides and Toxic
Substances Branch
~-~
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4APT-TS
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA 30303-8909
fii:.C \ 2 1991 .
William L. Meyer, Director
Division of Waste Management
Department of Environment, Health
and Natural Resources
P.O. Box 29603
Raleigh, NC 27611-9603
Dear Mr. Meyer:
The U.S. Environmental Protection Agency (EPA) has reviewed
your November 25, 1997, response to the Notice of Non-Compliance
(NON) Docket Number TSCA-4-97-11844. The NON identified
violations of conditions of the polychlorinated biphenyl (PCB)
disposal permit for the Warren County PCB Landfill (WCLF) and
required that North Carolina report what actions were or will be
taken to correct those violations.
Based on our review of your response, EPA is satisfied that
North Carolina has taken appropriate steps to correct water and
leachate quality monitoring deficiencies. EPA also finds that
the corrective action plan and schedule for upgrading the
leachate extraction system is acceptable. With regard to the
contingent plan for replacing the landfill cap, modifications as
described herein, would in EPA's opinion, produce a better
performing cap.
The Landfill Cap Evaluation Report prepared by S&ME, Inc.,
notes some evidence of root penetration and pinholes in the
existing polyvinyl chloride (PVC) cap . The condition and age of
the PVC cap indicate that it may not serve as an effective long
term barrier to moisture penetration. The State has proposed to
leave the PVC and underlying clay caps in place, remove 1 foot of
top soil and place a new 60 mil high density polyethylene (HDPE)
cap ov er the bridging soil that lies between the top soil and the
PVC cap. Since the bottom liner is not a true composite liner
system, a composite cap is not required and the State's proposed
new HDPE cap is technically adequate. However, removing the
bridging soil and old PVC cap and placing the new HDPE cap
directly over the existing clay cap, would result in a superior
performance composite landfill cap.
Given the State's current commitment to detoxify the WCLF,
the difference of opinion on landfill cap design may be moot
because the cap replacement plan is not likely to be implemented.
However, EPA reserves its right to revisit the replacement cap
design should North Carolina elect not to excavate and detoxify
the WCLF.
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EPA will continue to monitor North Carolina's efforts to
upgrade the leachate extraction system. Please advise us of any
changes in schedule or activities as this work progresses. We
also wish to offer our assistance on landfill detoxification. In
that regard, we will be happy to provide informal review comments
on any plans or proposals you receive from treatment technology
vendors. Early EPA involvement in the detoxification studies and
permit application development will help ensure a smoother
permitting process when the time arises.
If you have any questions concerning this letter, please
call Craig Brown of my staff, at [phone].
Carol L. Kemker
Chief
Pesticides and Toxic
Substances Branch
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA 30303-8909
1G , 1 ,.,
4APT-TS
Michael A. Kelly, Deputy Director
Division of Waste Management
Department of Environment, Health
and Natural Resources
P.O. Box 29603
Raleigh, NC 27611-9603
Dear Mr. Kelly:
1 \ \ .. ~
~-\Y, '-\
C -
This letter responds to your December 2, 1997, request for
U.S. Environmental Protection Agency (EPA) authorization to
continue storing polychlorinated biphenyl (PCB) soil samples for
future research and development (R&D) studies. The soil samples
are being stored in two over-pack containers at ECOFLO's
commercial PCB storage facility in Greensboro, North Carolina.
These two containers are the remainder of several containers of
soil that were extracted from the Warren County PCB Landfill
(WCLF) in March 1997, for use in R&D studies on alternative PCB
disposal methods. Earlier this year, two bench top R&D studies
were completed but the remaining soil samples may still be needed
for additional tests.
North Carolina and ECOFLO have expressed concern over
continued storage of this material in light of the one year
storage for disposal rule at 40 CFR §761.65(a). EPA does not
believe that the storage for disposal rule applies to this
particular situation for the following reasons. The soil samples
were removed from the WCLF with EPA's knowledge and approval for
use in R&D tests. At the time EPA approved the intrusive
sampling work at the WCLF, we were fully aware that R&D testing
would take a year or more to complete. EPA also approved North
Carolina's proposal to store R&D soil samples at an in-State
commercial PCB storage facility because there was no suitable
storage space at the WCLF. More importantly, this material is
being stored for the purpose of R&D testing, not for disposal.
North Carolina may continue to store R&D soil samples from
the WCLF at ECOFLO or at another approved location, until the
State determines that this material is no longer needed for
testing. When that decision is made, the container(s) holding
the remaining soil samples must be dated. The material must then
be disposed of within one year of that date.
For the present, each container holding the PCB soil samples
shall be marked with the PCB ML label and stored in an area that
meets 40 CFR §761.65(b) standards. The containers should not be
dated, but should be clearly identified as PCB samples by label
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2
or tag. A copy of this letter should also be kept on file at
your office and at the facility where the material is being
stored. Once the decision is made to dispose of this material,
the PCB sample identification tag or marking must be removed and
replaced with a storage date label .
I hope this clears up any questions you have about the
applicability of PCB storage rules to this material. Please call
Craig Brown at [phone], if you have additional questions
or need further assistance in this matter.
Sincerely,
Af;t~~=:
Chief
Toxic Substances Section
cc: Paul McAllister
VlUL.V \../1 1'1\..111..11 '-''--"'....,'"'-
D~artf\1ent of Environment, I
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
l 00 Alabama Street, S. W.
Atlanta, Georgia 30303-3104
Dear Craig:
December 2, 1997
As yo u are aware. the State of:-!orth Carolina, Division of Waste Management (D\v":v1), in
conjunction with the Warren County PCB \Vorking 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 t\vo
extracti.on wells in the landfill itself, extraction of so ils from the landfill for testing, extensive site
investigation and a pilot scale detoxification study.
The detoxification studies were done on soils taken from the landfill. Excess soils fro m the
placement of the extraction wells in the landfill and the accompanying rinse \Vater and viaste,
were sent to Utah for disposal. Four 85 gallon O\·er-pack drums, each containing four 5 gallon
buckets of soils from the landfill. \Vere sent to ECOFLO, a fully permitted hazardous \vaste
management company in Greensboro, NC, who also has a permitted PCB storage area.
Two 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 plan to seek funding from the North Carolina
General Assembly to detoxify the PCB landfill. The Legislature will convene in May of 1998
for a "short 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. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Attirmative 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 untiLthe General
Assembly convenes for the "long session" during which the next budget will be wrLtten 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 761.215, 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. Analysis of the soils taken from the landfill for PCB's did not show any
concentrations greater than 500 ppm. No PCB's measured in soil from the landfill have exceeded
900 ppm.
We formally 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 matter. You may call me at 919-733-4996, extension
203, if you have any questions.
Copy: Mr. William Meyer, DWM
Mr. Cary Lester, ECOFLO
Kindest regards;·
I I .' / -------'i : I ' \ \ r \ . '-,, \ . ·-. \ -. ' ''-, "'-....__:,\r'·' ...____:<.......,---''\
Michael A:--Kelly, REM \\
Deputy Di:~~\---_ .
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste ManagE:ment
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
November 25, 1997
DELIVERED VIA FEDERAL EXPRESS
/
Ms. Carol L. Kemker, Chief
Pesticides and Toxic Substances Branch
US Environmental Protection Agency, Region 4
Atlanta Federal Center
100 Alabama Street, S.W.
Atlanta, Georgia 30303-3104
DEHNR
SUBJECT:
DOCKET NO.:
RESPONSE TO NOTICE OF NON-COMPLIANCE
TSCA-4-97-11844
Dear Ms. Kemker:
The State of North Carolina, Department of Environment and Natural Resources,
Division of Waste Management, is responsible for the maintenance of the PCB landfill in Warren
County, NC, permitted by the EPA in 1981 under the Toxic Substances Control Act (TSCA).
This agency received the Notice of Non-Compliance (NON), Docket Number TSCA-4-
97-11844 for violations of that permit. Enclosed are our responses to that NON.
The Division,in conjunction with the Warren County PCB Working Group (WG), has
expended considerable resources on the landfill during the last two years as we have moved
toward the goal of detoxification. To date, these efforts have been focused in three areas: 1) site
investigation 2) bench-scale pilot study of detoxification technologies and, 3) phase II,
preliminary draft design.
During the site investigation, 18 new monitoring wells, including three off-site.
background wells, were installed. Two bore-holes were placed in the landfill from which soils
were extracted for the detoxification studies. Extraction wells were installed in the bore-holes
and are now monitored hourly for changes in water levels. Extensive sampling and analysis have
1
P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
taken place on all of the monitoring wells, landfill soils, leachate, surrounding surface soils,
sediment and stream samples. Some samples were split with the EPA, Athens Lab. A draft copy
of the site investigation and copies of all sampling results have been sent to Mr. Cr_aig Brown in
your office.
Two companies and two technologies were selected for pilot studies--ETG
Environmental using Base Catalyzed Decomposition (BCD), and ECOLOGIC using a chemical
dechlorination process. Following the results of this "phase I" study, the Working Group
selected the BCD technology as the one for detoxification, as recommended by their Science
Advisors. ETG is now working on a phase1I report which will be a draft remedial design plan
for detoxification of the landfill. Once completed (anticipated in mid-January), the WG and
division will put together a plan to seek funding for detoxification. The Department of
Environment and Natural Resources is committed to pursuing detoxification.
We anticipate various committees of the North Carolina General Assembly to begin
meeting in March 1998, with a short session beginning in May 1998. We expect to know by July
1 if funding will be available. It is possible that the request may have to wait until the long
session in January 1999.
The State of North Carolina will fund all activities required to comply with the with the
NON. We do not anticipate any problems associated with the activities scheduled between now
and July of next year, specifically implementation of our phase 1 plan. We have put together a
response to fully comply with the NON requirements of a Phase 2, if that is necessary.
In response to Violations # 1 and #2, the division has already implemented required
testing at the landfill. The monthly testing on the leachate, since November, has included PCBs,
pH, and specific conductance. The first round of semi-annual testing for 1997 was conducted
this past spring and included these parameters. The second round of semi-annual testing was
conducted on November 17 and 18. In addition to the monitoring wells, surface water and
sediment samples previously sampled, we have added all of the new wells strategically located
around the landfill. This monitoring is discussed in detail in the attachments.
Violation #3 is discussed in detail in the attachments. The division intends to do
considerable testing on the pump rates and re-charge rates of the leachate collection system,
including the two new extraction wells. Once we determine a sustainable pumping rate, we will
design an automatic pumping system to continuously remove water from the landfill. This will
facilitate detoxification and meet permit conditions. It is our belief that the leachate collection
system does function properly, however, the transmissivity of this system is a problem because
of the low permeability of the soils transmitting water to this layer. Use of the extraction wells
will help in the removal of the water, but the process could take several years to complete.
2
A contingency plan (phase 2) for replacing the landfill cover system is attached. It could
be implemented if we are unable to secure funding for the detoxification and fail to submit an
alternate method for PCB disposal next summer.
We appreciate EPA's working with us on this project. The State of North Carolina is
committed to ensuring that we are in compliance with the TSCA permit. Please contact Mr.
Michael Kelly at [phone]; extension 203 , if you have any questions regarding this
response.
Copy: Henry Lancaster, DENR
Michael Kelly, DWM
Pat Williamson
PCB Working Group
Science Advisors
i. cerely yoDurs ( ~
i " n . (~·. ; I ~
,-~
1
wh1iam L Mey~) .
--._}_.:,,-------Director \
3
VIOLATION #1:
RESPONSE TO NON FROM EPA, TSCA-4-97-11844
APPENDIX 1
MONTHLY MONITORING OF LEACHATE
The December 14, 1981 letter of approval for the PCB landfill requires monthly
monitoring for leachate quality and quantity, and proper disposal of collected leachate. The state
was exempted from testing for chlorinated cfrganics but is required to test for PCB, pH and
specific conductance. Although the state has performed certain monthly monitoring and checks
on the leachate, it has not conducted pH and specific conductance on a routine basis.
The state has the specific field equipment necessary to perform on-site testing for pH and
specific conductance, and will begin immediately to ensure that these tests are done each month.
Under normal circumstances, Division of Waste Management (DWM) personnel perform testing
and inspection of the landfill during the last two weeks of the month. All results of analyses will
be submitted to the EPA within 30 days of the testing, beginning with the November 1997
sampling event.
The leachate will be pumped, sampled and discharged according to the permit conditions
using the current equipment on site (gas powered diaphragm pump) until the new equipment
discussed in Violation #3, Leachate Collection System (LCS), can be designed and installed. It
is anticipated that this phase will be operational by June 1998. At that time, the state will begin
routine, continuous pumping of leachate from the LCS and the two bore-holes installed this
spring in the PCB landfill. This de-watering of the landfill will most likely be a long term event,
which will facilitate detoxification as well as meet permit conditions.
VIOLATION #2: SEMI-ANNUAL MONITORING
The state is required by its permit to do extensive semi-annual monitoring of the surface
water and groundwater at the site. This sampling is to be specific for PCBs, pH, and specific
conductance. Although the state has done continuous monitoring at the site for PCBs, it has not
completed monthly or semi-annual testing for pH and specific conductance.
In April and November 1997, the state performed extensive sampling at the landfill. The
April sampling was done as a part of the site investigation. Results of that event have been sent
to Mr. Craig Brown of your office. EPA personnel from the Athen's lab were present during part
of the sampling and split some samples with the state.
4
The semi-annual sampling was conducted November 17 -18, 1997. Samples were taken
from monitoring wells and surface water. In the past, the state sampled the four original
monitoring wells located around the landfill. Beginning this year, with the install~tion of new
wells at the site, we will use only three of the previous wells-#1, #2 and #3-and add five of the
new wells around the landfill, adjacent to the fence. These wells are numbered IA, 5D, 7, 11
and 12. Field instruments are being used for pH and specific conductance.
All results will be forwarded to the EPA as soon as they are available. Future testing for
the semi-annual events will occur in the spring and fall.
/
ADDITIONAL SAMPLING AND TESTING
As previously discussed, the state is working closely with the PCB Working Group in
pursuit of detoxification. During the next few months, as we implement the various tasks to
ensure compliance at the landfill, we will incorporate other air and groundwater tests designed to
help monitor the conditions of the landfill.
METHANE TESTING
On two occasions this year, the state has "gridded" off the perimeter of the landfill,
plugged the top eight inches of soil and systematically checked for methane. The landfill
generates gas as part of the natural decomposition of organic materials present, and methane is
nearly always detected in the vent pipe and bore-holes ( extraction wells) at the landfill.
The issue of airborne particulate matter containing PCBs is a concern of the Working
Group. Any such particulate matter escaping from the landfill may be expelled by "belches" of
gases from the landfill. There is also concern over the condition of the landfill cap.
The DWM will perform monthly monitoring for methane gas, and extensive quarterly
monitoring around the perimeter of the landfill to detect any breaches in the cap through which
methane gas may be escaping.
DIOXIN TESTING
There were a variety of dioxin compounds detected in numerous samples taken this past
spring. Two of the monitoring wells close to the landfill, #IA and #5D, showed positive hits for
several of the dioxin compounds similar to those in the landfill. Despite considerable discussion
about dioxin in the Site Investigation Report, the state cannot draw any conclusions from the
data.
5
Additional testing for dioxin will be conducted during the next semi-annual event on
selected wells, including #IA and #5D, the leachate, and at least one of the background wells.
AIR MONITORING
There has been much concern about the potential for airborne particles contaminated with
PCBs "belching" from the landfill. The state has conducted two air sampling events using PUF
filters and both low flow and high volume air pumps. One sample was positive for PCBs. The
concentration was extremely high, and therefore suspected as not being valid since no other
samples, including one directly beside it and the sample from inside the landfill, showed any
detectable levels of PCB.
Personnel monitors were used during the site work last spring during the excavation of
soils, installation of extraction wells, and cutting of the plastic liner for testing. None of these
samples were positive. EPA, likewise, performed high volume sampling over a 24-hour period
in August, and no PCBs were detected.
In December 1996, a carbon filter was placed on the vent pipe at the landfill to ensure
that any particulate coming from the landfill through the vent would be trapped. Concern is now
primarily over the possibility of particulate being belched from the landfill through cracks or
faults in the cap. Methane monitoring should assist in the identification of any cracks or failures
in the landfill cap.
The state will perform air monitoring routinely at the landfill and least a quarterly 24-
hour high volume sampling event.
WEATHER STATION/ WATER LEVEL MEASUREMENTS
The state has installed a weather monitoring station at the landfill to record temperature,
barometric pressure and rainfall. Monitoring devices have also been placed in both extraction
wells to hourly measure the water level in the landfill.
An on-site computer system records the data which is then downloaded on a monthly
basis by DWM personnel. Analysis of the data will include correlations between barometric
pressure and rainfall with the level of water inside the landfill. Continuous monitoring of the
water level in the landfill will provide useful information on the integrity of the cap and any
infiltration / exit of water into or out of the landfill.
The division also plans to add to the monitoring at least one of the monitoring wells
outside of the landfill.
6
VIOLATION #3: LEACHATE COLLECTION SYSTEM
SUBJECT: PCB Landfill, Warren County-Analysis of geotechnical testing results, and
evaluation of remedial alternatives for the existing leachate collection system.
INTRODUCTION
In 1993, the state reported that water was present in the landfill. Water was measured in the
leachate collection sump riser. Calculations were made as to the volume of water based simply
on the reported results of measured water levels in the leachate collection line and using
assumed porosities and saturations of the landfill contents. Two-bore holes were drilled in the
landfill in February 1997, to remove soils for bench scale testing of PCB detoxification
technology. Wells that were installed in these-bore holes are being continuously monitored for
water level changes. Soil samples were taken at intervals in the landfill during the drilling
process. Standardized geotechnical tests were performed by an independent testing laboratory.
The tests included determination of grain size, density, moisture content and permeability.
In September 1997 the USEP A issued a notice of Non-Compliance to the state. The state was
cited for violations of a permit condition requiring that the leachate be pumped to maintain the
head on the bottom liner system to less than one foot. This report is in response to that notice.
The state proposes a three-phase approach to bring the landfill into full compliance with its
operating permit. The three phases are:
• Analyze existing data to calculate the theoretical properties of the landfill, including
moisture content, porosity, yield, and capacity and yield of the leachate collection system;
• Perform pump tests on the existing leachate collection system and the two wells in the
landfill. The results will be compared to the theoretical values and pump sizes, and
ancillary equipment will be specified and obtained; and
• Install automatic pumps to extract the moisture from the landfill and discharge it through
the existing permitted on-site treatment and irrigation system.
This report includes the evaluation of the existing data obtained from the landfill investigation
and from ongoing continuous monitoring. A proposal for implementing phase 2 of the
remediation as well as a conceptual plan for the actual pumping is also included.
7
ANALYSIS OF EXISTING DATA
To effectively design a method for removing water in the landfill, it is necessary to evaluate the
new data about the landfill that was obtained during the February 1997 site investigation. Data
also exist from an ongoing continuous monitoring program that the state is currently conducting
at the landfill. The analysis will determine:
• How much moisture is in-the landfill;
• The characteristics of the material holding the moisture;
• The theoretical transmissivity of the leachate collection system(LCS). /
Moisture Content-
Samples were obtained from the landfill during the February boring. Seventeen jar samples,
obtained from split spoon sampling, and 10 undisturbed samples obtained from shelby tubes
were analyzed for moisture content in accordance with ASTM D2216 testing protocols. The tests
indicated that the landfill has an average moisture content of 13.45 percent by mass. Converting
this weight of water to a volume indicates that there are about 2 million gallons of moisture in
the landfill, and the average moisture content, on a volumetric basis, is 25 percent (vol/vol).
In 1982, moisture tests were performed on samples obtained from four borings in the landfill.
The samples were taken after large amounts of rain and before final closure of the landfill. At
that time, the reported moisture contents were a wider range of 5-20 percent, but still averaged
12.86 percent by weight. This translates to approximately 1.9 million gallons of moisture. The
moisture content in 1982 was 24 percent (vol/vol).
Total Porosity-
The bulk density, dry density and specific gravity of the landfill contents were obtained by
testing samples from 10 shelby tubes. The specific test methods used were ASTM D1587, D2937
and D854 respectively. The total porosity of the landfill can be calculated using the dry density
and specific gravity of the material. The total porosity of the system is 36 percent.
Clearly the moisture content of the landfill (25 percent) is less than the porosity (36 percent), so
the landfill is not saturated with water. During sampling of the landfill, visual observations of the
split spoon samples confirmed this . There was no free water that drained from the landfill
materials collected in the split spoons or shelby tubes.
Effective Porosity-
The effective porosity of the landfill soils was calculated using the grain-size analysis results
(ASTM D422) and plotting the results on a triangle chart produced by Johnston (1967). The
effective porosity or specific yield of the soil is a measurement of how much water an aquifer
will yield or give up under gravity drain conditions. It was determined that the landfill has a
calculated effective porosity of 18 percent (vol/vol).
8
Field Capacity-
The field capacity of the soil is a measurement of how much water a soil will absorb or hold. If
the moisture content of the soil is below the field capacity, then water will not grayity drain out
of the soil; if it is above, it will. The field capacity was determined using empirical equations
(reference EPA 1994). The field capacity of the landfill contents is 22 percent (vol/vol)
Available Moisture-
What is immediately evident is that the landfill is just barely above field capacity and only
slightly more than the estimated specific yield. Three percent of the volume of the moisture is
only 60,000 gallons, while 7 percent is 140;D00 gallons. Thus the moisture content of the landfill
is estimated to be 2 million gallons, with only 3-8 percent estimated to be available for removal.
Permeability-
Shelby tubes oflandfill contents were obtained and permeability tests (ASTM 5084) were run on
them. Slug tests were also performed on one of the bore holes. The test results indicate that the
permeability of the landfill contents is on the order of 1x10·5 cm/sec.
Transmissivitv of LCS-
Calculations were made of the theoretical transmissivity of the leachate collection system, the
sump, and the two wells in the landfill.
The transmissivity of the landfill leachate collection system is 0.015 gal/min/sq ft, a small
amount of water. It is important to note that the controlling factor in removing the water from
this landfill is not the transmissivity of the leachate collection system but the low permeability of
the soils transmitting water to this layer. Much has been said about the lack of pipes in the
landfill, but they would not significantly increase the amount of water collected since the amount
transmitted to the LCS is controlled by the landfill contents.
The maximum transmissivity of each bore hole well is 0.32 gal/min/sq ft. This assumes a 10
foot level of available moisture and an effective diameter of 0.698 feet. As moisture is removed
from the system, the length of the column will decrease and the flow will decrease accordingly.
LEA CHA TE COLLECTION SYSTEM TESTING
It will be necessary to perform pump tests on the leachate collection system and the two bore
holes to provide information that will be used in the final design of the system that will be
proposed for long-term remediation of the existing LCS. The theoretical calculations indicate
that the yield from the system is low. One goal of the tests will be to see if there is a sustainable
pumping rate at which the system can be continuously run.
9
Method-
To gather the data that is needed, several simple pump tests will be performed. Low volume,
adjustable flow rate pumps will be used. The first step will be to pump the test point dry, and
then measure how long recharge takes. In the second round of tests, continuous pumping will be
experimented with to determine if there is a pump rate at which sustained levels of pumping can
be done.
The specific type of pump, and whether it will be placed in the landfill or will reside atop the
landfill, will be determined by availability of equipment. The existing downhole sensors can be
used to monitor the recharge of the bore holes.
Treatment-
Treatment and disposal of the leachate recovered during the pump test is of prime concern. The
leachate could be discharged through the existing permitted treatment system. It is recommended
that external treatment be used for this test. The low flows expected can easily be treated with
small filtration equipment. This will be used since it is unknown how much sediment is in the
leachate. The use of staged equipment will allow for easy monitoring of the treatment process
and an ability to determine the amount of sediment in the leachate.
A series of three sediment filters will be used. Initially the size of the sediment filters will
descend from 10 to 5 to 1 microns. The leachate will pass through a packed bed filter of granular
activated carbon. The clean water will then be discharged through the existing permitted leachate
collection treatment system for final discharge to the sedimentation basin.
When the sediment filters need to be replaced, they will be removed from the filter housing and
put in double plastic bags. They will then be stored in an onsite drum until final disposal at an
approved disposal site.
LEACHATE REMOVAL
The results of the pump test will be used to properly design and specify the elements of a
leachate removal system. It is anticipated that the existing leachate collection sump riser and the
two new bore-holes will be equipped with low-flow pumps, which will be activated by water
level sensors. The leachate will be treated and discharged through the existing permitted
treatment system. The existing treatment system will be evaluated to determine if any of the
components need to be replaced or upgraded prior to actual startup. At the anticipated low-flow
rates, the water may be treated and discharged to the sedimentation basin or stored in a tank and
later used to irrigate the vegetation on the landfill.
The previous calculations have demonstrated that the amount of recoverable water in the landfill
is relatively small. Constant pumping of the leachate should return the landfill to compliance
with its operating permit. The amount of time this is expected to take will be determined after the
pump tests are analyzed.
10
Removal of available moisture from the landfill will also benefit any future plans to detoxify the
landfill contents. The p"roposed detoxification method is a thermal treatment process. Any
moisture that can be removed from the system should aid in lowering energy costs for the
process, since that is a volume of water that will not have to be boiled off during the treatment
process. It will also lower the amount of water and waste products that will have to be collected,
tested and disposed as a result of the detoxification process.
REFERENCES-
Johnson, A.L.(1967), " Specific Yield-Compilation of Specific Yields for Various Materials."
Geological Survey Water-Supply Paper 1622-D. Washington, D.C.
Schroeder, P.R., Dozier, T.S., Zappi, P.A., McEnroe, B.M., Sjostrom, J.W., and Peyton, R.L.
(1994). "The Hydro logic Evaluation of Landfill Performance (HELP)Model: Engineering
Documentation for Version 3," EPA/600/R-94/168b, USEPA Risk Reduction Engineering
Laboratory, Cincinnati, OH.
11
PHASE2: CAP REPLACEMENT
Monitoring well information indicates water level fluctuation is influenced to a far greater
degree by ambient air pressure rather than infiltration. The investigation earlier this year also
indicates that while the synthetic cap membrane has degraded, overall, it still provides relatively
good, though not perfect, protection from infiltration.
If a cap is required, we would recommend the following (listed from the bottom of the
cap to the top): ,,,
• Leave the existing 10 mil PVC cap and underlying clay in place;
The existing PVC liner and clay liner will act as a very effective redundant system. With
installation of an additional synthetic liner and drainage layer, infiltration to the existing
PVC cap should be effectively eliminated;
• Remove approximately one foot of the vegetative and erosion control cover to eliminate
organic matter and roots;
• Rework (shape, compact) the remaining cover to provide a suitable sub-base for
additional cap layers;
• Install a 60 mil HDPE synthetic cap.layer. The difference in cost between 40 mil and 60
HDPE is nominal. The 60 mil thickness provides greater security in seaming, puncture
resistance, and degradation;
• Install a fabric bonded HDPE single layer drainage net. These types of drainage nets
provide an extremely transmissive drainage layer effectively eliminating head (water
column) on the HDPE liner;
• Provide a continuous drainage collection system around the perimeter of the HDPE
drainage net. This would be a simple "french" drain that is connected to the drainage net.
• Discharge collected rain water to a sedimentation and erosion control pond(s) separate
from the existing structure. This will allow for separate constituent monitoring if
necessary in the future;
• Install a 2-foot vegetative and erosion control layer. The previously removed erosion
control layer material can be incorporated into this new layer; and
• Seed and mulch the new erosion control layer.
12
In addition to i~stalling the above cap system, passive methane venting would be
installed. Venting systems typically consist of collection pipes embedded in crushed rock filled
trenches just below cap systems and vented to vertical stand pipes.
For the PCB landfill, this would require breaching the existing PVC liner and clay cap to
install the vents.
To minimize disturbing the existing cap, alternative venting should be explored as a part
of the request for proposals (RFP) solicited for the final design of the additional cap system.
,/
In a caveat to the above presented preliminary design, the preliminary nature must be
emphasized. A final design would depend upon analysis and recommendations presented by the
engineering consultant once one is selected through the RFP process. For example, it may be
found that methane venting could be accomplished using the existing monitoring wells and vent
pipe.
In addition, decisions on landfill de-watering can affect the design in terms whether or
not the existing wells are utilized. Handling of leachate, if sprayed on the cap for example, would
affect the final design.
As all actions taken at the landfill can affect other elements and designs, any cap design
or other component design presented at this time must be considered preliminary and subject to
change.
If it is determined that cap or other improvements are necessary, the RFP development
and selection process should provide information needed to refine final designs.
13
APPENDIX2
SCHEDULE OF COMPLIANCE
RESPONSE TO NON FROM EPA, TSCA-4-97-11844
VIOLATION #1: MONTHLY MONIT0RING
Start date: November 1997
Monthly monitoring, usually done during the last two weeks of each month
Items measured: Leachate
Parameters: PCBs, pH, specific conductance
Leachate system: To be pumped at each visit until continuous system installed
Additional monitoring for methane
VIOLATION #2: SEMI-ANNUAL TESTING
Start date: April 1997
Most recent: November 17-18, 1997
Occurrence: Semi-annual testing to be in the spring and fall of each year
EPA to be notified of actually dates
Parameters: PCBs, pH, specific conductance*
Additional monitoring for dioxin--selected wells
Locations: All approved surface water and sediment sources
Monitoring wells--1, IA, 2, 3, SD , 7, 11 , 12**
Leachate , inlet and outlet
* Parameters for liquids; solids will be tested for PCBs only
* *Change in some well locations; addition of wells installed in spring of 1997 around
perimeter of the landfill.
14
VIOLATION #3: LEACHATE COLLECTION SYSTEM
Start date: November 1997, removal of water using existing LCS and pump
Occurrence: Monthly until installation of continuous pumping system
New pump system:*
Pump testing
Design and RFP
Plan to EPA
Contract issuance
Installation
In service
/
January 1998
February 1998
March 1998
April 1998
May 1998
June 1998
*Plan to include use of current LCS and both extraction wells installed in March 1997.
PHASE 2: CAP REPLACEMENT
A preliminary design for cap replacement is included in the Appendices. Cap
replacement will occur if funding for detoxification is not received. It is understood that EPA
desires cap replacement if an application for alternate PCB disposal for the landfill soils is not
received by August 27, 1998.
Funding for detoxification
Decision for detox/ cap replacement
Final design for cap
Submittal to EPA
RFP
Issuance of contract
Begin construction
*If required
15
March-June 1998
July 1998
July 1998*
August 1998
September 1998
November 1998
January 1999
j • ; ___ l..!..
JOINT WARREN COUNTY/STATE PCB LANDFILL
WORKING GROUP
Release : Immediately Date: Au_gust 29, 1997
EPA NON-COMPLIANCE NOTICE ISSUED TO STATE-:
LOCAL WORKING GROUP NOTIFIED
The Joint Warren County/State PCB Landfill Working Group (Working Group) was notified on
Thursday August 28, 1997 that the North Carolina Department of Environment, Health and Natural
Resources' Division of Waste Management has been is..."lled a notice of non-compliance by the United
States Environmental Protection Agency (EPA).
EPA in its letter of non-compliance states "EPA recognizes that eliminating the large amount c f
leachate that has accumulated in the Warren County Landfill (WCLF) may take several years due to
the degraded condition and/or limited capacity of the Leachate Collection System (LCS) drainage
layer and sump. There may also be more than one contributing factor to leachate production If the
leachate build-up was due only to storm water introduce during the operational period, the:1
upgrading the leachate pumping systern would be sufficient to correct the problem. There is some
evidence indicating that the leachate build-up is due in part to infiltration of precipitation th:rnugh the
landfill cover system. Therefore, replacing the cover system. in addition to the pump system upgrade
may also be necessary. Also in its non-compliance letter EPA indicated that another factor that must
be considered in addressing the leachate management problems is North Carolina's plan to detoxify
the WCLF contents and they do not recommend replacing the cover system if North Carolina pla.11s
to excavate and destroy PCBs in the landfill in the near future.
We are pleased that EPA responded to our concerns of non-compliance. We believe that based on
their two phase contingency plan, that they have considered our request of October 25, 1996 to link
compliance to detoxification
Since the establishment of the Working Group in 1994, we have hired two Science Advisors, who
have been assisting us in collecting and analyzing data from the landfill and determining the feasibility
and availability of a technology for detoxifying. We have done a site assessment and evaluation, have
had two companies perform pilot studies on soil from the landfill for detoxification and we are in the
process of evaluating the data. We expect to choose a detoxification technology by early fall and
to complete a design plan for that technology by the first of the year.
We plan to recommend to the State a feasible and safe technology and show to the tax payers that
a detoxification solution is more cost effective solution to all the problems of the landfill.
"Our goal is detoxification of the landfill and we will continue to work toward that end." said Dollie
B. Burwell, Co-Chair of the Working Group.
720 Ridgeway Street
Warrenton, N. C. 27589
Post-W' Fax Note
To From
I--U--l,.-'--""'-.,_..__.._.a..1..,.'-'-+---+-~~c:..a,,;.-'-'----'~-=---"---~·.c!.......:
Cc.
James B. H_u~t.1 ,t, Governor ~y.J~
DEHNR Wayne McOevitt, Secretary
North Carolina
Department of Enviroriment, Health and Natural Resources
Release:
\
Date:
Contact:
Immediately
August 28, 1997 Distribution:
,
. I -
Pat Williamson
919-733-4996, ex.337
Cap. Press; Warren, Vance
EPA ISSUES NON-COMPLIANCE NOTICE TO STATE AGENCY
RALEIGH -The US Environmental Protection Agency (EPA) has issued a Notice
of Non-Compliance to the Division of Waste Management, NC Department of
Environment, Health, and Natural Resources, for violating TSCA (Toxic Substances
Control Act) regulations pertaining to the state-owned PCB landfill in Warren County.
"We just received the Notice of Non-Compliance and plan to follow all of EPA's
recommendations and requirements, to the letter," said William L. Meyer, director of
the Division of Waste Management.
He said that state officials had been working closely with the Joint Warren
County/ State PCB Landfill Working Grau p to determine the current status of the
landfill and develop a plan to detoxify it. Funding for detoxification would have to be
appropriated by the NC General Assembly.
PCBs are polychlorinated biphenyls, a chemical once widely used as a liquid
insulation material in electrical transformers. The chemicals were banned in 1976. In
1978, about 30,000 gallons of PCBs were illegally dumped along more than 200 miles
of roads in 14 counties in North Carolina. A site near Afton in Warren County was
chosen for the landfill that would contain the PCB-contaminated soils picked up along
the roadsides.
In the fall of 1996, the 22-member Working Group sent a letter to EPA Region IV
Director John Hankinson requesting EPA staff to inspect the landfill and review state
files after a science advisor for the working group found the state was not in
compliance with certain conditions of its approval agreement with EPA.
In January 1997, Craig Brown with EPA Region IV inspected the landfill and
state PCB landfill operating records. He found that the Division of Waste Management
(DWM) had violated some of the monitoring and leachate management requirements
stated in the EPA letters of approval dated June 4, 1979 and December 14, 1981. The
violations and recommendations are:
Violation: The Notice of Non-Compliance (NON) states that the division's
monthly monitoring reports indicated no leachate samples were ever tested for pH
(indicates acidity) and specific conductance (indicates any change in water other than
what would be expected) as required in the letter of approval dated December 14, 1981.
Recommendation: That the division monitor leachate for PCBs, pH, and specific
conductance on a monthly basis beginning with the first monthly monitoring event
after receipt of the NON.
MORE
Public Affairs Office Don Reuter
Director, Office of Public Affairs
i~
P.O. B.ox 27687, Raleigh, N.C. 27611
.· .. ""\
\ .......
.. ---..
Violation: The December 14, 1981 EPA approval letter requires semi-annual
monitoring of groundwater monitoring wells and surface water for PCBs, pH, and
specific conductance. The NON states that the division never tested sampl_es for pH
and specific conductance, but did test regularly for PCBs except for 1987, 1995, and
1996, when only one set of samples was taken. Recommendation: That the state
monitor surface water and groundwater semi-annually for PCBs, pH, and specific
conductance.
Violation: The EPA letter of approval dated June 4, 1979, required the state to
install a leachate collection system (LCS) above and below the landfill's bottom liner
that would allow removal of any collected leachate. The liner was installed as required,
but the division has removed only small amounts of leachate since the landfill was
closed. Because there is at least 10 feet of standing liquid over the bottom liner, EPA
determined that the primary LCS (above the liner) does not meet the LCS performance
standard stated in the approval letter. The EPA's intent in the condition of approval
was to require installation and operation of a LCS that could remove leachate as it was
generated so there would be no build-up of leachate over the landfill liner system. EPA
considers both a properly functioning LCS plus a liner system are necessary to prevent
PCB releases to groundwater.
Recommendation: That the division upgrade the leachate pumping system if the
buildup of leachate was caused by storm water that collected in the landfill when it
was operational. However, there is some evidence that the leachate buildup may be
due in part to precipitation that entered through the landfill cover system. EPA stated
that it may be necessary to replace the cover system in addition to the pump system
upgrade. EPA does not recommend replacing the cover system if North Carolina plans
to excavate and destroy PCBs in the landfill in the near future.
Requirement: The NON also requires North Carolina to prepare and submit to
EPA for approval, a two-phase corrective action plan to eliminate leachate from the
landfill. Phase 1 must include a plan and schedule for replacing/upgrading the
existing leachate pumping system designed to operate on a more-or-less continuous
basis. A contingent, phase 2 plan and schedule for replacing the existing cover system
must be submitted to EPA for approval. EPA will require replacement of the landfill
cover if the state does not submit an application for an alternate method of PCB
disposal for the landfill soil within one year from the date North Carolina received the
NON. The two-phase corrective action plan must be submitted to EPA no more than
90 days after the state received the Notice of Non-Compliance.
The EPA imposed no fines, but the NON states that additional enforcement
action, including fines, could be assessed if North Carolina fails to implement the
recommendations or fails to submit a leachate management corrective action plan in a
timely manner.
EPA Contact: Mr. Craig Brown, 404-562-8990
Warren County Contact: Ms. Dollie Burwell, 919-981-0400 (w), 919-257-1353 (h)
#####
'I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER , ... ' .. ,..,,,
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
.,,. ~ .. ~, ~va~tr \
AUG 28 WJ7 ;
4 APT-TS
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
William L. Meyer, Director
Division of Waste Management
Department of Environment, Health
and Natural Resources
P .O. Box 27687
Raleigh , North Carolina 27611-7687
Subject :
Docket No.:
Dear Mr. Meyer :
Notice of Non-Compliance
TSCA-4-97-11844
The United States Environmental Protection Agency (EPA)
finds the State of North Carolina in violation of the
Polychlorinated Biphenyl (PCB) regulations, 40 CFR Part 761
promulgated under Section 6 (e) of the Toxic Substances Control
Act (TSCA).
On January 21 -22, 1997 , an EPA representative performed an
inspection of the Warren County PCB Landfill (WCLF) located in
Warren County, North Carolina and reviewed the facility operating
records located in the offices of the North Carolina Department
of Environment, Health and Natural Resources, Division of Waste
Management (DWM) in Raleigh, North Carolina . The WCLF, owned by
the State of North Carolina , was approved by EPA for disposal of
PCB contaminated soil. Requirements for construction, operation,
monitoring, reporting and recordkeeping were established as
conditions of approval in letters issued on June 4 , 1979 , and
December 14, 1981 . During the inspection , it was determined that
North Carolina has violated conditions of the approval(s)
pertaining to monitoring and leachate management. The specific
deficiencies found by EPA and steps North Carolina must take in
order to achieve compliance are set forth below in this Notice of
Non-Compliance (NON).
Violation 1 . Condition II .A., Letter of Approval dated
December 14, 1981, requires monthly monitoring for leachate
quality and quantity and proper disposal of collected leachate.
Required leachate monitoring parameters are specified in 40 CFR
§761. 75 (b) (6 ) (iii), formerly §761.41 (b) (5) (iii) and include
PCBs, pH , specific conductance , and chlorinated organics. North
Carolina requested and was granted a waiver from the requirement
for chlorinated organics monitoring per the June 4, 1979 , Letter
of Approval. Monthly monitoring reports compiled by the DWM
indicate that leachate samples were never tested for two
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'
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2
monitoring parameters required by the PCB disposal approval, pH
and specific conductance.
Recommendation. Starting with the first monthly monitoring
event after receipt of this letter and continuing monthly
thereafter, North Carolina shall monitor leachate for PCBs, pH,
and specific conductance. Field instruments may be used to
measure pH and specific conductance.
Violation 2. Condition II.H.2., Letter of Approval dated
December 14, 1981, requires semi-annual wonitoring of groundwater
monitoring wells and surface water for PCBs, pH, and specific
conductance. A review of the State's monitoring records
indicates that the State has carried out the required semiannual
monitoring during the post closure period with three exceptions.
Only one set of samples was collected in the following years:
1987, 1995, and 1996. Additionally, it appears that groundwater
and surface samples were tested for PCBs but have never been
tested for pH and specific conductance as required by the PCB
disposal approval.
Recommendation. Henceforth, North Carolina shall monitor
surface water and groundwater semi-annually as required by
Condition II.H.2., of the December 14, 1981, Letter of Approval.
All water samples shall be tested for PCBs, pH and specific
conductance. Field instruments may be used to measure pH and
specific conductance.
Violation 3. Condition B.10., Letter of Approval dated
June 4, 1979, required installation of a leachate collection
system (LCS), above and below the liner, that would allow removal
of any collected leachate. The LCS was installed as required by
the approval letter and North Carolina has removed nominal
amounts of leachate during the post-closure care period.
However, as evidenced by ten or more feet of standing liquid over
the liner, EPA has determined that the primary LCS (located above
the liner) does not meet the LCS performance standard specified
in Condition B.10. The intent of this condition of approval was
to require installation and operation of a LCS capable of
removing leachate as it is generated, to prevent a build-up of
leachate over the landfill liner system. EPA considers a
properly functioning LCS in combination with a liner system
necessary to prevent PCB releases to groundwater.
Recommendation. EPA recognizes that eliminating the large
amount of leachate that has accumulated in the WCLF may take
several years due to the degraded condition and/or limited
capacity of the LCS drainage layer and sump. There may also be
more than one contributing factor to leachate production. If the
leachate build-up was due only to storm water introduced during
the operational period, then upgrading the leachate pumping
system would be sufficient to correct the problem. There is some
evidence indicating that the leachate build-up is due in part to
,,
3
infiltration of precipitation through the landfill cover system.
Therefore, replacing the cover system, in addition to the pump
system upgrade, may also be necessary. Another factor that must
be considered by EPA in addressing leachate management problems
is North Carolina's plan to detoxify the WCLF contents. The
Agency does not recommend replacing the cover system if North
Carolina plans to excavate and destroy PCBs in the landfill in
the near future.
North Carolina shall prepare and submit for EPA's approval,
a two-phase corrective action plan (CAP) to eliminate leachate
from the WCLF. Phase 1, shall include a plan and schedule for
replacing (upgrading) the existing leachate pumping system (i.e.,
the gas-powered diaphragm pump housed in a small shed at the
north end of the landfill). The existing pump can only be
operated when an inspector makes a monthly visit to the site.
The new system should be designed to operate on a more-or-less
continuous basis (e.g., a submersible pump installed in the LCS
sump pumps leachate to a temporary holding tank that when full,
discharges leachate to the existing leachate treatment system).
A contingent, phase 2 plan and schedule for replacing the
existing cover system shall also be submitted to EPA for
approval. EPA will require replacement of the landfill cover if
North Carolina does not submit an application for an alternate
method of PCB disposal for the WCLF soil within one year from the
date of North Carolina's receipt of this NON. The two-phase CAP
shall be submitted to EPA within 90 days of North Carolina's
receipt of this NON.
Failure to correct the violations cited above could subject
North Carolina to penalties under TSCA. Further, this NON does
not preclude EPA from taking additional enforcement action,
including the assessment of civil penalties, in the event that
the remedies specified above are not implemented or North
Carolina fails to timely submit a leachate management CAP.
Please contact Mr. Craig Brown at [phone], if you
have any questions regarding this letter.
~::C EJ~
Carol L. Kernker
Chief
Pesticides and Toxic
Substances Branch
,,, ,~ ·;/ 0 . ...---1.::t'.'
~ :r State of North Carolina
fn,,--tr\' ~· L Department of Environment, frt".J e-i 11"'" Health and Natural Resources AVA .1~, f, Division of Solid Waste Management
I
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
February 5, 1997
Mr. Craig Brown, TSCA Permit Manager
Environmental Protection Agency
Region 4
100 Alabama Street, S.W.
Atlanta, Georgia 30303-3104
Dear Mr. Brown:
DEHNR
As you are aware, the State of North Carolina, Division of Waste Management (DWM),
continues to work with the Warren County Working Group and their Science Advisors on issues
surrounding the PCB Landfill in Warren County. On Monday of this week, I faxed to you a
copy of the proposed schedule of activities to be taking place at the landfill during the next 6
weeks.
This letter is to advise you that we currently plan to add 12 additional monitoring wells to the
area around the landfill and put in 3 off site, background wells l/2 to 2 miles away from the
landfill. I am enclosing a copy of a map depicting the additional well sites, except for the 3 off
site wells, as those site locations have not been completed as of today.
These well sites were picked by the Science Advisors and DWM personnel in order to provide
maximum sampling data on the ground water around the landfill as a part of a major sampling
event to take place (tentatively scheduled) the first week of March, 1997. I have also enclosed a
copy of a map showing the area within 1 /2 mile radius of the landfill which depicts the current
monitoring wells and proposed sampling sites for stream and sediment samples.
The contractor doing the monitoring well installation was given and will follow the US EPA
Region IV "Environmental lnvesti~ations Standard Operatin~ Procedures and Quality
Assurance Manual (May 1996)". Work will be over sighted by the Science Advisors and
DWM personnel. Monitoring wells will be constructed in accordance with the Title 15A NC
Administrative Code Subchapter 2C-"Well Construction Standards".
P.O. Box 27687,
Raleigh, North Carolina 27 611-7 687
Voice 919-733-4996 1:@MdJI.Pj~
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50°k recycled/1 O"lo post-consumer paper
Mr. Craig Brown, EPA Region 4
February 5, I 997
As noted in the schedule of events, the mobilization and work is planned to begin on
Wednesday, February 12. Please let us know of any further information you may wish to have
added to the Permit File on the TSCA Landfill, as well as any questions you may have.
I will keep you informed on our progress.
Copy: Mr. William L. Meyer
Warren County PCB Wor
Mr. Patrick Barnes
Dr. Joel Hirschhorn
·ng_~roup
--------------·---
~/-;\)( \_)' / ~ f .. -.,.r~--:' / \ .\· .. • , 'II ·•., .. \ ... '-------, surface Waler (new) surface Waler (existing) soiVscdimcna lnoniloring Wells existing moniloring wells leachate sample, hy,lmm,nch \~-6. -~~ ,,. 6 8 G) M "1 I 8 -iii-..;.. ·,, ,-·-----,.... ,' ----·~· .. , : '----____ _ .... , .. ,.... -------------.... .......... ---... .... _____ : , ! '7 . -l • ... : I .... , I .... , .... , ,.... ,. ~ ~·· .. •• • .. ' • I I , I , -· ,• ,, / \ \ (
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-----• I ---------·---....... _,..
February 6, 1997
MEMORANDUM
TO: WORKINGGRO~P \J~~
FROM: MIKE KELLY -~"-J
SUBJECT: UPDATE ON DIVISION ACTIVITIES
1. Drilling: We are scheduled to begin work at the landfill on Wednesday, February
12. Both vendors for the monitoring wells and the bore holes in the landfill will mobilize on this
day. S&ME anticipates being finished in the landfill by February 24. Environmental
Investigations are estimating 2 1/2 weeks to complete the wells.
2. RFP FOR PILOT STUDY: This RFP was mailed out on Friday January 31 to eighteen
vendors. It was advertised in the Raleigh paper on Sunday, February 2, and should be posted on
the internet this week. A mandatory meeting is scheduled for Monday, February 17 and the
completed bids are due on Wednesday, March 19.
3. SAMPLING: We are tentatively looking at the first week in March (beginning March 3)
as the week to pull samples for the PCB, Dioxin / Furan testing. The contracted laboratory for
Dioxin / Furan (Southwest Laboratory of Oklahoma) has been notified and sample bottles are
being shipped. Their representative will keep that week open to retrieve the samples from the
Science Advisors.
4. AIR SAMPLING: I have talked with Southern Testing Laboratories in Wilson and
indicated the detection limits Dr. Hirschhorn has recommended. They have indicated that they
can follow the methods Dr. Hites did in his study and achieve these detection limits. I anticipate
that we can have the sampling plan redone and be ready to sample within the next two weeks, as
the work is progressing at the landfill.
5. OFF SITE WELL: We are still trying to finalize the location of the off site wells. Of
the 3 we need, only 1 is for sure; we have permission at two other sites which are not the prime
locations but may be used. This will be a top priority in the next few days.
6. SAMPLING PLAN: Patrick Barnes has completed and sent the sampling plan back to
the state. As soon as we have the off site wells firmed up, we will complete the sampling plan.
A copy of the current draft has been given to both contractors.
State of North Carolina
Department of Environment,
Health and Natural Resources
, Division of Waste Management .,
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
AVA
DEHNR
January 6, 1997
Winston A. Smith, Director
Air, Pesticides and Toxic Management Division
US Environmental Protection Agency, Region 4
Atlanta Federal Center
100 Alabama St., SW
Atlanta, GA 30303-3104
SUBJECT: Response to 12/31/96 letter from EPA
Dear Mr. Smith:
The Division of Waste Management (DWM) offers our full cooperation for your review of
the State's compliance with the conditions of the TSCA approval and Cooperative Agreement
relative to the Warren County PCB Landfill.
Mr. Mike Kelly, Deputy Director of the Division of Waste Management, will serve as the
primary state contact for providing any assistance that you request. Mr. Kelly may be reached at
919-733-4996, ext. 203. lfl can be of any assistance please contact me at ext. 201.
WLM/sh
cc: Henry Lancaster
Mike Kelly
t,,Pat Williamson
PCB Working Group
c:wpfiles/pcbll7smith.ltr
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
William L. Meyer, Director
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
Cl r State of North Carolina ..pl ·d Department of Environment,
_.,~ · t Health and Natural Resources
fl -t"''" . Division of Solid Waste Management I""'. ·1 1 .... f,1:,,e' James B. Hunt, Jr., Governor
i'J..r Jonathan B. Howes, Secretary
NA
DEHNR ff , William L. Meyer, Director February 5, 1997
Mr. Craig Brown, TSCA Permit Manager
United States Environmental Protection Agency, Region 4
100 Alabama Street, S.W.
Atlanta, Georgia 30303-3104
Dear Mr. Brown:
The State of North Carolina, Division of Waste Management, and the Warren County PCB
Working group, along with the Science Advisors, will be undertaking a number of activities
associated with the PCB Landfill in Warren County, with a goal of detoxification.
Beginning on February 12, we will be installing new monitoring wells around the landfill and
looking at the integrity of the top liner of the landfill itself, followed by the installation of two
bore holes in the landfill, and extraction of approximately 2,000 pounds of soil.
This soil will be shipped to vendors chosen to perform bench scale pilot studies on its
detoxification using either Base Catalyzed Dechlorination (BCD) or Gas Phase Chemical
Reduction technology. The Request for Proposals was mailed out last week. A pre-requisite to
bidding on this project is attendance at a pre-bid meeting to be held on Monday, February 17,
1997, at 10:00 AM, here in our conference room.
It is my general feeling and that of Science Advisor Dr. Joel Hirschhorn, that your presence at
this pre-bid meeting may be very beneficial in order to provide information to possible vendors
on any requirements EPA may have regarding permits to perform the pilot testing we seek.
Furthermore, Dr. Hirschhor,n and I would like to have a telephone conference with you sometime
during the next week to talk over some issues regarding this testing.
I hope that you will be able to attend the meeting here on the 17th. I will be in touch with you in
the near future to arrange a time for our conference call and to answer any questions you may
have.
Kinde
{
1c ae ,
Deputy Director
Copy: Dr. Joel Hirschhorn, Mr. Patrick Barnes, Warren Coun Working Group
P.O. Box 27687,
Raleigh , North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/l0°lo post-consumer paper
'l --
£,, 11 State of North Carolina d,::r J.r Department of Environment AVA Pc,:1
•. ~ I:.. Health and Natural Resources ·pr1'~\_-J. 11~Division of Waste Management
! v · f Jt.; James B. Hunt, Jr., Governor
(A \,vJ J~~athan B. Howes, S~cretary
W1ll1am L. Meyer, Director DEHNR
Project: Methane Sampling PCB Landfill
Project Participants: Wendy Peacock
Larry Rose
Date: January 29, 1997
Methane readings are a vital part of the monthly inspection of the PCB landfill located in
Warren Co. During this date, a methane reading using the GA-90 was perfonned on the central
vent on the landfill.
Time
11 :57am
3:45pm
Temp
F
42.7°
48.3°
Barometric
Pressure
Hg
30.51"
30.42"
Other reading that were observed were:
CB4Readin1:
% vol in air %LFL
0.8% 16%
1.1% 22%
CO1 % vol in air
0.7
Location
Raleigh
PCBLAN
PCBLAN
Raleigh
0 1 % vol in air
20.8
Warren County is located approximately 60 miles north of Raleigh, therefore you should
expect a temperature decrease of 2°F to 5°F difference. As cold temperatures have an effect of
the amount of gas measured from the center vent, another test will be conducted when
temperatures are higher. It is shown that a small amount of landfill gas particularly methane is
being produced within the landfill. Bore holes that surround the perimeter of the landfill will
be measured and the results will be compared. A weather station should be completed within
the next few weeks.
P.O. Box 27687,
Raleigh , North Carolina 27611-7687
Voice 919-733-4996
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50"/4 recycled/10"/o post-consumer paper
.,,,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
4APT-TS
Mr. William L. Meyer
Director
Division of Solid Waste Management
Department of Environment, Health
and Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
SUBJ: Warren County PCB Landfill
Dear Mr. Meyer:
As you are aware, the U.S. Environmental Protection Agency
(EPA) has received inquiries from the Joint Warren County/State
Polychlorinated Biphenyl (PCB) Landfill Working Group regarding
the State of North Carolina's compliance with Toxic Substances
Control Act (TSCA) and Comprehensive Emergency Response
Compensation and Liability Act (CERCLA) requirements for the
Warren County PCB Landfill. After review of EPA files for both
our TSCA and CERGLA programs we have decided to conduct an on-
site inspection as well as a review of your operating records for
this facility. We are also planning at this time to conduct some
limited groundwater and leachate sampling, if conditions allow.
The primary focus of our review would be the State's
compliance with the conditions of the TSCA approval for the
landfill, and any applicable conditions in the State/EPA
Cooperative Agreement _under which this landfill was constructed.
I ail, ro2qc1estiug yoi...;_r s:::,ope:.:-.ati8Yl with this review, and also ask
that you let us know of any additional information that may be
relevant to the questions raised by the Working Group.
Mr. Craig Brown of my staff and Ms. Beverly Hudson of the
North Carolina Site Management Section (CERCLA) will be
conducting the records review. Mr. Brown may be reached at
[phone], Ms. Hudson may be reached at [phone]. One
of them will be contacting you shortly to schedule a visit to
your offices and to plan the site visit.
Recycled/Recyclable • Printed wtth Vegetable 011 Based Inks on 100% Recycled Paper (40% Postconsumer)
2
If you would like to discuss this further, please contact
Craig Brown of my staff.
cc: Linda Rimer
Sincerely,
~ J Vi;;;;:, f
W nston A~v--jl~t~
rector
Kir, Pesticides and Toxics
Management Division