NCD980602163_20010622_Warren County PCB Landfill_SERB C_Correspondence, Region IV TSCA 1999 - 2001-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4APT-TS
Ms. Patricia M. Backus, P.E.
Division of Waste Management
North Carolina Department of
Environment and Natural Resources
1646 Mail Service Center
Raleigh, NC 27699-1646
Dear Ms. Backus:
J H 2 2 '2001
Thank you for your May 29, 2001 , letter concerning North Carolina's plans to abandon
groundwater monitoring wells at the Warren County Polychlorinated Biphenyl (PCB) Landfill in
preparation for the Detoxification and Redevelopment Project. The wells slated for abandonment
are part of the groundwater monitoring system required in the December 14, 1981, PCB disposal
approval letter issued to North Carolina by the U.S. Environmental Protection Agency (EPA).
North Carolina is hereby authorized to abandon its PCB landfill groundwater monitoring
system at the Warren County PCB Landfill. North Carolina is also released from the
requirements for semi-annual monitoring, reporting, and recordkeeping requirements as they
relate to ground water monitoring as set forth in its PCB disposal approval and the federal PCB
regulations at 40 CFR §761.75.
Please contact Craig Brown of the EPA Region 4 staff at [phone], if you have any
questions concerning this matter.
Sincerely,
Winston A Smith
Director
Air, Pesticides and Toxics
Management Division
Internet Address (UAL) • http://www.epa.gov
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North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
William L. Meyer, Director
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
June 8, 2001
I received a correction to the analytical results of the semiannual monitoring of the Warren County
PCB Landfill. The sample of the influent to the leachate treatment system had been reported as <0.0003
ppm PCBs. The corrected result is 0.0003 ppm PCBs. I have attached an updated table of the sampling
results for your records.
In there are any questions or comments, please call me at [phone] ext. 308.
Copy: . BilLMeye
Mr. Mike Kelly
Mr. Lany Rose
Mr. Harry Zinn
Warren County CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
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Ground Water
1
1A
2
3A
5(deep)
7(shallow)
11
12
Surface Water
RCUS
RCDS
UTUS
UTDS
Sediment
RCUS
RCDS
UTUS
UTDS
Leachate
Influent
Effluent
SEMIANNUAL SAMPLING RESULTS
Warren County, NC PCB Landfill
PCBs
(ppm'
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.10
<0.10
<0.10
<0.10
0.0003
<0.0001
30-Apr-01
Specific
Conductance
pH (umhos1
6.08 107
6.48 137
6.13 90
6.40 99
6.03 91
5.95 75
5.84 54
5.98 129
7.30 91
7.36 103
7.34 110
7.02 77
6.89 1080
6.76 957
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
PMS 06/08/2001
North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
William L. Meyer, Director
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
June 5, 2001
Attached is a table containing the results of the semiannual monitoring of the Warren County PCB
Landfill. The sampling event was conducted on April 30. As in the past no PCBs were found in
groundwater, surface water, leachate effluent or sediment samples collected.
As I indicated in my letter of May 29, initial site preparation for tl1e detoxification and
redevelopment project is starting. Most of the monitoring wells used in our semiannual monitoring events
will be abandoned for the project. That is scheduled for next week. The electrical service to the landfill
will also be upgraded in the near future. Power will not be available to operate the leachate pumping
system for about two months. The system was shut down last week and tlle water level inside the landfill
was approximately 3-4 feet above the bottom.
Our detoxification contractor, IT Corporation, is preparing and submitting the final designs and
plans for approval. I will be using some of tllese plans to prepare the request by tlle state to remediate the
land.fill following 40CFR 761.61 (a) as you indicated would be necessary at our meeting in Raleigh in April.
I expect to begin preparing that request shortly.
In there are any questions or comments about the sampling event or any activities associated with
the detoxification efforts and project schedule, please call me at [phone] ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Mr. Harry Zinn
Warren County CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
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Ground Water
1
1A
2
3A
5(deep)
7(shallow)
11
12
Surface Water
RCUS
RCDS
UTUS
UTDS
Sediment
RCUS
RCDS
UTUS
UTDS
Leachate
Influent
Effluent
SEMIANNUAL SAMPLING RESULTS
Warren County, NC PCB Landfill
PCBs
(com)
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.10
<0.10
<0.10
<0.10
<0.0003
<0.0001
30-Apr-01
Specific
Conductance
pH (umhos)
6.08 107
6.48 137
6.13 90
6.40 99
6.03 91
5.95 75
5.84 54
5.98 129
7.30 91
7.36 103
7.34 110
7.02 77
6.89 1080
6.76 957
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
PMB 06/05/2001
~~c,f-·
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North Carolina
Department of Environment and Natural Resources A~,A
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
William L. Meyer, Director
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
_.,: n .;,,-, ____ _
NCDENR
May 29, 2001
The purpose of this letter is to confirm our intent to abandon some of the monitoring wells at the Warren County
PCB Landfill as part of the site preparation for the Detoxification and Redevelopment Project and to supply the
information about the location of tl1e wells as you requested.
I have enclosed two drawings that depict site plan and wells to be abandoned. Drawing No. C-2 shows the
demolition plan for the landfill site. The monitoring wells to be abandoned are MW-lA on tl1e east side of tile
landfill; MW-11, MW-7 (shallow), and MW-7 (deep) on tile soutil side; MW-3 (deep), MW-3 (shallow), and MW-
12 on the west side; and MW-5 (deep) and MW-5 (shallow) on the north side of the landfill. By comparing the
demolition plans with tile preliminary site plan in Drawing C-3 you can see it would be very difficult to protect tilese
wells during the project. The abandonment of the wells is scheduled to begin during the week of June 4 and will be
performed according to procedures issued by tl1e DENR Division of Water Quality, Groundwater Section.
I also wish to confirm that the state understands, as per a previous discussion, tilat if tile detoxification is not
completed, tile state will be required to install new monitoring wells to replace tile ones removed.
If you have any questions, please do not hesitate to call me at 919-733-4996 ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Warren County PCB Landfill CAB
Mr. Gary Duke, IT Corporation
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc~s
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North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
William L. Meyer, Director
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
April 2, 2001
This letter is to notify you that operation of the leachate removal system at the Warren County PCB
Landfill has resumed. We first attempted to restart the system on March 1. Unfortunately, there were plugging
problems with the compressed air system that required several troubleshooting trips to the landfill and repair shop
before all were fixed. On Friday, the 301\ we finally got everything running.
With the resumption of leachate pumping, we will also return to more frequent monitoring of the water
level in the landfill and monthly sampling and analysis of leachate. As happened last year, we observed fluctuations
in the water level in the landfill during the down time. However, no significant change in level was observed.
I also want to inform you that the semiannual required sampling, the last before the start of the
detoxification project, has been scheduled for the week of April 23rd .
If you have any questions, please contact me at [phone] ext 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Warren County PCB Landfill CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
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JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
November 20, 2000
This letter is to again request permission to shut down the leachate removal system at the
Warren County PCB Landfill (W CLF) during the winter months.
The water level in the landfill has continued to drop but at a slower rate. The removal
rate this year has averaged less that 0.1 gpm compared with 0.5 gpm when we started the system
in 1999. To date, approximately 135,000 gallons of leachate have been removed and the water
level in the landfill has dropped from approximately 13 to 14 feet above the bottom to less than 3
feet (this is the lowest we can read due to the sediment in the bottom of our monitoring wells).
As with last year, my concern is potential damage to various parts of the leachate
pumping system due to freezing. The normal minimum temperatures in the area in which the
WCLF is located are below freezing during those months. We have already experienced snow and
freezing weather over the past few days.
Thus I am requesting that the state be allowed again to suspend the pumping of leachate
during the months of December, January, and February. As with last year, we will drain, clean
out, and dry components in the system to prevent damage. During the winter we will continue to
monitor water levels in the landfill at least once a month and continue to perfom1 monthly
inspections. If an increase in water level is observed, the situation will be assessed and continuous
pumping reinitiated immediately if warranted.
If you would like more information or find anything I have documented here
unacceptable, please call me at [phone] ext 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Warren County PCB Landfill CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1 646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLI NA 27699-1 646
401 OBERLIN R0A0, SUITE 1 SO, RALEIGH, NC 27605
PHONE 91 9-733·4996 FAX [phone]
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4
4APT-TS
Deborah F erruccio
Rt. 2, Box 163-J
Norlina, NC 27563
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303·8960
. ~ov 1 4 2or.c
Dear Ms. Ferruccio:
Thank you for your October 30, 2000, letter concerning the Warren County
Polychlorinated Biphenyl (PCB) Landfill detoxification project. You expressed interest in the
estimated time-frame for review and approval of a PCB disposal application, including the on-site
demonstration test. You also asked if we could provide an approximation of the project cost.
In order to answer your first question we shall list the key steps in the review/approval
process and provide an estimate of the time to complete each step and then an overall estimate of
the time-frame from receipt of application to full operation authorization. Please note that these
projections are estimates and optimistic ones at that. However, we do believe they can be
achieved if North Carolina and their contractors continue to work closely with the U.S .
Environmental Protection Agency (EPA) PCB program staff.
EPA understands that North Carolina has pre-qualified three PCB treatment/disposal
service providers. We expect that North Carolina will select a PCB treatment/disposal contractor
by the end of December 2000. By May 2001 , we expect the treatment/disposal contractor to
submit its PCB disposal application to the Agency. Typically, it takes a motivated applicant about
three to six months to address all of the Agency's comments and concerns. During the
application review period, we assume the contractor will begin site preparations at the landfill and
begin to assemble the treatment/disposal system. By end of December 2001, and following public
notice, we would expect to issue an approval to conduct shake-down testing and the
demonstration test. The shake-down testing allows the contractor to adjust and optimize
operational parameters (e.g., soil feed rate, temperature, batch size, etc.) in preparation for the
demonstration test. After a month or two of shake-down operation we would expect the
contractor to be ready to run the demonstration test in February or March 2002. The
demonstration test should take about a week to 10 days. In the meantime we would begin to
review data that was collected during the shake-down period and use that information as a basis
for issuing an interim approval to operate. We expect it would take another six months to prepare
and review the demonstration test report. Assuming all went well, at that point we would prepare
and public notice a draft approval for full operation. Allowing for public participation and
finalizing the approval we would expect to issue a final approval somewhere around the end of the
year 2002.
lntemet Address (URL) • http://www.epa.gov
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I
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2
The above milestones and schedules reflect about an 18-month time span between EPA' s
receipt of the application and issuance of the final approval. However, if the testing performed
during the shake-down period indicates that the contractor is meeting state and federal treatment
standards and that any system emissions are within acceptable limits, EPA would allow the
contractor to continue operating the treatment/disposal system under an interim approval from
completion of the demonstration test through issuance of the final approval. Therefore, it is
possible that the Warren County PCB Landfill treatment/disposal system could be operating on a
routine basis in as little as 12 months.
Regarding your question on project cost, EPA is unable to provide a meaningful cost
estimate at this time. Pat Backus or Mike Kelly of North Carolina's Division.of Waste
Management should be able to provide you with a pretty good estimate of the cost to complete
the project following the selection of the treatment/disposal contractor around the end of this
year.
Should you have any further questions on this project, please contact Craig Brown of the
EPA Region 4 staff at [phone] or brov,m.craig({lkpa.gov.
cc: Pat Backus, NCDWM
Sincerely,
Winston A. Smith
Director
Air, Pesticides and Toxics
Management Division
JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
~tb p NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
September 13, 2000
Mr. Winston M. Lue
Office of Pollution Prevention and Toxics
US Environmental Protection Agency
401 M Street SW (MC 7404)
Washington, DC 20460
Dear Winston:
This is to inform you that we have selected an oversight contractor for the Warren County PCB
Landfill Detoxification Project Our choice is Earth Tech, Inc. Earth Tech, as the former Rust
Environment and Infrastructure, was involved with the Sangamo Weston Superfund site in South
Carolina where 60,000 tons of PCB-contaminated soil was successfully treated using theonal
desorption.
Personnel from Earth Tech may be contacting you concerning pennitting and other TSCA-related
questions pertaining to the detoxification project I wanted to let you know that they do have a
legitimate reason for asking.
In addition, Governor Jim Hunt and Congresswoman Eva Gayton received letters from Tim
Fields offering EPA in-kind services to support the detoxification project. The State Budget
Office has determined that in-kind services can count as part of the federal match required by our
General Assembly to use $7M of the funds appropriated last year. This means we can proceed
with the phased funding of the detoxification project As such, a request for qualifications will be
issued within the next week. You may receive calls from some of these potential contractors also.
Thank you for your assistance and if you have any questions please give me a call.
Sincerely,
Patricia M. Backus, PE
cc: Bill Meyer, DENR -Division of Waste Management
Mike Kelly, DENR-Division of Waste Management
Jim Cloonan, PE -Earth Tech
WIS MN1MM·N
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699·1646
401 OBERLIN ROAD, suiTE 1 so, RALEIGH, NC 27605
PHONE 91 9-733·4996 FAX 919-715•3605
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f
JAMES 8. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
i /'
Septemberl3,2000
Mr. Hiroshi A. Dodahara
Office of Pollution Prevention and Toxics
US Environmental Protection Agency
401 M Street SW (MC 7404)
Washington, DC 20460
Dear Mr. Dodahara:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
This is to inform you that we have selected an oversight contractor for the Warren County PCB
Landfill Detoxification Project Our choice is Earth Tech, Inc. Earth Tech, as the former Rust
Environment and Infrastructure, was involved with the Sangamo Weston Superfund site in South
Carolina where 60,000 tons of PCB-contaminated soil was successfully treated using thermal
desorption.
Personnel from Earth Tech may be contacting you concerning permitting and other TSCA-related
questions pertaining to the detoxification project I wanted to let you know that they do have a
legitimate reason for asking.
In addition, Governor Jim Hunt and Congresswoman Eva Clayton received letters from Tim
Fields offering EPA in-kind services to support the detoxification project. The State Budget
Office has detennined that in-kind services can count as part of the federal match required by our
General Assembly to use $7M of the funds appropriated last year. This means we can proceed
with the phased funding of the detoxification project As such, a request for qualifications will be
issued within the next week. You may receive calls from some of these potential contractors also.
Thank you for your assistance and if you have any questions please give me a call.
Sincerely,
Patricia M. Backus, PE
cc: Bill Meyer, DENR -Division of Waste Management
Mike Kelly, DENR -Division of Waste Management
Jim Cloonan, PE -Earth Tech
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA .27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
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I_ ~VA
NCDENR
JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
, SECRETARY
WILLIAM L, MEYER
DIRECTOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Septemberl3,2000
Mr. Oaig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
DearOaig:
This is to inform you that we have selected an oversight contractor for the Warren County PCB
Landfill Detoxification Project Our choice is Earth Tech, Inc. Earth Tech, as the former Rust
Environment and Infrastructure, was involved with the Sangamo Weston Superfund site in South
Carolina where 60,000 tons of PCB-contaminated soil was successfully treated using thermal
desorption.
Personnel from Earth Tech may be contacting you concerning peonitting and other TSCA-related
questions pertaining to the detoxification project I wanted to let you know that they do have a
legitimate reason for asking.
In addition, Governor Jim Hunt and Congresswoman Eva Clayton received letters from Tim
Fields offering EPA in-kind services to support the detoxification project. The State Budget
Office has determined that in-kind services can count as part of the federal match required by our
General Assembly to use $7M of the funds appropriated last year. This means we can proceed
with the phased funding of the detoxification project As such, a request for qualifications will be
issued within the next week. You may receive calls from some of these potential contractors also.
Thank you for your assistance and if you have any questions please give me a call.
Sincerely,
Patricia M. Backus, PE
cc: Bill Meyer, DENR -Division of Waste Management
Mike Kelly, DENR-Division of Waste Management
Jim Cloonan, PE -Earth Tech
lilm .. , ....
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1 646
401 OBERLIN ROAD, SUITE I SO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
I
JAMES B. HUNT JR.
GOVERNOR
• BILL HOLMAN
,,, SECRETARY
f. WILLIAM L. MEYER
DIRECTOR
-, __. .. .,, .......
' .._ t~-
( --··
f t
November 2, 2000
Mr. Oaig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Attached is a table containing the resuhs of the semiannual monitoring of the Warren
County PCB Landfill. The sampling event was conducted on October 9 and 10. pH and specific
conductance were measured for both groundwater and surface water samples with the exception of
the specific conductance for wells IA and 11 and the leachate system influent and effluent. The
field equipment malfunctioned when analyzing those samples and a backup unit was not available.
In there are any questions or comments, please call me at [phone] ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Mr. Harry Zinn
Sincerely,
~~/i-,. ~d1..,/
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699·1646
401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605
PHONE [phone] FAX 919•715-3605
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER • 50% RECYCLED/I 0% POST·CONSUMER PAPER
Ground Water
1
1A
2
3A
5(deep)
7(shallow)
11
12
Surface Water
RCUS
RCDS
UTUS
UTDS
Sediment
RCUS
RCDS
UTUS
UTDS
Leachate
Influent
Effluent
SEMIANNUAL SAMPLING RESULTS
Warren County, NC PCB Landfill
October 9-10, 2000
Specific
PCBs Conductance
loom) pH (umhos)
<0.0001 6.07 104
<0.0001 6.25 **
<0.0001 5.93 78
<0.0001 6.19 63
<0.0001 5.78 92
<0.0001 5.59 95
<0.0001 5.47 **
<0.0001 6.02 79
<0.0001 6.46 45
<0.0001 6.56 43
<0.0001 6.30 56
<0.0001 6.46 41
<0.10
<0.10
<0.10
<0.10
0.0003 6.85 **
<0.0001 6.70 **
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
** -Field equipment problem
PMB 11/02/2000
....
C'l
(0
JAMES 8 . HUNT i : ·•. ..
GOVERNOR
BILL HOLMAN
SECRETARY
r
WILLIAM L. MEYER
DIRECTOR
'\"'' .,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 15, 2000
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Craig:
As I mentioned during your visit to the Warren County PCB Landfill last month, we have
observed some problems that may limit our ability to monitor the water level. This letter is about
that problem and an update on the progress of leachate removal since resuming pumping in
February.
As a reminder, the main components of the pumping system are a slant well pneumatic
pump, a solar-powered pump cycle controller, and an air compressor. The controller is
programmed to cycle the pump on and off. Sediments and other contaminants are removed by the
filter treatment system (sand and activated carbon beds). The filter treatment system also serves to
dampen the pulsing flow from the leachate pump so that the treated effluent discharges as a
continuous stream.
Figure 1 shows the cumulative amount of leachate pumped from the landfill since the
start up of the continuous pumping. The total pumped to date is approximately 130,000 gallons.
As the leachate removal has continued, the rate of removal of leachate has dropped. The initial
removal rate was 0.5 gpm and the current removal rate is 0.07 gpm. By listening to the venting of
compressed air during the pump's operation, it is apparent that the sump is empty after about two
minutes. The pump cycle has been reduced to match the available leachate and to avoid
unnecessary wear on the air compressor.
The water level in the landfill also continues to drop. Figures 2 shows the water level in
the south well inside the landfill. The current water level is below three feet. Lately when
measuring the level, we have noticed some problems. Randomly dropping the level indicator into
the wells gave no water level on a few occasions. Sediments were observed along with leachate in
the wells. The deposition is not uniform so it is difficult to predict the level of sediments in the
well. Unfortunately we may have to settle for levels reported as "less than" rather than a specific
depth.
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1 646
401 OBERLIN ROAO, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER • 50% RECYCLED/I 0% POST-CONSUMER PAPER
Mr. Oaig Brown
August 15, 2000
Page2of4
Currently the site is visited approximately every two weeks to check the system's operation and to
measure the water levels and discharge rate. The state also continues to sample the influent to and effluent
from the filter treatment system. A graph of the results is shown in Figure 3. The PCB concentration of the
treated effluent continues to be <0.1 ppb.
If you would like more information or have any questions, please call me at [phone]
ext 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Sincerely,
Pat Backus
PCB Landfill Project Manager
Warren County PCB Landfill CAB
Mr. 0-aig Brown
August 15, 2000
Page 3 of 4
1,40,000
120,000
ii 100,000 !!
'i t ao.ooo l.
l
i ao.ooo
1 40,000
20,000
0 ,I
Figure 1
CONTINUOUS LEACHATE PUMPING AT WARREN COUNTY PCB LANDFILL
Cummulatlve Amount Removed
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15
14
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12
11
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Figure 2
Water Level In South Well
Warren County PCB Landfill
• .... ' • -
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12/01196 03'311117 0712Wi7 11f.lM7 O:n&'98 07/241118 11/211118 O:Y.111119 071111W 11/1SW 03'1&00 07/13'00
0■t•
Mr. Oaig Brown
August 15, 2000
Page 3 of 4
e ... .e
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0.0015
0.0010
0.0005
Figure 3
PCB Content of Influent and Effluent of Laachate TrNtment System
Warren County PCB Landfill
0.0000 +----+-----1----+----+-----1----+----+-----l--------l
<SOWA
Linl
02'11n18 OS'JC>98 011'07/118 12'1&'118 03'2&'119 07/0W9 10'12'99 01/20'00 04'2a'OO Ot.'07/00
D■t•
_.,_.,,1.1.,t ..,._Effluent
JAMES 8. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
May 2, 2000
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Attached is a table containing the results of the semiannual monitoring of the Warren
County PCB Landfill. The sampling event was conducted on April 5 and 6. pH and specific
conductance were measured for both groundwater and surface water samples with the exception of
wells 1 A and 1 1. Wells 1 A and 11 were essentially dry and it was difficult to obtain enough
material for all tests.
In there are any questions or comments, please call me at [phone] ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLI NA 27699-1 646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER
Ground Water
1
1A
2
3A
5(deep)
?(shallow)
11
12
Surface Water
RCUS
RCDS
UTUS
UTDS
Sediment
RCUS
RCDS
UTUS
UTDS
Leachate
Influent
Effluent
SEMIANNUAL SAMPLING RESULTS
Warren County, NC PCB Landfill
April 5-6, 2000
Specific
PCBs Conductance
(ppm) pH (umhos)
<0 0001 5.85 141
<0.0001 ** **
<0.0001 5.91 96
<0.0001 6.11 104
<0.0001 5.82 89
<0.0001 5.64 79
<0.0001 ** **
<0.0001 5.48 124
<0.0001 6.95 77
<0.0001 7.13 84
<0.0001 7.10 81
<0.0001 6.95 68
<0.10
<0.10
<0.10
<0.10
0.0010 6.90 1037
<0.0001 6.96 921
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
** -Not enough sample to test
PMB 05/02/2000
JAMES 8. HUNT JR. '
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
February 25, 2000
This letter is to notify you that operation of the leachate removal system at the Warren
County PCB Landfill was resumed today. As we mentioned in our meeting with you in January,
we did observe fluctuations in the water level in the landfill during the down time. However, the
fluctuations were similar to those that had been observed prior to installation of the automated
leachate pumping system and did not indicate a significant change in level.
With the resumption of leachate pumping, we \v:i.11 also return to more frequent
monitoring of the water level in the landfill and monthly sampling and analysis ofleachate. If you
have any further questions, please contact rne at [phone] ext. 308.
•
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Warren County PCB Landfill CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Proj ect Manager
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAO, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EqUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER -50% RECYCLE0/10% POST-CONSUMER PAPER
.. ,,::..,:;\,.· . ;r,,,:
----:: ., .. -~ . ~-. ----!" ··~
'l/J•>;;
NCDEMR
JAME!/8. HUNT JR.·
. GOVERNOR
BILL HOLMAN
.'_SECRETARY
' ~· -~ :~ ." . ' WILLIAM L. MEYER , ' . . .
DIRECTOR · •
.. -:~:>::!tt~~,, -::~-~
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,. ":;,:;
~~~:?
.~Ji,
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
December 3, 1999
Attached is a table containing the results of the semiannual monitoring of the Warren
County PCB Landfill. The sampling event was conducted on October 25 and 26. AB mentioned
in a previous letter, I did ensure that the pH and specific conductance were measured for both
groundwater and surface water samples with the exception of well IA Well IA is essentially dry
and it is difficult to obtain enough material for all tests.
In there are any questions or comments, please call me at [phone] ext 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699·1646
401 OBERLIN ROAD, SUITE 1 50, RALEIGH, NC 27605
PHONE 919-733·4996 FAX 919-71 5·3605
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
Ground Water
1
1A
2
3
5(deep)
?(shallow)
11
12
Surface Water
RCUS
RCDS
UTUS
UTDS
Sediment
RCUS
RCDS
UTUS
UTDS
Leachate
Influent
Effluent
Semiannual Sampling Results
Warren County, NC PCB Landfill
October 25-26, 1999
Specific
PCBs Conductance
(ppm) pH (umhos)
<0.0001 4.86 112
<0 0001 ** **
<0.0001 6.10 129
<0.0001 6.60 136
<0.0001 5.52 92
<0.0001 6.40 99
<0.0001 5.04 238
<0.0001 5.68 94
<0.0001 6.97 110
<0.0001 6.92 109
<0.0001 7.01 109
<0 0001 7.12 114
<0.10
<0.10
<0.10
<0.10
<0.0001 6.94 1006
<0.0001 7.14 1007
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
** -Not enough sample to test
PMB 12/03/1999
Patricia M. Backus, PE
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: [phone] ext. 308
Fax: [phone]
Fax
To: Pat Barnes
Fax: [phone]
Phone: [phone]
Re: FYI - A Few Things
□ Urgent 0 For Review
• Comments:
A few miscellaneous items .....
NCDENR
From: Pat Backus
Pages: 8
Date: 11 /12/99
CC:
□ Please Comment □ Please Reply □ Please Recycle
(1) Attached is an abstract that I printed from the National Science Foundation web site about a grant
to the Roanoke River Valley Consortium. This is the only current one that I found listed. I am
sending it to you so you can see what it actually says and to maybe spark some ideas for the
future. ( I am not suggesting that you change the Community Outreach Plan. What you have in
the Community Plan is fine with me.)
(2) I have also attached a copy of a letter I sent to Craig Brown requesting that the leachate pumping
be suspended during the winter months. I meant to bring this to your attention when you were
here but forgot. I did send a copy to Dollie also. I think the letter explains itself.
(3) Please return the aerial slides. Those were the only ones we have and I need to put them back in
the files. Thanks.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
NOV 1 0 1999
4APT-TS
Patricia M. Backus, PE
North Carolina Department of Environment
and Natural Resources
Division of Waste Management
40 I Oberlin Road, Suite I 50
Raleigh, NC 27605
Dear Ms. Backus:
Thank you for your October 29, I 999, letter concerning the proposed shutdown of the
automated leachate pumping system at the Warren County Landfill from December 1999, through
February 2000 The U.S. Environmental Protection Agency (E PA) concurs with the proposed
shutdown to protect the system from freeze damage over the winter months.
EPA understands that during the shut down period personnel from North Carolina· s
Di vision of Waste Management will continue monthly inspections and water le vel measurements
at the landfill and that the automated pumping system will be returned to service in March 2000.
If during the winter time monthly inspections North Carolina observes an increase in water le vel in
the landfill of more than l O percent above the baseline level measured in at the time the system is
shut down in December 1999, you should notifi y EPA. Craig Brown of the EPA Region 4 staff is
the Agency's point of contact on this matter. He may be reached at [phone].
Sincerely,
Alfreda Freeman
Chief
Toxic Substances Section
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed wtth Vegetable 011 Based Inks on Recycled Paper (Minimum 25% Postconsumer)
JAMES B. HUNT JR.
GoVERN0R
WAYNE MCDEVITT
SECRETARY
WILLIAM L. MEYER
DIRECTOR
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
November 1, 1999
This letter is to document our recent telephone conversation concerning the semiannual
monitoring at the Warren County PCB Landfill.
I reviewed the Notice of Non-Compliance from 1997 and the referenced Letter of
Approval dated December 14, 1981 . Neither required that the results of the semiannual
monitoring events be reported to EPA However, this can be done in the future and I will place a
copy of this letter in our files for future reference.
Our records confirmed, as you had indicated, that that state did send you the results from
the monitoring event conducted in November of 1997. Since then four other monitoring events
have been conducted with the most recent occurring October 25 and 26 oflast week. The results
of the first three events are shown in the attached table. In reviewing the data, I noticed that the
pH and specific conductance had not been recorded for every groundwater and surface water
sample. I provided the samplers with a copy of the Notice of Non-Compliance that reiterates this
requirement to ensure that all these measurements were taken during last week's event and that
they will be taken in the future. 1 will send you a copy of the results of the last monitoring event
when the PCB analyses are completed.
In there are any questions or comments, please call me at [phone] ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
401 OBERLIN ROAD, SUITE 1150, RALEIGH, NC 27605
PHONE 919-733•4996 FAX [phone]
AN EQUAL OP'P0RTUNITY / AFFIRMATIVE ACTION EMPLOYER· 150% RECYCLED/I 0% POST•CONSUMER PAPER
Semiannual Sampling Results
Warren County, NC PCB Landfill
Ma.-18-19, 1998 October 26-27, 1998
Specific
PCBs Conductance
teem) pH
Ground Water
1 <0.0001 5.71
1A <0.0001
2 <0.0001 5.84
3 <0.0001 5.21
5(deep) <0.0001 5.71
7(shallow) <0.0001 5.44
11 <0.0001
12 <0.0001 5.40
Surface Water
RCUS <0.0001
RCDS <0.0001
UTUS <0.0001
UTDS <0.0001
Sediment
RCUS <0.10
RCDS <0.10
UTUS <0.10
UTDS <0.10
Leachate
Influent 0.0002 6.59
Effluent <0.0001 7.10
RCUS -Richneck Creek Up Stream
RCDS -Richneck Creek Down Stream
UTUS -Unnamed Tributary Up Stream
UTDS -Unnamed Tributary Down Stream
(umhos]
100
100
54
88
72
159
1201
589
Specific
PCBs Conductance
(ppml pH (umhos]
<0.0001 5.95 1289
<0.0001
<0.0001 5.96 1125
<0.0001 6.36 1217
<0.0001 6.00 1076
<0.0001 5.67 88
<0.0001
<0.0001 5.47 1152
<0.0001
<0.0001
<0.0001
<0.0001
<0.10
<0.10
<0.10
<0.10
0.0004 6.70 1536
<0.0001 6.33 840
April 19-20, 1999
Specific
PCBs Conductance
(ccm) pH (umhosl
<0.0001 6.08 104
<0.0001
<0.0001 5.84 97
<0.0001 6.09 111
<0.0001 6.20 90
<0.0001 5.98 76
<0.0001
<0.0001 6.17 111
<0.0001
<0.0001
<0.0001
<0.0001
<0.10
<0.10
<0.10
<0.10
0.0006 6.82 989
<0.0001 6.68 829
PMB 11/01/1999
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Patricia M. Backus, PE
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: [phone] ext. 308
Fax: [phone]
To: Dolly Burwell
Fax: [phone]
Phone: [phone]
Re: Letter to EPA
□ Urgent 0 For Review
• Comments:
..
NCDENR
From: Pat Backus
Pages: 6
Date: 1 0/29/99
CC:
D Please Comment D Please Reply D Please Recycle
This is a copy of a letter to EPA in Atlanta concerning pumping leachate during the winter months when
there is a risk of freezing. I apologize for not mentioning this to you when talking earlier this week.
As the letter indicates, I have concerns about operating the leachate pumping and treatment system
during the winter months when it is reasonable to expect some freezing weather will occur at the
landfill. I talked with several folks about what measures we could take to winterize the system (in other
words, keep everything wann enough to avoid freezing). From my previous jobs working for chemical
companies, I am familiar with what it takes to really protect a system, with failures that can still occur if
you have an extreme event, and the problems frozen lines can cause. I did not feel comfortable
considering that we are 55 miles away and cannot come up every day to monitor what's going on. We
have been so successful in pumping water from the landfill with this system that I hate to jeopardize
getting the rest of the water out by damaging equipment.
I discussed this with Craig Brown at TSCA-Region IV and he verbally agreed with my views about this.
He recommended that I document the conversation with this letter. I have sent a copy to Robin for the
CAB but wasn't sure when you would see it. (I , too, am looking forward to having a Community
Involvement Coordinator to be a contact.) An important point with Craig was that we continue to
monitor the water levels and to reassess this if there is a significant increase in water level.
Ideally, I would have liked to present this letter at one of the meetings before sending it, but with the
cancellations and delays in setting the next CAB meeting, I felt I needed to go ahead and send it now.
If you have any questions, give me a call.
~ '·~:~ ~·· ·-~-~1'
.WAYN_E,MCDEVIT"!' _,-;.~ ~, \
SECR'S.,TAR1 .'
::~:·.~~-;;t~~~~
,., I'-. ,!_I'•---
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Mr. Brown:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
October 29, 1999
This letter is to document our recent telephone conversation concerning the operation of
the leachate removal system at the Warren County PCB Landfill (WCLF) during the winter
months.
As I reported to you in August, we have seen a significant drop in the water level in the
landfill since the startup of the continuous leachate pumping system. To date, approximately
90,000 gallons ofleachate have been removed and the water level in the landfill has dropped from
approximately 13 to 14 feet above the bottom to 4 to 5 feet. The water levels in the landfill,
leachate pumping rate, and operation of equipment have been checked weekly. Data from this
monitoring is shown in figures I, 2, and 3. As the level has dropped, we have also observed a
drop in the recharge rate to the sump, which in turn has reduced our leachate removal rate. The
reduced head (driving force) could explain this reduced rate. Because of this, we will not be able
to eliminate the water level in the landfill by the end of the year as I had projected in August.
My present concern is the operation of the leachate pumping system during the months of
December through February. The normal minimum temperatures in the area in which the WCLF
is located are below freezing during those months (see attachment for climatological normals for
Arcola, NC in southeast Warren County). These temperatures have caused pumping problems in
the past. All of our equipment with the exception of the leachate pump is located above ground. I
have considered the use of insulation and heat tape but do not think these would adequately protect
the system.
The two most vulnerable points are the compressed air lines and the treatment units.
Despite several filters, we still find significant moisture and a small amount of oil in the
compressed air lines. While not desirable, the system can operate with some moisture in the air if
the temperatures are above freezing. Freezing in the lines could cause a series of events to occur
which would damage the compressor and the pump controller. The sand filter, which does the
bulk of the leachate treatment by removing soils particles contaminated with PCBs, operates with
a level of water above the bed. The activated carbon bed removes PCBs soluble in the leachate.
Both media are contained in modified concrete septic tanks. Freezing in these units could
potentially damage the integrity of the unit, restrict flow through the unit, or prevent adsorption of
the PCBs onto the carbon. The remote location, approximately 50 miles from our offices, does not
allow us to check the system daily, which with a continuous system is critical to prevent problems.
For these reasons I proposed to you in our conversation that the state suspend the
continuous pumping of leachate during the months of December, January, and February. This
would allow us to drain, clean out, and dry components in the system to prevent damage. During
the winter we will continue to monitor water levels in the landfill at least once a month and
continue to perform monthly inspections. If an increase in water level is observed, the situation
will be assessed and continuous pumping reinitiated immediately if warranted.
401 OBERLIN ROAD, SUITE ISO, RALEIGH, NC 27605
PHONE [phone] FAX 919-71 S-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -SO% RECYCLED/I 0% POST-CONSUMER PAPER
During our conversation you indicated that this plan was reasonable and acceptable. Based on your
agreement, we intend to proceed with shutting the continuous pumping system down in early December and putting
the system back on-line at the beginning of March. If you would like more information or find anything I have
documented here unacceptable, please call me at [phone] ext. 308.
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Mr. Larry Rose
Warren County PCB Landfill CAB
Sincerely,
Patricia M. Backus, PE
PCB Landfill Project Manager
15
14
13
12 • • .
• t 11
10
9 :e.
~ 8 > .!
.! 7
i 6
5
4
3
2
0
12/01/96 03131/97 07/29/97
15
14 .. .
• t • 13
12
11
10
g 9
~ 8 1
~ 7 ;;
~ 6
5
4
3
2
0
12/01/96 03131/97 07/29/97
Figura 1 • Water Laval in South Wall
Warran County PCB Landfill
... • -•• . •
11/26197 03126198 07/24/98 11/21/98
Date
Figura 2 • Water Laval in North Wall
Warran County PCB Landfill
• .. . . •• • •
11/26197 03126198 07/24/98 11/21/98
Date
• .. ...
4t ,., ....
• --
03121/99 07/19/99 11/16199
. • • . . ► , .. -.
03121/99 07119i99 11/16199
(Please note that the north well is closer to the leachate pump and the effect of drawdown has been
seen in the level at this welL If the pump shuts down, the level will rebound as shown in a few
points on the chart of the north well. Also the bottom of the landfill is sloped toward the north
end. This explains the slight variations in level in the north well and the slight difference in level
between the north and south wells.)
..
.;
~
"C g_
E :, a.
-g
..:
'" > ~ :i E E :, u
140,000
120,000
100,000
80,000
60,000
40,000
20,000
0
Figure 3 •
CONTINUOUS LEACHATE PUMPING AT WARREN COUNTY PCB LANDFILL
Cummulative Amount Removed
__,,...,,---~
~ v-
/
/"
---V
_/ ~
-----~
28-Feb 20-Mar 09-Apr 29-Apr 19-May 08-Jun 28-Jun 18-Jul 07-Aug 27-Aug 16-Sep 06-Oct
Dote
Southeast Regional Climate Center
Climatological Normals 1961-90
ARCOLA , NC ( 310241)
Percent Missing: 2.25
< Choose Station >
Climatological Normals (1961-90)
ARCOLA , NC 310241 ) Percent Missing : 2 . 25
MinTemp(F) MaxTemp(F) AvgTemp(F) AvgPrcp(in)
Jan 26.8 47.5 37 .2 3 .53
Feb 29.1 51. 6 40 .4 3 .65
Mar 36.9 60.9 48 .9 3 .79
Apr 44.8 70.7 57 .7 3.00
May 53 .4 78.2 65.8 3.97
Jun 61. 7 85.2 73 .4 3.92
Jul 66.1 88 .5 77 .3 4.40
Aug 65.3 87 .1 76. 2 4 .83
Sep 58.5 81. 6 70.1 3.32
Oct 46.7 71.2 59.0 3.23
Nov 38.5 62 .7 50.6 3.30
Dec 31. 2 52 .3 41. 8 3.35
Ann 46 .6 69 .8 58.2 44.29
Dave Barthel, [e-mail]
Avg Snow (in)
1. 8
2.9
1. 2
0.0
0.0
0.0
0 .0
0.0
0.0
0 .0
0 .1
0 .5
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
RECEIV ED
OFFICE OF THE SECRETPi RY
SEP 3 0 1999
Honorable Jesse Helms
United States Senate
Washington, DC 20510-3301
Dear Senator Helms:
7 19Sd
Thank you for your letter of August 25, 1999, on behalf of Mr. Ken Ferruccio regarding
the polychlorinated biphenyl (PCB) detoxification project for the Warren County Landfill
(WCLF) in Warren County, North Carolina. Enclosed with your letter was a 12-page
memorandum from Mr. Ferruccio to Wayne McDevitt, former Secretary of the North Carolina
Department of Environment and Natural Resources (NCDENR) outlining his reasons for rejecting
the Secretary's offer to serve on the WCLF Citizen Advisory Board (CAB).
We have reviewed Mr. Ferruccio's memorandum, which is largely a critique of the WCLF
CAB and its current structure. The purpose of the WCLF CAB is to provide local citizens a
greater voice in the decision-making process for the WCLF detoxification project. However,
Mr. Ferruccio does not believe that the WCLF CAB will operate independent of U.S.
Environmental Protection Agency (EPA) and State of North Carolina control. Mr. Ferruccio
seems to view the CAB as incapable of serving the interests of the local community since, as he
sees it, the CAB is funded by North Carolina. Mr. Ferruccio has identified EPA and North
Carolina as the parties responsible for creating and perpetuating the WCLF.
The decision on the future disposition of the WCLF must be made by the State of North
Carolina (the site owner) in consultation with•the local community. EPA encourages consultation
on PCB cleanup · decisions but does not prescribe procedures or mechanis!J1..s for consultations
with local citizens on such matters.
Regarding the selection of base catalyzed decomposition (BCD) as the preferred
technology for treating the PCB contaminated soil at WCLF, EPA bad no involvement in this
decision, nor was EPA's opinion sought. It is our understanding that BCD was selected by the
Joint Warren County/State PCB Landfill Working Group (the CAB's predecessor) based on the
advice of their science advisors. BCD is an innovative treatment technology that may be suitable
for destruction of chlorinated organic compounds such as PCBs and pesticides. However, as we
have advised NCDENR, BCD has not been approved at the commercial scale for PCB disposal
under the Toxic Substances Control Act (TSCA). IfBCD is to be used at the WCLF, North
Carolina must first obtain a TSCA PCB disposal approval. To obtain such an approval, North
Carolina will have to demonstrate that the BCD treatment system it constructs is capable of
consistently reducing the PCB concentration in the WCLF soils to below two parts per million.
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The State must also demonstrate that its BCD treatment system will not pose an unreasonable risk
of injury to human health or the environment. The approval process, which includes a
demonstration test, generally takes from 18 to 30 months from the time EPA receives an approval
application.
The self-implementing PCB remediation waste regulations at 40 CFR §761.61(a) were
established to encourage voluntary cleanup of PCB sites and could be applied at WCLF. These
regulations contain provisions for cleanup of PCB contaminated sites without having to obtain a
written approval from EPA. Cleanup activities that do not require an approval include:
( 1) excavation and off-site disposal of contaminated material; (2) on-site soil washing with a non-
chlorinated solvent; and (3) on-site treatment using a PCB disposal technology approved under 40
CFR §§761.60(e) or 761.70. However, it is EPA's understanding that the local/state working
group and the state legislature have already selected BCD for use at the WCLF. As indicated
above, if North Carolina stays with BCD, a TSCA approval will be required.
Ifl may be of further assistance, please feel free to contact the Office of External Affairs
at [phone].
Sincerely,
egional Administrator
William Holman, NCDENR
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4APT-TSS
Michael A. Kelly, Deputy Director
Division of Waste Management
North Carolina Department of
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
AU6 1 3 1999
Environment and Natural Resources
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Dear Mr. Kelly:
Al,:q 1110.9 uu IJ'.J
Raca iv·sd
Waste /,1anagement
0i'1ision
Thank you for your July 30, 1999, letter to Carol Kemker concerning the Warren County
Landfill (WCLF) project. You have proposed that the detoxification of polychlorinated bi phenyl
(PCB) contaminated soil at the WCLF, now be managed as a corrective action or voluntary
cleanup project under the State's Inactive Hazardous Sites Program. You have indicated that
cleanup projects under this program can be expeditiously completed without lengthy delays due to
permitting. If, as you seem to be suggesting, treatment of the PCB contaminated soil at the
WCLF using Base Catalyzed Decomposition (BCD) technology be conducted without the benefit
of a Toxic Substances Control Act (TSCA) permit, I am afraid we must disagree.
The U.S. Environmental Protection Agency (EPA) has worked closely with your office to
resolve compliance problems at the WCLF and assist you with developing a cleanup strategy for
the closed landfill. In your February 16, 1999, meeting with Craig Brown of EPA Region 4's staff
and Winston Lue of EPA Headquarters, the TSCA permitting process and probable time frames
for issuing an operating permit to treat the WCLF soils were discussed. EPA understood from
the meeting that North Carolina would select a BCD treatment contractor/vendor in late Fall
1999, and submit an alternative PCB disposal permit application in January or February 2000.
Because EPA' s PCB program office has never issued a TSCA permit for PCB disposal using
BCD technology at the commercial scale, EPA staff recommended a two step permitting process
for the WCLF project. Our most optimistic projections for permitting were foi-issuance of a
Research and Development permit in the Summer of 2000, and issuance of a full scale operating
permit in Fall 2001.
As Mr. Brown has discussed with you previously, there are several cleanup alternatives for
the WCLF that would not require issuance of a new TSCA permit. PCB site cleanups may be
conducted under the self-implementing PCB cleanup regulations at 40 CFR §761.6l(a) without
EPA' s written approval. Under this option contaminated soil may be excavated, transported and
disposed of at an off-site TSCA permitted facility. This option does allow for treatment of soil
on-site using soil washing technology. Under this option soil could also be treated on-site using a
Internet Address (URL) • http://www.epa.gov
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previously TSCA-permitted treatment process. Currently, BCD is not among the nationally
permitted PCB treatment technologies. Thus, it would appear that none of the cleanup
alternatives available under the 40 CFR §761.6l(a) self-implementing option would meet criteria
agreed to by the State and the local WCLF Working Group. If the State and the WCLF Working
Group are committed to use of BCD treatment for detoxifying the PCB contaminated soil at the
WCLF, we see no way of avoiding the TSCA permitting process.
We would be happy to meet with you to discuss this matter further. If you wish to meet, I
recommend that we schedule this meeting for sometime after September 13, 1999, so that Craig
Brown of my staff would be available to attend the meeting. If you wish to set a meeting date or
if you have any questions, please contact me at ( 404) 562-8977.
Sincerely,
~l)f~;A'7
Alfreda--Freeman ti (J"' '
Chief
Toxic Substances Section
JAMES B. HUNT JR.
.GoVERNOR ~ •,
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,WAYNE MCDEVl,::t" :4 ""-, ' _,,..
DIRECTOR
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 12, 1999
Mr. Craig Brown
Pesticides and Toxic Substances Branch
US Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Dear Craig:
DIVISION OF WASTE MANAGEMENT
In February the State of North Carolina installed a new leachate pump at the
Warren County PCB Landfill to address Notice of Non-Compliance, Docket Number TSCA-
4-97-11844. This letter is to update you on its operation.
The main components of the pumping system are a slant well pneumatic pump, a
solar-powered pump cycle controller, and an air compressor. The controller is programmed
to turn the pump on for approximately five minutes each hour around the clock. Sediments
and other contaminants are removed by the filter treatment system (sand and activated
carbon beds). The filter treatment system also serves to dampen the pulsing flow from the
leachate pump so that the treated effluent discharges as a continuous stream.
Figure 1 shows the cumulative amount of leachate pumped from the landfill since
start up of the new pump. The total pumped to date is approximately 60,000 gallons. A
significant drop in the water level in the landfill has also been observed. Figures 2 and 3
show the manual measurements of water level in the north and south wells inside the
landfill dating back to their installation. (Unfortunately, there is a gap in data because a
datalogger was used to monitor relative changes in the level and was not well calibrated to
the manual measurements.) The water level at the bottom of the each chart represents the
bottom of the well. As you can see before pumping the water level was 13 to 14 feet. The
last measured levels indicate that the level is now approximately 6 to 7 feet. (Note: the
level in the north well is slightly lower that the south because the leachate is pumped from
the north side and there is a cone of depression.) This drop seems impossible based on
the estimates of 1 to 2 million gallons of water in the landfill, however, it does correspond
with the estimates of only 60,000-140,000 gallons of "free" water presented at our meeting
in February. If we can maintain out current pumping rate, the water level in the landfill
should be eliminated by the end of the year.
Currently the site is visited each week to check its operation and to measure the
water levels and discharge rate. Downtime has occurred due to mechanical problems and
the discharge rate has varied from 0.3 to 0.5 gpm due to experimentation with controller
settings. The State also continues to sample the influent to and effluent from the filter
treatment system. Results for the past year are shown in Figure 4. An increase in the PCB
concentration of the influent was seen after continuous pumping started, but the treated
effluent continues to remain at <0.1 ppb.
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• 150% RECYCLED/I 0% POST-CONSUMER PAPER
Mr. Craig Brown
August 12, 1999
Page 2
If you would like more information or have any questions, please call me at [phone] ext 308 .
Copy: Mr. Bill Meyer
Mr. Mike Kelly
Ms. Pat Williamson
Sincerely,
Pat Backus
PCB Landfill Project Manager
140,000 120,000 -~ 100,000 -.9 "C G) C. E :l fl. ..: E <( G) > .. .!!! :l E E :l (.) PMB 80,000 60,000 40,000 -20,000 0 28-Feb -Figure 1 CONTINUOUS LEACHATE PUMPING AT WARREN COUNTY PCB LANDFILL Cummulative Amount Removed ____..-~ i-----20-Mar 9-Apr 29-Apr .,,......-~ -------19-May Date 8-Jun -~ -~ 28-Jun __.... ~ 18-Jul 7-Aug 8/12/99
338 337 ~-~ ◄► ♦ ◄► ♦ 336 335 334 333 _ 332 -::. iii 331 > ~ ... 330 C1) -nl 3:: 329 328 -327 326 -325 . 324 323 -12/1/96 3/11/97 6/19/97 9/27/97 \ '-Figure 2 Water Level in North Well Warren County PCB Landfill ~•--.-• ---1/5/98 ♦ ♦ 4/15/98 Date ♦ ♦ 7/24/98 Level J ast drawday, n whenpuml/J wa s dawn fora few days. ~ \j ... ' ♦ ~ .... ♦ ♦ •-11/1/98 2/9/99 5/20/99 8/28/99 pmb 8/12/99
338 337 -♦ ♦ ♦ 336 . .... 335 334 -333 g 332 -Gi > ~ 331 ... G) -330 CG 3: 329 328 327 -326 -. 325 324 ' 12/1 /96 3/11 /97 6/19/97 Figure 3 Water Level in South Well Warren County PCB Landfill •• • ♦ ♦ ♦ ' 9/27/97 •----• .... T ------------1 /5/98 4/15/98 Date --7/24/98 T ♦• ♦ •♦ ♦ 11/1/98 2/9/99 5/20/99 8/28/99 pmb 8/12/99
::0-a. a. -C: 0 :.:: cu L. ... C: Q) 0 C: 0 u al u c.. 5.0 4.0 3.0 2.0 1.0 0.0 6/4/98 Figure 4 PCB Content of Influent and Effluent of Leachate Treatment System Warren County PCB Landfill I \ -.,,.-----/ ~ -lJ V v ~ ~ --------7/24/98 9/12/98 11/1/98 [~ ----Influent -12/21 /98 2/9/99 Date -Effluent -. --3/31/99 ------5/20/99 l....-11 --7/9/99 8/28/99 pmb 8/12/99
JAMES 8. HUNT JR.
•. GOVERNOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 30, 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
The·State of North Carolina has been working over the past several years with the
citizens of Warren County to evaluate technologies to remediate the Warren County PCB
Landfill. The landfill was constructed in Warren County in 1982 despite extreme
opposition from the community. At that time, Governor Jim Hunt stated that "the state
will push as hard as it can for detoxification of the landfill when and if the appropriate and
feasible technology is developed." Since his return to office in 1992, the State has been
working closely with the citizens of Warren County under the Joint Warren County/State
PCB Landfill Working Group. The Working Group conducted a lengthy, thorough
evaluation and selected the EPA-developed Base Catalyzed Decomposition technology for
on-site remediation. They also established stringent soil cleanup standards of 200 parts
per billion for PCBs and 200 parts per trillion Toxicity Equivalent Concentration (TEQ)
for dioxins/furans.
Since 1992, the North Carolina General Assembly has provided $4M for this
project and has committed to match up to $7M of any federal funds that the PCB
detoxification project might secure. EPA Region IV has already provided the community
with a significant grant that includes funding for a community involvement coordinator.
In the event additional federal money is not secured, Governor Hunt has promised he will
include the remaining funds required in next year's budget. The Governor backs an
aggressive schedule to ensure that remediation begins during his administration that ends
in January of 2001. •
Since closure, the landfill has been monitored under the TSCA program. The
landfill was a remedy to a former NPL site and, therefore, does not fall under
CERCLA/SARA. However, the State believes that the detoxification should fall under the
requirements of a corrective action or voluntary cleanup project. The State would like to
use the guidelines of the North Carolina Inactive Hazardous Sites Program in order to
expedite the cleanup while there is strong support of the project. The Program's policy is
to be consistent with the intent of CERCLA/SARA and the National Contingency Plan.
Under this program, both voluntary and state-mandated site cleanups are being completed
without lengthy delays due to permitting.
401 OBERLIN ROAO, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• 150% RECYCLED/I 0o/o POST-CONSUMER PAPER
Ms. Carol L. Kemker
July 30, 1999
Page 2
While using the Inactive Hazardous Sites Program, the State would welcome EPA involvement in
the project. I have enclosed a copy of the program's Guidelines for Assessment and Cleanup for
reference. We would appreciate the opportunity to meet with you to discuss this matter further at your
earliest convenience.
Copy: Mr. William Meyer
Ms. Pat Williamson
Ms. Pat Backus
Mr. Craig Brown
Sincerely,
Michael A. Kelly, CHMM,REM
Deputy Director
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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, 1998, 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, 1997.
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 \
field 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
~tfect, however, we are investigating other means of measurement. Currently, we
pfan 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 a~e well below drinking water standards.
401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER · 50% RECYCLED/I 0% POST-CONSUMER PAPER
Ms. Carol L. Kemker
March 2, 1999
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
. _,.·,.,
. '''.;~:-.•
~W'A
NCDENR
JAMES B. HUNT JR.
GovERNOR
WAYNE MCDEVITT
~ SECRETARY
·WILLIAM L. MEYER
DIIIIECTOR
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, 1998, 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, 1997.
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
doi ng 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, I 999, 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
field 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 ofleachate 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 effiuent 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 ISO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· 50% RECYCLED/10o/o POST-CONSUMER PAPER
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