8105_8103_Rutherford_MonitoringPlans_FID1088734_20171109

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7.0 MONITORING PLAN
7.1 SUMMARY OF REGULATORY REQUIREMENTS
North Carolina Solid Waste regulations require that C&D landfills implement a detection phase
monitoring program for ground water and surface water. Normally, this includes an up gradient
background well and several down gradient (or cross gradient) compliance wells, along with several
strategically placed surface water sampling locations with up gradient and down gradient coverage.
Well placement is based on the hydraulic and topographic characteristics of the site, determined in
the Site Suitability and Design Hydrogeologic investigations. Compliance wells are placed at a
“review boundary” located approximately half the distance to the “compliance boundary,” which is
normally established 50 feet inside the facility boundary, or 150 feet from the waste boundary.
Detection phase monitoring includes semi-annual sampling and analysis for compliance with North
Carolina ground water standards, i.e., 15A NCAC 2L .0300 (the “2L rules”). The detection phase
sampling list includes organic constituents on the Appendix I list 1 (i.e., volatiles and semi-volatiles
that are analyzed by US-EPA Method 8260 and the RCRA metals), key indicator parameters
(measured in the field), and – new for the 2006
C&D Rules – several additional constituents (mercury, manganese, sulfate, iron, alkalinity, and total
dissolved solids). As of June 2010 monitoring of tetrahydrafurans (TFC’s) are required at CDLFs. A
number of other changes in the monitoring requirements have occurred since the subject facility
was permitted in 2009, including:
.0600 Rules - Applicable to all Facilities permitted under the .0500 Rules. October 2006 Memo »
Addendum to the Oct 2006 Memo » October 2007 Memo »
Electronic Data Deliverable (EDD) Template (Last updated: May 5, 2010)
Solid Waste Environmental Monitoring Data Form (Last updated: June 10, 2009)
The Solid Waste Section web site, http://portal.ncDEQ.org/web/wm/sw/envmonitoring, provides
comprehensive environmental monitoring requirements for landfills, including a standardized
Sampling and Analysis Plan (SAP), Groundwater, Surface Water, and Soil
Sampling for Landfills, which is not replicated in this document.
Assuming no detects of ground water constituents that exceed a 2L standard, the term of
detection phase monitoring runs for the operational life of the facility plus the post- 1 40 CFR Part
258 closure period (minimum of 30 years beyond closure). Should one or more detected
constituents exceed a 2L standard, the facility must undergo an expanded assessment monitoring
program to determine the source, extent, and rate of contaminant migration, plus an evaluation of
potential human receptors and/or other environmental impacts.

The subject facility contains a closed MSW landfill unit, which is undergoing assessment monitoring

Rutherford County MSW Facility Plan Update 2017 Permit Renewal October 2017
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in accordance with NC DEQ Division of Waste Management rules, due to prior detections of certain
constituents at levels that exceed the 2L standards in certain compliance wells – this condition is
not unusual at closed, unlined MSW landfills. The assessment sampling program, conducted (by
others) concurrent with the detection phase monitoring for the C&D landfill, shares the background
well and several surface water sampling locations. At the present time, no detects have been
attributed to the C&D landfill. Ongoing assessment monitoring activities will likely continue to focus
on areas south of the cross-country power line (which delineates the C&D unit from the closed
MSW unit), within areas that are down gradient of the C&D unit.
7.2 GROUND WATER MONITORING
The following discusses the rationale behind planned amendments to the detection phase
monitoring program for the C&D landfill, reflected in the Sampling and Analysis Plan. The format of
the SAP is consistent with that used for numerous Division-accepted landfill monitoring programs.
7.2.1 Monitoring System Requirements
The Design Hydrogeologic study for CDLF Phase 1A indicates a radial ground water flow pattern
toward the south, southwest, and southeast. This flow pattern reflects surface topography along
a sharp ridge, surrounded on three sides by surface streams (i.e., ground water receptors). The
CDLF is situated on the west side of the ridge, with the predominant ground water flow direction to
the west and southwest, toward a receptor stream and/or the closed MSWLF. No ground water
users are located between the CDLF unit and the receptor stream. The stream provides on-site
discharge for the upper aquifer.
Ground water typically occurs within the dense saprolite mantle, with relatively dry soil existing
above the water-bearing zones, but water levels frequently stabilize at higher elevations than first
encountered (during drilling) due to topography-induced hydrostatic pressure. Differential
weathering results in a gradational boundary between the dense, unconfined to partly confined,
porous-flow saprolite (Unit 1 with N < 100 bpf and Unit 2 with N = 100+ bpf) and the predominantly
confined fracture-flow bedrock (Unit 3).
The placement of wells for the CDLF focuses on the saprolite (Units 1 and 2) and/or upper bedrock
(Unit 3) on the west and southwest sides of the unit, with minor emphasis on the east and north
(cross-gradient) directions. Based on these conditions, the detection phase monitoring program for
the CDLF unit includes 6 wells: one facility background well (MW-2) and five compliance wells (MW-
4, MW-12, MW-13, MW-14 and MW-15).
Well depths determined from the subsurface data reflect the position of the saprolite (Units 1 and
2) as the uppermost aquifer. Table 7A following this section shows the well construction data.
Figure 1 shows the locations of the monitoring well network.
7.2.2 Background Water Quality

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Low concentrations of metals also have been detected on occasion at the facility background
well, MW-2, including cadmium, lead, and zinc.
7.2.3 Point of Compliance Water Quality
The 2L ground water standards are applicable for the compliance boundary, tempered with
background water quality data.
7.2.4 Sampling and Analysis Procedures
Industry accepted protocols (also consistent with Division guidelines) are discussed in the
Sampling and Analysis Plan.

7.2.5 Detection-phase Monitoring Parameters
The sampling parameters consist of the EPA Appendix I list of organic constituents and metals,
modified by the 2006 C&D Rules.
7.2.6 Sampling Frequency
The detection phase sampling frequency shall be semi-annually.

7.2.7 Water Level Elevations
During each sampling event, water levels shall be measured from the top-of-casing at each
monitoring well.

7.2.8 Reporting
Data analysis and reporting, consistent with Division requirements, are described in the
Sampling and Analysis Plan.

7.2.9 Source Demonstration
In the event of the detection of a ground water constituent that exceeds a 2L standard, an
evaluation may be made in accordance with Division policy to determine the source, e.g., sampling
error, laboratory contamination, extenuating circumstances (improper repairs to a well or
incidental spill near a well). Typically, re-sampling is performed

7.2.10 Monitoring Well Design
Wells shall be (and currently are) designed in accordance with 15A NCAC 2C.

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7.2.11 Monitoring Well Layout
The layout takes advantage of topographic features (as indicators of fracture patterns that influence
ground water flow) and access considerations within the generally steep terrain.

7.2.12 Alternative Monitoring Systems
No alternative sampling points have been specified.

7.2.13 Assessment Monitoring
Assessment monitoring requirements are outlined in Rule .0545 of the 2006 C&D Rules. If
conditions require assessment monitoring, a plan will be prepared for review by the Division. It is
anticipated that any future assessment of the CDLF will be tied into the ongoing assessment of the
closed MSWLF. At present, no such conditions are known.
The foregoing discussion is presented for information purposes and is not intended to alter the
ongoing assessment monitoring program, with the possible exception of bringing the more
recent NC DEQ requirements to light. The monitoring program for the closed MSWLF has been in
effect for more than 15 years (by others) and has been conducted to the general satisfaction of the
regulators. Assessment monitoring for the closed MSWLF is conducted under different rules.
Changes effected by this plan update are limited to the CDLF, but may be adapted to the
assessment work.

7.3 SURFACE WATER MONITORING
Surface water monitoring should (and does) focus on the unnamed tributary shown to be a ground
water discharge feature west of the CDLF, including a new sampling station (SW-5) shall be
established below the underdrain (beneath the west toe of the Phase 1A footprint). Refer to the
site plan depicting existing and planned surface water sampling locations, presented in the
Sampling and Analysis Plan.

7.4 GAS CONTROL AND MONITORING
7.4.1 Regulatory Limits
Division rules specify an explosive gas limit of 25% of the Lower Explosive Limit (LEL) (5% methane
in standard atmosphere) within occupied structures and 100% LEL at the facility boundary. Figure
2 shows the locations of the gas monitoring wells.

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7.4.2 Monitoring Program
Conditions at the C&D landfill are not conducive to extensive migration of explosive gases at
concentrations that would approach the regulatory thresholds for action, C&D wastes are typically
non-putrescible and the facility boundary is downhill and along a water course. There is a possibility
that landfill gas from the closed MSWLF unit could migrate beneath the CDLF unit and become
indistinguishable from gas generated by the CDLF unit. An evaluation of existing methane
monitoring is beyond the scope of this report, but gas detectors are located within the buildings.
7.4.3 Corrective Action
Corrective action to control gas migration, if any is required, might consist of additional passive
venting and/or active gas recovery. The likelihood of such measures ever being required is remote
– this issue is addressed in the interest of compliance with the rules.
7.5 WASTE ACCEPTANCE POLICY
Monitoring of the waste intake is addressed in the Operations Plan, which calls for routine waste
screening and record keeping with respect to waste types, sources, and haulers. Adherence to
these criteria will reduce the likelihood of developing a ground water impact in the future.

SW-3
SW-2
SW-5
I HEREBY CERTIFY THAT THIS
PLAN AND SPECIFICATION
WAS PREPARED BY ME OR
UNDER MY DIRECT
SUPERVISION AND THAT I AM
A DULY REGISTERED
ARCHITECT OR ENGINEER
UNDER THE LAWS OF THE
STATE OF NORTH CAROLINA
AS SIGNIFIED BY MY HAND
AND SEAL.169 Oak Street, Forest City, N.C. 28043ph: 828.247.4495 fax: [phone] INCH = FEETGRAPHIC SCALE
200 0 100 200 400 600
200
0
NOT
FOR
CONSTRUCTION