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HomeMy WebLinkAboutCCB0057_Nash_SwiftCreek_GW_FID1279934_201806ERM NC, Inc. February 5, 2019 NCDEQ - Division of Waste Management Solid Waste Section 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Attention: Ms. Jackie Drummond - Compliance Hydrogeologist Reference: Water Quality Monitoring Report Submittal Swift Creek CCB Structural Fill - CCB0057 Battleboro, Nash County, North Carolina Ms. Drummond: 8000 Corporate Center Dr. Suite 200 Charlotte, NC 28226 (704)541-8345 (704) 541-8416 (fax) On behalf of Reuse Technology, Inc., ERM NC, Inc. (ERM) is transmitting the enclosed report of groundwater and surface water quality monitoring conducted at the Swift Creek site in June 2018. The water quality monitoring is being conducted in accordance with the approved Corrective Action Plan dated February 2015. If you should have any questions or require additional information concerning this submittal, please contact Tom Wilson (tom.wilson@erm.com) or Dave Wasiela (dave.wasiela@erm.com). Sincerely, ERM NG Inc. Thomas M Wilson, P.G. cc: Mr. John R. Thomas, ReUse Technology, Inc. Mr. Bob Waldrop, Full Circle Solutions, Inc. Attch: Water Quality Monitoring Report Submitted to: ReUse Technology Submitted by: ERM NC, Inc. (ERM) Ballantyne One 15720 Brixham Hill Ave, Suite 120 Charlotte, NC 28277 www.erm.com The business of sustainability 77 a ' �. r. � .•�]'lt ._ _ _.. '.W . _. '�, ter•: ����'4Cs:"..y�'�.."'r. 2018 Water Quality Monitoring Report Swift Creek CCB Structural Fill — CCB0057 June 2018 (Revised through 2-5-19) Swift Creek Project Reuse Technology Inc. ReUse Technology, Inc. 2018 Water Quality Monitoring Report Swift Creek CCB Structural Fill — CCB0057 Battleboro, Nash County North Carolina CCB0057 February 5, 2019 Project No. 0397281 Dave Wasiela, P.E. Senior Project Engineer Thomas M. Wilson, PG Principal -in -Charge Nso~a SEAL 1113 h ERM NC, Inc. 15720 Brixham Hill Avenue Suite 120 Charlotte, North Carolina 28277 (704) 541-8345 (704) 624-7928 (fax) © Copyright 2018 by ERM Worldwide Group Limited and/or its affiliates (`ERM'). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM. Swift Creek Project Reuse Technology Inc. TABLE OF CONTENTS 1. INTRODUCTION AND SITE HISTORY.................................................................................1 1.1. Introduction..................................................................................................................1 1.2. Summary of Site Environmental History and Corrective Action....................................1 2. CONCEPTUAL SITE MODEL...............................................................................................3 2.1. Hydrogeology...............................................................................................................3 2.2. Contaminant Fate and Transport.................................................................................4 3. WATER QUALITY MONITORING ACTIVITIES....................................................................5 3.1. Objectives....................................................................................................................5 3.2. Monitor Well Installation...............................................................................................6 3.3. Monitoring Methods.....................................................................................................6 4. MONITORING RESULTS.....................................................................................................7 4.1. Groundwater Monitoring Results..................................................................................7 4.2. Surface Water Monitoring Results..............................................................................10 4.3. Laboratory Data Quality Analysis...............................................................................10 5. SUMMARY.........................................................................................................................10 DRAFT Swift Creek Project Reuse Technology Inc. TABLES Table 1: Monitor Well Construction Data Summary Table 2: Historical Groundwater Elevation Data Table 3: Groundwater and Surface Water Analytical Event Results Table 4: Groundwater and Surface Water Field Parameter Results FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Site Location Map Site Map and Monitor Well Locations Shallow Groundwater Potentiometric Map — June 2018 Groundwater Analyses - Constituents Exceeding 2L Groundwater Standards — June 2018 Groundwater Analyses — Sulfate — Surficial Aquifer Hydrogeologic Profile A -A' Sulfate Concentrations Over Time — Selected Monitor Wells APPENDICES A Historical Groundwater and Surface Water Analytical Data B Field Sheets C Boring Logs D Laboratory Data Report DRAFT Swift Creek Project Reuse Technology Inc. 1. INTRODUCTION AND SITE HISTORY 1.1. Introduction On behalf of ReUse Technology, Inc. (ReUse), ERM NC, Inc. (ERM), has prepared this Water Quality Monitoring Report associated with corrective action activities conducted for the Swift Creek Coal Combustion By -Products (CCBs) Structural Fill site (CCB-0057) located along U.S. Highway 301 north of Battleboro, Nash County, North Carolina, (hereafter called the "Site" or "subject property"). Corrective actions have been implemented at the Site to address groundwater quality impacts in accordance with the Corrective Action Plan (CAP) (ERM February 27, 2015) approved by the North Carolina Department of Environmental Quality (NCDEQ) on March 12, 2015. The corrective actions were implemented in 2017 and included temporary removal of CCB materials to allow raising the floor foundation above the seasonal high groundwater table, placing the CCB materials on the raised floor in a reduced footprint, installation of a synthetic liner (cap) over the limits of the CCBs, and drainage improvements to minimize rainfall infiltration. Groundwater and surface water monitoring activities presented herein are being conducted at the Site to monitor the effectiveness of the corrective actions. The Site location is shown in Figure 1. A Site map is included as Figure 2. 1.2. Summary of Site Environmental History and Corrective Action The Site is a 25 acre property in northeast Nash County bounded by US Highway 301 to the west, Lane Swamp to the north and east and Swift Creek to the south. The area surrounding the site is comprised of sparsely populated agricultural land and partially wooded land. In December 2011, the Solid Waste Section approved a proposed plan submitted by Reuse to use CCBs as structural fill material in the development of the 25 acres as a commercial property. In September 1992, ReUse began placement of CCBs as beneficial use fill at the site. In January 2003, the last shipment of CCBs was accepted at the site. In March 2003, the site had been graded, compacted, covered with an 18-inch soil cap and planted with grass seed. In December 2003, Full Circle Solutions, Inc. purchased the business assets of ReUse Technology, Inc. including the Swift Creek Site. According to records of Full Circle Solutions, Inc., a total of approximately 134,000 tons of CCBs were placed at the Site. On November 4, 2004, the Closure Notice was forwarded to the Solid Waste Section. In August 2004, Sherrill Environmental, Inc. reported the results of groundwater monitoring at four newly installed monitoring wells (MW-1 S/MW-1 D, MW-2S/MW-2D) at the site. Lead and sulfate were detected at concentrations above the respective North Carolina 2L Groundwater Standards in the shallow groundwater on the east side of the CCB fill. In October 2004, the Solid Waste Section required an assessment by ReUse to determine the extent of the groundwater impact resulting from the placement of CCBs at the Site. In March 2006, a Comprehensive Site Assessment for the Swift Creek Project was submitted to the Solid Waste Section which included the results of an expanded groundwater and surface water assessment. ERM 1 DRAFT Swift Creek Project Reuse Technology Inc. In September 2006, a Compliance Order was issued by the Solid Waste Section to ReUse. In December 2006, pursuant to the Compliance Order, an Assessment Monitoring Plan and a Swift Creek Dewatering Analysis were submitted to the Solid Waste Section. The Assessment Monitoring Plan described a proposed groundwater and surface water monitoring program for the site. The Swift Creek Dewatering Analysis described a proposed dewatering subsurface drain along the western boundary of the fill along US Highway 301 to remove water from the coal ash fill and lower the local groundwater table to provide a required minimum 1-foot vertical separation between coal ash and seasonal high groundwater elevations. The Assessment Monitoring Plan was approved by the Solid Waste Section in February 2007. The Swift Creek Dewatering Analysis was conditionally approved by the Solid Waste Section in July 2007 based on the performance of the proposed dewatering plan. In January 2008, a dewatering subsurface drain was installed consisting of a 6-inch PVC drain pipe along the western boundary of the fill along US Highway 301. The drain was designed to lower the local groundwater table to provide a required minimum 1-foot vertical separation between coal ash and seasonal high groundwater elevations. Groundwater collected in the pipe was transmitted by gravity flow to an outfall box located at the north end of the site at Lane Swamp. The groundwater and surface water monitoring program was initiated at the site in October 2007 in accordance with the Assessment Monitoring Plan. The program consisted of semi-annual sampling and laboratory analytical testing for metals and sulfates at eight (8) groundwater monitoring well locations and three (3) surface water monitoring locations. Groundwater levels were also measured in the monitoring wells and piezometers in order to evaluate ground water flow direction and determine water levels relative to the CCB fill. The reported results of the groundwater monitoring from 2007 to 2014 confirmed groundwater quality impacts including concentrations of sulfate, arsenic and lead at levels above the respective North Carolina 2L groundwater standards. The monitoring reported no impacts to surface water quality in Lane Swamp or Swift Creek adjacent to the facility. The Division of Waste Management issued a "Warning Notice" to Full Circle Solutions and ReUse dated May 16, 2014. The notice stated that the required groundwater vertical separation between filled CCBs and seasonal high groundwater elevations had not been achieved and exceedances of the North Carolina 2L groundwater standards had been routinely reported. As a result, a "Groundwater Corrective Action Application" was required to be submitted for approval. On behalf of Full Circle Solutions and ReUse, ERM NC, Inc. (ERM) submitted a Corrective Action Application to the Division of Waste Management dated October 16, 2014 for approval. The Corrective Action Application proposed the construction of a synthetic liner (cap) and drainage improvements as corrective actions to significantly reduce or eliminate rainfall infiltration and leachate generation from the beneficial fill. Two contingency corrective actions also were identified. The Division issued approval in December 2014 and requested the submittal of a detailed Corrective Action Plan (CAP) to the Solid Waste Section. The Corrective Action Plan was submitted in February 2015 and approved by the NCDEQ Solid Waste Section in March 2015. The Corrective Action Plan was designed to raise existing CCBs DRAFT Swift Creek Project Reuse Technology Inc. to above historically high groundwater levels to prevent the leaching of contaminants of concern from the existing CCBs. The CAP included the installation of a protective liner system, cover soil layer, and drainage outlets to prevent infiltration of precipitation into the CCBs to assist in the prevention of leaching. The footprint of the limits of ash was condensed from approximately 10 acres to 5 acres reducing the effective infiltration area. Implementation of the Corrective Action Plan was delayed approximately 1 year in 2015-2016 due to a North Carolina Department of Transportation (NCDOT) project to realign US Highway 301 along with bridge replacements across Swift Creek. The corrective measures began on April 24, 2017 and were completed on January 12, 2018. In accordance with the CAP, a performance monitoring and reporting plan was implemented in 2018 to monitor the effectiveness of the corrective action. The elements of the performance monitoring plan include: • Semi-annual groundwater and surface water monitoring and reporting, • Quarterly inspection and reporting of the Site for cap structural integrity, erosion control, proper drainage, etc., and • Corrective Action Effectiveness Reports prepared every five years to evaluate and document a reduction in contaminant concentrations in groundwater and a stable or decreasing plume extent. 2. CONCEPTUAL SITE MODEL 2.1. Hydrogeology Based on the corrective action and monitoring work by ERM as well as previous site investigation activities performed by others, the following updated conceptual site model has been developed. The Site is located in the Coastal Plain physiographic province of North Carolina. The site surficial geology consists of alluvial terrace deposits consisting of layers and mixtures of silts, clay, sands and gravels. The alluvial deposits at the site range in thickness from approximately 8 to 16 feet. The shallow ground water at the site occurs in the alluvial deposits and is referred to as the surficial or alluvial aquifer. The alluvial aquifer sands are of low to moderate permeability (average hydraulic conductivity 0.67 feet/day). Within the alluvial aquifer zone, a yellowish -brown clay layer was encountered in the majority of the borings for monitoring wells and piezometers installed at the site. The clay layer of the alluvial aquifer at the site is approximately 1 to 4 feet thick and has a low permeability (average hydraulic conductivity 0.002 feet/day). The clayey layer behaves as a confining layer or perching layer which appears to limit the vertical migration of contaminants at the site. On the west (upgradient) edge of the site, the clay layer was reported absent in the borings for former wells MW-5S, MW-5D, P-23 and P- 24. The alluvial deposits at the site are underlain by the Yorktown Formation, a regionally ERM 3 DRAFT Swift Creek Project Reuse Technology Inc. extensive marine deposit. At the site, the upper Yorktown Formation consists typically of a greenish -gray, clayey, silty, shelly, very fine sands, is encountered from approximately 13 feet to the maximum depth of investigation of 35 feet, and has a low permeability (average of 0.002 feet per day). No groundwater quality impacts have been detected in monitoring wells completed in the deeper Yorktown aquifer zone. The general groundwater flow pattern at the site is controlled largely by two groundwater discharge features: Lane Swamp to the north and east and Swift Creek to the south. Groundwater flow in the area of the site is generally from west to east with a northeast component of flow toward Lane Swamp at the north end of the site, and a southeast component of flow toward Swift Creek at the south end of the site. 2.2. Contaminant Fate and Transport The key features of the site conceptual model for contaminant fate and transport are summarized as follows: • The depth to groundwater ranges from 0 feet bgs at the creeks and swamps to more than 6 feet in topographically higher areas (not including the beneficial fill footprint). • The regional groundwater flow regime within the surficial (alluvial) aquifer flows west to east with north and south flow components near Swift Creek and Lane Swamp which serve as shallow groundwater discharge features. • The estimated groundwater velocities at the site are very low. The historical calculated groundwater velocities are approximately 6 feet per year for the surficial (alluvial) aquifer and approximately 0.03 feet per year for the deeper Yorktown aquifer. • Prior to the 2018 corrective action, seasonal rises of the underlying water table and rainfall infiltration downward through the old soil cap resulted in water infiltration into the coal ash fill. Constituents within the coal ash fill were dissolved by the infiltration water and became mobile. The former infiltration mechanism has been mitigated by the corrective action. • Once the infiltration water enters the surficial groundwater, it migrates laterally above a clay confining or perching layer within the alluvial aquifer zone towards the groundwater discharge features of Lane Swamp and Swift Creek which serve to limit the lateral extent of the affected groundwater. The limited lateral extent of the affected groundwater is evident at wells MW-2S and 2D, located approximately 200 feet east of the former perimeter of the beneficial fill, where no 2L groundwater exceedances are observed. Similarly, there is no evidence of affected groundwater to the west (upgradient) as evidenced by groundwater monitoring results at current monitoring wells MW-5RS and MW-5RD and former monitoring wells MW-5S and 5D. • Based on historical groundwater monitoring results, the groundwater quality impacts at the site are limited to the surficial aquifer zone. No groundwater quality impacts are detected in the deeper aquifer zone of the Yorktown Formation. • The swamps and creeks surrounding the beneficial fill site act as a "natural perimeter drain" and intercept of the affected groundwater. Based on the historical surface water monitoring results, there are no surface water quality impacts to Lane Swamp or Swift Creek due to affected groundwater from the site. ERM 4 DRAFT Swift Creek Project Reuse Technology Inc. 3. WATER QUALITY MONITORING ACTIVITIES 3.1. Objectives Demonstration of effectiveness of the completed remediation is the primary objective of the water quality monitoring program (i.e. remedial performance monitoring). This objective can be achieved primarily by monitoring the success in reducing the site -specific contaminants of concern (COC) in groundwater in the site monitor wells and thereby mitigating the potential for surface water quality impacts due to contaminated groundwater migration and discharge to surface water. The applicable preliminary remedial goals for groundwater and surface water are summarized below. Groundwater Surface Water NC 21L NC 213 Standard' Standard' (mg/L) (mg/L) Compounds Arsenic 0.01 0.15 Barium 0.7 NE Cadmium 0.002 h Chromium (Total) 0.01 h Lead 0.015 0.025 Mercury 0.001 0.000012 Selenium 0.02 0.005 Silver 0.02 0.00006 Sulfate 250 NE pH 6.5-8.5 6.0-9.0 1 North Carolina 2L Groundwater Quality Standard. 2 North Carolina Surface Water Quality Standard for Class C Waters NE = Not Established mg/L = milligrams per liter h = hardness dependent dissolved metal standard Water quality monitoring is conducted in accordance with the Corrective Action Plan (ERM March 2015). Following is a discussion of the groundwater and surface water monitoring activities conducted at the Site during the reporting period. ERM 5 DRAFT Swift Creek Project Reuse Technology Inc 3.2. Monitor Well Installation ERM installed two new monitor wells at the Site in June 2018. The new monitor wells, MW- 5RS and MW-5RD, were installed as replacements for former upgradient wells MW-5S and MW-51D which were abandoned in 2015 by the NCDOT as part of the Highway 301 realignment project. The new wells were located hydraulically upgradient (west) of the Site on the west side of Highway 301 (see Figure 2) to monitor background water quality in the surficial aquifer (MW-5RS) and deep aquifer (MW-5RD) zones. The monitor wells were installed under an NCDOT right-of-way encroachment agreement (E-0420981800025). ERM contracted with Geologic Exploration to drill and construct the replacement monitor wells with ERM oversight. The wells were installed by hollow stem auger method in accordance with North Carolina well construction standards. Monitor well MW-5RS was completed to a total depth of 18 feet below ground level (bgl) with a 10-foot screen interval from 8 to 18 feet bgl. Monitor well MW-5RD was completed to a total depth of 35 feet bgl with a 5-foot screen interval from 30 to 35 feet bgl. Both wells were completed as flush -mount well heads and properly developed by pumping. The well elevations were determined by a licensed surveyor. The boring logs and well construction details are provided in Appendix C. 3.3. Monitoring Methods A water quality monitoring event was conducted at the Site on June 28-29, 2018. Groundwater and surface water samples were collected from the following monitor wells and surface water locations. Monitor Wells Surface Water Locations MW-1 S SW-1 MW-1 D SW-2 MW-2S SW-3 MW-2D MW-3 MW-4 MW-5RS MW-5RD MW-6 MW-7 MW-8 Subtotal: 11 Subtotal: 3 The monitor well and surface water locations are shown on . Monitoring well construction details are summarized in Table 1. DRAFT Swift Creek Project Reuse Technology Inc. All monitor wells were gauged for water levels and then purged and sampled by low -flow purging methods. The surface water samples were collected as grab samples using clean containers. Field parameters (pH, conductivity, temperature, dissolved oxygen & oxidation reduction potential) were measured for each groundwater and surface water sample by calibrated meters. Well purge logs were completed for each monitor well to document the stabilization of field parameters prior to sample collection. Well purge logs are provided in Appendix B. The groundwater and surface water samples were placed in laboratory supplied containers and placed on ice. The samples were submitted to North Carolina certified laboratory Shealy Environmental Services (NC329) and were analyzed for eight specific metals, sulfates and total dissolved solids using the analytical methods summarized below: Analvtical Methods EPA Method Compound EPA Method 6010 Arsenic Barium Cadmium Chromium (Total) Lead Selenium Silver EPA Method 7470C Mercury EPA 300.0 Sulfates SM 2540 C Total Dissolved Solids 4. MONITORING RESULTS 4.1. Groundwater Monitoring Results Groundwater monitoring activities were conducted at 11 monitor wells at the Site. Groundwater depth -to -water gauging and elevation data are presented in Table 2. The depths to groundwater on June 26, 2018 ranged from approximately 4 to 11 feet BTOC. A potentiometric surface map for the surficial (alluvial) aquifer zone for the June 2018 monitoring event is presented as Figure 3. Groundwater flow in the surficial aquifer over most of the Site is generally west to east-northeast towards Lane Swamp which serves as a groundwater discharge zone. At the southern edge of the Site, there is a localized east-southeast component of groundwater flow towards Swift Creek, which is located south of the Site and also serves as a groundwater discharge zone. Using the current groundwater elevation data, the hydraulic gradients for the Site were calculated and are summarized below. DRAFT Swift Creek Project Reuse Technology Inc. Horizontal Hydraulic Gradient - Surficial Aquifer 26-Jun-18 Well Head Head Distance Hydraulic Designation Elevation Change Change Gradient ft ft ft ft/ft MW-5RS 91.86 2.13 700.00 0.0030 MW-6 89.73 MW-4 94.41 4.90 400.00 0.0123 MW-3 89.51 Average Hydraulic Gradient 0.0076 Vertical Hydraulic Gradients 26-Jun-18 Head Mid - Well Measurement Head Head Point Hydraulic Up/ Designation Location Elevation Change Length Gradient Down Elevation* Change ft MSL ft ft ft ft/ft MW-1 S 88.84 90.18 -0.17 19.74 -0.009 Up MW-1 D 69.10 90.35 MW-2S 81.07 90.31 0.05 19.85 0.002 Down MW-2D 61.22 90.26 Groundwater seepage velocities were calculated using Darcy's equation, summarized as: Where: V=(Kxi)/ne V = seepage velocity of groundwater in ft/day K = hydraulic conductivity in ft/day i = hydraulic gradient (ft/ft) ne = effective porosity As summarized below, based on the June 2018 hydraulic gradients and the previously calculated mean hydraulic conductivities, the estimated groundwater seepage velocity in the surficial aquifer zone using a primary porosity range of 10 to 25% is approximately 6 to 15 feet per year. Seepage Velocity Range (Surficial Aquifer) = = (0.55) (0.0076) / (0.25) = 1.68E-02 ft/day = (0.55) (0.0076) / (0.10) = 4.19E-02 ft/dgy Range of 25% 6.12 ft/yr porosity 10% 15.30 ft/yr of 6 to 15 ERM 8 DRAFT Swift Creek Project Reuse Technology Inc. The June 2018 groundwater analytical results are summarized in Table 3 for metals, sulfate and TDS, and in Table 4 for field parameters. Constituents that exceeded North Carolina 2L groundwater standards are summarized on Figure 4. Laboratory analytical reports for the sampling event are provided in Appendix D. A historical groundwater data summary is provided in Appendix A. For the June 2018 monitoring event, six analytes were detected above their respective North Carolina 2L Groundwater Standards, as summarized in the following table. Current Maximum Concentrations in Groundwater— June 2018 Analyte Maximum Concentration (mg/L) NC 2L (mg/L) Arsenic 0.055 0.01 Cadmium 0.0074 0.002 Lead 0.10 0.015 Sulfate 1,000 250 Total Dissolved Solids 9,400 500 mg/L = milligrams per liter Sulfate, a primary indicator analyte for CCB contaminant releases, was detected in groundwater at concentrations above its 2L standard (250 mg/L) at 5 of the 11 monitor wells. The distribution of sulfate concentrations across the Site is depicted in plan view in Figure 5. A hydrogeologic profile across the Site, including sulfate concentrations in groundwater, is presented in Figure 6. The highest concentrations of sulfate were detected in groundwater samples from monitor wells located on the north (downgradient) end of the site, with 1,000 mg/L sulfate detected both at MW-6 and MW-8. An elevated sulfate concentration (980 mg/L) was also detected in the groundwater sample from MW-3 located on the southern (locally downgradient) side of the Site. The June 2018 groundwater monitoring results for sulfate concentrations were compared to the results of the December 2014 monitoring event which was the most recent monitoring event prior to implementation of the corrective action. Compared to the December 2014 results, the June 2018 sulfate concentrations showed an increase at monitor wells MW-3, MW-6, MW-7 and MW-8; and remained relatively stable at MW-1 S. Graphs of sulfate concentrations over time for selected monitor wells are presented in Figure 7. Notably low values of pH were measured in the groundwater samples from MW-6 (3.9), MW-7 (3.8) and MW-8 (3.9). The low pH values at the three wells are consistent with historical monitoring results, and correlate with detections of arsenic and lead at concentrations above their respective North Carolina 2L groundwater standards at the three wells. There were no exceedances of 2L standards in the three monitor wells located on the west (upgradient) side of the Site (MW-4, MW-5RS & MW-5RD). Three monitor wells located on the east side of the Site (MW-1 D, MW-2S & MW2D) only had exceedances of 2L standards for one parameter, total dissolved solids. The elevated TDS concentrations at MW-1 D, MW-2S and ERM 9 DRAFT Swift Creek Project Reuse Technology Inc. MW21D do not appear to be attributable to sulfate or metals which were not present at elevated levels. 4.2. Surface Water Monitoring Results Consistent with historical monitoring results, the June 2018 surface water monitoring results indicated no exceedances of any North Carolina 2B surface water standards for any samples collected from Swift Creek (SW-1) and Lane Swamp (SW-2 & SW-3). The June 2018 surface water sampling results are summarized in Table 3. Laboratory analytical reports for the surface water samples are provided in Appendix D. Historical surface water data is summarized in Appendix A 4.3. Laboratory Data Quality Analysis Quality assurance/quality control (QA/QC) samples collected during the June 2018 groundwater sampling activities included one blind duplicate sample collected at MW-IS. The duplicate sample of MW-1 S and the MW-1 S sample results can be compared in Table 3. The analytical results of the MW-1 S and duplicate groundwater samples compare favorably indicating no analytical discrepancy. 5. SUMMARY Corrective actions have been implemented at the Site to address groundwater quality impacts in accordance with the approved CAP. The corrective actions were completed in January 2018 and included temporary removal of CCB materials to allow raising the floor foundation above the seasonal high groundwater table, placing the CCB materials on the raised floor in a reduced footprint, installation of a synthetic liner (cap) over the limits of the CCBs, and drainage improvements to minimize rainfall infiltration. Groundwater and surface water monitoring activities are being conducted at the Site to monitor the effectiveness of the corrective actions. The June 2018 water quality monitoring event evaluated groundwater and surface water quality conditions at the Site approximately 5 months after the corrective action implementation. In general, the monitoring results indicate that, due to the relatively low groundwater flow rates at the Site, groundwater quality improvements are not yet evident in the monitoring wells located at the downgradient perimeter of the Site. Additional time will be required before improvements to shallow groundwater quality occur as a result of the corrective action. However, the June 2018 surface water quality results continue to demonstrate that there have been no surface water impacts to Swift Creek or Lane Swamp due to discharges of affected groundwater from the Site. In accordance with the CAP, semi-annual water quality monitoring will continue at the Site. ERM 10 DRAFT Swift Creek Project Reuse Technology Inc. TABLES TABLE 1 MONITOR WELL CONSTRUCTION DATA SUMMARY - SWIFT CREEK PROJECT Monitor Well Top of Casing Elev. Ground Surface Elev. Casing Stick Up Screen Interval Total Depth (TOC) Alluvial/ Marine Status MW-is 99.54 96.8 2.7 3-13 15.7 84.0 Active MW-1 D 99.90 97.1 2.8 23-33 35.7 84.0 Active MW-2S 94.87 92.1 2.8 6-16 18.7 78.5 Active MW-21D 95.22 92.2 3.0 26-36 39.1 78.5 Active MW-3 102.15 99.2 3.0 7-17 20.0 82.2 Active MW-4 106.06 104.1 2.0 8-18 20.0 89.1 Active MW-5S 102.68 99.7 3.0 6-16 17.0 88.2 Abandoned MW-51D 102.67 99.8 2.9 25-35 37.9 88.2 Abandoned MW-5RS 98.80 TBD Flush Mount 8-18 18.0 70.6 Active MW-5RD 98.57 TBD Flush Mount 30-35 37.9 70.6 Active MW-6 98.41 95.0 3.4 6-16 19.4 79.0 Active MW-7 98.63 95.1 3.5 6-16 19.5 79.0 Active MW-8 95.42 92.4 3.0 6-16 19.0 76.4 Active Piezometer P-1 108.19 105.6 2.6 20-30 32.6 Abandoned P-2 109.53 106.7 2.8 20-30 32.8 Abandoned P-3 106.18 104.4 1.8 18-28 30.0 Abandoned P-4 106.57 104.0 2.6 20-30 32.6 Abandoned P-5 108.39 105.9 2.5 20-30 32.5 Abandoned P-6 109.79 107.5 2.3 20-30 32.3 Abandoned P-7 107.77 105.9 1.9 30-40 41.9 82.9 Abandoned P-8 106.53 103.9 2.6 30-40 42.6 82.9 Abandoned P-9 103.32 100.9 2.4 20-30 32.4 87.0 Abandoned P-10 108.17 106.1 2.1 20-30 32.1 89.1 Abandoned P-11 101.88 99.2 2.7 13-23 25.7 82.0 Abandoned P-12 107.04 104.0 3.0 6-16 19.0 Abandoned P-13 108.99 105.9 3.1 6-16 19.1 Abandoned P-14 105.38 101.9 3.5 4-14 17.5 Abandoned P-15 103.76 101.0 2.8 4-14 16.8 Abandoned P-16 105.28 102.1 3.2 4-14 17.2 Abandoned P-17 105.31 101.8 3.5 4-14 17.5 Abandoned P-18 111.21 107.5 3.7 5-15 18.7 Abandoned P-19 111.86 108.3 3.6 7-17 20.6 Abandoned P-20 107.00 104.2 2.8 7-17 19.8 Abandoned P-21 104.99 99.5 5.5 4.5-11.5 16.5 Abandoned P-22 103.60 101.8 1.8 17-27 28.8 87.0 Abandoned P-23East 109.75 107.1 2.7 9-19 21.8 90.0 Abandoned P-24West 103.17 101.1 2.1 3-13 15.3 90.0 Abandoned B-1 107.66 105.7 2.0 14-19 21.0 88.9 Abandoned TABLE 2 HISTORICAL GROUNDWATER ELEVATION DATA SWIFT CREEK - CCB0057 BATTLEBORO, NORTH CAROLINA Page 1 of 1 Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Depth Elevation Gauging Date ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC ft MSL ft BTOC It MSL ft BTOC It MSL ft BTOC It MSL ft BTOC It MSL ft BTOC It MSL Well Identification MWAS MWAD MW-28 MW-2D MW-3 MW-4 MW-5S MW-5D MW-6 MW-7 MW-8 MW-5RS MW-SRD Lane Swamp TOC Elevation: 99.54 99.90 94.87 95.22 102.15 106.06 102.68 102.67 98.41 98.63 95.42 98.80 98.57 92.25 TOC Stickup (Ft from GL) 2.7 2.8 2.8 3.0 3.0 2.0 3.0 2.9 3.4 3.5 3.0 N/A Screened Interval(Ft BGL) 3-13 23-33 6.16 26-36 7-17 8-18 6-16 25-35 6-16 6-16 6-16 8-18 30-35 N/A Geologic Zone Screened Surficial Sudicial Surtcial Deep (Yorktown) Surficial Surfcial Surfcial Deep (Yorktown) Surficial Surficial Surficial Surficial Deep (Yorktown) N/A 12Jan-2005 8.21 91.33 8.57 91.33 4.72 90.15 4.7 90.52 9.85 92.50 11.24 94.82 6.01 96.67 6.4 96.27 7.17 91.24- 1-Aug-2006 8.11 91.43 8.28 91.62 NM -- NM 9.48 85.39 10.15 95.91 5.86 96.82 5.68 96.99 7.18 91.23 7.74 90.89 NM - -- - -- - - 6-Sep-2006 8.69 90.65 9.05 90.85 4.83 90.04 4.87 90.35 10.32 84.55 11.41 94.65 6.94 95.74 6.84 95.83 7.74 90.67 8.68 89.97 NM - -- - -- - - 4-Apr-2007 7.80 91.74 8.18 91.72 4.4 90.47 4.75 90.47 9.31 85.56 9.96 96.10 6.12 96.56 5.96 96.71 7.28 91.13 7.8 90.83 4.84 90.58 -- - -- - - 21-Aug-2007 10.89 88.65 11.30 88.60 6.77 88.10 6.82 88.40 11.4 83.47 13.28 92.78 9.57 93.11 9.1 93.25 10.8 87.61 10.71 87.92 7.67 87.75 -- - -- -- - 21-Oct-2007 11.40 88.14 11.76 88.14 7.31 87.56 7.43 87.79 12.98 81.89 14.06 92.00 10.62 92.06 10.63 92.04 11.9 86.51 11.41 87.22 8.3 87.12 -- - -- - 31Jan1008 9.13 90.41 9.42 90.48 4.86 90.01 5.02 90.20 10.7 84.17 14.11 91.95 7.65 95.03 8.11 94.56 8.44 89.97 8.71 89.92 5.57 89.85 -- - -- - - 22-Mar-2008 8.10 91.44 8.44 91.46 4.4 90.47 4.54 90.68 9.18 85.69 13.28 92.78 6.98 95.70 7.34 95.33 7.18 91.23 7.79 90.84 4.78 90.64 -- - -- - 2.51 89.74 9-APr-2008 9.26 90.28 9.47 90.43 4.58 90.29 5.02 90.20 10.98 83.89 14.82 91.24 10.87 91.81 10.72 91.95 8.92 89.49 9.06 89.57 5.97 89.45 -- - -- - 3.1 89.15 17Jun-2008 9.12 90.42 9.42 90.48 5.03 89.84 5.23 89.99 10.1 84.33 14.05 92.01 8.93 93.75 8.1 93.75 8.36 90.05 9.06 89.57 6.09 W33 -- - -- - 3.2 89.05 13Jan-2009 8.22 91.32 8.55 91.35 4.26 90.61 4.46 90.76 9.35 85.52 13.41 92.65 7.16 95.52 7.54 95.13 7.02 91.39 7.6 91.03 4.58 90.84 -- - -- - 2.52 89.73 31-Mar-2009 7.60 91.94 7.96 91.94 4.36 90.51 4.38 90.84 6.74 88.13 12.43 93.63 5.98 96.70 6.22 96.45 6.81 91.60 7.2 91.43 4.21 91.21 -- - -- - 2.5 89.75 23Jun-Jun 8.62 90.92 8.92 90.98 4.41 90.46 4.77 90.45 10.06 84.81 13.86 92.20 9.83 92.85 9.63 93.04 7.72 90.69 8.52 90.11 5.56 89.86 -- - -- - 2.9 89.35 30-Sep-2009 8.86 90.68 9.18 90.72 4.64 90.23 5.00 90.22 10.82 84.05 14.7 91.36 10.4 92.28 10.26 92.41 8.08 90.33 8.51 90.12 5.5 89.92 -- - -- -- 3.15 89.10 "_Dec-2009 7.54 92.00 NM -- 4.22 90.65 NM 8.68 86.19 12.85 93.21 6.3 96.38 NM -- 6.78 91.63 7.13 91.50 4.21 91.21 -- - -- - 2.8 89.65 31-Mar-2010 7.37 92.17 7.74 92.16 2.42 92.45 4.46 90.76 8.64 86.23 12.52 93.54 5.8 96.88 6.19 96.48 6.77 91.64 7.93 90.70 3.96 91.46 -- - -- - 2.14 90.11 29Jun-2010 9.35 90.19 NM 4.94 89.93 NM 10.66 84.21 14.62 91.44 9.97 92.71 NM -- 9.21 89.20 9.25 89.38 6.31 89.11 -- - -- - 3.35 88.90 28-Sep-2010 9.23 90.31 10.05 89.85 4.8 90.07 5.50 89.72 11.55 83.32 14.8 91.26 10.85 91.83 11.1 91.57 9.11 89.30 8.52 90.11 5.48 89.94 -- - -- -- 4.1 88.15 13-Dec-2010 8.54 91.00 NM 4.36 90.51 NM 10.12 84.75 14.02 92.04 8.72 93.96 NM -- 7.37 91.04 7.93 90.70 4.81 90.61 -- - -- - 2.02 90.23 28-Mar-2011 8.03 91.51 8.42 91.48 4.35 90.52 4.67 90.55 9.17 85.70 13.32 92.74 7.45 95.23 7.84 94.83 7.25 91.16 7.53 91.10 4.42 91.00 -- - -- - 2.85 89.40 26Jun-2011 10.05 89.49 10.35 89.55 6.02 88.85 6.32 88.90 11.23 83.64 14.82 91.24 10.59 92.09 10.43 92.24 9.2 89.21 9.98 88.65 7.04 88.38 -- - -- - 2.85 89.40 28-Sep-2011 7.84 91.70 NM 4.24 90.63 NM 8.9 85.97 13.09 92.97 7.62 95.06 NM -- 7.13 91.28 7.71 90.92 4.83 90.59 -- - -- - 2.2 90.05 18-Dec-2011 8.00 91.54 8.35 91.55 4.32 90.55 4.65 90.57 8.88 85.99 13.1 92.96 7.35 95.33 7.7 94.97 6.98 91.43 7.53 91.10 4.47 90.95 -- - -- - 1.8 90.45 23-Mar-2012 8.01 91.53 8.35 91.55 4.31 90.56 4.56 90.66 8.89 85.98 13.01 93.05 7.35 95.33 7.66 95.01 7.03 91.38 7.75 90.88 4.8 90.62 -- - -- - 1.65 90.60 28Jun-2012 8.39 91.15 8.72 91.18 4.65 90.22 4.92 90.30 9.4 85.47 13.38 92.68 8.52 94.16 8.54 94.13 7.42 90.99 8.45 90.18 5.63 89.79 -- - -- - 1.95 90.30 18-Sep-2012 7.41 92.13 7.86 92.04 4.16 90.71 4.5 90.72 8.21 86.66 12.73 93.33 7.21 95.47 7.45 95.22 6.82 91.59 7.37 91.26 4.51 90.91 -- - -- - 1.52 90.73 17-Dec-2012 8.04 91.50 8.44 91.46 NM NM 9.19 85.68 13.36 92.70 8.55 94.13 8.76 93.91 6.82 91.59 7.37 91.26 4.51 90.91 -- - -- -- 1.45 90.80 26-Mar-2013 7.87 91.67 8.13 91.77 4.23 90.1 4.46 90.76 8.71 86.16 12.1 93.22 7.03 95.65 7.38 95.29 7.08 91.33 7.26 91.37 4.22 91.20 -- - -- - 2.05 90.20 12-Apr-2013 8.30 91.24 8.59 91.31 4.31 90.56 4.72 90.50 9.59 85.28 14.13 91.93 8.48 94.20 8.7 93.97 7.47 90.94 7.8 90.83 4.82 90.60 -- - -- - 2.85 89.40 25Jun-2013 8.00 91.54 8.34 91.56 4.18 90.69 4.57 90.65 9.05 85.82 12.97 93.09 6.1 95.76 7.44 95.23 7.05 91.36 7.7 90.93 4.69 90.73 -- - -- - 2.45 89.80 26-Sep-2013 8.38 91.16 8.67 91.23 4.32 90.55 4.71 90.51 9.57 85.30 13.65 92.41 9.5 93.18 9.5 93.17 8.75 89.66 8.19 90.44 5.25 90.17 -- - -- - 3.05 89.20 28-Mar-2014 7.74 91.60 8.03 91.87 4.33 90.54 4.54 90.68 8.56 86.31 12.53 93.53 6.68 96.00 7.03 95.64 6.92 91.49 7.23 91.40 4.39 91.03 -- - -- - 1.85 90.40 27Jun-2014 8.43 91.11 8.74 91.16 4.45 90.42 4.8 90.42 9.69 85.18 13.93 92.13 7.78 94.90 8.8 93.87 8.33 90.08 8.54 90.09 5.6 89.82 -- - -- - 2.95 89.30 26-Sep-2014 7.82 91.72 8.20 91.70 3.91 90.96 4.28 90.94 8.62 86.25 13.81 92.25 6.68 96.00 7.33 95.34 7.1 91.31 7.36 91.27 4.4 91.02 -- - -- - 1.95 90.30 17-Dec-2014 7.88 91.66 8.30 91.60 4.22 90.65 4.53 90.69 9.01 85.86 13.71 92.35 7.94 94.74 7.46 95.21 7.24 91.17 7.4 91.23 4.34 91.08 -- - -- - 2.1 90.15 28Jun-Jun 9.36 90.18 9.55 90.35 4.56 90.31 4.96 90.26 10.35 89.51 11.65 94.41 Abandoned 2015 Abandoned 2015 8.68 89.73 9.12 89.51 5.86 89.56 6.84 91.96 10.52 88.05 - - NE - Not Established BTOC Below Top of Casing BGL- Below ground level --= N. Measured ft MSL =feet above Mean Sea Level TOC Stickup data per Shemll Environmental, Assessment Montoring Report, Feb 10, 2015 RJRnSMft Creek Tables RI DW ,f A2. GW Elevations TABLE 3 GROUNDWATER AND SURFACE WATER ANALYTICAL EVENT RESULTS SWIFT CREEK STRUCTURAL FILL - CCB0057 BATTLEBORO, NORTH CAROLINA Page 1 of 1 Sample Location / ID Date D m 0 oo �' n Q 3 s o o 7 r n 0 ,� Cn m � 3 - cn m � v o o--I (- a v NC 2L Groundwater Standard 0.01 0.7 0.002 0.01 0.015 0.001 0.02 0.02 250 500 NC 213 Surface Water Standard 0.15 NE h h 0.025 0.000012 0.005 0.00006 NE NE GROUNDWATER MONITORING WELLS MW-1S 6/28/18 <0.015 0.24 <0.005 <0.030 <,, <0.0002 <0.02 <0.01 320 8,100 Duplicate (MW-1S) 6/28/18 <0.015 0.24 <0.005 <0.030 <0.01 <0.0002 <0.02 <0.01 340 7,8' MW-1 D 6/28/18 <0.01 0.66 <0.005 <0.01 <0.010 <0.0002 <0.02 <0.01 19 8,200 MW-2S 6/28/18 <0.015 0.13 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 <1 790 MW-2D 6/28/18 <0.015 0.13 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 <1 790 MW-3 6/28/18 <0.015 0.066 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 830 MW-4 6/28/18 <0.01 0.041 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 66 450 MW-5RS 6/29/18 <0.015 0.098 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 12 420 MW-5RD 6/29/18 <0.01 0.15 <0.001 <0.01 <0.01 <0.0002 <0.01 <0.01 26 230 MW-6 6/28/18 0.04 0.041 0.047 0.1 <0.005 <0.01 0.045 <0.0002 <0.02 <0.01 1,000 6,300 MW-7 6/28/18 0.0074 <0.02 0.089 <0.0002 <0.02 <0.01 770 9,400 MW-8 6/28/18 a0.055 0.056 <0.005 <0.02 0.1 <0.0002 <0.02 <0.01 1,000A 8,400 SURFACE WATER SW-01 6/28/18 <0.015 0.031 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 <1 73 SW-02 6/28/18 <0.015 0.089 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 <1 130 SW-03 6/28/18 <0.015 0.032 <0.005 <0.01 <0.01 <0.0002 <0.02 <0.01 <1 76 All concentrations in milligrams per liter (mg/L) unless otherwise noted. --- Not sampled NE - Not established Bold with gray background indicates exceedance of NC Groundwater or Surface Water Standai h = hardness dependent dissolved metal standard Swift Creek Tables R1 DWWxlsx/Table 3-Event Data 2018-06 TABLE 4 GROUNDWATER AND SURFACE WATER FIELD PARAMETER RESULTS SWIFT CREEK STRUCTURAL FILL - CCB0057 BATTLEBORO, NORTH CAROLINA Page 1 of 1 Sample Location / ID Date = CD CDCDoC ��-, (Q@ V y Q 3� z a :T o Xo niaQ a �; <0 0 O� 2 0 v 3 a NC 2L Groundwater Standard 6.5 - 8.5 NE NE NE NE NE NC 2B Surface Water Standard 6.0 - 9.0 NE NE 50 NE >5.0 GROUNDWATER MONITORING WELLS 27.0 25.6 14,679 1,221 47 -93 0.2 0.2 MW-is 6/28/18 6/28/18 5.8 5.3 MW-1D 6.9 3.5 MW-2S 6/28/18 6.3 21.0 448 0.0 -36 0.2 MW-2D 6/28/18 7.1 25.0 444 9.7 18 1.3 MW-3 6/28/18 5.5 27.2 7,611 9.1 60 0.3 MW-4 6/28/18 6.4 25.1 72 6.9 56 0.3 MW-5RS 6/29/18 6.9 23.9 454 6.5 45 3.4 MW-5RD 6/29/18 7.3 23.0 327 19.5 29 0.1 MW-6 6/28/18 3.9 25.3 9,665 0.2 196 0.8 MW-7 6/28/18 3.8 23.0 13,584 1.9 243 1.4 MW-8 6/28/18 3.9 19.0 11,539 0.5 125 0.7 SURFACE WATER SW-01 6/28/18 7.0 28.5 101 NM -3 4.2 SW-02 6/28/18 7.0 29.7 369 90.0 0 0.7 SW-03 NM NE - Not established NM - Not measured Bold value exceeds applicable pH standard Swift Creek Tables R1 DWW.xlsx/Table 4-Field Parameters2018-06 Swift Creek Project Reuse Technology Inc. FIGURES ,I a� SITE LOCATION -� I � all. a1£vCUTCHIN i= L- -� o I aar I� c,\ O'U1�TT - ROCKY M 9 ^ .,-�_ ` aam aanle�wro 1l W,amcsTaa �✓�� �\ m � Y� - - o + — SOURCE: USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE: L SCALE 1:24000 1 1/2 0 1 MILE u NORTH CAROLINA 1000 0 1000 2000 3000 4000 5000 6000 7000 FEET N D 7 b CONTOUR INTERVAL 10 FEET DOTTED LINES REPRESENT 5-FOOT CONTOURS QUADRANGLE LOCATION NATIONAL GEODETIC VERTICAL DATUM OF 1929 SWIFT CREEK FIGURE i z ERM, NC INC. STRUCTURAL FILL — CCB0057 � ReUse Technology r ERM Battleboro, NC L