1401_Caldwell_MSWLF_EnvironmentalDetermination_FID1322565_20190617

MEMORANDUM
TO: Former CSI Landfill Facility General File
FROM: Mary Siedlecki, HWS Project Manager
THROUGH: Bud McCarty, HWS Branch Head
DATE: June 17, 2019
SUBJ: Evaluation of Former CSI Landfill Facility's Status Under the
Environmental Indicator Event Code (CA750)
I. PURPOSE OF MEMO
This memo is written to formalize an evaluation of Former CSI Landfill Facility's status in
relation to the following corrective action event code defined in RCRAInfo:
Migration of Contaminated Groundwater Under Control (CA750) — YE.
II. SUMMARY OF FOLLOW-UP ACTIONS
The groundwater contaminant plume is large and dilute in nature. Concentrations of total volatile
organic compound concentrations in most monitoring wells have decreased by greater than 90
percent in comparison to their maximum concentrations as a consequence of natural degradation
processes. Groundwater quality will continue to be monitored to ensure that degradation
continues.
Attachments: CA750: Migration of Contaminated Groundwater Under Control
ec: John Johnston, US EPA Region 4, Restoration and UST Branch
Stan Kiser, Caldwell County
Heather Watson, Caldwell County
Kathy Greene, Caldwell County
Bud McCarty, Hazardous Waste Section
Mary Siedlecki, Hazardous Waste Section
Ernie Lawrence, Hazardous Waste Section
Jackie Drummond, Solid Waste Section
Mark Harper, Flynn Environmental
Leo Moretz, Hart and Hickman

DOCUMENTATION OF ENVIRONMENTAL INDICATOR DETERMINATION
RCRA Corrective Action
Environmental Indicator (EI) RCRIS code (CA750)
Migration of Contaminated Groundwater Under Control
Facility Name: Former CSI Landfill Facility
Facility Address: 1200 Dragstrip Road, Hudson, Caldwell County, North Carolina
Facility EPA ID #: NCD 086 871282
Has all available relevant/significant information on known and reasonably suspected releases to the
groundwater media, subject to RCRA Corrective Action (e.g., from Solid Waste Management Units
(SWMU), Regulated Units (RU), and Areas of Concern (AOC)), been considered in this EI determination?
_X If yes -check here and continue with #2 below.
If no - re-evaluate existing data, or
If data are not available, skip to #8 and enter "IN" (more information needed) status code.
BACKGROUND
Definition of Environmental Indicators (for the RCRA Corrective Action)
Environmental Indicators (EI) are measures being used by the RCRA Corrective Action program to go beyond
programmatic activity measures (e.g., reports received and approved, etc.) to track changes in the quality of the
environment. The two EI developed to -date indicate the quality of the environment in relation to current human
exposures to contamination and the migration of contaminated groundwater. An EI for non -human (ecological)
receptors is intended to be developed in the future.
Definition of "Migration of Contaminated Groundwater Under Control" EI
A positive "Migration of Contaminated Groundwater Under Control" EI determination ("YE" status code) indicates
that the migration of "contaminated" groundwater has stabilized, and that monitoring will be conducted to confirm
that contaminated groundwater remains within the original "area of contaminated groundwater" (for all groundwater
"contamination" subject to RCRA corrective action at or from the identified facility (i.e., site -wide)).
Relationship of EI to Final Renledies
While Final remedies remain the long-term objective of the RCRA Corrective Action program the EI are near -term
objectives which are currently being used as Program measures for the Government Performance and Results Act of
1993, GPRA). The "Migration of Contaminated Groundwater Under Control" EI pertains ONLY to the physical
migration (i.e., further spread) of contaminated ground water and contaminants within groundwater (e.g., non -aqueous
phase liquids or NAPLs). Achieving this EI does not substitute for achieving other stabilization or final remedy
requirements and expectations associated with sources of contamination and the need to restore, wherever practicable,
contaminated groundwater to be suitable for its designated current and future uses.
Duration / A licabili(% of EI Determinations
EI Determinations status codes should remain in RCRIS national database ONLY as long as they remain true (i.e.,
RCRIS status codes must be changed when the regulatory authorities become aware of contrary information).
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (En RCRIS code (CA750)
2. Is groundwater known or reasonably suspected to be "contaminated" 1 above
appropriately protective "levels" (i.e., applicable promulgated standards, as well as other
appropriate standards, guidelines, guidance, or criteria) from releases subject to RCRA
Corrective Action, anywhere at, or from, the facility?
_X If yes - continue after identifying key contaminants, citing appropriate "levels," and
referencing supporting documentation.
If no - skip to #8 and enter "YE" status code, after citing appropriate `levels," and
referencing supporting documentation to demonstrate that groundwater is not
"contaminated."
If unknown - skip to #8 and enter "IN" status code.
Rationale and Reference(s):
The former CSI facility operated as a hazardous waste management facility on a 1.59-acre parcel
leased from Caldwell County (Figure 1). The former CSI facility is in the west -central portion of an
approximately 148-acre parcel of land owned by Caldwell County; approximately 103 acres of this
property was utilized as the Caldwell County landfill. The parcel directly west of the former CSI
facility is known as the "former Haas property" and occupies approximately 44-acres. The Site is
bordered to the south by residential properties on Drag Strip Road and Lick Mountain Drive, and to
the east, north, and west by undeveloped private property.
The hazardous waste management facility was constructed by Caldwell County, which operated it
from April 1976 until January 1977. From March 1977 until 1989, Caldwell County leased the
facility to CSI. During this time, the facility incinerated and/or repackaged, consolidated, blended,
and liquefied waste for off -site shipment or use as fuel. The facility handled hazardous wastes from
the US Navy and other industries, including torpedo fuel, solvents, waste oils, paints, tank bottoms,
glues, and sludges.
Numerous, extensive investigations of potential impacts at the site have been conducted beginning
in the late 1980's. A global groundwater monitoring network was installed and first sampled in
January 1995. Groundwater collected from monitoring wells GM-1, GM-2, and MW-2, and MW-3,
was analyzed for the complete Appendix IX parameter list, which includes volatile organic
compounds (VOCs), semi -volatile organic compounds (SVOCs), chlorinated and
organophosphorus pesticides, herbicides, and metals.
Results of the RCRA Facility Investigation indicated that VOCs were the primary constituents of
concern at the site. The highest concentration of VOCs was detected in monitoring wells in and
immediately downgradient to the east of the former CSI facility. Groundwater quality is currently
monitored on an annual basis beginning in 2001.
The 2018 annual groundwater monitoring event was conducted from October 22-25, 2018.
Groundwater samples were collected from the Haas Spring and from each of the following
monitoring wells: FPC-MW-01, FPC-MW-03, FPC-MW-07A, MW-C, MW-2, MW-2A, MW-3,
MW-3A, GM-1, GM-5, and GM-6 (Figure 1). Groundwater samples were analyzed for VOCs using
EPA Method 8260.
Constituents that exceed 15A NCAC Subtitle 2L Groundwater Standards (2L Groundwater
Standards) include benzene; 1,1-dichlorethane; 1,2-dichloroethane, 1,2-dichloroethane; 1,2-
06/03/19 Page 2

dichloropropane, tetrachloroethylene, vinyl chloride. The most elevated concentrations are
measured in monitoring well GM-1.
For purposes of this Environmental Indicator Determination, the highest concentration measured
in groundwater in October 2018 is compared to the respective 15A NCAC Subtitle 2L Groundwater
Standard (last amended on July 1, 2016).
Constituent' Highest Measured
Concentration2
15A NCAC Subtitle 2L Groundwater
Standard2
Benzene
7.5 GM-1
1
1,1-Dichlorethane
10.6 GM-1
6
1,2-Dichloroethane
161 GM-1
0.4
1,2-Dichloro propane
1.4 GM-1
0.6
Tetrachloroeth lene
2.8 FPC-MW-03) j
0.7
Vinyl Chloride
2.3 MW-2A)
0.03
' 1,4-Dioxane was measured in monitoring well GM-1 at 570 ug/L in 1998 (21-Groundwater Standard = 3 ug/L). !,4-Dioxane
is not included in the annual monitoring program. This constituent will be included in the monitoring program conducted as
part of the final remedy.
' All concentrations are in micrograms per liter (ug/L). The monitoring well characterized by the most elevated concentration
is included.
References
Flynn Environmental, Incorporated, Annual Groundwater Monitoring Report, November 15, 2018
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
Footnotes: 1 "Contamination" and "contaminated" describes media containing contaminants (in any form, NAPL
and/or dissolved, vapors, or solids, that are subject to RCRA) in concentrations in excess of appropriately protective
risk -based "levels" (for the media, that identify risks within the acceptable risk range).
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (En RCRIS code (CA750)
3. Has the migration of contaminated groundwater stabilized (such that contaminated
groundwater is expected to remain within "existing area of contaminated groundwater ,2 as
defined by the monitoring locations designated at the time of this determination)?
_X If yes - continue, after presenting or referencing the physical evidence (e.g., groundwater
sampling/measurement/migration barrier data) and rationale why contaminated
groundwater is expected to remain within the (horizontal or vertical) dimensions of the
"existing area of groundwater contamination"2).
If no (contaminated groundwater is observed or expected to migrate beyond the designated
locations defining the "existing area of groundwater contamination' 2) - skip to #8 and enter
"NO" status code, after providing an explanation.
If unknown - skip to #8 and enter "IN' status code.
Rationale and Reference(s):
As discussed in Item Number 2 above, contaminant concentrations are generally highest in
monitoring well GM-1 (located in the source area of the former CSI facility (Figure 1)). The total
concentration of measured VOC concentrations in GM-1 decreased from a maximum of 2,509
microgram per liter (ug/L) in August 1996 to 301.5 ug/L in October 2018.
The Corrective Measures Study — Revision 2 (dated June 29, 2018) compared the change in total
VOC concentrations in individual monitoring wells as a function of time. Concentrations of total
VOCs in most monitoring wells decreased by greater than 90 percent in comparison to their
maximum concentrations. VOCs were only measured at concentrations exceeding regulatory
standards in five of eleven wells during the October 2018 monitoring event, including FPC-MW-03,
FPC-MW-07A, MW-2A, GM-1, and GM-5.
The groundwater contaminant plume is large and dilute in nature. The trend in total VOC
concentration was evaluated using a Mann -Kendall analysis. Mann -Kendall is a non -parametric
statistical analysis used to evaluate trends over time. The trends are identified as "decreasing,"
"probably decreasing," "stable," "no trend," "probably increasing," or "increasing."
Eight monitoring wells were identified as "decreasing," one monitoring well was identified as
"probably decreasing," and two monitoring wells (MW-7A and GM-6) were identified as having "no
trend." Although the data from GM-6 was characterized as having "no trend," this characterization
is considered meaningless because the data set only contained two detections of constituents
between 2001 and 2017 for GM-6.
In conclusion, the results of the Mann -Kendall analysis indicate that total VOC concentration have
generally been declining due to natural attenuation over time. Groundwater monitoring data and
statistical evaluations indicate that the groundwater contaminant plume has stabilized.
References
Flynn Environmental, Incorporated, Annual Groundwater Monitoring Report, November 15, 2018
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
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2 "existing area of contaminated groundwater" is an area (with horizontal and vertical dimensions) that has been verifiably
demonstrated to contain all relevant groundwater contamination for this determination, and is defined by designated (monitoring)
locations proximate to the outer perimeter of "contamination" that can and will be sampled/tested in the future to physically verify
that all "contaminated" groundwater remains within this area, and that the further migration of "contaminated" groundwater is not
occurring. Reasonable allowances in the proximity of the monitoring locations are permissible to incorporate formal remedy
decisions (i.e., including public participation) allowing a limited area for natural attenuation.
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (EI) RCRIS code (CA750)
4 Does "contaminated" groundwater discharge into surface water bodies?
_X If yes - continue after identifying potentially affected surface water bodies.
If no - skip to #7 (and enter a "YE" status code in #8, if #7 = yes) after providing an
explanation and/or referencing documentation supporting that groundwater
"contamination" does not enter surface water bodies.
If unknown - skip to #8 and enter "IN' status code.
Rationale and Reference(s):
The Site is located within the Piedmont physiographic and Inner Piedmont tectonic province. The
topography of the Site is characterized by gently rolling to undulating hills with moderate slope
valleys. The surrounding area is relatively mountainous, maturely dissected terrain with local relief
ranging from 300 to 600 feet. Topographic elevation at the site varies from approximately 1,700
feet above mean sea level (ft msl) at the ridge where the former CSI facility is located to
approximately 1,440 ft msl in the valley near the toe of the landfill (Figure 2). Surface water at the
Site drains away from the ridge where the former CSI facility is located to the east and the west.
Intermittent streams are present in east- and west -trending valleys on both sides of the ridge
(Figure 3).
References
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (En RCRIS code (CA750)
Is the discharge of "contaminated" groundwater into surface water likely to be
"insignificant" (i.e., the maximum concentration3 of each contaminant discharging into
surface water is less than 10 times their appropriate groundwater "level," and there are no
other conditions (e.g., the nature, and number, of discharging contaminants, or
environmental setting), which significantly increase the potential for unacceptable impacts
to surface water, sediments, or eco-systems at these concentrations)?
If yes - skip to #7 (and enter "YE" status code in #8 if #7 = yes), after documenting: 1) the
maximum known or reasonably suspected concentration3 of kgy contaminants discharged
above their groundwater "level," the value of the appropriate "level(s)," and if there is
evidence that the concentrations are increasing; and 2) provide a statement of professional
judgement/explanation (or reference documentation) supporting that the discharge of
groundwater contaminants into the surface water is not anticipated to have unacceptable
impacts to the receiving surface water, sediments, or eco-system.
X If no - (the discharge of "contaminated" groundwater into surface water is potentially
significant) - continue after documenting: 1) the maximum known or reasonably suspected
concentration3 of each contaminant discharged above its groundwater "level," the value of
the appropriate "level(s)," and if there is evidence that the concentrations are increasing;
and 2) for any contaminants discharging into surface water in concentrations3 greater than
100 times their appropriate groundwater "levels," the estimated total amount (mass in
kg/yr) of each of these contaminants that are being discharged (loaded) into the surface
water body (at the time of the determination), and identify if there is evidence that the
amount of discharging contaminants is increasing.
If unknown - enter "IN" status code in #8.
Rationale and Reference(s):
Seven surface water samples were collected in 1998 as part of the Phase I RCRA Facility
Investigation. The samples were collected from intermittent streams located both on- and off -Site
(Figure 3). The results of the surface water sampling event are summarized in Table 1. When
concentrations are compared to current surface water standards, vinyl chloride exceeds the
15A NCAC Subtitle 2B Surface Water Standard (213 Surface Water Standard) at sample location
SW-5 (Table 1). SW-5 is located on -Site downgradient of the landfill.
The measurement of vinyl chloride in surface water collected from sample location SW-5 (3.9 ug/L)
exceeds ten times the 15A NCAC Subtitle 2L Groundwater Standard of (0.03 ug/L). Thus, the
discharge of contaminated groundwater to SW-5 is deemed "significant" based on data collected
in 1998.
References
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
3 As measured in groundwater prior to entry to the groundwater -surface water/sediment interaction (e.g.,
hyporheic) zone.
06/03/19 Page 7

Migration of Contaminated Groundwater Under Control
Environmental Indicator (En RCRIS code (CA750)
6. Can the discharge of "contaminated" groundwater into surface water be shown to be
"currently acceptable" (i.e., not cause impacts to surface water, sediments or eco-systems
that should not be allowed to continue until a final remedy decision can be made and
implemente&)?
X_ If yes - continue after either: 1) identifying the Final Remedy decision incorporating these
conditions, or other site -specific criteria (developed for the protection of the site's surface
water, sediments, and eco-systems), and referencing supporting documentation
demonstrating that these criteria are not exceeded by the discharging groundwater; OR 2)
providing or referencing an interim-assessment,5 appropriate to the potential for impact,
that shows the discharge of groundwater contaminants into the surface water is (in the
opinion of a trained specialists, including ecologist) adequately protective of receiving
surface water, sediments, and eco-systems, until such time when a full assessment and final
remedy decision can be made. Factors which should be considered in the interim -
assessment (where appropriate to help identify the impact associated with discharging
groundwater) include: surface water body size, flow, use/classification/habitats and
contaminant loading limits, other sources of surface water/sediment contamination, surface
water and sediment sample results and comparisons to available and appropriate surface
water and sediment "levels," as well as any other factors, such as effects on ecological
receptors (e.g., via bio-assays/benthic surveys or site -specific ecological Risk
Assessments), that the overseeing regulatory agency would deem appropriate for making
the EI determination.
If no - (the discharge of "contaminated" groundwater can not be shown to be "currently
acceptable") - skip to #8 and enter "NO" status code, after documenting the currently
unacceptable impacts to the surface water body, sediments, and/or eco-systems.
If unknown - skip to 8 and enter "IN" status code.
- Rationale and Reference(s):
Volatile organic compounds, including aromatic hydrocarbons and chlorinated volatile organic
compounds (CVOCs), may degrade over time through natural attenuation processes in many
groundwater systems. This can include physical processes, such as dilution, adsorption, and
dispersion; or chemical processes, such as oxidation of benzene or natural reductive dechlorination
of CVOCs.
A Corrective Measures Study — Revision 2 was submitted to the Hazardous Waste Section on
June 29, 2018. Multiple lines of evidence were used to support a recommendation of monitored
natural attenuation as the final remedy decision to address the large, dilute groundwater
contaminant plume. These same lines of evidence support a finding that the discharge of
contaminated groundwater into surface water may currently be acceptable.
Groundwater geochemical parameters were reviewed and determined to be favorable for the
natural attenuation of Site constituents of concern. This determination was in turn supported by an
evaluation of groundwater contaminant trends over time. The evaluation provided solid evidence
that natural attenuation of the contaminant plume is occurring at the Site. Concentrations of total
VOCs in most monitoring wells decreased by greater than 90 percent in comparison to their
maximum concentrations. A Mann -Kendall analysis indicates that eight monitoring wells are
characterized by "decreasing" contaminant trends; one monitoring well is characterized by a
"probably decreasing" contaminant trend; and two monitoring wells (MW-7A and GM-6) are
characterized as "no trend." Volatile organic compounds are only measured at concentrations
06/03/19 Page 8

exceeding regulatory standards in five of eleven wells during the October 2018 monitoring event,
including FPC-MW-03, FPC-MW-07A, MW-2A, GM-1, and GM-5.
Furthermore, the former Haas Spring has been sampled on an annual basis beginning in 2001. No
constituents of concern were measured at a concentration exceeding the 2L Groundwater Standard
since 2003 which is characteristically more stringent than the 2B Surface Water Standard.
Table 2 tabulates analytical results for the former Haas Spring. Note that vinyl chloride is not
included in the tabulation. Table 2 only lists those compounds detected in at least one sample
during the monitoring period. The laboratory reporting limit for vinyl chloride (5 ug/L) indicated only
that this compound was not measured (i.e., it was not detected at a concentration exceeding the
laboratory reporting limit). Future analyses performed for vinyl chloride as part of an approved final
remedy will be completed with a method detection limit of 1 ug/L which is less than the current 2B
Surface Water Standard of 2.4 ug/L.
References
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
4 Note, because areas of inflowing groundwater can be critical habitats (e.g., nurseries or thermal refugia)
for many species, appropriate specialist (e.g., ecologist) should be included in management decisions that
could eliminate these areas by significantly altering or reversing groundwater flow pathways near surface
water bodies.
5 The understanding of the impacts of contaminated groundwater discharges into surface water bodies is a rapidly
developing field and reviewers are encouraged to look to the latest guidance for the appropriate methods and scale
of demonstration to be reasonably certain that discharges are not causing currently unacceptable impacts to the
surface waters, sediments or eco-systems.
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (EI) RCRIS code (CA750)
7. Will groundwater monitoring / measurement data (and surface water/sediment/ecological
data, as necessary) be collected in the future to verify that contaminated groundwater has
remained within the horizontal (or vertical, as necessary) dimensions of the "existing area
of contaminated groundwater?"
X If yes - continue after providing or citing documentation for planned activities or future
sampling/measurement events. Specifically identify the well/measurement locations
which will be tested in the future to verify the expectation (identified in #3) that
groundwater contamination will not be migrating horizontally (or vertically, as necessary)
beyond the "existing area of groundwater contamination."
If no - enter "NO" status code in #8.
If unknown - enter "IN" status code in #8.
Rationale and Reference(s):
Routine groundwater monitoring has been conducted at the site since 2001. Groundwater
monitoring will continue until such time that the final remedy is approved. If the final remedy
proposed in the Corrective Measures Study — Revision 2 is approved, an effective monitoring
program will be implemented in accordance with the schedule presented in Table 2.
References
Hart and Hickman, Corrective Measures Study— Revision 2, June 29, 2018.
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Migration of Contaminated Groundwater Under Control
Environmental Indicator (EI) RCRIS code (CA750)
8. Check the appropriate RCRIS status codes for the Migration of Contaminated Groundwater
Under Control EI (event code CA750), and obtain Supervisor (or appropriate Manager)
signature and date on the EI determination below (attach appropriate supporting
documentation as well as a map of the facility).
_X_ YE - Yes, "Migration of Contaminated Groundwater Under Control" has been
verified. Based on a review of the information contained in this EI determination,
it has been determined that the "Migration of Contaminated Groundwater" is
"Under Control" at the former CSI facility, EPA ID # 086 871 282 located at
1200 Dragstrip Road in Hudson, Caldwell County, North Carolina. Specifically,
this determination indicates that the migration of "contaminated" groundwater is
under control, and that monitoring will be conducted to confirm that contaminated
groundwater remains within the "existing area of contaminated groundwater"
This determination will be re-evaluated when the Agency becomes aware of
significant changes at the facility.
NO - Unacceptable migration of contaminated groundwater is observed or expected.
Completed by
Supervisor
title Branch Head
EPA Region or State State of North Carolina
Locations where References may be found:
Date
Date
r
h1ts://de .nc. govlaboutldivisionslwaste-mana jementlwaste-mana ement-rules-datale-documents
Contact telephone number and e-mail:
(name) Mary Siedlecki
(phone #) 919-707-8208
(e-mail). man.siedlecki;a ncdenr.vov
06/03/19 Page 11

LEGEND
SITE PROPERTY BOUNDARY
ADJACENT PARCEL BOUNDARY
INTERMITTENT STREAM
SOURCE AREA
TREELINE
MONITORING WELL LOCATION
�,00*(
n u(
APPROXIMATE
0 400 80D
SCALE IN FEET
,mF
SITE LAYOUT
PROJECT FORMER CSI FACILITY
1200 DRAG STRIP ROAD
HUDSON, NORTH CAROLINA
2923 South Tryon Street -Suite 100
hart Na- hickman
fart Charlotte, North Carolina 28203
w 704-586-0007(p) 704-586-0373(o
SMARTER .NVWAX*AEWM SOU)TKM License # C-1269 / #C-245 Geology
DATE: 11-21-17
1 REVISION NO. 0

NORTHERN INACTIVE
I LANDFILL CELL f
c 1t •�_Jr'f �
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IN-3
rG
-p
f
GM-5
SOUTHERN INACTIVE i
LANDFILL CELL /
Ile
OFPC-Mw-c6
`k —
1
LEGEND
SITE PROPERTY BOUNDARY
ADJACENT PARCEL BOUNDARY
INTERMITTENT STREAM
— CHAINLINK FENCE
TREELINE
------- 4500TOPOGRAPHIC CONTOUR
ELEVATION (FT MSL)
MONITORING WELL LOCATION
Ir
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rfP1 .,, fi
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8
APPROXIMATE
0 400 _ 800
SCALE IN FEET
�r SITE TOPOGRAPHY
PROJECT FORMER CSI FACILITY
1200 DRAG STRIP ROAD
HUDSON, NORTH CAROLINA
2923 South Tryon Street -Suite 100
hart hiekman
Charlotte, North Carolina 28203
�
704-586-0007(p) 704-586-0373(f)
SMARTEN ENVROWENfAL SOl.U7KM License # C-1269 / #C-245 Geology
DATE: 11-6-17
REVISION NO.0

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a
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x LEGEND
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SURFACE WATER SAMPLE
LOCATION
t , SEEP SAMPLE LOCATION
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0 800 1600
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PROJECT FORMER CSI LANDFILL
1200 DRAG STRIP ROAD
HUDSON, NORTH CAROLINA
v 2923 South Tryon Street -Suite 100
hart 'ti hickman Charlotte, North Carolina 28203
704586-0007(p) 704586-0373(o
SMARTER "WIRONMENT/LL SOLUTWN5 License # C-1269 / #C-245 Geology
DATE: 3-20-18
1 REVISION NO.0

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Table# 9,
Corrective Measures Monitoring Schedule
Former CSI Facility
Hudson, Caldwell County, North Carolina
H&H Job No. CAL-004
Well ID
Parameters
2018
(Annual)
2019
(Semiannual)
2020
(Biennial)
2022
(Biennial)
2025 4
(3-year)
FPC-MW-01 s
VOCs, FP
X
FPC-MW-03
VOCs, FP
X
X
X
X
FPC-MW-07 4
VOCs, FP
X
FPC-MW-07A
VOCs, FP
X
X
X
X
MW-2
VOCs, FP
X
X
X
X
MW-2A
VOCs, FP
X
X
X
X
MW-3
VOCs, FP
X
X
X
X
MW-3A '
VOCs, FP
X
MW-C
VOCs, FP
X
GM-1
VOCs, FP
X
X
X
X
GM-5
VOCs, FP
X
X
X
X
GM-6 1
VOCs, FP
X
Haas Spring 3
VOCs, FP
X
X
Alan Tolbert S rin 3
VOCs
X
X
Kevin Tolbert Spring 3
VOCs
X
X
Leonard Tolbert Spring 3
VOCs
X
X
Ray Austin S rin 3
VOCs
X
X
Ray Austin Well
VOCs
X
X
Martha McLean Well 3
VOCs
X
X
Truett Haas Well 3
VOCs
X
X
Clearview Church Well 3
VOCs
X
X
SW-3 3
VOCs
X
X
SW-5 3
VOCs
X
X
Notes:
1) Monitoring wells MW-3A, MW-C, GM-6 to be removed from monitoring program if no compounds are detected
above 2L Standards during 2018 annual monitoring event.
2) If the 2018 sample from FPC-MW-01 has no constituents above 2L standards, future sampling may be
discontinued with approval of DEQ.
3) Potable wells and springs, and surface water samples SW-3 and SW-5 to be removed from monitoring program
if no compounds are detected above applicable standards during 2018 annual and 2019 semiannual monitoring
event.
4) Monitoring well FPC-MW-07 has not been located since 2009. If it is not located in
2018, it will be removed from future monitoring events.
5) After 2025, monitoring will be conducted every three years.
VOCs = Volatile Organic Compound (including 1,4-dioxane)
FP = Field Parameters (DO, temperature, conductivity, pH, oxidation-reduction potential)
- Monitoring wells will be removed from sampling program if no compounds are above
2L Standards or risk -based remediation goals for 3 consecutive events
C:1UsersUmoretzU7esktoplCaldwell CountylCaldwell County CMS Tables.xlsx
Table 7 (Page 1 of 1)
6r.2/2018 Hart & Hickman, PC