P1226_Sept 2017 Bi Annual GW Sampling Report_20171012

S&ME, Inc. | 3201 Spring Forest Road | Raleigh, NC 27616 | p 919.872.2660 | www.smeinc.com
October 12, 2017
North Carolina Department of Environmental Quality
Division of Waste Management, Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699
Attention: Mr. Ed Mussler via email: [e-mail]
Reference: September 2017 Bi-Annual Groundwater Sampling Event
Owen Farm Borrow Pit Solid Waste Demonstration Project
Plymouth, North Carolina
S&ME Project No. 1040-01-537
Dear Mr. Mussler:
S&ME, Inc., on behalf of Geo-Specialty Chemicals (GSC), is submitting the September 2017 Bi-Annual Groundwater
Sampling Report as required under the conditions of the Solid Waste Demonstration Project which GSC is
performing with the North Carolina Department of Environmental Quality - Division of Waste Management.
The enclosed report presents analytical results of groundwater samples collected from the four monitor wells
located at the Owen Farm Borrow Pit in Plymouth, North Carolina. In accordance with a letter from the Division,
dated November 21, 2013, groundwater was sampled for the following constituents: sulfate, aluminum, specific
conductivity, temperature and pH. The reported concentrations of sulfate and aluminum were below the North
Carolina groundwater protection standards. Therefore, we respectfully request that DEQ allow GSC to discontinue
the bi-annual groundwater sampling at the Owen Farm Borrow Pit.
If you have any questions or require additional information, please contact our office at [phone].
Sincerely,
S&ME, Inc.
Josephine Martin Samuel P. Watts, P.G.
Project Scientist I Senior Project Manager
[e-mail] [e-mail]
Attachment: September 2017 Annual Groundwater Sampling Event, dated October 6, 2017
cc: Ms. Charita Redding (GSC)
Mr. Perry White (GSC)

S&ME, Inc. | 3201 Spring Forest Road | Raleigh, NC 27616 | p 919.872.2660 | www.smeinc.com
October 6, 2017
Geo-Specialty Chemicals
P.O. Box 68
Plymouth, NC 27962
Attention: Mr. Perry White via email: [e-mail]
Reference: SEPTEMBER 2017 BI-ANNUAL GROUNDWATER SAMPLING EVENT
Owen Farm Borrow Pit - Solid Waste Demonstration Project
Plymouth, North Carolina
S&ME Project No. 1040-01-537
Dear Mr. White:
S&ME, Inc. (S&ME) is pleased to provide you with the September 2017 sampling report as required under the
conditions of the Solid Waste Demonstration Project which Geo-Specialty Chemicals (GSC) is performing with the
North Carolina Department of Environmental Quality - Division of Waste Management (NCDEQ-DWM). This
report presents analytical results of groundwater samples collected from selected monitor wells located at the
Owen Farm Borrow Pit in Plymouth, North Carolina (Figure 1).
 Project Background
In September 1994, GSC (as CYTEC Industries, Inc.) received approval from the DWM to use processed silica to
assist in the restoration of selected tracts of farm land to productive use. Specifically, approximately 48,000 cubic
yards of processed silica were used, over a period of two years, to fill a soil borrow pit to a compatible elevation
with adjacent fields. Operational conditions of the Solid Waste Demonstration Project included groundwater
monitoring at the site.
Since 1994, GSC has conducted groundwater monitoring at the site and submitted the sampling results to the
DWM on a semi-annual basis. After reviewing the recent and historical data from the groundwater monitoring,
S&ME concluded in its reports for the September 2007 and March 2008 sampling events that “… GSC has
demonstrated that restoration of land resources has been performed without an adverse release of constituents to
the environment that may pose a threat to public health and safety.” Accordingly, S&ME requested, on behalf of
GSC, that DWM consider termination of the Solid Waste Demonstration Project and semi-annual groundwater
monitoring at the site.
In a letter dated April 17, 2008, Mr. Brian Wootton of the DWM responded, in part, that based on the historical
detections of aluminum and sulfate in the groundwater samples and periodic detections of sulfate in excess of the
250 mg/l North Carolina 2L groundwater standard, the Solid Waste Section will allow the groundwater sampling
schedule to be reduced from semi-annual to annual (in September). In September 2010, S&ME conducted the
third of the three annual September groundwater sampling events and submitted the results to DWM. In a letter
dated January 3, 2011, Mr. Wootton responded that the DWM, Solid Waste Section reevaluated the groundwater
data and “requires that groundwater sampling continue on an annual basis (September, for the following

Owen Farm Borrow Pit - Solid Waste Demonstration Project October 6, 2017
Geo-Specialty Chemicals Page 2
S&ME, Inc.
constituents: Sulfate, Aluminum, Specific Conductivity, Temperature, and pH) since detections of Sulfate and
Aluminum have fluctuated and not leveled off…”
After the September 2013 annual sampling event, in a letter dated November 21, 2013 from Mr. Wootton, the
Solid Waste Section approved reducing the groundwater sampling schedule from annually (September) to
biannually (every second year) in September. A copy of Mr. Wootton’s letter is attached for reference in Appendix
III.
 Groundwater Measurement and Sampling Activities
On September 11, 2017, S&ME personnel visited the referenced site to collect groundwater samples from the four
selected monitor wells (MW-1, MW-2, MW-3, and MW-4). Depth to groundwater was measured in each well prior
to sampling. Water level measurements were compared to the surveyed measuring points on the wells and
converted to relative groundwater elevations. These elevations were used to construct the attached groundwater
potentiometric map (see Figure 2). These results show that groundwater flow continues to flow toward the west,
in accordance with previous data. Water levels were higher than recent sampling events, likely reflecting higher
precipitation amounts.
Using bailers, the monitor wells were purged of three well volumes of water prior to collecting samples for
analysis. While purging the wells, specific conductivity, pH, and temperature were measured in the groundwater
collected from each well. These field data are summarized in Table 1. Groundwater samples designated for
laboratory analysis were then collected by dedicated bailers and placed in laboratory-supplied containers, stored
on ice, and transported under standard Chain-of-Custody protocol to ENCO Laboratories, located in Cary, North
Carolina.
 Laboratory Analytical Results
The samples were analyzed for total aluminum and sulfate using EPA Method 6010D and EPA Method 300.0,
respectively. Table 2 summarizes the laboratory analytical results for the September 2017 groundwater sampling
event. Sulfate concentrations reported for the samples collected ranged from 32.0 mg/L in MW-1 to 220.0 mg/L
in MW-4. Total aluminum concentrations in the samples ranged from 1.42 mg/L in well MW-1 to 2.66 mg/L in
well MW-4. A copy of the laboratory analytical results is included as an attachment in Appendix IV.
 Discussion of Results
Conditions of the Solid Waste Demonstration Project which GSC is performing with the DWM do not establish
performance criteria, or water quality standards for the Owen Farm Borrow Pit project, and it is unclear what (if
any) regulatory criteria should be applied to the project. Regulations pertaining to the classifications and water
quality standards applicable to groundwater of North Carolina are located in Title 15A of the North Carolina
Administrative Code, Subchapter 2L (15A NCAC 2L). The 2L Standard for sulfate is 250 mg/L. There is no 2L
Standard for aluminum promulgated in this Rule (last amended on April 1, 2013). However, Section .0200,
Paragraph (d) of this Rule provides a method to calculate groundwater protection standards for a substance for
which a 2L Standard has not been established under the rules. The calculated groundwater protection standard for
aluminum is 3.5 mg/L. It should be noted this is a general calculation (not a site-specific) of the groundwater
protection standard for aluminum, and 15A NCAC 02L .0202, Paragraph (d), section (3) allows alternative
methodology for the derivation of the groundwater protection standards “Where naturally occurring substances
exceed the established standard, the standard shall be the naturally occurring concentration as determined by the
Director [of the Division of Environmental Management].” Because aluminum is a naturally occurring substance in

Owen Farm Borrow Pit - Solid Waste Demonstration Project October 6, 2017
Geo-Specialty Chemicals Page 3
S&ME, Inc.
groundwater, it may be possible to establish an alternative, site-specific groundwater protection standard for to
aluminum concentrations in groundwater.
Table 3 summarizes the historical analytical data from previous and current sampling events for comparison. In
comparing the September 2017 sampling event data with the results of the previous sampling event of September
2015, the following trends can be seen:
 Aluminum concentrations in groundwater stayed about the same, in all four monitor wells;
 Sulfate concentrations in groundwater decreased in one monitor well (MW-3), and increased slightly in
the other three monitor wells (MW-1, MW-2 and MW-4).
Figures 3 and 4 are also presented for evaluation of historical trends in the laboratory analytical results for
aluminum and sulfate concentrations, respectively. As shown on Figure 3, aluminum concentrations appear
variable in all four wells from October 1994 through March 1998. After that date, aluminum levels remained
consistently low, with most results being at or below 5 mg/L through March 2001. The aluminum results have
shown some fluctuation in recent years but with peaks at or below 20 mg/L. During this most recent sampling
event, aluminum concentrations in groundwater samples, MW-1 and MW-4, have concentrations less that 5mg/L,
with MW-1 having less than 2 mg/L. MW-2 and MW-3 have a concentration of more than 5 mg/L. For the past
two sampling events (2015 and 2017), aluminum concentrations have been less than 3.5 mg/L in all four monitor
wells.
As shown on Figure 4, the sulfate results have been somewhat more variable, with levels being initially above 75
mg/L or less for several years. After mid-1999, sulfate levels in samples from wells MW-1 and MW-2 remain
approximately below 75 mg/L while the levels in MW-3 and MW-4 become more elevated and variable. Sulfate
levels in these two wells in March 2006 exceeded the sulfate 2L Groundwater Standard. Since that event, sulfate
levels have continued to fluctuate, but have remained below the 2L Standard of 250 mg/L for sulfate.
Figure 5 provides a historical record of the pH of groundwater from all four monitor wells. Groundwater pH
measured during the September 2017 sampling event increased slightly in all four monitor wells, relative to
measurements recorded during the September 2015 event. Overall, since 1995 there has been little variability in
pH levels recorded at the site, with a slightly higher pH in monitor well MW-2, relative to the other three wells.
Owen Farm Borrow Pit - Solid Waste Demonstration Project October 6, 2017
Geo-Specialty Chemicals Page 4
S&ME, Inc.
♦Closing
S&ME appreciates the opportunity to be of service to GSC. If you have any questions or require additional
information, please contact our office at [phone].
Sincerely,
S&ME, Inc.
Jo Martin Samuel P. Watts, P.G.
Project Scientist I Senior Project Manager
[e-mail]
Attachments
Attachment I – Tables
Attachment II – Figures
Attachment III – Correspondence
Attachment IV – Laboratory Analytical Report
cc: Ms. Charita Redding, (GSC)

Attachments

S&ME, Inc.

Attachment I – Tables

Monitor TOC Depth to Depth to Groundwater Specific
Well Elevation Water Bottom Elevation Temp Conductance
I.D.(feet)From TOC of Well (feet)(oC)pH (mS/cm)
(feet)(feet)
MW-1 39.41 5.29 20.05 34.12 21.6 4.10 282
MW-2 35.62 18.76 30.05 16.86 17.3 4.60 229
MW-3 24.61 9.90 19.20 14.71 19.1 4.20 220
MW-4 32.31 15.33 26.43 16.98 17.4 4.20 557
oC - degrees Celsius
mS/cm – microSiemens per centimeter
pH – standard units
MW-1 MW-2 MW-3 MW-4
(mg/L)(mg/L)(mg/L)(mg/L)
1.420 2.190 2.030 2.660
34.0 46.0 93.0 220.0
mg/L - milligrams per Liter
TABLE 1
FIELD MEASUREMENT DATA
September 11, 2017
OWEN BORROW PIT
(mg/L)
0.100
OWEN BORROW PIT
PLYMOUTH, NORTH CAROLINA
S&ME PROJECT NO. 1040-01-537
5 - 15
PLYMOUTH, NORTH CAROLINA
S&ME PROJECT NO. 1040-01-537
Analyte
Aluminum (Total)
Sulfate
TABLE 2
LABORATORY ANALYTICAL RESULTS
Quantitation Limits
September 11, 2017
T:\Projects\2001\ENV\01-537 Owen Farm Borrow Pit - Geospecialty Chemicals\Reports\2017 September\Sept_2017_Owen_HistData.xls
Monitor Analyte Oct-94 Mar-95 Jun-95 Sep-95 Dec-95 Apr-96 Nov-96 Mar-97 Sep-97 Mar-98 Sep-98 Apr-99 Oct-99 Mar-00 Sep-00 Jan-02 Mar-02 Sep-02 Mar-03 Sep-03 Mar-04 Sep-04 Mar-05 Oct-05 Mar-06 Sep-06 Mar-07 Sep-07 Mar-08 Sep-08 Sep-09 Sep-10 Sep-11 Sep-12 Sep-13 Sep-15 Sep-17
Well ID
Aluminum 62 3.8 1.7 2 2 3.17 6.88 0.260 2.34 1.53 1.80 1.37 1.48 1.46 1.36 3.24 2.16 2.03 3.92 1.61 2.25 1.18 1.23 1.3 1.28 1.43 7.16 9.45 1.48 1.4 1.59 5.91 1.64 1.87 1.43 0.92 1.42
MW-1 Sulfate 76 77 88 56 81 63.3 56.2 46.8 45.9 53 49.7 47.7 46.7 55.4 41 75 59 53 69 52 59.2 52.6 51.7 62 112 52.0 47 47.2 56.4 70 56.6 54.5 54.2 49.1 40.0 32.0 34.0
pH 3.9 4.4 4.4 4.1 4.0 4.5 4.4 4.8 4.2 3.9 4.4 4.7 4.0 4.3 3.8 4.2 5.3 5.6 6.4 4.8 5.8 4.8 4.4 4.9 4.8 4.2 4.43 3.9 3.8 3.72 4.20 3.98 4.04 4.40 4.08 3.90 4.10
Aluminum 18 4.6 2 11 15 4.14 4.85 0.113 4.35 0.450 0.352 0.270 0.794 0.329 0.399 0.147 0.402 0.595 6.28 4.07 1.51 2.39 <0.20 1.50 2.41 3.56 2.53 2.32 0.74 <0.10 3.6 0.441 1.05 4.77 6.22 2.5 2.19
MW-2 Sulfate 23 32 31 25 24 28.8 23.0 17.3 24.7 33 28.9 30.9 34.8 27.9 26.8 44 29 39.5 43 25 30.7 29.3 24.4 36.6 29.1 38 33 44.5 35.6 49 36.8 46.5 35.1 37 36 37 46
pH 4.7 4.6 4.6 4.9 5.0 4.9 4.8 5.9 4.7 5.3 4.7 5.0 5.7 4.8 4.2 4.6 5.1 6.0 6.0 5.2 6.4 5.6 4.3 8.9 5.3 4.6 5.04 4.6 5.2 4.31 4.28 4.72 4.75 5.10 4.32 4.30 4.60
Aluminum 6.3 4.4 1.9 24 24 3.78 7.82 0.106 5.67 0.482 0.935 0.508 0.634 1.21 0.648 1.95 1.62 1.85 7.37 2.46 11.5 5.27 3.38 4.78 2.5 9.06 3.74 7.4 8.2 1.55 4.15 4.93 0.372 4.21 5.69 2.77 2.00
MW-3 Sulfate 25 26 21 21 27 26.7 23.4 34.3 48.8 36 61.5 63.3 25.4 137.5 35 150 110 145 25 12 235 134 242 63.5 332 83 200 105 75.7 185 97.7 182 5 97.8 97 200 93
pH 4.3 5.5 5.5 4.2 5.0 5.1 4.6 5.3 4.5 4.7 4.6 4.7 4.6 4.3 4.1 4.6 3.3 5.0 6.7 4.6 7.0 4.4 3.9 7.5 4.6 4.2 4.47 4.0 4 3.68 3.07 4.09 4.42 4.54 3.92 3.80 4.20
Aluminum 24 9.2 3.3 17 60 6.33 2.93 BQL 14.7 0.746 1.19 0.501 0.889 1.46 0.607 1.03 2.25 2.19 8.17 4 3.56 1.38 2.6 2.33 2.79 3.36 3.69 18.2 1.73 1.56 2.77 2.20 2.83 5.90 4.56 2.98 2.66
MW-4 Sulfate 64 63 95 68 73 55.5 60.4 16.6 49.1 50 61.2 53.7 50.5 241 49 80 63 79 69 59 244 161 97.8 183 430 95.0 234 113 81.6 84 76 187 77 79 90 210 220
pH 4.4 4.3 4.3 4.4 5.0 4.5 4.4 4.7 4.6 4.7 4.6 4.5 4.3 4.2 3.9 5.4 4.6 5.4 6.2 4.4 5.8 4.5 4.2 6.0 4.6 4.2 4.30 4.1 3.8 3.94 2.92 4.13 4.24 4.17 3.79 3.80 4.20
Aluminum and Sulfate concentration values are reported in mg/L units.
pH values are reported in standard units.
NA = Not Analyzed
TABLE 3
HISTORICAL SUMMARY OF GROUNDWATER QUALITY DATA
OWEN FARM BORROW PIT
PLYMOUTH, NORTH CAROLINA
S&ME PROJECT NO. 1040-01-537
T:\Projects\2001\ENV\01-537 Owen Farm Borrow Pit - Geospecialty Chemicals\Reports\2017 September\Sept_2017_Owen_HistData.xls

S&ME, Inc.

Attachment II – Figures

MW-1MW-4MW-3MW-2DIRT ROADSR 1
1
0
0
LON
G

R
I
D
G
E

R
O
A
D
SR 1106APPROXIMATE LIMITS OFMONITOR WELLGROUNDWATER ELEVATION (FT.)GROUNDWATER FLOW DIRECTIONMW-2(34.12)LEGEND(34.12)POTENTIOMETRIC SURFACE20(DASHED WHERE INFERRED)(14.71)(16.98)(16.86)±3.6 ACRESWASTE DISPOSAL AREA20
30
1618222426
28
32
20
30
16182224
26
28
32
FIGURE NO.Drawing path: \\RALNC\Active\Projects\2001\ENV\01-537 Owen Farm Borrow Pit - Geospecialty Chemicals\CAD\B2532.dwg
PROJECT NUMBERDATE:SCALE:OWEN FARM BORROW PIT
GEO-SPECIALTY CHEMICAL
PLYMOUTH, NORTH CAROLINA29-26-17POTENTIOMETRIC MAP SEPTEMBER 2017
1" = 60'1040-01-537N060120 (IN FEET)GRAPHIC SCALE (IN FEET)GRAPHIC SCALE
0
10
20
30
40
50
60
70
Oct-94Feb-95Jun-95Oct-95Feb-96Jun-96Oct-96Feb-97Jun-97Oct-97Feb-98Jun-98Oct-98Feb-99Jun-99Oct-99Feb-00Jun-00Oct-00Feb-01Jun-01Oct-01Feb-02Jun-02Oct-02Feb-03Jun-03Oct-03Feb-04Jun-04Oct-04Feb-05Jun-05Oct-05Feb-06Jun-06Oct-06Feb-07Jun-07Oct-07Feb-08Jun-08Oct-08Feb-09Jun-09Oct-09Feb-10Jun-10Oct-10Feb-11Jun-11Oct-11Feb-12Jun-12Oct-12Feb-13Jun-13Oct-13Feb-14Jun-14Oct-14Feb-15Jun-15Oct-15Feb-16Jun-16Oct-16Feb-17Jun-17Concentration (mg/L)Date
Figure 3
Total Aluminum Concentration in mg/L vs Time
MW-1 MW-2 MW-3 MW-4
Owen Farm Borrow Pit
S&ME Project 1040-01-537
0
50
100
150
200
250
300
350
400
450
500
Oct-94Feb-95Jun-95Oct-95Feb-96Jun-96Oct-96Feb-97Jun-97Oct-97Feb-98Jun-98Oct-98Feb-99Jun-99Oct-99Feb-00Jun-00Oct-00Feb-01Jun-01Oct-01Feb-02Jun-02Oct-02Feb-03Jun-03Oct-03Feb-04Jun-04Oct-04Feb-05Jun-05Oct-05Feb-06Jun-06Oct-06Feb-07Jun-07Oct-07Feb-08Jun-08Oct-08Feb-09Jun-09Oct-09Feb-10Jun-10Oct-10Feb-11Jun-11Oct-11Feb-12Jun-12Oct-12Feb-13Jun-13Oct-13Feb-14Jun-14Oct-14Feb-15Jun-15Oct-15Feb-16Jun-16Oct-16Feb-17Jun-17Concentration (mg/L)Date
Figure 4
Sulfate Concentration in mg/L vs Time
MW-1 MW-2 MW-3 MW-4 Owen Farm Borrow Pit
S&ME Project 1040-01-537
0
1
2
3
4
5
6
7
8
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Oct-94Feb-95Jun-95Oct-95Feb-96Jun-96Oct-96Feb-97Jun-97Oct-97Feb-98Jun-98Oct-98Feb-99Jun-99Oct-99Feb-00Jun-00Oct-00Feb-01Jun-01Oct-01Feb-02Jun-02Oct-02Feb-03Jun-03Oct-03Feb-04Jun-04Oct-04Feb-05Jun-05Oct-05Feb-06Jun-06Oct-06Feb-07Jun-07Oct-07Feb-08Jun-08Oct-08Feb-09Jun-09Oct-09Feb-10Jun-10Oct-10Feb-11Jun-11Oct-11Feb-12Jun-12Oct-12Feb-13Jun-13Oct-13Feb-14Jun-14Oct-14Feb-15Jun-15Oct-15Feb-16Jun-16Oct-16Feb-17Jun-17pHDate
Figure 5
pH vs Time
MW-1 MW-2 MW-3 MW-4 Owen Farm Borrow Pit
S&ME Project 1040-01-537

S&ME, Inc.

Attachment III – Correspondence

DWM Letter, November 21, 2013

North Carolina Department of Environment and Natural Resources Division of Waste Management Pat McCrory Dexter R. Matthews John E. Skvarla, III Governor Director Secretary
1646 Mail Service Center, Raleigh, North Carolina 27699-1646 Phone: [phone] Internet: http://portal.ncdenr.org/web/wm/sw An Equal Opportunity \ Affirmative Action Employer
SOLID WASTE SECTION
November 21, 2013
Sent Via Email – [e-mail]
Mr. Perry White,
Geo-Specialty Chemicals PO Box 68
Plymouth NC 27962
RE: Owen Borrow Pit – Solid Waste Demonstration Project Water Quality Monitoring Requirements –
Plymouth, NC Washington County
Dear Mr. White:
The Solid Waste Section received on November 7, 2013, the September 2013 Annual Groundwater Sampling Report
by S&ME, Inc., on behalf of Geo-Specialty Chemicals (GSC) regarding the Owen Farm Borrow Pit – Solid Waste Demonstration Project located in Plymouth, North Carolina.
Based on historical and recent groundwater data submitted, the Solid Waste Section will allow the groundwater
sampling schedule be reduced from annually (September) to biannually (every second year) in September for the same constituents; Sulfate, Aluminum, Specific Conductivity, Temperature, and pH. The Solid Waste Section will
also allow an Alternate Source Demonstration (ASD) be presented to the Solid Waste Section that is based on groundwater data obtained from the existing groundwater monitoring wells and additional temporary groundwater
monitoring wells located further away from the former borrow pit. If groundwater data results from these wells conclude that the constituents; Aluminum and Sulfate are naturally occurring, then groundwater monitoring
sampling requirements maybe possibly reduced further or ceased entirely.
If you have any questions or concerns regarding this letter, please feel free to contact me at (919) -707-8258 or by e-mail at [e-mail].
Sincerely,
Brian Wootton Hydrogeologist
Solid Waste Section
cc: sent via email to Mr. Samuel P. Watts, P.G. - S&ME, Inc.
Ms. Charita Redding - Manager of Safety & Environmental Affairs, Geo-Specialty Chemicals (GCS)
Mr. Ed Mussler - Solid Waste Section Mr. Ervin Lane - Solid Waste Section

S&ME, Inc.

Attachment IV – Laboratory Analytical Report