4406_ROSCANS_1995

State of North Carolina 'T
Department of Environment, LTRMAI
Health and Natural Resources A&410
Division of Solid Waste Management
James B. Hunt, Jr., Governor c F1
Jonathan B. Howes, Secretory C
William L. Meyer, Director
November 15, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. James A. Giaugue
Process Engineer
Champion International Corporat:
P.O. Box C-10
Canton, N.C. 28716
Re: Issues Discussed During Conference Calls on October 23, 25 and November 14, 1995,
Concerning the Landfill Number 6 Water Quality Assessment Plan Submitted by Roy F.
Weston, Inc.(Permit #44-06).
Dear Mr. Giaugue,
The following are comments and questions which were generated by the Solid Waste
Section (Section) during the review of volumes I and II of the Interim Report, Preliminary Data
Review For Landfill Number 6 and volumes I, II and III of the Groundwater and Surface Water
Assessment For Landfill #6 report submitted to this office by Roy F. Weston, Inc. (Weston).
Following each question are the responses provided by you and Mr. Derric Brown, also of
Champion International Corporation (Champion) or Mr. Bill Morris of Roy F. Weston, Inc.
during teleconference discussions on October 25, 26 and November 14.
Comments and questions on the Interim Report, Preliminary Data Review For Landfill
Number 6:
Volume I
1) Page 2-1, section 2.1, first paragraph; the Solid Waste Permit Number for Landfill
Number 6 is 44-06.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX 919-71&3605
An Equal Opportunity Affirmative Action Employer 60% recycled/ 10% post -consumer paper

Response: This was a typographic error which was transcribed from earlier permitting
documents.
2) Pages 2-8 and 2-9; are there any data (soil type, characteristics, permeability, etc.) on the
"native soils" utilized in the bottom liners of the cells where few or no exploratory
borings were performed? Are the bottom elevations of these cells known? This
information may be useful in predicting contaminant flow velocities, fate and transport,
especially in those cells without leachate collection systems (F,G,H).
Response: If this information exists, it has not been found. If this information is discovered
at a later date it will be incorporated into the evaluation of the cell's construction.
3) There appears to be the following discrepancies when comparing Table 2-3, Table 1 in
Appendix B, (and in Volume I, page 2-15 and table 2-1) the boring logs and the well
construction records:
a) The values given for total depth (in feet) below top of casing (BTOC) for MW-1,
MW-lA, MW-2, MW-3A, MW-4, MW-5, MW-5A, MW-12, MW-14, MW-15
actually appear to be from ground surface. In addition, were the values given for
depth to water (in feet) below top of casing (BTOC) on November 8, 1994
calculated from ground surface (see Table 2-3)?
b) Several of the monitoring wells are recorded as being screened in bedrock but the
available boring logs indicate auger refusal in the partially weathered rock zone.
Are any of the present monitoring wells screened in bedrock? If so, how were
they installed (i.e. cored, air drilled, etc.)?
Response: Corrected tables are completed and will be provided for insertion into the
Groundwater and Surface Water Assessment for Landfill Number 6 work plan
dated March, 1995.
4) It is noted that MW-4 and MW-6 are located strategically down gradient from waste cells
but are not constructed according to the standards set forth in the N. C.A. C., Title 15A,
Subchapter 2C, Section. 0100, Well Construction Standards and/or the North Carolina
Water Quality Monitoring Guidance Document For Solid Waste Facilities. Water
quality data from these sample locations could be affected by the monitoring well
construction deficiencies. MW-8, MW-9 and MW-10 also have construction deficiencies
but at this time it is considered that these wells are not being impacted by the facility.
5) Page 2-11, second paragraph; referring to the well construction log for MW-2, the
bentonite seal appears to be located properly. The Section concurs with Weston's
evaluation of the bentonite seal in MW-6.
Response: This change will be made in the Groundwater and Surface Water Assessment
for Landfill Number 6 work plan dated March, 1995.
6) Page 2-13, section 2.4, first paragraph; did TCLP testing begin in June, 1993 (according

to the narrative) or July, 1988 (according to summary chart on page 2-14)? Did testing
on waste occur from June, 1983 to July, 1988?
Response: TCLP testing began in July 1988. No testing occurred on the Landfill #6 waste
stream between June, 1983 through July, 1988. The correct date will be inserted
in the narrative in the Groundwater and Surface Water Assessment for Landfill
Number 6 work plan dated March, 1995.
7) Appendix A, second page; clarification is needed on the sample substance "poly" and
"sludge"?
Response: "Poly" is a plastic coating for milk cartons. It is produced at the Canton Mill and
the waste poly is no longer landfilled but incinerated. "Sludge" is the solid
material from the Mill's waste water treatment operation. It consists of waste
lime, tree bark, soil, fiber, etcetera.
8) Appendix D; on what material was the used oil analysis performed and in which cell was
it placed?
Response: This material was not landfilled; it was recycled.
Volume II
1) Page F-1, section 2.0, first paragraph; the use of polyethylene bailers to purge and sample
is not permitted. Either Teflon and stainless steel bailers should be used for sampling
and purging.
Response: Polyethylene bailers will not be used to purge monitoring wells or to collect
samples. This change will be made throughout the Groundwater and Surface
Water Assessment for Landfill Number 6 work plan dated March, 1995.
Comments and questions on the Groundwater and Surface Water Assessment for Landfill
Number 6:
Volume I
1) The Section recommends that the "seep" mentioned on page 2-20, third paragraph, be
evaluated for a possible surface water sampling location.
Response: The "seep" is just a wet area near the toe of the slope. Running or pooling water

has never been observed at this location. In an effort to reduce the amount of
infiltration and subsequent development of "seeps", standing water on the top of
this active cell is pumped off after precipitation events.
2) Are records available on the amount of leachate generated throughout the life of each of
the cells with leachate collection systems? If so, can this data be used to predict the
amount of leachate generated by the cells without leachate collection systems?
Response: That information is not available at the present time. If the information becomes
available at a later date it will be utilized in the assessment.
3) Page 7-1, the first recommendation; the Section needs further details on the proposed
"two temporary groundwater monitoring points" before granting approval. In addition, a
more precise location is required before installing any of the proposed monitoring wells.
Response: The proposed "two temporary groundwater monitoring points" to be installed in
the eastern portion of Area B are to be screened across the water table. These
monitoring points will be constructed as monitoring wells and will not be
abandoned without prior approval from the Section. The proposed four wells
along the eastern property boundary, the one proposed between MW-4 and MW-
13, and the one proposed between MW-2 and NM-13 (total of six monitoring
wells) are to be screened in the first water producing zone in the bedrock.
Additional shallow wells will be nested at some of these locations (two along the
eastern property boundary and one each at the other two proposed monitoring
wells located adjacent to Bowen Branch) if the water table is encountered above
the top of bedrock. Additional topographic maps which include the proposed
monitoring well locations will be provided.
5) All future monitoring wells should be constructed according to the standards set forth in
the N. C.A. C., Title I5A, Subchapter 2C, Section. 0100, Well Construction Standards and
the North Carolina Water Quality Monitoring Guidance Document For Solid Waste
Facilities.
Volume II
1) In Table 7A the mercury results for the two sampling events are extraordinarily high
when compared to results from samples taken before and after 1994. Can an explanation
of these data be provided?
Response: An error was made in transferring the data from the laboratory reports to the
chart. The true values are near or below the N.C.A.C. 2L standard.
2) What and where are the coal pile wells and surface water sample results referred to in the
data package?

Response: The coal pile and the surrounding monitoring wells and surface water locations
are not associated with Landfill #6. They are located on the Canton Mill facility
proper.
Volume III
1) Page J.2-4, section J.2.7.1: what word was omitted from the first sentence?
Response: The sentence should read "Prior to the pumping test, pretest background water
levels will be monitored for 12 hours at the observation wells and the well to be
pumped." In addition, a well at the site that is considered to be out of the
influence of the pumping will also be monitored during the 12 hour pretest period
and during the entire time of the pumping test. This information will be used to
establish a baseline for correction of drawdown data to account for the pre -
pumping trend.
2) Page J.2-5, fourth bullet point; the collection, effects and inclusion of these data
(atmospheric pressure and precipitation during test) in the assessment report are required.
Response: This information will be provided.
3) Page J.2-4 through J.2-7; what are the expected time intervals that water level readings
will be taken during the step drawdown, pumping and recovery tests? Measurements in
the observation wells should occur often enough after testing begins to avoid missing the
initial drawdown and recovery data.
Response: Automated dataloggers will be used to collect drawdown and recovery data from
each of the observation wells and the pumping well. The dataloggers will be
programmed to begin recording just before the initiation of the pump.
Compressed reading times during the initial drawdown and recovery of the
observation wells will be appropriately designed to insure collection of data that
will accurately define the drawdown curves.
4) Describe the "on -site drinking water sources" and their location(s) mentioned on page
J.4-2.
Response: The only private water supply well on the site is in the northwestern area of the
property adjacent to a home. This area is not expected to be impacted by the
landfilling activity at this time. City water hauled from the Mill will be used
instead of the previously designated "on -site drinking water sources".
5) Attachment B, Laboratory QA/QC Program; the Section requires water quality sample
analysis by a laboratory certified by the Division of Environmental Management for
groundwater analysis (15A NCAC 211.0800). The laboratories used for water analysis

for solid waste management facilities shall be certified under the Division of
Environmental Management Certification program for the approved methods and at the
approved levels of certification. Data from laboratories that do not have the appropriate
certification or did not use specified test methods will be deemed unacceptable.
Field and laboratory personnel should be informed that unfiltered water samples are
required by the Section. Filtered samples may be collected for comparison purposes but
that is in addition to unfiltered samples.
Based on the conversation that took place during our November 14 teleconference it is
the Section's understanding that corrected pages which reflect the necessary changes will be
distributed for insertion into volumes I, II and III of the Groundwater and Surface Water
Assessment For Landfill #6 report. In the future two copies of progress reports and/or additional
assessment phase plans will be sufficient.
Concurrence with this letter serves as plan approval and implementation of assessment
activities can begin immediately. If you have any questions about this letter, please contact me
at [phone], extension 261.
Sincerely,
Mark Poindexter, Hydrogeologist
Groundwater Compliance Unit, Solid Waste
Section
c: Phil Prete
Jvi% Patterson
Central file
Filenarne: 44-06N2.ast

CHRhgPIOPd Eo H:S
IE,:704-646-6892 AUG 04'95 17:38 No-Ci11 P-01
FAX COVER SHEET
ENVIRONMENTAL, OCCUPATIONAL,
HEALTH- AND SAFETY.
CHAMPION INTERNATIONAL CORP.
CANTON MILL
FROM: 1p" &r .t f{ 4-1
DATE: flgl.5 TIME:r
NLIM13ER QF PAGES:
(INCLUDING CAPER)
NOTE: r
4
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SENDERS PHONE NUMBEW (704) 646-
FAX NUMBER:(704) 646-092
S BTUD
EAX PROBLEIYIS:

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
LAND QUALITY SECTION: Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801(704) 251-6208
County Hd� °'�� Project: C 1 ., i on 1 �3 n 11 G �,e / Case #
Project Location_ Ow —I L v"/ 22"Id
Person(s) Financially Responsible I a
99
1. Pictures: Yes ❑ No� Number Prints ❑ Slides ❑ Video ❑
2. Weather & soil conditions
3. Is site currently under Notice of Violation ? Yes ❑ No Er
4. Is the site in compliance with the S.P.C.A. and Rules ? Yes❑ No Er If no check violations below.
5. Violations:
❑ a. No approved plan, G. S. 113A-57 (4) and 15A N.C.A.C. 4B.0007(c) ❑ f. Failure to take all reasonable measures, 15A N.C.A.C.413.0005
❑ b. Failure to follow approved plan, G.S. 113A-61.1
❑ c. Failure to submit revised plan, G.S. i13A-54.1(b) and
15A N.C.A.C. 4B.0018(a)
1 d. Failure to provide adequate groundcover, G.S. 113A-57(3) and
15A N.C.A.C. 4B.0007 (b) or 15A N.C.A.C. 413.0024 (e)
❑ e. Insufficient measures to retain sediment on site, G.S. I I3A-57(3)
❑ g. Inadequate buffer zone, G.S. 113A-57(1)
❑ h. Graded slopes and fills too steep, G.S. 113A-57(2) or 15A
N.C.A.C. 4B.0024 (d)
❑ i. Unprotected exposed slopes, G.S. 113A-57(2)
❑ j Failure to maintain erosion control measures,
15A N.C.A.C.4B.0013
❑ k.Other (describe)
6. Has off -site sedimentation occurred since last inspection ? Yes ❑ No ErRemarks Yt-z�, eAr_J
Degree: Slight ❑ Moderate ❑ Severe ❑ Remarks
7. Contact made with (Name) Title (Name)
Inspection Report given to:
8. Copy of inspection report to be sent to person(s) responsible:ye
Other (Name) f2a. t e /✓s .1 99 j Date Sent 2 - 2, P 9S
9. Corrective actions needed: G s t a b 1r sh d aG 7. u e— a/ JV V yam„ CoriGy bh 1 11
Cl Z` � -b Ge h '0 � c,1.
10.Comments: S,tc Ad✓ f�ce.q J,G'c—)e.d -�ut d4 a4J4 1gu tcy¢ 4e�d�tye
� i0 G! h. ol G �s JP.� !y d,t' h �'� �e G h G� ✓' �� b'% � G> �1
v
Report by: Others present
Date of inspection 2 - 2 Y - 9,57 Time arriving on site / / .' 22 A .11 Time leaving site _ / /, / ,S A A

MEETING AGENDA
DATE: November 29, 1994
TIME: 9:00 am to 10:00 am
PARTICIPANTS: Jim Patterson, Derric Brown, Jim Giauque
MEETING OBJECTIVES: Develop a common understanding of issues
associated with the Canton Mill Landfill
Number 6.
1. Administrative Agreement on Consent/Site investigation
status.
2. Area A East - operational study.
3. Areas B, C, And H - operational status.

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
..r qq `` tt � (�
Type of Facility '' i vl I,t AVM A � ` : t Permit # ko County. ° ayi" CI L� O. C t
fN !`
Name of Facility °4 ? 1 � ,� Vti Location i� :� �' i41 h,
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
II_ Operational Requirements Followed Yes No
15A N.C_ Admin. Code 138 Section '' J
A. Specific Violation(s) by number and letter.
III. other Violations of Rule or Law
IV. Evaluator's Comments !n r•A f v hir°•aft:-tj I tb V ( tt. S ?c-arc
V. Continuation Page Required? Yes pf No Receiving Signature
Evaluation Date '� 1 'r Solid Waste Sectiari
DEHNR 3793 (Part~I-White: Facility Part II Canary: Cent
Solid Waste Section (Review 7/94)
Office Part III Pink: Regional office)

Purpose: G.S. 130A-294 requires that an evaluation program be established for the
operation of solid waste management facilities on a statewide basis. The
Solid Waste Management Act and Solid Waste Management Rules codified at
15A NCAC 13B list requirements which must be followed by solid waste
facilities.
Instructions: Solid Waste Section personnel shall complete the evaluation form each
time they conduct official evaluations. The form shall be signed by
the person(s) receiving the report.
Distribution: but on: Part I tidzite: facility copy
Part II Canary: Raleigh central office file copy
Part III Pink: Regional office file copy
Disposition: This form may be retained in accordance with the Record Retention and
Disposition Schedule of the Solid Waste Section, Solid Waste Management
Division of the Department of Environment, Health and Natural Resources.

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid haste Section
SOL/ID WASTE MANAGEMENT FACILITY EVALUATION REPORT
Type of Facility Permit Cointy_%
Name of Facility C, Location � 2 5
Date of Last Evaluation
I. Permit Conditions Followed f Yes No N/A
A. Specific Condition(s) Violated
II. Operational Requirements Followed Yes No
15A N.C. Admin. Code 13B Section V C)
A. Specific Violation(s) by number and letter.
v
III. Other Violations of Rule or Law
IV. Evaluator's Comments
V. Continuation Page Required? Yes No Receiving Signatur,�/
Evaluation Date / �� ! ? Solid Waste Section K&
DENNR 3793 (Part I White: Facility Part II Canary: Central office
Solid Waste Section (Review 7/94)
�A
Part III Pink: Regional Office)

Purpose: G.S. 130A-294 requires that an evaluation program be established for the
oration of solid waste management facilities on a statewide basis. The
Solid Waste Management Act and Solid Waste Management Idles codified at
15A NCAC 13B list requirements which must be followed by solid waste
facilities.
Instnict;ons: Solid Waste Section personnel shall omplete the evaluation form each
time they conduct official evaluations. The form shall be signed by
the person(s) receiving the report.
rwhite: copy
Part II Canary: .h central office file ...
Part IEEI, ..
Disposition: This form may be retained in accordance with the Record Retention and
Disposition Schedule of the Solid Waste Section, Solid Waste Management
Division of the Department of Environment, health and Natural Resources.

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Kanagement
Solid Waste Section
SOLID WASTE MANAfEIENT FACILITY EVALUATION REPORT
Type of Fac i L i ty '`y Yt 2/17 Permit �3�"'79 County.
Name of Facility_( - ­10112 4,n' el k1 Location
Date of Last Evaluation
1. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
II. Operational Requirements Followed y, Yes No
15A N.C. Actin. Code 13B Section
A. Specific Violation(s) by nuiber and letter.
III. Other Violations of Rule or Law
IV. Evaluator's Comments
V. Continuation Page Required? Yes No Receiving Signature,• , �i_�.��dr' •, y
Evaluation Date Solid Waste Section
DEHNR 3793 (Part I White: Facility Part II Canary: Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/%)

Purpose: G.S. 130A-294 requires that an evaluation program be established for the
operation of solid waste management facilities on a statewide basis. The
Solid Waste Management Act and Solid Waste Management Rules codified at
15A NCAC 13B list requirements which must be followed by solid waste
facilities.
Instructions: Solid Waste Section personnel shall ccaplete the evaluation form each
time they conduct official evaluations. The form shall be signed by
the person(s) receiving the report.
Distribution: ' as•
Pdft IEE Canary: Raleigh central office file copy
Part III Pink: Regional office file copy
Disposition: This form nay be retained in accordance with the Record Retention and
Disposition Schedule of the Solid Waste Section, Solid Waste Management
Division of the Department of Environment, Health and Natural Resources.