7407_CandDLandfillInc_20160317_SourceDemonWorkPlan_DIN25789

SCS Engineers, P.C. Environmental Consultants 2520 Whitehall Park Drive 704 504-3107 and Contractors Suite 450 FAX [phone] Charlotte, NC 28273-3557 www.scsengineers.com

Offices Nationwide
March 17, 2016
File No. 022114708.00

Ms. Jackie Drummond
NC Division of Waste Management Solid Waste Section
Mail Service Center 1646
Raleigh, NC 27699-1646

RE: Source Demonstration Work Plan Ground Water Assessment – Phase 1
C&D Landfill, Inc. (Pitt County, NC)
NC Solid Waste Permit #74-07

Dear Ms. Drummond:
On behalf of C&D Landfill, Inc., SCS Engineers, PC (SCS) is pleased to present this Work Plan
for a Source Demonstration at the referenced facility. The Facility entered into Assessment
Monitoring in late 2009 (second semi-annual monitoring event) after negotiating an Appendix II
sampling protocol based on a preliminary characterization of a ground water impact. The impact appears to focus on an old drainage ditch excavated for prior agricultural use of the site. The
detected constituents from the Appendix I sampling list, which triggered the Assessment in
accordance with 15A NCAC 13B .0545, appeared to consist of petroleum hydrocarbons and
pesticides. Initial site permitting, beginning ca. 2000, and subsequent monitoring oversight was
provided by David Garrett & Associates, who initiated the Assessment program.
At this time the Assessment monitoring has shown no new constituents in the groundwater, and
the data appear to support the initial presumption regarding the source of the contaminants. This
document is respectfully submitted to the Division of Waste Management to initiate the next step
in characterizing the ground water impact. This document contains a brief summary of known
conditions and protocols for conducting the Source Demonstration.
Please contact us if you have any questions regarding this report.

Sincerely,
G. David Garrett, PG, PE Mike Cobb, PG
Project Manager Project Professional
SCS ENGINEERS SCS ENGINEERS
3 /1 7 /2016
cc: Judson Whitehurst, C&D Landfill, Inc.
Steve Lamb, PE, SCS Engineers, PC

C:\Users\3921gdg\Documents\Projects\EJE Recycling\Landfill\Phase 2B permit\PTC transmittal letter 7-17-14.doc
C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
| |

Source Demonstration Work Plan
Ground Water Assessment – Phase 1
C&D Landfill, Inc. (Pitt County, NC)
NC Solid Waste Permit #74-07

Submitted to:

NCDEQ Division of Waste Management
Solid Waste Section
217 W Jones Street
Raleigh, NC 27603

Presented To:

C&D Landfill, Inc.
802 Recycling Lane
Greenville, NC 27834

Presented By:

SCS ENGINEERS, PC
2520 Whitehall Park Drive, Suite 450
Charlotte, NC 28273-3557
704 504-3107

March 17, 2016
File No. 02214708.00
C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
i

Table of Contents

Section Page
1.0 BACKGROUND ........................................................................................................................... 2
1.1 Site History ......................................................................................................................... 2
1.2 Assessment Monitoring ..................................................................................................... 2
1.3 Data Trends ....................................................................................................................... 4
2.0 FIELD INVESTIGATION ............................................................................................................... 4
2.1 Sampling Locations .......................................................................................................... 4
2.2 Sampling Protocols ........................................................................................................... 5
2.3 Laboratory Analysis ......................................................................................................... 5
3.0 ANALYSIS and REPORT ............................................................................................................. 6
3.1 Data Compilation .............................................................................................................. 6
3.2 Regulatory Review ............................................................................................................ 6
3.3 Follow-Up Work ................................................................................................................ 6
3.4 Final Report ........................................................................................................................ 6

Figure 1 Site Map
C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
2
1.0 BACKGROUND
1.1 Site History
C&D Landfill, Inc., is an unlined construction and demolition debris landfill (CDLF) regulated under 15A NCAC 13B .0537 et seq. Phase 1 of the CDLF covers approximately 15 acres and opened in 2001, following site characterization studies performed ca. 2000 that identified the
ground water flow conditions. Subsurface conditions within the upper 70 feet consist of two
relatively sandy aquifers (fluvial and shallow marine sediments) separated by a partial confining
layer (deep marine silt-clay associated with the Yorktown Formation). An upward hydraulic gradient exists beneath much of the site due to mild artesian pressure within the deeper aquifer.
Ground water is shallow, typically within 5 feet beneath the surface, and is directed to the south,
toward large receiving streams (Grindle Creek and/or the Tar River). The downgradient area
between the facility and the streams is mostly within the 100-year floodplain and contains extensive wetlands. Grindle Creek has a class C-NSW stream designation (fresh water, supportive of aquatic life and recreation, nutrient sensitive). The nearest receiving streams are
not blue-line features. There are no ground water users located down-gradient of the facility and
virtually no down-gradient development potential exists. The surrounding area is served by
public water supply, derived from wells but which are miles away and upgradient. Past uses of the site include agriculture and recreational hunting and four-wheeling – activities
which are potential sources of some of the contaminants observed in excess of the 2L standards.
The initial waste material brought to the facility was Hurricane Floyd flood damaged demolition
debris, which was collected under emergency management conditions. That is, materials not normally admitted to a CDLF under the Solid Waste regulations may have been introduced and/or one or more spills near a drainage feature in a remote corner of the site, southwest of
Phase 1, may have caused the impact. Ground water monitoring did indicate certain inorganic
background constituents – not the focus of this assessment – which are exacerbated by turbidity.
The organic constituents have been detected only sporadically.
1.2 Assessment Monitoring
The following is a summary of the detected constituents that triggered the Assessment Monitoring along
with relevant 2L Standards, which were discussed in the 2009 Assessment Work Plan. Detections after
the Assessment began (through Fall 2015) are listed below in bold type:

MW-3s MW-3d MW-3A MW-8
Acetone
(2L_6000 μg/l) ........................... 5.6 / 9.10J ............................................................ 4.5

Benzene
(2L_1.0 μg/l) .............................. 2.1 / 3.1 ...................................... 0.9J*/ 1.7 ......... 0.7 / 1.9

2-Butanone (MEK)
(2L_4000 μg/l) ......................................................................................................... 1.1
C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
3
MW-3s MW-3d MW-3A MW-8
Chloroethane
(2L_3000 μg/l) .......................... 0.7

Chloromethane
(2L_3 μg/l) ................................. 0.5

Carbon Disulfide
(2L_700 μg/l) ........................................................................................................... 0.2

1,2-Dichloroethane
(2L_0.4 μg/l) .............................. 0.7

Cis-1,2-Dichloroethene
(2L_60 μg/l) .............................. 1.3 ........................................................................ 0.2

Ethylbenzene
(2L_600 μg/l) ............................. 0.4 / 0.8J

Methylene Chloride
(2L_5 μg/l) .............................. 0.3J / 0.8J ............................................................. 0.2

Toluene
(2L_600 μg/l) ............................. 0.4

Trichloroethene (TEC)
(2L_3 μg/l) ................................. 0.3J

Vinyl Chloride
(2L_0.3 μg/l) .............................. 0.5

Dinoseb
(2L_7 μg/l) ................................. 0.821J*

2,4,5-TP (Silvex)
(2L_50 μg/l) ............................... 0.738J*

*First detected after the Assessment began. J denotes concentrations detected below reporting limit.
Some of the standards may have changed since this data was compiled in 2011.
Tetrahydrafuran has not been considered, as it was not monitored when the Assessment began.
Inorganic constituents have been shown to be regional background, exacerbated by high turbidity.
No organic constituents have been detected at MW-3d.
C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
4
1.3 Data Trends
Data through the November 2015 sampling event show a consistent decline in many parameters,
despite the fact that reporting limits and a few standards have decreased since the monitoring
program began. Significant trends relative to the Assessment Monitoring are as follows:

• Benzene is holding steady just slightly above the 2L Standard at MW-3s, detected above
2L only once at MW-3A, and detected sporadically with recent non-detects at MW-8.

• Constituents present (at any concentrations) before the Assessment that have not been
detected (or were detected below 2L or the SWSL) include Acetone, 2-Butanone, Carbon
Disulfide, Cis-1,2-Dichloroethene, Chlorobenzene, Ethylbenzene, Methylene Chloride,
Trichloroethene, Toluene, Vinyl Chloride, Dinoseb and 2,4,5-TP (Silvex).

• Constituents listed on the pre-assessment detection list, but are no longer listed, i.e., these
have not been detected since the database was updated by SCS, include Chloroethane,
Chloromethane, and 1,2-Dichloroethane.

2.0 FIELD INVESTIGATION
2.1 Sampling Locations
Six test pits will be excavated for soil sampling and in situ observations. The test pits will be
excavated to a depth between 48 and 64 inches. Additional test pits without sampling may be
added based on preliminary field test results.

SCS recommends sampling test pits in the following locations, shown on Figure 1:

• Two test pits on a line between existing groundwater monitoring wells MW-10 and MW-
11, such that each point is equidistant from the nearest two points;
• One test pit between monitoring wells MW-11 and MW-8;
• One test pit between monitoring wells MW-8 and MW-12, remaining within the drainage
feature;
• One test pit between monitoring wells MW-8 and MW-3s, remaining within the drainage
feature;
• One test pit in the MW-3 cluster of wells (MW-3s, MW-3d, and MW-3A), offset at least
20’ from the nearest well to minimize any impact the disturbance of material caused by
the excavation may have on the wells.

C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
5
2.2 Sampling Protocols
Prior to excavation, SCS will conduct photo-ionization testing on “clean” soil located outside the
limits of the drainage feature suspected to be the source of contamination. SCS will identify a
suitable upgradient location in which to dig a “clean” test pit and direct the equipment operator
to excavate to between 48 and 64 inches below ground surface (bgs). Then, using a RAE
Systems MiniRAE 3000 (or similar) photo-ionization detector (PID), SCS will obtain a
background reading of hydrocarbons present in native soil. Further, SCS will collect a sample
from this “clean” soil (per the method laid out below) to be sent to the laboratory for analysis.
SCS understands the Landfill will provide a backhoe or other piece of equipment and an operator
to assist in excavating this and subsequent test pits.

Sampling will occur at each location within the upper 24 inches and between 48 to 60 inches,
unless suspect staining is observed at a shallower depth. As decontaminating heavy equipment
between each test pit is not feasible, soil samples will be collected from material that did not
come into contact with the excavator bucket to minimize the risk of cross-contamination. To
achieve this, SCS will direct the operator to halt excavation approximately six inches above the
depth at which samples will be collected. SCS will then use a hand auger to drill down to the
sampling depth and collect the necessary soil samples. The hand auger will then be
decontaminated using a mixture of distilled water and phosphate-free soap, and rinsed with
distilled water.

At each sample location, SCS will obtain a reading with the PID from the depth at which soil
samples are collected. SCS will also direct the Landfill’s operator to excavate a number of
additional test pits for the sole purpose of attempting to delineate the extent of contamination
using the PID; no soil samples will be collected from these additional test pits.

2.3 Laboratory Analysis
The samples collected from each test pit will be analyzed with EPA Method 8260B, Volatile
Organic Compounds. This method covers all detected constituents listed above, with the
exception of Dinoseb and Silvex, both herbicides. To assess the presences of these two
constituents, samples will be analyzed with EPA Method 825 1A, Chlorinated Herbicides.

C&D Landfill, Inc. (Permit 74-07)
Ground Water Source Demonstration Work Plan
6
3.0 ANALYSIS AND REPORT
3.1 Data Compilation
The results of the Source Demonstration sampling and analysis will be compiled into tables and
portrayed on a site map. The ground water data records going back to the beginning of the
facility will be compiled, as well, to support the findings of the Source Demonstration.

3.2 Regulatory Review
Upon completion of the laboratory testing, SCS will review the data and findings of the
investigation with NC DEQ officials. The intent is to show (if supported by the data) that the
source of the contaminants is pre-landfill activities within and near the drainage feature, such as
past agriculture and possible fuel spill(s), as the suspected source of contamination.

Recommendations for further investigation, if required and an evaluation of appropriate remedial
measures (e.g., monitored natural attenuation) will be discussed in the report with input from NC
DEQ officials.

3.3 Follow-Up Work
Further investigations or analytical work are not anticipated at this time. Depending on the data
from the upcoming investigation, and the input of the Division, additional work may be required.

3.4 Final Report
Following the review, SCS will prepare a summary report with conclusions pertaining to the
source of the contaminants, including (but not limited to) a discussion of the nature and extent of
the contaminants, comparison of contaminants found in this study with those commonly
associated with other landfills, a rate of migration and concentration analysis (based in part on
earlier dispersion models generated during permitting), and a potential receptor evaluation.

PHASE 2
PHASE 1
14
1
3
13
13
12
1
2
12
14
13
SC
S

E
N
G
I
N
E
E
R
S
,

P
C
25
2
0

W
H
I
T
E
H
A
L
L

P
A
R
K

D
R
I
V
E
,

S
U
I
T
E

4
5
0
CH
A
R
L
O
T
T
E
,

N
O
R
T
H

C
A
R
O
L
I
N
A

2
8
2
7
3
PH
O
N
E
:

(
7
0
4
)

5
0
4
-
3
1
0
7

F
A
X
:

(
7
0
4
)

5
0
4
-
3
1
7
4
CL
I
E
N
T
DA
T
E
RE
V
I
S
I
O
N
N0
.
PR
O
J
E
C
T

T
I
T
L
E
SH
E
E
T

T
I
T
L
E
AP
P
.

B
Y
:
Q/A

R
V
W

B
Y
:
CH
K
.

B
Y
:
DW
N
.

B
Y
:
DS
N
.

B
Y
:
PR
O
J
.

N
O
.
DATE:
SCALE:
DRAWING NO.
1 1
AS SHOWN
JANUARY 2016
02
2
1
4
7
0
4
.
0
0
GD
G
TA
S
DM
C
MV GD
G
C&
D

L
A
N
D
F
I
L
L
,

I
N
C
.
80
2

R
E
C
Y
C
L
I
N
G

L
A
N
E
GR
E
E
N
V
I
L
L
E
,

N
C

2
7
8
3
4
(2
5
2
)

7
5
7
-
0
0
2
3
20
1
6

S
O
U
R
C
E

D
E
M
O
N
S
T
R
A
T
I
O
N
C&
D

L
A
N
D
F
I
L
L

P
H
A
S
E
S

1

&

2

(
7
4
-
0
7
)
WA
T
E
R

Q
U
A
L
I
T
Y

R
E
P
O
R
T
N