4101_Guilford_HighPoint_MSWLF_Seaboard_SamplingRequest_FID1596058_20210809

SEABOARD GROUP If AND THE CITY OF HIGH POINT
August 16, 2021
Eric B. Aufderhaar, P.G., Environmental Program Consultant
Jackie Drummond, Hydrogeologist
North Carolina Department of Environmental Quality
Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Re: HydraSleeve Equivalency Demonstration Workplan
Former Seaboard Chemical and Riverdale Drive Landfill Site
Jamestown, Guilford County, North Carolina
Dear Eric and Jackie:
The Seaboard Group II and the City of High Point are proposing to evaluate an alternate
groundwater sample collection method for the water quality monitoring events at the former
Seaboard/Riverdale Drive Landfill Site. If approved by NCDEQ, this Equivalency
Demonstration Workplan will be implemented during the fall 2021 water quality monitoring
event at the Site with an evaluation provided following submittal of the Annual Water Quality
Monitoring Report.
HydraSleeve Sampling Device
The HydraSleeve is a no -purge passive grab sampling device, meaning that it is used to collect
groundwater samples directly from the screened interval of a well without having to purge the
well prior to sample collection. As the groundwater at the Site contains high concentrations of
contaminants, the elimination of purge water is a significant advantage over other sample
collection methods.
The HydraSleeve collects a sample from the screened section of the well only. It excludes water
from any other part of the water column in the well through the use of a self-sealing check valve
at the top of the sampler. No -purge sampling devices like the HydraSleeve collect formation -
quality water under undisturbed, non- pumping natural flow conditions. It is a single -use
disposable sampler that is not intended for reuse, so there are no decontamination requirements
for the sampling device itself.
The Hydra Sleeve sampling device is approved by Region IV EPA and is included in Section 3.6
of the EPA SESD Operating Procedure Manual. An excerpt from the Operating Procedure
Manual discussing the use of HydraSleeve is attached to this Workplan.

There are several videos available which demonstrate the use and application of the HydraSleeve
sampling device. A few representative video links are provided below:
How the HydraSleeve Works (52 sec):
hLtps://www.youtube.com/watch?v=gV 2qCUoqDl
Installing the HydraSleeve (5:33 min):
https://www.youtube.com/watch?v=HwDYc5y9NDc
Removing the HydraSleeve (7:28 min):
hLtps://www.youtube.com/watch?v=rz9!pVgjjsE
HydraSleeve Equivalency Demonstration Procedure
There are currently twenty-five groundwater monitoring wells included in the annual water
quality monitoring program at the Site. Based on preliminary conversations with NCDEQ staff,
a total of ten monitoring wells have been selected for duplicate sampling during the fall 2021
monitoring event. The ten selected monitoring wells and relevant screened intervals and water
quality information are provided below:
Monitoring Well ID
Well Screen Interval
Total VOCs *
1,4-Dioxane
MW-1
47' - 57'
BQL
BQL
MW-12B
48' — 58'
125 ug/1
110 ug/1
MW-15A
19' — 34'
1,449 ug/l
1,100 ug/1
OW-DR2
176' — 186'
1,060 ug/1
280 ug/1
PW-3D
179' — 209'
76,030 ug/l
160 ug/1
PW-5D
272' — 282'
1,272 ug/1
460 ug/1
PW-10I
80' 100,
281 ug/1
250 ug/1
PW-131
235' — 250'
146 ug/1
68 ug/1
PW-16D
169' — 179'
68 ug/1
BQL
W-4A
54' — 64'
344 ug/l
30 ug/l
* October 2020 Analytical Data
A Site Map showing the location of these ten monitoring wells is attached to this Workplan.

The HydraSleeve samples will be collected a minimum of 2 days prior to the routine monitoring
event which uses low -flow sampling procedures. This is to assure the well casing water is
undisturbed at the time of both sample collection events. The HydraSleeve sampling devices
will be installed and allowed to equilibrate for approximately two hours prior to retrieval of the
sample. As with the routine monitoring event, the samples will be analyzed for VOCs by EPA
Method 8270D and 1,4-dioxane by EPA Method 8270D SIM. In addition to the routine field
measurements (pH, temperature, specific conductance, and dissolved oxygen), the turbidity of
the sample will also be determined at the time of collection.
Following receipt of the analytical data from the sampling events, the data from the HydraSleeve
sampling will be compared to the data obtained during the routine annual monitoring event using
low -flow procedures. This comparison will be provided separate from the Annual Water Quality
Monitoring Report and will contain a summary of the work performed and a comparison of the
data received for the wells in the demonstration. While an exact quantitative match is not
anticipated, a qualitative approach to the evaluation of the data will be applied. The observed
magnitude of contaminant concentration as well as the ratio of specific contaminants in a
particular sample should indicate the equivalency of the sample collection methods.
If there are any questions or comments regarding this Equivalency Demonstration Workplan,
please contact the undersigned at 919/605-4719 Please direct any correspondence related to this
matter to:
Mr. Craig Coslett
de maximis, inc.
1550 Pond Road, Suite 120
Allentown, PA 18104
Email: ccoslettkdemaximis.com.
Respectfully,
Seaboard Group II and City of High Point
Gary D. Babb, P.G.
Babb & Associates, P.A.
Mr. Gary Babb, P.G.
and Babb & Associates, P.A.
5506 Bradford Pear Ct
Raleigh, NC 27606
Email: [e-mail]
Attachment: EPA SESD Operating Procedure Manual Excerpt
Site Sample Location Map
Cc: Mr. Craig Coslett
de maximis, inc.

3.6.1 Minimum Purge Sampling COPY
The pump or tubing inlet is deployed in the screened interval. A volume of water equal
to the internal pump and tubing volume is pumped to flush the equipment. Sampling then
proceeds immediately. While superficially similar to Low -Flow sampling, the results
obtained in this method will be sensitive to the vertical pump or tubing inlet placement
and are subject to the limitations described above.
3.6.2 Passive Diffusion Bags
The no -purge Passive Diffusion Bag (PDB) typically consists of a sealed low -density
polyethylene (LDPE) bag containing deionized water. They are deployed in the screened
interval of a well and allowed to equilibrate, commonly for two weeks, prior to retrieval
and decanting of the water into sample containers. Many volatile organic compounds
will reach equilibrium across the LDPE material, including BTEX compounds and many
chlorinated solvents. Compounds showing poor equilibration across LDPE include
acetone, MTBE, MIBK, and styrene. PDBs have been constructed of other materials for
sampling other analytes, but the vast majority of PDB samplers are of the LDPE material.
Various vendors and the Interstate Technology and Regulatory Council (ITRC) can
provide additional information on these devices.
3.6.3 HydraSleevesTM
HydraSleeevesTM are no -purge grab sampling devices consisting of a closed -bottom
sleeve of low -density polyethylene with a reed valve at the top. They are deployed in a
collapsed state to the desired interval and fill themselves through the reed valve when
pulled upward through the sampling interval. The following is a summary of their
operation:
Sampler placement — A reusable weight is attached to the bottom of the sampler or
the sampler is clipped to a weighted line. The HydraSleeveTM is lowered on the
weighted line and placed with the top of the sampler at the bottom of the desired
sampling interval. In -situ water pressure keeps the reed valve closed, preventing
water from entering the sampler. The well is allowed to return to equilibrium.
Sample collection - The reed valve opens to allow filling when the sampler is moved
upward faster than 1 foot per second, either in one continuous upward pull or by
cycling the sampler up and down to sample a shorter interval. There is no change in
water level and only minimal agitation during collection.
Sample retrieval - When the flexible sleeve is full, the reed valve closes and the
sampler can be recovered without entry of extraneous overlying fluids. Samples are
removed by puncturing the sleeve with the pointed discharge tube and draining the
contents into containers for sampling or field parameter measurements.
SESD Operating Procedure Page 21 of 34 SESDPROC-301-R4
Groundwater Sampling
Groundwater Sampling (301 )_AF.R4
Effective Date: April 26, 2017

Because the HydraSleeve" is retrieved before equilibration can occur and they are
constructed of non -Teflon® materials, there may be issues with sorbtion of contaminants in the
use of this sampler.
3.6.4 Snap Samplers
The Snap Sampler is a patented no -purge groundwater sampling device that employs a
double -end -opening bottle with "Snap" sealing end caps. The dedicated, device is
deployed at the desired position in the screened interval with up to six Snap Samplers and
six individual sampling bottles. The device is allowed to equilibrate in the screened
interval and retrieved between 3 and 14 days after deployment. Longer deployments are
possible to accommodate sampling schedules.
To operate, Snap Samplers are loaded with Snap Sampler bottles and the "Snap" caps are
set into an open position. Samplers are deployed downhole with an attachment/trigger
line and left to equilibrate downhole. To collect samples, the Snap Sampler bottles seal
under the water surface by pulling a mechanical trigger line, or using an electric or
pneumatic trigger system. The trigger releases Teflon® "Snap Caps" that seal the double -
ended bottles. The end caps are designed to seal the water sample within the bottles with
no headspace vapor. After the closed vial is retrieved from the well, the bottles are
prepared with standard septa screw caps and labeled for laboratory submittal.
The manufacturer of the Snap Sampler provides considerable additional information on
the validation and use of the device.
3.7 Equipment Considerations
Equipment choices are dictated by the purging and sampling method used, the depth to
water, the quantity of water to be pumped, and quality considerations. The advantages
and disadvantages of various commonly used pumps are discussed in the sections below
and summarized in Table 1, Purge and Sample Strategies with Equipment
Considerations. Additional information on the use of individual pumps is available in
SESD Operating Procedure for Pump Operation, SESDPROC-203.
3.7.1 Use of Peristaltic Pumps
Peristaltic pumps are simple, inexpensive, and reliable equipment for purging and
sampling where the limit of suction is not exceeded (approximately 25-30 vertical feet
from the groundwater surface to the pump). When used for sampling, they should be
equipped with new Teflon® tubing for each well. The flexible peristaltic pump -head
tubing should also be changed between wells.
Samples for organic analyses cannot be exposed to the flexible peristaltic pump -head
tubing, both due to the risk that the tubing would sorb contaminants and the propensity of
this tubing to contribute organic compounds to the sample. Samples can be collected
without contact with the pump -head tubing by the use of vacuum transfer caps for
SESD Operating Procedure Page 22 of 34 SESDPROC-301-R4
Groundwater Sampling
Groundwater Sampling (301 )_AF.R4
Effective Date: April 26, 2017

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