3405_Forsyth_RJReynolds_RuralHall_Indus_GWRequest_FID1646025_20220221

ERM FRN Inc. Telephone: [phone]
Summit Avenue Fa+1 704 624 7928
NC 28203 www.erm.com
February 21, 2022
North Carolina Department of Environmental Quality
Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attention: Ms. Jaclynne Drummond
[e-mail]
Via Email
Subject: Proposed Modifications to Sampling and Analysis Plan
Permit #34-05 - Edwards Road Landfill
Edwards Road
Rural Hall, Forsyth County, North Carolina
Dear Ms. Drummond:
On behalf of R.J. Reynolds Tobacco Company, ERM NC, Inc. (ERM) is providing additional
information regarding the recent request in the Groundwater & Surface Water Monitoring Semi -
Annual Summary Report - October 2021 (ERM, February 14, 2022) to transition to a reduced annual
monitoring frequency, in addition to removal of barium, cadmium and lead from the routine analytical
program at the subject Site. Based on our February 15, 2022 conversation, we understand the North
Carolina Department of Environmental Quality Division of Waste Management (NCDEQ DWM) is
reluctant to approve the request for discontinuing analysis for barium, cadmium and lead due to the
recent levels reported in piezometer samples from the Site. The following information is submitted to
further support the request to discontinue analysis for barium, cadmium and lead in routine water
samples.
Elevated levels of barium, cadmium and lead, along with other metals reported in piezometer
samples PZ-1 through PZ-5 between 2011 and April 2020, were not considered representative of
groundwater conditions due to elevated turbidity readings in the samples. Insufficient water volume
in the piezometers prevents the use of low -flow sampling procedures. A request was made to
discontinue metals analysis of the piezometer samples following the April 2020 monitoring event and
approval by DWM was provided on July 9, 2020. The piezometer samples continue to be analyzed
for sulfates and total dissolved solids in accordance with DWM's prior approval.
Barium, cadmium and lead have not been detected in samples from the eight permanent
groundwater monitoring wells or the former supply well (PW-1) above the applicable North Carolina
(NC) groundwater standards (15A NCAC .0200 2L) since 2009. Barium concentrations in surface
water samples have consistently been below the applicable NC surface water standard (15A
NCAC .0200 2B) since monitoring began in 1988. Cadmium has not been detected in surface water
samples since 2015, when it was reported in the sample collected from upgradient location SS-50.
Intermittent detections of lead have been reported in surface water samples collected from the Site,
primarily at locations upgradient of the landfill (SS-20, SS-25, SS-30 & SS-50). Lead was reported at
a concentration of 2.7 micrograms per liter (pg/L) in the SS-60 sample collected adjacent to the
landfill in 2017, which was slightly above the 2B standard of 1.0 pg/L, but has not been detected
since. Lead has not been detected in surface water samples collected from locations downgradient
of the landfill (SS-40, SS-80, SS-90). The intermittent lead detections in surface water samples,
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ERM
February 21, 2022
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primarily upgradient of the landfill, are likely attributable to suspended sediment from upstream run-
off and not associated with the Site.
We believe the above rationale supports the prior recommendation to transition to a reduced annual
monitoring frequency, as well as the removal of barium, cadmium and lead from the routine analytical
program at the subject Site. We respectfully request the NCDEQ DWM's concurrence with these
recommendations to implement the above modifications. If acceptable, please provide written
authorization to modify the Sampling and Analysis Plan accordingly. Please contact Mr. Scott Snow
of R.J. Reynolds Tobacco Company at 336-741-2236 or me if you have any questions or comments.
Sincerely,
AZ Z
Project Manager
cc: Mr. Scott Snow - R.J. Reynolds Tobacco Company
Mr. Max Hopkins - R.J. Reynolds Tobacco Company
Mr. Brian Wilson - ERM
Mr. Dave Wasiela - ERM