HomeMy WebLinkAbout1401_Caldwell_MSWLF_NCD086871282_CorrectiveMeasuresUpdate_FID1747957_20221128ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
SENT VIA EMAIL
Donald Duncan, County Manager
Caldwell County North Carolina
905 West Avenue
Lenoir, North Carolina 28645
NORTH CAROLINA
Environmental Quality
November 28, 2022
Re: Corrective Measures Study for Groundwater Contamination
Former CSI Landfill
1200 Dragstrip Road
Hudson, North Carolina
EPA Identification Number: NCD 086 871 282
Dear Mr. Duncan and Ms. Cox:
Heather Cox, Deputy Director
Caldwell County Public Utilities
1385 Fairview Drive, Southwest
Lenoir, North Carolina 28645
As per a request from the Hazardous Waste Section (HWS), Caldwell County contracted with Hart and Hickman to develop a
Corrective Measures Study (CMS) for groundwater contamination associated with the former CSI Landfill facility located at
1200 Dragstrip Road in Hudson, North Carolina. This request was made by the HWS pursuant to requirements cited in the
January 16, 1998, Consent Decree between the United States of America and Caldwell County et al., Section VII, Items 16 and
17.
The CMS was finalized by Hart and Hickman on March 28, 2018. The CMS focused solely on groundwater contamination because
identified soil impacts had previously been addressed under the direction of the U.S. Environmental Protection Agency.
The CMS focused on groundwater impacts and evaluated potential corrective actions to address groundwater contamination while
ensuring continued protection of human health and the environment. The recommended corrective action to address groundwater
contamination at the Facility was monitored natural attenuation (MNA) in conjunction with previously -recorded Perpetual Land Use
Restrictions (LURs). The HWS concurred with this recommendation and proceeded to move the project forward by scheduling a
timeframe for public input regarding the decision to remediate groundwater through MNA.
A 45-day public participation period was scheduled beginning on August 3, 2018, and ending on September 17, 2018. Additionally,
a public hearing was conducted on September 5, 2018. Due to reasons beyond the control of the HWS (e.g., the pandemic), the
CMS was never finalized.
Due to the elapsed time, the HWS requests that the CMS be updated to include recent groundwater monitoring results and an
updated receptor survey. Additionally, the HWS asks that groundwater be sampled for Per- and Polyfluoroalkyl Substances (PFAS)
using EPA Method 1633. As you may know, PFAS is an emerging contaminant issue in North Carolina and landfill leachate is a
known source of PFAS. It is important that PFAS be sampled to ensure that all possible contaminants of concern are evaluated.
Depending on sample results, risk -based remediation may be a viable remedial approach as opposed to MNA. The remedial path
forward should be discussed with your environmental consultant.
D E Q�� North Carolina Department of Environmental Quality I Division of Waste Management
-
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA
oeParonemmrnrironmemaiouai� � 919.707.8200
Due to the length of time that has elapsed, the HWS respectfully asks that this work be completed in the next 60 days. If you have
any interest in meeting with the HWS to discuss further, I will make the necessary arrangements. Please do not hesitate to contact
me at 984-269-2463 or at mary.siedlecki ,ncdenr.gov.
Sincerely,
Mary �(/eedlecki, Project Manager
Hazardous Waste Section
Division of Waste Management, DEQ
ec: Donald Duncan, Caldwell County Manager
Heather Cox, Caldwell County Public Utilities (Deputy Director)
Barry Calloway, Caldwell County Public Utilities (Director)
Kim Caulk, HWS Branch Head
Mary Siedlecki, HWS Project Manager
Jaclynne Drummond, Solid Waste Section Project Manager
John Johnston, EPA
Danesha Byron, EPA
Carlin Slusher, Hart and Hickman
Justin Ballard, Hart and Hickman
E Q Q North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA _
OepammammEmimnmameiausil /`� 919.707.8200