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Home My WebLink About1401_Caldwell_MSWLF_NCD086871282_CorrectiveMeasuresStudyRevision3Comments_FID1811352_20230724ROY 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 July 24, 2023 Heather Cox, Deputy Director Caldwell County Public Utilities 1385 Fairview Drive, Southwest Lenoir, North Carolina 28645 Re: DEQ Comments on Corrective Measures Study, Revision 3 (dated June 30, 2023) Former CSI Landfill 1200 Dragstrip Road Hudson, North Carolina EPA Identification Number: NCD 086 871 282 Dear Mr. Duncan and Ms. Cox: The Hazardous Waste Section (HWS) has completed review of the Corrective Measures Study, Revision 3. This document was revised in response to a request from the HWS in correspondence dated November 28, 2022. Specifically, the HWS requested that the Corrective Measures Study, Revision 2, be revised to include (1) monitoring results compiled after 2018; an updated receptor survey, and sampling results for Per- and Polyfluoroalkyl Substances (PFAS). The request to sample for PFAS is due to the presence of two closed landfill cells at the facility. Landfills are being sampled because landfill leachate has been identified as a potential source of PFAS and must be investigated. The Solid Waste Section issued a memorandum requiring PFAS sampling at solid waste landfills starting July 1, 2023 (attached). The presence of PFAS compounds has been established in groundwater at the facility. After completing an internal risk evaluation, the HWS determined that there is currently minimal risk to potential receptors. Consequently, the HWS is not requiring additional investigation, assessment, or routine monitoring at this time. That said, the HWS requests that one additional round of PFAS sampling be conducted to confirm the preliminary results. Sampling should be conducted in a subset of monitoring wells characterized by the most elevated concentrations. The exact number and location of monitoring wells to be sampled must be approved by the HWS. Laboratory analysis must include 5:3 FTCA. It is recommended that EPA Draft Method 1633 be used. There is no requirement that the laboratory used be located in the state of North Carolina. The HWS will provide final comments on the Corrective Measures Study, Revision 3, following receipt of the confirmation analytical results for PFAS. 01-11- 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 - oepamnemof rnvimnmemmouaifty /� 919.707.8200 If you have any questions or comments, please contact me at mary.siedlecki(@deg.nc.gov or at 984-269-2463. Sincerely, Mary S' lecki, Project Manager Hazardous Waste Section Division of Waste Management, DEQ Attachments: Memorandum PFAS Monitoring Requirements for Solid Waste Sanitary Landfills (March 13, 2023) 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 Danesha Byron, EPA David Egetter, EPA Carlin Slusher, 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 ROY COOPER Governor ELIZABETH S. BISER Secretary MICHAEL SCOTT Director NORTH CAROLINA Environmental Quality March 13, 2023 MEMORANDUM To: Solid Waste Directors and Lan wners/Operators From: Ed Mussler, Section Chief NC Division of Waste Management, Sold Waste Section Re: PFAS Monitoring Requirements for Solid Waste Sanitary Landfills Background Per -and polyfluoroalkyl substances (PFAS) are a group of manufactured compounds used in a variety of industries, such as aerospace, automotive, textiles, and electronics, and are widely used in commercial and consumer products such as food packaging, water- and stain -repellent fabrics, nonstick products, and firefighting foams. Many of these products and by-products are commonly disposed in solid waste landfills. PFAS, including perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), are a concern because they: • do not break down in the environment, • can move through soils and contaminate drinking water sources, • build up (bioaccumulate) in fish and wildlife, and • have been linked to adverse health effects in humans and animals. PFAS Sampling The Solid Waste Section (Section) is requiring that all groundwater, surface water, and leachate samples collected at solid waste sanitary landfills after July 1, 2023 be analyzed for per- and polyfluorinated substances (PFAS), in accordance with the requirements and procedures for groundwater and surface water monitoring established under 15A NCAC 13B Rules .0601, .0602, .0544, .0545, .1623, and .1630 through .1637, 15A NCAC 02L, and the provisions of G.S. 143- 215.1(a). This includes any active, inactive, or closed sanitary landfill currently conducting and reporting water quality and/or leachate sampling results to the Section. The Section has determined that all sanitary landfills analyze groundwater, surface water, and leachate samples for PFAS to ensure protection of human health and the environment due to the potential health hazards associated with PFAS. This requirement is in conjunction with the NC DEQ's Action Strategy for PFAS to manage the risks of PFAS in the State. Landfills are one of several priority areas in the plan and sampling will help to identify possible PFAS associated with the regulated management of solid waste and to evaluate the presence of PFAS in the environment from these managed activities. Collection and evaluation of this information will also assist the Department in developing sound policies with respect to PFAS in the environment. 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 - oepamnemorenvo-nnmemaiQuality /� 919.707.8200 Sampling Frequency and Laboratory Analytical Methods for PFAS Collection of samples for PFAS analysis should be conducted for all monitoring locations (groundwater, surface water, underdrain, and leachate) and during the landfill facility's regular compliance monitoring schedule as required by the facility permit and/or most current approved water quality monitoring plan. The Section is requiring groundwater, surface water, and leachate samples to be analyzed using EPA (Draft) Method 1633 for the full list of PFAS compounds for the method. Please note that specific considerations and protocols are required to avoid cross -contamination and minimize sample bias for PFAS. A current listing of laboratories accredited to perform EPA Draft Method 1633 can be found here: https://www.denix.osd.mil/edqw/accreditation/accreditedlabs/index.html. To view the labs, search for `Draft EPA Method 1633' under Methods. Please note that different labs are accredited for different matrices. NOTES - Sampling and Analytical: • The analytical methods should be the most recent versions of the analytical method(s) stated above. Sampling must be planned so that required holding times for analytical methods are met. • EPA Draft Method 1633 is currently single -lab validated and is expected to soon become multi - lab validated. The method will undergo QC with a current expected time to be Final in 2023 or 2024. • The Section considers ` J"flag values valid and relevant in the decision -making process and hence all `J"flag values should be reported. • Online technical resources on PFAS sampling protocols, fact sheets, analytical methods, and other issues, can be found here: Interstate Technology and Regulatory Council (ITRC) PFAS Website Reporting PFAS analytical results must be reported as part of the regularly submitted monitoring report along with the laboratory data report (electronic format pdf copy). Laboratory data must be submitted in accordance with the most current DEQ electronic data deliverable format (EQUIS). If you have any questions, please contact Perry Sugg, Environmental Compliance Branch Head, at (919) 707-8258 or via email at perry.sugg&ncdenr.gov. Thank you for your cooperation in this matter. 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 - DaP.mm.mmEwimnm�lQu.� /� 919.707.8200