4101_Guilford_CityHighPoint_Riverdale_MSWLF_Seaboard_PFASMonitoringWorkPlanResponse_FID1817705_20230918

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
September 18, 2023
R. Craig Coslett, Project Coordinator
Seaboard Group II and the City of High Point
c/o de maximis, Inc.
1550 Pond Road, Suite 120
Allentown, PA 18103
Re: PFAS Monitoring Workplan Approval with Conditions
Seaboard Group II and the City of High Point
Former Seaboard Chemical and Riverdale Drive Landfill Site
Jamestown, Guilford County, North Carolina
EPA ID# NCD071574164
Solid Waste Section Permit No.: 4101-MSWLF-1979
Dear Mr. Coslett,
Both the Hazardous Waste Section (HWS) and the Solid Waste Section (SWS) of the Division of
Waste Management (DWM) have reviewed the Technical Memorandum No. E-12 — PFAS
Monitoring Workplan dated September 11, 2023. The DWM is requiring the Former Seaboard
Chemical and Riverdale Drive Landfill Site to conduct PFAS monitoring in addition to the routine
water quality monitoring beginning with the Fall 2023 monitoring event as indicated during our
August 2, 2023 call and in the DWM letter dated August 10, 2023. The Seaboard Group II and
the City of High Point have proposed the following groundwater monitoring wells and surface
water sampling locations for a standalone one-time PFAS sampling event using EPA Method
1633: MW-1, MW-12A, MW-3C, PW-6I, MW-10, SW-2, and SW-4.
Based upon a review of the document, the DWM approves the proposed five groundwater
monitoring wells and two water sampling locations. However, the DWM is also requiring the
sampling of groundwater monitoring wells W-4A and PW-3D during this PFAS standalone event
in addition to requiring a confirmatory PFAS sampling event using EPA Method 1633 to include
MW-1, MW-12A, MW-3C, PW-6I, MW-10, W-4A, PW-3D, SW-2, and SW-4. Well PW-3D is a
deep bedrock well and a passive sampling device (e.g. HydraSleeve) is approved for sampling
provided that the device and associated equipment are PFAS free and an equipment blank is also
collected and tested for PFAS by EPA Method 1633.
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

PFAS Monitoring Workplan with Conditions
Former Seaboard Chemical and Riverdale Landfill Site
September 18, 2023
Page 2
From the August 2, 2023 meeting, the DWM understands that surface water sampling of
Randleman Lake for PFAS is being planned by the Piedmont Triad Water Authority. In the August
10, 2023 letter, the Workplan was to include the sharing of the results of the surface water sampling
with DWM, and the submitted Workplan did not mention those results. Please provide those results
to the DWM at your earliest opportunity.
Please contact us if you have any questions or concerns.
Sincerely,
� TSGzti
Eric B. Aufderhaar, Project Manager
Facilities Management Branch, Hazardous Waste Section
Division of Waste Management, NC DEQ
ec: Ed Mussler, Solid Waste Section Chief
Kim Caulk, Facilities Management Branch Head, Hazardous Waste Section
Perry Sugg, Environmental Compliance Branch Head, Solid Waste Section
Jackie Drummond, Hydrogeologist, Solid Waste Section
Gary Babb, Babb & Associates
D E Q2� 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
NoarHcar�oiwn �
Department of EnWronmental Quality/`� 919.707.8200