8801_ROSCANS_1991

::Zcusta a division of P. H. GLATFELTER CO.
P.O. BOX 200 • PISGAH FOREST, NORTH CAROLINA 28768 • TELEPHONE [phone]
Mr. Gary Ahlberg
Division of Solid Waste Management
North Carolina Department of Environment,
Health and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Gary:
September 5, 1991
Subject: Draft Permit -Ecusta Ash Landfill
I appreciate this opportunity to comment on the latest draft of the
proposed permit for the Brown No. 2 ash landfill. This draft contains
a new operating requirement in paragraph 4 of "Monitoring and
Reporting Requirements." This paragraph requires that we report
annually on the amount of waste (by weight) disposed of at this
landfill, which is compiled on a monthly basis. A copy of this report
must be sent to the Solid Waste Section in Raleigh and to Transylvania
County.
The Brown No. 2 ash landfill is a monofill used only for the disposal
of coal ash generated at our facility in Pisgah Forest. It receives
no other material. We do not weigh our trucks of ash going to this
landfill. We do, though, calculate how much ash is disposed of in
this landfill on a monthly basis.
Currently, we are required by the North Carolina Division of
Environmental Management to monitor the ash content of all coal burned
at Pisgah Forest. The sampling and analysis of such coal meets
current DEM and ASTM guidelines. The resultant values are used by the
State of North Carolina to determine our air quality permit fees and
for inclusion in EPA's NESHAP system. It is proposed that this
calculated number be used instead of weighing of our individual trucks
of ash going to this landfill.
As pointed out above, one of the requirements of this section is that
these reports be sent on an annual basis to Transylvania County.
Please advise us in the permit who or what position in Transylvania
County needs to receive the report. Currently, we are being advised
by Transylvania County that they know nothing about this.
Thank you for the opportunity of commenting on this draft permit. As
always, I enjoy discussing with you our perennial subject of the Brown
Ecusta
a division of P. H. GLATFELTER CO.
PISGAH FOREST. NORTH CAROLINA 28768
Mr. Gary Ahlberg
Division of Solid Waste Management
September 5, 1991 Page 2
No. 2 ash landfill. If you have any questions or comments, please
call me at 704-877-2347.
RJG:mh
Copy to: C. N. Carter
D. W. Monk
Sincereiy,
ECUSTA DIVISION
P.H. Glatfelter Company
ti.~
Environmental Affairs
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. R. J. Gussman, Director
Environmental Affairs
Ecusta Corporation
Pisgah Forest, N. c. 28768
May 8, 1991
William L. Meyer
Director
Re: Revisions To The Groundwater Monitoring Plan For The Ecusta Ash
Landfill (Permit# 88-01)
Dear Mr. Gussman,
Presently there is no monitoring system that specifically
targets the impact of the Ecusta Ash Landfill on the ground water of
the area. As we discussed in our telephone conversation this past
week, the Solid Waste Section feels at least one additional
monitoring well is needed at the ash monofill site.
Under typical circumstances at least four ground water
monitoring wells are required around each distinct landfill facility.
Because of the unique features and layout of the Ecusta facilities,
the Section will allow the use of existing monitoring wells at the
site (which are located primarily to monitor the impact of the sludge
landfill and the aeration stabilization basin) as part of the
monitoring system for the ash landfill. However at least one
additional monitoring well needs to be installed at the site.
Because there are homes and trailers with private drinking water
wells to the northwest of the ash landfill, a monitoring well will be
required on this side of the site. This well should be installed on
the northwest side of the landfill site inside the ditch near the
entrance road to the facility, in the approximate location as shown
on the attached map. The well should be installed with the screen
set so that the seasonal high water table falls just under the top of
the screen. A minimum screen length of 10 feet will be required and
a screen length of of 15 feet is recommended, if the hydrogeological
conditions permit. The well should be designed so that the water
table always falls within the screened interval and so that there is
always a sufficient amount of water in the well (even under seasonal
low water conditions) to allow a representative sample to be taken of
the ground water in the upper part of the aquifer.
An Equal Opportunity Alllnnative Action Employer
Page 2
Well documentation for the existing wells at the site indicate
that the two downgradient wells are drilled to a depth of about 17 to
18 feet, with the water table from 2 to 5.5 feet below ground surface
elevation. There.are no boring logs for these wells on record in our
office, so it is not clear what type of material was encountered in
the boring of these wells. Based on this information it is clear
that effective monitoring wells can be established in this area.
The monitoring system for the ash landfill should also include a
sample taken from the outfall from the discharge pipe for the erosion
control pond at the base of the ash monofill. The two surface water
sampling locations previously approved by our office should also be
sampled as part of the monitoring system.
In summary, the water quality monitoring system for the Ecusta
sludge and ash landfill facilities (Permit# 88-01) will include the
three existing monitoring wells, the proposed new monitoring well,
the previously approved surface water locations, and a sample from
the sediment basin outfall pipe at the ash monofill.
The new monitoring well should be installed by July 31, 1991.
A complete and accurate Well Completion Record (DHS 3342) should be
submitted to the Solid Waste Section within 15 days of well
installation. In addition, please submit to us a summary of the
hydrogeological data accumulated from the boring operation. Include
boring logs and other pertinent subsurface information.
After the new well has been installed the Solid Waste Section
will make arrangements to visit the site. At that time
representatives from the Section well inspect the monitoring system
and perform a baseline sampling. After the results of the sampling
are reviewed, the Section will make a determination as to the
frequency of sampling and the sampling parameters that will be
required for future routine detection monitoring.
If you have questions or comments please contact this office at
[phone].
cc: Gary Alhberg
Jim Patterson
Don Link
Attachments
Sincerely,
~~
Bobby Lutf?"J'
Hydrogeologist
Solid Waste Section
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. R. J. Gussman, Director
Environmental Affairs
Ecusta Corporation
Pisgah Forest, N. c. 28768
June 11, 1991
William L. Meyer
Director
Re: The Groundwater Monitoring Plan For The Ecusta Ash Landfill
(Permit# 88-01)
Dear Mr. Gussman,
This letter is written in response to your letter of May 17,1991
regarding monitoring of the Ecusta Ash Landfill. After further
review, and discussion with Mr. Don Link, D.E.M. Hydrogeological
Supervisor, the Division of Solid Waste Management still feels that
at least one additional ground water monitoring well is necessary to
detect the effects of the facility on the ground water of the area.
Therefore, the Division will ask that the monitoring plan for the Ash
Landfill be modified according to the conditions outlined in the
May 8, 1991, letter from this office.
Both the Division of Environmental Management and the Division
of Solid Waste Management agree that it would be best to screen the
proposed well above bedrock. The additional boring logs that you
submitted with your recent letter give me more confidence that a
shallow monitoring well, screened at the water table, can be
installed above bedrock. However, if the hydrogeologic conditions
make it necessary, the well may have to extend into the rock.
The other revisions to the Monitoring Plan, as outlined in the
May 8th letter from our office, should be implemented as soon as
possible. This includes the installation of the proposed monitoring
well by July 31, 1991. If you have any further questions, please
contact this office at [phone].
cc: G9-{y Ahlberg
t.dim Patterson
Don Link
Sincerely,
3d~r ~
Bobby tfu:tfy ~
Hydrogeologist
Solid Waste Section
An Equal Opportunity Afflnnative Acdon Employer