8801_ROSCANS_1998

Ecusta a division of P.H. GLATFELTER co.
R. J. GUSSMAN
P.O. BOX 200 • PISGAH FOREST, NORTH CAROLlNA 28768-0200
TELEPHONE [phone]
Director, Environmental Affairs
Tel. [phone]
Fax [phone]
Mr. Bobby Lutfy
Solid Waste Section
Division of Waste Management
401 Oberlin Road --Suite 150
Raleigh, NC 27605
Dear Mr. Lutfy:
Subject: Ash Monofill, 88-01
Groundwater Compliance Determination
Transylvania County
August 24, 1998
Attached are the responses to your questions contained in your letter of
July 9 in regards to the ash monofill. I appreciate the time it took you to
review our submittals and hope that these answers will satisfy your
concerns.
We believe that the information contained in Attachments A and B of the
November 24, 1997 submittal do show a reasonable demonstration of
compliance after closure. The concentration of sulfate in the downgradient
well Q88V5 do exceed those in the upgradient well and the subchapter 2L
standards. However, when you review the off-site drinking water well
analytical data, it demonstrates the 2L standard for sulfate is not being
exceeded at the compliance boundary. Downgradient well Q88VS is located
approximately 50 feet from the compliance boundary. Between it and the
boundary is a surface stream that has shown a significant increase in
sulfate concentration. It appears that the majority of the sulfate that is
found in the upper acquifer and sampled by Q88VS, is being discharged to
this surface stream.
Mr. Bobby Lutfy
Page 2
August 24, 1998
The HELP model was used to determine the effectiveness of the barrier
layer. Since the ash is located above the ground water elevation, hydraulic
conductivity of the barrier layer is critical. By the proper selection of the
barrier layer, infiltration through the base of the landfill will be <0.1 inch
per year. As you are aware, coal ash landfills are very difficult to model.
Please see the attached letter from J.C. Coffey of June 13, 1997 on this
subject. Any suggestions that you may have as to suitable models would be
greatly appreciated.
After you review this information, please give me a call and we will set up a
satisfactory time for the two of us to meet either in Raleigh or Pisgah Forest
to more fully discuss the future of this landfill.
RJG:ls
Attachment
cc: C. S. Burghardt
C. N. Carter
L. W. Nelson
J. E. Patterson /
,., ·-.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
July 9, 1998
Mr. Robert J. Gussman
Director, Environmental Affairs
Ecusta Division of P.H. Glatfelter Co.
P.O. Box 200
Pisgah Forest, N.C. 28768-0200
RE: 15A NCAC 2L Groundwater Compliance Demonstrations
For Ecusta Industrial Landfills 88-01 and 88-05
Dear Mr. Gussman,
The Hydrogeologic Unit of the Solid Waste Section has
reviewed the information submitted to demonstrate
compliance with the 2L Groundwater Standards at the
compliance boundaries for the Ecusta industrial waste
landfills. Some of the information that has been
provided is confusing and contradictory. There is also
some important information necessary to make a compliance
demonstration that has not been provided. Please review
the following questions and comments and provide the
corrections, revisions, and additional information that
is needed to evaluate the groundwater standard compliance
demonstration.
88-01 Ash Monofill
June 26. 1996 Submittal
Item 1
Permit 88-01 includes both a coal ash landfill unit
and a sludge landfill unit. Is the sludge landfill
unit still in operation? What is the waste
characterization for the sludge?
Item 2
Where is the,sludge landfill unit in relation to
the ash landfill unit?
The report states: "The permitted waste boundary
and the permitted facility boundary are also
represented by a single line". Past rules required
a minimum 50 foot buffer between the waste boundary
and the facility boundary. Current requirements
are for a minimum buffer of 200 feet.
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
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Ecusta
Page 2
It appears that the property outside the facility boundaries
to the northeast, southeast, and southwest are P.H. Glatfelter
property, and the property to the northwest is not P.H.
Glatfelter property.
The drawing seems to indicate that only monitoring well Q88V5
is located within the facility boundaries. T.his well appears
to be slightly over 50 feet from both the waste boundary and
the property boundary and less than ten feet from the facility
boundary.
The drawing only indicates two surface water sampling points.
It is the understanding of the Solid Waste Section that the
spring drain outfalls are also required to be sampled.
Item 3
Two of the three downgradient monitoring wells do not appear
to be located or designed so as to effectively monitor the
landfill units.
The spring underdrains are also required to be sampled for
water quality.
The report states: "Two inorganic compounds, sulfate and
total dissolved solids (TDS), consistently exceeded the NC 2L
standards in Q88V5". This monitoring well is the only real
compliance well for the ash landfill and it is located at the
compliance boundary. It appears therefore that the ash
landfil.l is not able to demonstrate compliance with the 2L
standards at the compliance boundary.
November 24. 1997 Submittal
Attachment A:
The Water Quality Monitoring Plan provides no evaluation or
discussion of the following: 1) the number, location, and
design of the current monitoring wells, 2) the number and
location of the current surface water monitoring sampling
sites, 3) the sampling parameters, and 4) possible upgrades
to the monitoring plan. In addition to the suggested sampling
parameters, at a minimum sampling and analysis should also be
done for the eight RCRA metals, total dissolved solids (TDS),
and a voe scan comparable to the Appendix I list using EPA
Method 8260. It is not necessary to test for TOC. The
drawing submitted with the Water Quality Monitoring Plan is
not legible.
. ;.
Ecusta
Page 3
On page 2 of the report there are descriptions of "gravity
drain lines" and "french drains 11 • It is stated that "These
drains discharge either to the sedimentation basin or to the
channel at the base of the ASB dike". A detailed diagram
needs to be provided that shows the location of all of the
"drain lines" and "french drains" at the ash landfill.
4.0 Compliance With 15 NCAC 2L Standards
While there has been some modeling using HELP of
infiltration through the cap, there does not appear to be
any modeling of the quantity and quality of water from
the base of the landfill, nor any modeling of the
subsurface water quality at the compliance boundary.
Additional subsurface characterization may be necessary
to properly evaluate fate and transport through the
subsurface to the compliance boundary.
As stated in the report: "Well Q88V5, downgradient of the
ash monofill, is located near the compliance boundary
directly west of the ash monofill''· "The concentrations
of sulfate in downgradient well Q88V5 consistently exceed
those in the upgradient well and the Subchapter 2L
standards". These statements are accurate and indicate
that the ash monofill is not able to demonstrate
compliance with the 2L standards at the compliance
boundary. Some of the subsequent discussion in the
report (at the bottom of page ten and on pages 12 and 13)
is inconsistent with these statements. This discussion
and the summary statement appear to be inaccurate.
Appendix A describes two piezometers installed into the
existing landfill. Was authorization obtained to install
these piezometers? Where were they installed? Are the depths
"below ground surface" depths below the top of ash or depths
below the actual native soil materials? The map showing the
location for these piezometers and the boring logs need to be
provided in the report. If the piezometers were installed
into the water table, were they installed in a way that would
not spread contamination deeper into the aquifer? Do the two
piezometers still exist or have they been properly abandoned?
Attachment B:
Virtually all of the comments and questions raised for
Attachment A are also applicable to Attachment B, although
some of the page references would be different. No modeling
has been provided to demonstrate compliance with the 2L
standards at the compliance boundary. Current water quality
data indicates exceedences of the 2L standards at the
compliance boundary for Sulfates and TDS.
Ecusta
Page 4
88-05 Process Waste Landfill
May 2. 1996 Submittal
Item 1
The waste stream characterization should evaluate not only the
existing waste stream but also the wastes disposed of at this
site in the past. The Superfund studies indicate a diverse
waste stream with a number of chemical constituents that could
be a source of contamination.
Item 2
The report states: "a single boundary line represents the
current waste footprint, the projected waste boundary as of
January 1, 1998, and the permitted waste boundary". The
report implies that this area along with "the sediment pond on
the southeast end of the site" is the permitted facility
boundary. Past rules required a minimum 50 foot buffer between
the waste boundary and the facility boundary. Current
requirements are for a minimum buffer of 200 feet.
The report also states: "The property boundary is the outer
perimeter of the island". If this is the case, who owns the
property on the other side of the Davidson River and the
canal?
The topography elevations are not legible on the drawing.
What is the normal stream elevation of the Davidson River just
above the weir?
The original Well Construction Permit issued by DEM on
September 27, 1990, was for "eight (8) monitor wells", with
well nests at locations MW-1, MW-2, and MW-3. Is this what
was actually constructed? This does not appear to match
current records. Are the nested wells at locations MW-1 and
MW-2 still in place, or have they been properly abandoned?
Some limited Drilling Log information has been provided for
MW-3, MW-4, and MW-4A, however no boring log data has been
provided for the other monitoring wells.
Please provide a copy of the results of the study done after
these wells were initially installed, including all well
construction records, boring logs, measurements of depths to
water, vertical gradients, direction and rate of groundwater
flow, water quality data, etc.
Ecusta
Page 5
Item 3
Please provide a copy of the Hydrogeologic Assessment of the
Olin/Ecusta Landfill by RMT, dated December 1991.
The report states: "Estimated concentrations of vinyl
chloride, 1,2-dichloroethane, benzene, and bis(2-ethylhexyl)
phthalate were above the NC 2L standards". In light of this
and the past waste disposal practices at the site, it does not
seem reasonable to make the later statement that "there is no
evidence that the process waste landfill is not in compliance
with NC 2L ground water quality standards".
October 29. 1997 Submittal
The report states: "The results of this (HELP) analysis
conclude that this landfill cap (24" soil at lOE-5 cm/sec) or
equivalent will virtually eliminate the infiltration from
precipitation and storm water into the landfill and the risk
of impacting ground water quality". Modeling by the Solid
Waste Section indicates that this design of soil cap is not
generally effective in significantly reducing infiltration.
The HELP model appears to only model infiltration through the
proposed cap. There does not appear to be any modeling of the
volume and concentration of contaminants from the bottom of
the landfill, nor is there subsurface modeling of possible
contaminants at the 2L compliance boundary. Additional
hydrogeologic characterization may be necessary to properly
evaluate fate and transport through the subsurface to the
compliance boundary.
Reference is made in the report to a "water table map which
was based on data collected on October 15, 1991". Please
provide a copy of this map.
The conclusions state: "the process waste landfill will comply
with 15 NCAC 2L standards once the final cap has been
constructed" . This statement is somewhat suspect, and in
addition it does not address the possibility of contamination
at the compliance boundary while the facility is in operation
and prior to the construction of the final cover.
The Process Waste Landfill Monitoring Plan provides no
evaluation or discussion of the following: 1) the number,
location, and design of the current monitoring wells, 2) the
number and location of the current surface water monitoring
sampling sites, 3) the sampling parameters, and 4) possible
upgrades to the monitoring plan.
Ecusta
Page 6
In light of the numerous contaminants previously identified to
be present at the site, the proposed sampling parameters need
to be expanded to include RCRA metals, Sulfates, a voe scan
(using EPA Method 8260), and a SVOC scan (using Method 8270).
The 5 YR. Grading Plan is designed in such a way that the
surface is flat and this would increase infiltration. The
design should be such as to minimize infiltration if the
landfill should need to be closed early due to a failure to
demonstrate compliance with the 2L standards at the compliance
boundary.
The Monitoring Location Map seems to indicate the downgradient
surface water sampling point (P002) is located below the weir.
Is this correct?
In summary, the information submitted for both landfills is
incomplete and somewhat contradictory. No modeling has been done
to show the quantity and quality of leachate coming from the bottom
of the landfill or the level of possible contaminants at the
compliance boundary . Present water quality data seems to indicate
levels of contamination that exceed the 2L standards at the
compliance boundary at the ash landfill (88-01) and that there is
the probability of possible levels of contamination that exceed the
2L standards at the process waste landfill (88-05).
Please provide the additional information and modeling data to
demonstrate "a design that will ensure that the ground water
standards established under 15A NCAC 2L will not be exceeded in the
uppermost aquifer at the compliance boundary". This information
should be submitted to the Solid Waste Section within the next 90
days so we can continue the review of the demonstration. If a
reasonable demonstration of compliance can not be made, it may be
necessary to develop a strategy and timetable for closing the
landfill(s) prior to the five years planned.
If you have any questions regarding these comments and questions,
please contact me at [phone], extension 258.
Sincerely,
$~!~!
Bobby Lutfy, Hydrogeologist
Solid Waste Section
cc : Jim Coffey, Solid Waste Section
Jim Patterson, SWS -Asheville
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