8801_ROSCANS_2000

JAMES B. HUNT
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEY~·~-> ' ,,,;_,
DIRECTOR
December 18, 2000
Mr. D. M. Cody
Director of Environmental Affairs
Ecusta Division
P.H. Gladfelter Company
P. 0. Box 200
Pisgah Forest, NC 28768
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Re: Transition Plan, Ecusta Industrial Landfill, Permit Number 88-01
Transylvania County
Dear Mr. Cody:
The purpose of this letter is to inform the owner/operator that the Solid
Waste Section(Section) has approved the Transition Plan for Phase I of the
referenced industrial waste landfill submitted by Sevee & Maher Engineers, Inc.
dated December 5, 2000.
The so-called "industrial waste rule"-Rule .0503(2)( d)(ii) of the solid
waste management rules codified at 15A NCAC 13B, required that operators of
industrial waste landfills operating on or after January 1, 1998, submit to the
· Division of Waste Management, Solid Waste Section(Section) 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 established by
the Division in accordance with 15A NCAC 2L.
In a letter dated June 7, 1999, the Section informed the owner/operator
that review of the submitted information had been completed and that it had been
determined that the current landfill design did not meet the requirements of the
industrial waste rule. The approved Transition Plan contains changes to the
design, construction and operation of the existing landfill to ensure compliance
with the industrial waste rule. The approved plan is designed to cut-off, collect,
and treat ground water migrating from the landfill and includes: an underdrain
system in Phase I, a slurry wall downgradient of Phase I, an interceptor drain and
pump station up gradient of the slurry wall, and stormwater management dikes and
ditches. Detailed construction plans will submitted to the Section in April, 2001
and construction will begin following Section approval. Operation of Phase I
should begin in September, 2001.
The approved plan limits Phase I to a vertical expansion over the existing
landfill footprint established prior to January 1, 1998. The approved Transition
Plan allows this phase of operation of the landfill until January 1, 2003. lii11 WWl•MM·M
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
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Mr. Cody
December 18, 2000
Page 2
The Section will evaluate the effectiveness of the proposed landfill design to determine if the
landfill design ensures compliance with the industrial waste rule. If the landfill design ensures
compliance with the industrial waste rule, a five-year permit will be issued effective January 1,
2003.
If there are any questions, please contact me @[phone], extension 255.
Sincerely,
a:::Co£~ifr
Permitting Branch
Solid Waste Section
cc: Dexter Matthews
Phil Prete
Jim Patterson
Bobby Lutfy
Bill Sessoms
Sevee & Maher Engineers, Inc.
Waste Management and Hydrogeologic Consultants
December 5, 2000
NCDENR
Attn: Jim Coffey
401 Oberlin Road
Suite 150
Raleigh, NC 27605
Subject: P.H. Glatfelter-Ecusta Division
Ash Landfill
Dear Mr. Coffey:
On behalf of P.H. Glatfelter (Ecusta), Sevee & Maher Engineers, Inc. (SME) is
submitting this request to initiate operation of Ecusta's ash landfill into the Phase I
transition area until expiration of its current permit in December 2003. Ecusta staff
expects the existing landfill area to be at capacity by October 2001. Prior to beginning
operations in Phase I, some site development will be conducted, including: underdrain
pipes in Phase I; a slurry wall downgradient of Phase I; an interceptor drain and pump
station up gradient of the slurry wall; and storm water management dikes and ditches.
The installation of a slurry wall and interceptor drain will create a barrier to the
movement of potentially contaminated groundwater beyond the facility boundary. In
addition, installation of the slurry wall is expected to improve the current groundwater
quality below 2L groundwater standards at MW-Q88V5A, which is located downgradient
of the ash landfill and Phase I. The goal will be to comply with Industrial Solid Waste
Management Rule 0503(2)(d), and meet the 2L groundwater standards in MW-Q88V5A
by December 2003, or at least show a statistical downward trend in the parameters that
currently exceed the 2L groundwater standard. The statistical methods used in a trend
analysis will follow guidance provided in the July 1992 Addendum to Interim final
Guidance for Statistical Analysis of Groundwater Monitoring at RCRA Facilities.
The proposed site development plans for Phase I will be provided to the Department
through submittal of a transition plan. In addition, the transition plan will provide a
Page I of2
4 Blanchard Road P.O. Box 85A Cumberland Center, ME 04021 [phone] FAX [phone] www.smemaine.com
waste sequencing plan and any changes to the operations. The proposed schedule to
implement this transition plan is as follows:
1. January 2001 -February 2001: Conduct field investigation to collect data
for slurry wall and interceptor drain design;
2. April 2001: Submit transition plan and engineering drawings and receive
approval to begin construction;
3. June 2001 -September 2001: Construct slurry wall and site development
for Phase I; and
4. Begin landfill operations in Phase I.
We are confident that the site can continue operation and be in compliance with the
industrial landfill regulations with the changes proposed above. If you have any
questions regarding this submittal please do not hesitate to contact Mike Cody of P.H.
Glatfelter, or me.
Sincerely,
//.
Guy H. Cote,
Chief Engineer
cc: M. Cody, Ecusta
001205ncdenr.doc
December 5, 2000
Page2of2
-GOVERNOR
BILL HOLMAN
SE:CRE:TARY
:""''l"l ·. ,'I'.-:.,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 25, 2000
Mr. James McElduff, PE, and
Mr. Mark Taylor, PG
Fletcher Group, Inc.
322 South Main Street
Greenville, S.C. 29601
RE: March 2000 Ash Landfill Transition Plan and Ash
Monofill Permit Application for the Ecusta Division
of P.H. Glatfelter Company (Permit Number 88-01)
Dear Mr. McElduff and Mr. Taylor;
The initial hydrogeologic review has been done for the
above referenced documents for the Ecusta Ash Landfill .
I have not yet completed a full detailed hydrogeologic
technical review. However, the initial review resulted
in the identification of a number of significant issues
that need to be addressed before further review is
warranted. Please consider the following questions and
comments and respond as necessary:
ASH LANDFILL TRANSITION PLAN
Pg 6 Because this landfill has been in operation for
over 20 years, and downgradient wells have already
been affected by contaminant transport, intrawell
statistical evaluations alone are not sufficient to
properly evaluate ground-water quality.
Pg 6 Because o f historic ground-water quality data that
exceeds the N.C. 2L Standards, additional ground-
water monitoring wells and water quality assessment
are needed at the site.
Attachment D
Pg 2 The policy of the Solid Waste Section prohibits
field decontaminatiijn of sampling equipment. All
decontamination must be done in a properly equipped
laboratory.
Pg 2 & 3 It is not clear from the monitoring plan if
three to five well volumes are to be purged, or if
"low-flow" purging techniques are to be used, or if
some hybrid me thod is to be employed.
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER
Ecusta Landfill
Page 2
Pg 3 According to the May 1996 edition of EPA' s "Environmental
Investigations Standard Operating Procedures and Quality
Assurance Manual" on page 7-2: "Stabilization (of indicator
parameters) occurs when pH measurements remain constant within
0.1 Standard Unit (SU), specific conductance varies no more
than 10 percent, and the temperature is constant for at least
three consecutive readings". And on page 7-4: "When
peristaltic pumps ... are used, only the intake line is placed
into the water column. The line placed in the water should
be. . . standard-cleaned Teflon tubing, for peristaltic pumps".
Pg 3 For deeper monitoring wells, use of peristaltic pumps will not
be possible. What type of sampling techniques and equipment
will be used for the deeper wells?
Pg 3 The "Appendix I of 40 CFR Part 258" constituent list is for
Municipal Solid Waste Landfill Facilities (MSWLFs) and is not
appropriate for Industrial Ash Monofills.
Pg 3 There are some inconsistences in the plan regarding sampling
frequency for the first two years of sampling.
Pg 4 Low-level approved methods are required for most of the metals
analyses. Regular ICP (Method Number 6010) is not approved
for low-level analyses. "Trace ICP" or "ICP/MS" has been
approved by the NC DWQ Lab Certification program for some of
the laboratories. Table 1 indicates "Total" Chromium. Total
(unfiltered) samples are required for all inorganic and metals
water quality analyses.
Pg 8 Trip blanks and equipment rinsate blanks are generally a
standard part of sampling landfill sites. Equipment rinsate
blanks are not required if dedicated in-place pumps are used
or if certified disposable Teflon hailers are used.
Pg 9 Statistical analyses and other parts of the .1600 rules are
for MSWLFs are not generally required for Industrial Landfill
sites.
General Why are you proposing to discontinue use of the existing
upgradient monitoring well V2 and beginning to use a new
upgradient monitoring well V7?
Attachment A Are Boring Logs available for the newer monitoring
wells that were installed? Was Well V6 advanced to auger
refusal? It was previously indicated the Well V5 was advanced
to near auger refusal. The well log for Well V5B would now
indicate that Well V5 was not terminated at auger refusal.
Ecusta Landfill
Page 3
ASH MONOFILL PERMIT APPLICATION
Pg 3 Shouldn't the date at the end of the first paragraph on pg. 3
be September 2001?
Pg 7 The drawings indicate that additional property is being added
to the previously approved facility boundaries. The siting
requirements, .0503(1), such as a wetlands evaluation, and the
geologic and hydrogeologic study, .0504(1) (c), are required
for this additional property before it can be incorporated
into the facility boundaries.
Pg 9 The hydrogeologic study, . 0504 (1) (c), requires that basic
hydraulic characteristics be determined for "each major
lithologic unit". Representative hydraulic conductivity
values and porosity values (both total porosity and effective
porosity values) need to be provided for each of the distinct
hydrogeologic uni ts, which would include at a minimum the
following: ash fill, finer grained saprolitic soils, coarser
grained saprolitic soils, partially weathered rock (PWR),
finer grained alluvial soils, coarser grained alluvial soils,
and fractured bedrock.
Pg 14 Shouldn't the ground-water flow direction referenced on the
middle of page 14 be southwest, rather than "southeast"?
General Previous references have been made that (the relocated)
Thrash Branch is serving as a ground-water discharge feature.
However there is no discussion or data that supports this
assumption. The only data available, the water table
elevations for the VS well nest, would seem to indicate that
Thrash Branch is not acting as an effective ground-water
discharge feature.
Pg 18 Design Requirements:
The design drawings indicate that the horizontal buffer
requirements are not being met. Most critically, Rule
. 0503 (2) (f) (ii) requires "A 500-foot minimum buffer between
private dwellings and wells and disposal areas". This will
virtually eliminate the Phase 2 area. (Reference Drawing
Number R-728-DS.)
Further evaluation is also needed to demonstrate that the
vertical buffer requirements are being met, as required by
Rule . 0503 (2) (d) (i) . Some of the piezometers indicate that
ground water has risen up into the ash previously landfilled
at the site.
Ecusta Landfill
Page 5
The Log Of Test Boring for PZ-1 and PZ-2R indicate saturated
conditions in portions of the existing ash fill.
Appendix J Please refer to the previous comments regarding the
Groundwater Monitoring Plan in Attachment D of the Ash
Landfill Transition Plan.
In summary, the initial hydrogeologic review has resulted in the
identification of several critical problems in the Ecusta Ash
Landfill application: The additional property to be added to the
facility needs to be thoroughly characterized and evaluated. The
basic hydraulic characteristics for each distinct hydrogeologic
unit present at the site need to be determined. The landfill
design needs to meet the horizontal buffer requirements, especially
the requirement of a minimum 500 foot buffer from residences and/or
wells. All of the new landfill unit needs to be designed with an
acceptable liner. The ground-water model needs to include
calculations for leakage through the liner system and provide well
documented representative input values for the subsurface transport
of contaminants to the relevant point of compliance.
These basic issues need to be resolved in a satisfactory manner
before a more complete hydrogeologic technical review can be
completed. If you have any questions regarding this letter, or
would like to schedule a meeting to discuss these issues, please
contact me at [phone], extension 258.
Sincerely,
~~
Bobby Lutfy
Hydrogeologist
Solid Waste Section
cc: Jim Coffey, Solid Waste Section
Bill Sessoms, Solid Waste Section
Jim Patterson, SWS Asheville Office
David Cody, P.H. Glatfelter -Ecusta Division