9102T_VanceCoTS_LeachateReleaseAssmt_FID1833594_20240404

March 26, 2024

Mr. Ervin Lane
1646 Mail Service Center
Raleigh, NC 27699
RE: Recommended Sampling Plan
Vance County Transfer Station
Henderson, North Carolina

Dear Mr. Lane:

On behalf of GFL Environmental, Smith Gardner, Inc. (S+G) has prepared this Sampling Plan
in response to a suggestion during a DEQ inspection performed on Thursday, March 7th, 2024.
During this inspection, standing water was observed near the southern end of transfer trailer
loading bay. Upon the discovery of the existing concrete and asphalt potentially being broken,
and a repair to the area approved, DEQ representatives recommended the facility collect a
confirmation soil sample to ensure any possibly contaminated soils have been removed. To
respond to this recommendation, we propose the following actions.

Sampling Plan

S+G personnel will mobilize to the site to collect soil samples from the area of concern, shown
on the attached . To evaluate soil quality and determine if potentially impacted soils
have been removed, S+G proposes to collect two (2) discrete grab samples as shown on
.

The soil sample will be collected from a depth between one (1) and two (2) feet below grade.
Soil samples will be analyzed for the Appendix I list of constituents (40 CFR 258 Appendix I),
total phosphorous, sulfate, nitrate and pH by a North Carolina certified laboratory.

Due to the naturally occurring inorganic metals in the soils of North Carolina, S+G will
compare the results from this sample to three background soil samples previously collected
from various upstream sites to evaluate naturally occurring constituents. These locations
(BG-1, BG-2, and BG-3) are also shown on .

As stated above, the background data will be used for comparison to results from soils
adjacent to the transfer station loading bay.

Analytical results will also be compared to the Preliminary Soil Remediation Goals (PSRGs)
for protection of groundwater to evaluate potential impact. If soils are found to be impacted,
additional analysis using the Synthetic Precipitation Leaching Procedure (SPLP) will also be
performed to quantify potential constituent leaching.

DocuSign Envelope ID: CB04ED08-1131-4597-AFF3-65E3034024CA
Mr. Lane
March 26, 2024
Page 2 of 2
Schedule

Due to the location of the soils and their proximity to the building and loading bay, GFL has
scheduled the repair to the area to be concurrent with the collection of the sample. With the
Department’s approval, GFL will implement the sampling plan as early as Friday, March 29,
2024, weather pending.

Reporting

Within 20 business days after receiving the laboratory analytical data, S+G will submit a report
to NCDEQ summarizing sample collection techniques and laboratory analytical data results.
Analytical data will be compared to site background conditions and relevant standards (NC
Soil Preliminary Soil Remediation Goals – Protection of Groundwater). This report will also
include a map of sampling locations, and conclusions.

S+G appreciates your timely review of this response plan and we are prepared to implement it
following approval. If you have any questions or require additional information, please contact
us at 919-828-0577 or by email below.

Sincerely,
SMITH GARDNER, INC.

Lou J. Krasuski Joan A. Smyth, P.G.
Project Manager Senior Hydrogeologist
[e-mail] [e-mail]

Attachments - Figure 1

cc: John Pfleger – GFL Environmental
Randy Deming – GFL Environmental
Jason Watkins - NCDEQ
Drew Hammonds – NCDEQ
Amanda Thompson – NCDEQ

File
H:\Projects\Waste Industries (Vance County Transfer Station)\GFLVANCE 24-1\GFL Vance Sampling Plan.docx
DocuSign Envelope ID: CB04ED08-1131-4597-AFF3-65E3034024CA
3/26/2024
DocuSign Envelope ID: CB04ED08-1131-4597-AFF3-65E3034024CA