Loading...
HomeMy WebLinkAbout1101_Buncombe_MSWLF_GWCA_CAPAddendum_FID1878215_20240530CORRECTIVE ACTION PLAN ADDENDUM - PHYTOREMEDIATION OLD BUNCOMBE COUNTY LANDFILL WOODFIN, NORTH CAROLINA Facility Permit Number 1101-MSWLF-1979 UIC Permit No. WI0100353 Prepared For: Buncombe County, North Carolina BLE Project Number J23-14175-10 May 29, 2024 BLE North Carolina Business Licenses C-284 & C-1538 IM 13UNNELL LAMMONS ENruNEERING 6004 Ponders Court I Greenville, 5C 29615 t, 864-288.1265 A 864,286.4330 &R info@ble[orp.rom BLECORP.COM 13UNNELL I � CANNONSNS ENGINEERING May 29, 2024 Buncombe County Solid Waste Department 81 Panther Branch Road Alexander, North Carolina 28701 Attention: Ms. Kristy Smith Subject: Corrective Action Plan Addendum - Phytoremediation Old Buncombe County Landfill Woodfin, North Carolina DWM Permit Number 1101-MSWLF-1979 DWR UIC Permit No. WI0100353 BLE Project Number J23-14175-10 Dear Ms. Smith: Bunnell-Lammons Engineering, Inc. (BLE) is pleased to present this Corrective Action Plan (CAP) Addendum for the Old Buncombe County Landfill located in Woodfin, North Carolina. The CAP Addendum is being submitted in general accordance with North Carolina Rules for Solid Waste Management, [Rules] T15A NCAC 13B .1636 and .1637. The CAP Addendum contained herein includes content required by the cited rule and includes information and technical data germane to the subject site as outlined in the NC Solid Waste Section Guidelines for Corrective Action at Solid Waste Management Facilities (dated 3/07). We appreciate the opportunity to serve as your environmental consultant on this project and look forward to continuing work with you at the Old Buncombe County Landfill. If you have any questions, please contact us at (864) 288-1265. Sincerely, BUNNELL LAMMONS ENGINEERING INC. �ce J. Downes, P.G. Project Geologist Registered, NC #2618 cc: Ms. Jaclynne Dnmunond — DWM-ARO A4,1 Andrew W. Ales der, P.G., RSM Consultant Hydrogeologist Registered, NC #1475 6004 Ponders Court, Greenville, SC 29615 (,864.288.1265 a 864.288.4430 Wg info@hleMrp.com BLECORP.COM 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation May 29, 2024 Old Buncombe County Landfill — Buncombe County, North Carolina BLE Project Number J23-14175-10 TABLE OF CONTENTS 1.0 INTRODUCTION..........................................................................................................................1 1.1 Background Information.................................................................................................................. 1 1.2 Corrective Actions to Date............................................................................................................... 2 1.3 1,4-Dioxane Distribution and Trends............................................................................................... 3 2.0 PLAN FOR THE SUPPLEMENTAL REMEDY....................................................................... 3 2.1 Phytoremediation............................................................................................................................. 3 2.1.1 Fauna Selection.....................................................................................................................4 2.1.2 Implementation..................................................................................................................... 4 2.1.3 Ongoing Monitoring and Maintenance Schedule................................................................. 5 2.1.4 Remedy Timeframe and Institutional Requirements............................................................ 5 2.1.5 Continuation of Approved Remedies.................................................................................... 6 3.0 QUALIFICATIONS...................................................................................................................... 6 4.0 CLOSING.......................................................................................................................................6 5.0 REFERENCES...............................................................................................................................6 Figures Figure 1 Site Location Map Figure 2 Areas of DX Impact Figure 3 Phytoremediation Pilot Areas iofi 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation Old Buncombe County Landfill — Buncombe County, North Carolina 1.0 INTRODUCTION 1.1 Background Information May 29, 2024 BLE Project Number J23-14175-10 Buncombe County provides post -closure care for the Pre -Subtitle D MSWLF (unlined) located at 2726 Riverside Drive, Woodfin, North Carolina (Figure 1). The county operated the facility as a municipal solid waste (MSW), industrial solid waste (ISW), and construction and demolition (C&D) landfill. The landfill is separated into four (4) waste areas labeled A through D. Waste areas A, B, and C stopped receiving waste before October 9, 1991, and waste area D stopped receiving waste on September 27, 1997. Groundwater and surface water monitoring is performed at the site in accordance with a SWS approved Corrective Action Plan (CAP) dated September 3, 2014 [DIN 21838 (SCS Engineers File No 09204072.06)] and a SWS approved Requestfor Reduction ofMNA Parameters dated November 30, 2016 [DIN 27144 (SCS Engineers File No 09204072.14)]. Prior to the second semi-annual sampling event of 2020, BLE submitted (on behalf of Buncombe County) the Report of 1, 4-Dioxane Sampling and Analysis November 2018 to April 2020 dated September 1, 2020 [FID 145059] which included updated groundwater and surface water matrices. The report and updated matrices were approved by the SWS. Buncombe County applied for, and was granted a permit for subsurface injection of materials for enhanced bioremediation of VOCs (chlorinated solvents) in groundwater as part of the correction action at the facility. An underground injection control (UIC) Permit (No WI0100353) was transmitted by the DWR on September 11, 2015. The permit issue date was September 15, 2015. The permit was renewed on September 21, 2020 and expires on August 31, 2025 (effective dates). The facility requires semi-annual groundwater and surface water monitoring and reporting in accordance with the CAP, et seq., and UIC permit. The selected remedies in the approved CAP include Monitored Natural Attenuation (MNA), Institutional Controls, and In Situ Enhanced Bioremediation and Bioaugmentation. The institutional controls included a restrictive cover (landfill cap), fencing, and a landfill gas collection system. Those remedies are described in the project records (prepared by others) and are not part of the CAP Addendum. BLE prepared a Corrective Action Evaluation Report, Water Quality Data Through October 2021 dated March 30, 2022 [FID 1661864 (BLE Project No. J20-14175-03)] as required in the CAP. The CAER documented that chlorinated solvents and other classes of volatile organic compounds (VOCs) present in groundwater have degraded or should continue to degrade. However, trends of a limited number of VOCs (1,4-Dioxane [DX] in particular) indicated that supplemental remedial actions may be beneficial. BLE recommended the evaluation of phytoremediation as a voluntary supplemental remedy to address the subject VOCs. The CAER indicated that the evaluation, remedy selection, and corrective action plans should be prepared and submitted in three (3) phases. The SWS approved the Corrective Action Evaluation Report (CAER) on April 12, 2022 (FID 1664186). BLE completed Phase I of an evaluation of phytoremediation as a voluntary supplemental remedy in 2022 and 2023 and issued a report titled Phytoremediation Assessment Report dated August 23, 2023 (BLE Project No. J22-14175-07). The report concluded that data indicates that phytoremediation is a viable remedy for the VOC impacts to groundwater at the site. The report recommended that the facility proceed directly with Phase II and Phase III of the phytoremediation plan pathway in general accordance with the SWS approved CAER. 1 of 6 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation May 29, 2024 Old Buncombe County Landfill — Buncombe County, North Carolina BLE Project Number J23-14175-10 Phase II was selection of remedy in accordance with the solid waste rules. An executed North Carolina Solid Waste Groundwater Corrective Action Application form was submitted to the SWS to add the voluntary supplemental remedy as required. The SWS approved the selection of remedy in a letter titled Selection of Remedy Phytoremediation (Supplemental Remedy) dated October 27, 2023 [FID 1819776]. Phase III is the submission of this CAP addendum which includes: 1) preparation of design plans; 2) procurement of selected flora; 3) the installation of flora; and 4) ongoing monitoring and maintenance (inspection, testing, and normal horticultural practices). 1.2 Corrective Actions to Date The selected remedies in the approved CAP include Monitored Natural Attenuation (MNA), Institutional Controls, and In -Situ Enhanced Bioremediation and Bioaugmentation. The institutional controls included a restrictive cover (landfill cap), fencing, and a landfill gas collection system. A summary of those selected remedies and their status is as follows: MNA MNA baseline sampling began in October 2014 and was completed in April 2016. SCS requested a reduction of MNA parameters in November 2016 which was denied by the SWS. However, the SWS did approve a reduction in the frequency of MNA sampling to semi-annually every three years beginning in 2019 (2019, 2022, 2025...). The MNA monitoring frequency was subsequently modified as recommended in the CAER, et. Seq. The MNA remedy is in progress. In -Situ Enhanced Bioremediation and Bioaugmentation • Two in -situ enhanced bioremediation events have occurred: a Pre -CAP pilot scale injection in 2007- 2008 and a post -CAP injection in 2015. A bio-treatability study performed by SiREM in 2015 and included in SCS's Monitored Natural Attenuation Sampling Report dated May 5, 2015 (SCS File No. 09204072.14) concluded that bioaugmentation was not necessary at the site. This pilot bioremediation remedy is currently active. Restrictive Cover (Landfill Cap) • All disposal areas have been closed and capped in accordance with permit modifications for closure under 15A N.C. Administrative Code Chapter 13B. This remedy is functionally complete. Fencing • Perimeter fencing has been installed to restrict access to the waste areas. This remedy is functionally complete. Landfill Gas Collection System • An active gas collection system has been installed at the facility and is currently being operated by Buncombe County staff. Landfill gas is collected and incinerated via flare located on the facility. This remedy is active. 2 of 6 1s 1M 1i Corrective Action Plan Addendum - Phytoremediation May 29, 2024 Old Buncombe County Landfill — Buncombe County, North Carolina BLE Project Number J23-14175-10 1.3 1,4-Dioxane Distribution and Trends DX has been detected in fourteen (14) of the twenty-five (25) groundwater monitoring wells and four (4) of the six (6) established surface water monitoring locations at the facility. The locations of DX concentration detections are along the eastern portion of site, on the topographic slope down to the French Broad River, with the exception of an isolated area on the western portion of the site (MW-8, MW-23-119, and SW-10) (Figure 2). The data in the CAER indicated that concentration trends of DX in groundwater monitoring wells MW-3, MW-4A, MW-5, MW-6, MW-6-192, MW-17-60, MW-17-137, and MW-18-78 appear to be increasing. Additionally, the concentration trends of DX in surface water location SW-2A appear to be increasing. Detected concentrations of DX have exceeded the Maximum Contaminant Level, as established in the NCDEQ, Groundwater Classifications and Standards (NC2L) of 3.0 µg/l in fourteen (14) of the groundwater monitoring wells (MW-B, MW-3, MW-4, MW-4A, MW-5, MW-6, MW-6-192, MW-17-60, MW-17-137, MW-18-78, MW-19-75, MW-19-110, MW-21-21, and MW-21-94) during at least one semi-annual sampling event. Detected concentrations of DX have exceeded the North Carolina Surface Water Standards for Class B freshwater under Title 15A Subchapter 2B (NC2B) of 80 micrograms per liter (µg/1) in SW-3 and SW-4 during at least one semi-annual sampling event. 2.0 PLAN FOR THE SUPPLEMENTAL REMEDY 2.1 Phytoremediation Phytoremediation is the general use of plants to remediate environmental media in situ. These processes include: 1) rhizofiltration (absorption, concentration, and precipitation of heavy metals by plant roots); 2) phytovolatilization (removal and dispersal via transpiration); 3) phytoextraction (extraction and accumulation of contaminants in harvestable plant tissues such as roots and shoots); 4) phytotransformation (degradation of complex organic molecules to simple molecules which are incorporated into plant tissues); 5) phytostimulation or plant -assisted bioremediation (stimulation of microbial and fungal degradation by release of exudates/enzymes into the root zone); 6) and phytostabilization (absorption and precipitation of contaminants, principally metals, by plants). These processes may or may not involve periodic harvesting of plants, depending upon method utilized. The approach is applicable to a wide range of organic and inorganic contaminants and is most appropriate for sites where large volumes of groundwater with relatively low concentrations of contaminants must be remediated to strict standards. The technology is most effective where groundwater is within ten feet of the ground surface. Phytoremediation has been documented as an effective remedy for many sites impacted by contaminants of many types including but not limited to VOCs and metals (Landmeyer, 2012). The technology is highly cost- effective and has a low risk of negative environmental impact and/or increased risk of exposure. Phytoremediation is highly effective for sites with shallow groundwater where the plant roots can directly access the groundwater and intercept a contaminant plume. A shallow groundwater table is present at the site in the areas of surface water impacts. Performance of phytoremediation on other areas of the site would be less effective due to deep depths to groundwater and the existence of landfill caps whose integrity would be jeopardized by rooting of the required flora. 3 of 6 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation May 29, 2024 Old Buncombe County Landfill — Buncombe County, North Carolina BLE Project Number J23-14175-10 The remediation of VOC plumes by phytovolatilization processes have been shown to be exceptionally reliable, requiring very little maintenance or post -installation care after the flora are established. In many cases, high-water use flora are selected which depress the water table during water uptake and transfer residual VOCs to the atmosphere through transpiration. Phytoremediation would be reliable as plant uptake can be observed by measuring groundwater level variation and contaminant concentrations in plant tissues. Remediation of DX utilizing phytoremediation occurs through phytovolatilization whereas the plants sequester, translocate, and transpire the contaminant. DX is photodegradated by UV light in the atmosphere once evapotranspired by the plant. Phytoremediation has been documented as a successful remedial option for DX in shallow groundwater conditions ( Ferro et al., 2013). Three (3) areas have been selected for the phytoremediation pilot program. The three (3) areas are set to target SW-2A, SW-3, and SW-4 due to the increasing concentration trend of DX in SW-2A and exceedance of the NC2B in SW-3 and SW-4 (Figure 3). Groundwater in the three (3) phytoremediation pilot program areas ranges from approximately six (6) feet below ground surface (bgs) to twenty-three (23) feet bgs. 2.1.1 Fauna Selection BLE performed a field reconnaissance to assess the condition, type, and efficacy of the existing flora and conducted three (3) rounds of phyto tissue sampling in the DX areas of interest (August 2022, October 2022, and May 2023). The results were documented in a report titled Phytoremediation Assessment Report dated August 23, 2023 (BLE Project No. J22-14175-07). A tree sap composite sample containing sap from a Sycamore, a Hickory, a Maple, and a Birch tree was analyzed and a concentration of DX was detected. The report concluded that the existing fauna are extracting DX from the groundwater and phytoremediation is a viable option as a supplemental remedy. Prior studies performed by others have shown that Hybrid Poplar trees are an effective species for phytoremediation due to growth rate and being phreatophytic (Gordon et. al., 1998, Kafle et. al., 2022). Hybrid Poplar (Populus deltoides x Populus nigra) was selected for phytoremediation implementation at the site to supplement the existing fauna. 2.1.2 Implementation Three (3) areas have been selected for the phytoremediation pilot program (Figure 3). The areas where phytoremediation trees are to be planted will be cleared of competing fauna (grasses, shrubs, saplings, and small diameter trees less than 5 inches). Mature trees (diameter greater than 5 inches) will be left in place to provide slope stability and to continue extracting DX from the groundwater. Strategic removal of selected fauna will provide the planted trees a greater opportunity of successfully rooting during the spring. Two (2) soil samples from each of the phytoremediation pilot program areas (six total samples) will be analyzed for pH, buffer pH, extractable phosphorus, potassium, calcium, magnesium, zinc, manganese, copper, and boron, and sodium and lime requirements prior to the planting of the phytoremediation trees. Requirements for supplemental fertilizer will be assessed based on the soil laboratory results. 4 of 6 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation May 29, 2024 Old Buncombe County Landfill — Buncombe County, North Carolina BLE Project Number J23-14175-10 The Hybrid Poplars will be planted using a dibble or shallow augered hole at a target depth of 1.5 feet or greater on approximate 15-foot centers in the three (3) areas shown on Figure 2. Each pilot program area will be oriented parallel to the stream leading to the target surface water sampling location, extending laterally approximately 30 feet from each side from the stream centerline. Approximately 50 trees per pilot area (150 total) will be planted. Adjustments to the number and locations of trees will be made based on field conditions encountered (e.g., hard soil, rock, steep slopes, existing flora). 2.1.3 Ongoing Monitoring and Maintenance Schedule Semi-annual sampling of the groundwater monitoring wells and surface water locations will continue to be performed each spring and fall. The data from future semi-annual events shall be reviewed to monitor DX concentrations near the phytoremediation areas. Groundwater and precipitation levels shall be monitored during the first year following planting to determine if irrigation is required. Quarterly inspections of the phytoremediation areas shall be conducted and documented to monitor tree growth, competing fauna growth, supplemental irrigation/fertilizing needs, and tree replacement. Inspections will be recorded on an inspection log retained by the facility. Any items noted to be deficient will be addressed to ensure the continued growth of the phytoremediation trees. Tree tissue samples shall be collected and analyzed for DX via EPA Method 8270E (SIM), or equivalent, five (5) years after planting. This will allow the hybrid poplars a sufficient maturation period so that sampling of the tree's tissue is not detrimental to the continued growth of the tree. A second sampling event shall occur after seven (7) years of growth to determine if DX uptake from the groundwater aquifer is still occurring. The results from the 5-Year and 7-Year sampling events will be documented and reported to the SWS as either part of the next CAER or independently as the schedule allows. Potential expansion of the phytoremediation pilot program or development of a full-scale phytoremediation program will be evaluated based on the results obtained. 2.1.4 Remedy Timeframe and Institutional Requirements Phytoremediation will not remediate contaminants in the source area but will act as a living barrier to limit the transport of contaminants already present in the groundwater. The performance of this remedy will not shorten remedial timeframes for groundwater compliance but should control migration of the plume to potential receptors. Phytoremediation used in conjunction with source control measures may shorten times to compliance. We estimate that the time required for soil testing and implementation will require a minimum of 1 year with ongoing assessment at 5- and 7-year intervals as specified in Section 2.1.3. Except for the approval of a phytoremediation remedy by the SWS as part of a CAP (Rule .1637), no other permitting is required. 5 of 6 1s 1m 1i Corrective Action Plan Addendum - Phytoremediation Old Buncombe County Landfill — Buncombe County, North Carolina 2,1.5 Continuation of Approved Remedies May 29, 2024 BLE Project Number J23-14175-10 The approved remedies should continue as the remedial actions for the site. The next evaluation should be performed on data collected during the April 2026 and October 2026 sampling events and the CAER should be submitted in 2027. Plans for renewal or closure of the UIC permit (which expires on August 31, 2025) should be prepared and submitted to the DWR in early 2025 in accordance with the permit requirements. We note that a minimum of one CAER will be prepared and submitted within the initial 5-year phytoremediation implementation period. 3.0 QUALIFICATIONS The approaches used in this CAP Addendum are consistent with those normally employed in environmental remedial projects of this type. Our evaluation of site conditions has been based on our understanding of the site and project information and the data provided to BLE. This CAP Addendum has been prepared on behalf of and exclusively for the use of Buncombe County, North Carolina and shall not, in whole or in part, be used or relied upon by any other parry (excluding the DWM and DWR) without BLE's prior written consent. 4.0 CLOSING We appreciate the opportunity to be of service to Buncombe County, North Carolina. Please contact us at (864) 288-1265 if you have any questions or comments. 5.0 REFERENCES Ferro, A.M., et al., 2013, Phytoremediation of 1,4-dioxane-containing recovered groundwater. International Journal of Phytoremediation, 15(10), 911-923. Gordon, Milton, et al. Phytoremediation of trichloroethylene with hybrid poplars, Environmental Health Perspectives 106.suppl 4 (1998): 1001-1004. Kafle, Arjun, et al., 2022. Phytoremediation: Mechanisms, plant selection and enhancement by natural and synthetic agents, Environmental Advances, Volume 8. Landmeyer, James E., 2012, Introduction to Phytoremediation of Contaminated Groundwater, Historic Foundation, Hydrologic Control, and Contaminant Remediation, Springer Science+Business Media, B.V., New York, NY. 6 of 6 Figures GOLDYIF �� Q 25 `7 � kl=Nmo�� ODFIN 1",pLfA. -SANT HQ Ashelawn Gardens), �Zof Memory/ -morial Garden I 1 I Bus u CPC q\\ ��OLivette-Cem--I-., .. 25 70 O V U 19 e t � rro�� �� ti�U w QOI J� �n0 �4�R0 AL7URq ploy C�Q OLd �Macedonifa r)I l � Cerff 251 N gUDUBON DR 3 O F �' SSUODI, "a p a - F�Q ti10 1.� �o �2° � 13eave,�dairs E1kMourREFERENCES: USGS TOPOGRAPHIC MAP, 7.5 2000 1000 0 2000 4000 i MINUTE SERIES, WEAVERVILLE AND APPROXIMATE SCALE IN FEET LEICESTER. NC. QUADRANGLE 2019 DRAWN: ZJD DATE' 5-13-24 FIGURE IM BUNNELL M LAMMONS SITE LOCATION MAP CHECKED: AWA CAD: BCOLFIOP-SLM M ENGINEERING CLOSED BUNCOMBE COUNTY LANDFILL 6004 Ponders Court, Greenville, SC 29615 WOODFIN, NORTH CAROLINA 1 APPROVED: AWA JOB NO: J23-14175-10 Phone: (864) 288-1265 Fax: (864) 288-4430 '.TION ED BY WATER S LAN D ACTIVE MONITORING WELLS INACTIVE MONITORING WELLS ABANDONED MONITORING WELLS ACTIVE SURFACE WATER SAMPLING LOCATIONS INACTIVE SURFACE WATER SAMPLING LOCATIONS MW-2 MW-12-10 MW-9 SW-1 SW-5 MW-3 MW-13-10 MW-10 SW-2 SW-6 MW-4 MW-14 MW-16 SW-2A SW-7 MW-4A MW-17A MW-17 SW-3 SW-8 MW-5 MW-17B DPL-2 SW-4 SW-9 SW-10 MW-6 MW-18-3 MW-6-192 MW-19-4 MW-7 MW-20-3 MW-8 MW-20-32 MW-12-25 MW-21-4 MW-13-35 MW-22-78 MW-13-132 MW-22-143 MW-15 MW-23-186 MW-17-60 MW-A MW-17-137 M W-17-310 MW-18-78 M W-19-75 MW-19-110 MW-21-21 M W-21-94 MW-23-119 M W-24-45 MW-24-160 DPL-1 MW-B NOTE: ACTIVE SAMPLING MONITORING WELLS AND SURFACE LOCATIONS ARE TO BE SAMPLED AND TESTED TWICE ANNUALLY. INACTIVE MONITORING WELLS ARE TO BE CHECKED FOR DEPTH TO GROUNDWATER ONLY. LEGEND MW-2® ACTIVE GROUNDWATER MONITORING WELL MW-14® INACTIVE GROUNDWATER MONITORING WELL MW-9 ABANDONED GROUNDWATER MONITORING WELL SW-1- ACTIVE SURFACE WATER MONITORING LOCATION SW-54 INACTIVE SURFACE WATER MONITORING LOCATION PROPERTY BOUNDARY SURFACE WATER TOPOGRAPHIC SURFACE CONTOUR IN FEET ABOVE MSL CONTOUR INTERVAL = 10 FEET MONITORING POINT IMPACTED BY 1,4—DIOXANE 250 125 0 250 500 APPROXIMATE SCALE IN FEET REVISIONS No. DESCRIPTION BY DRAWN: ZJD CHECKED: AWA APPROVED: AWA DATE: 5-21-24 CAD FILE: BCOLF-10PDXAREA JOB NO: J24-14175-10 � LAMMONS ENGINEERING 6004 Ponders Court, Greenville, SC 29615 Phone: (864) 288-1265 Fax: (864) 288-4430 AREAS OF 1,4—DIOXANE IMPACT OLD BUNCOMBE COUNTY LANDFILL WOODFIN, NORTH CAROLINA FIGURE NO. 2 MW-2® LEGEND ACTIVE GROUNDWATER MONITORING WELL MW-14® No SW-1- WE INACTIVE GROUNDWATER MONITORING WELL ABANDONED GROUNDWATER MONITORING WELL ACTIVE SURFACE WATER MONITORING LOCATION INACTIVE SURFACE WATER MONITORING LOCATION PROPERTY BOUNDARY SURFACE WATER TOPOGRAPHIC SURFACE CONTOUR IN FEET ABOVE MSL CONTOUR INTERVAL = 10 FEET APPROXIMATE LOCATION OF PHYTOREMEDIATION PILOT AREA 150 75 0 150 300 APPROXIMATE SCALE IN FEET REFERENCES: 1. DRAWING REFERENCE FILE TITLED, "CORRECTIVE ACTION PLAN, OLD BUNCOMBE COUNTY LANDFILL" PROVIDED BY SCS ENGINEERS DATED, SEPTEMBER 3, 2014. 2. GROUNDWATER MONITORING WELLS AND SURFACE WATER POINTS SURVEYED BY ED HOLMES AND ASSOCIATES LAND SURVEYORS, PENNSYLVANIA ON AUGUST 31, 2022. PHYTOREMEDIATION PILOT AREA NOT TO SCALE GNeP�pO �N P �.K sw-zn sw-s I MW ��I�MW-194 m I F MW 19-]5 �( 11 �MW-19-110.�� �- I �00 000 MW IOI MW 20-32 I� MW-21-96 j MW-l'l (DRY)/ / M W 21 21 MW 3 DPL-1 DPL-2 (Abandoned) AREA B AREA C II I� II II II II II II II II I � J 0 MW-9 (Abandoned) v \ \ I 5Y(ANandoned) MW 10 14 MW-16 (Abandoned) I o O f / SW-10 MW- MW 23-119 M W-22-143 MW-23-186 REVISIONS No. DESCRIPTION BY DRAWN: ZJD CHECKED: AWA APPROVED: AWA DATE: 5-21-24 CAD FILE: BCOLF-1OP—Phyto No: J24-14175-10 � LAMMONS ENGINEERING 6004 Ponders Court, Greenville, SC 29615 Phone: (864) 288-1265 Fax: (864) 288-4430 PHYTOREMEDIATION PILOT AREAS OLD BUNCOMBE COUNTY LANDFILL WOODFIN, NORTH CAROLINA FIGURE NO. 3