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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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LOCATIONS
INACTIVE
SURFACE
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SW-6
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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
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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