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REPORT
PFAS Work Plan
Wake Reclamation, LLC - Brownfield Road C&D Landfill, Permit No. 92-31,
Wake County, North Carolina
Submitted to:
Wake Reclamation, LLC
2600 Brown Field Road
Raleigh, North Carolina 27610
Submitted by:
WSP USA Inc.
5B Oak Branch Drive Greensboro, NC 27407
[phone]
February 20, 2025
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Distribution List

Ervin Lane, Hydrogeologist, Department of Environmental Quality, Division of Waste Management, Solid Waste
Section, 1646 Mail Service Center, Raleigh, North Carolina 27699, [e-mail]. (Electronic Copy)
George Metcalf, Landfill Manager II, Wake Reclamation, LLC, 2600 Brown Field Road, Raleigh, North Carolina
27610, [e-mail], 919-604-2273
Scott Kamp, Facility Manager, Wake Reclamation, LLC, 2600 Brown Field Road, Raleigh, North Carolina 27610,
[e-mail], 919-215-3670
Bryan Wuester, Area Landfill Director, 3301 Benson Drive, Suite 601, Raleigh, NC 27609,
[e-mail]. (Electronic Copy)
John Pfleger, Regional Environmental Compliance Manager, 3301 Benson Drive, Suite 601, Raleigh, NC 27609,
[e-mail]. (Electronic Copy)
Matthew Terrell, Regional Vice President, 3301 Benson Drive, Suite 601, Raleigh, NC, 27609,
[e-mail]. (Electronic Copy)

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Table of Contents

1.0 INTRODUCTION ............................................................................................................................................. 1
2.0 SITE DESCRIPTION ....................................................................................................................................... 1
2.1 Compliance History .............................................................................................................................. 1
2.2 Hydrogeologic Setting .......................................................................................................................... 2
2.3 Sensitive Receptors ............................................................................................................................. 3
3.0 ALTERNATE SOURCES OF PFAS ............................................................................................................... 3
3.1 NRRRF Nitrate Contamination Monitoring and Remediation .............................................................. 4
3.2 Biosolid Application and PFAS Impacts ............................................................................................... 6
3.2.1 PFAS In Soil and Groundwater Following Historical Land Application of Biosolids ....................... 6
3.2.2 Surveillance of PFAS In Sludge and Biosolids At 12 Water Resource Recovery Facilities ........... 7
3.2.3 Preliminary Evaluation of Potential Alternate Sources ................................................................... 7
4.0 FIELD INVESTIGATION ................................................................................................................................. 7
4.1 Groundwater Investigation ................................................................................................................... 8
4.2 Surface Water Investigation ................................................................................................................. 9
5.0 ANALYTICAL METHODS ............................................................................................................................ 10
6.0 REPORT DELIVERABLES ........................................................................................................................... 10
7.0 REFERENCES .............................................................................................................................................. 10

TABLES
Table 1 – Summary of Historical Groundwater Elevation Data in Monitoring Wells
Table 2 – Summary of Estimated Horizontal Flow Velocities

FIGURES
Figure 1 – Site Location Map
Figure 2 – Site Layout Map
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Figure 3 – Groundwater Contour Map, December 2, 2024
Figure 4 – Historical Land Application

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1.0 INTRODUCTION
This PFAS Work Plan has been prepared on behalf of Wake Reclamation, LLC (WR) in response to the Notice of
Regulatory Requirements (NORR) from the North Carolina (NC) Department of Environmental Quality (DEQ)
dated November 22, 2024. The NORR was issued in response to detections of per- and polyfluoroalkyl
substances (PFAS) in groundwater and surface water samples at the Brownfield Road Construction and
Demolition (C&D) Landfill (hereafter, referred to as the Site). The Brownfield Road C&D Landfill is located at
2600 Brown Field Road in Raleigh, NC. The landfill is owned and operated by WR under NC Solid Waste Permit
no. 92-31. As outlined in the NORR, NC DEQ requested that within 90 days of receipt, WR submit a PFAS Work
Plan that include the following:
▪ Groundwater investigation and monitoring
▪ Assessment of groundwater and surface waters to determine the nature and extent of the contamination and
to assess the potential or existence of offsite PFAS migration, either via groundwater or surface water
▪ An anticipated schedule of activities moving forward to include any actions necessary to reduce the direct
discharge to the environment, if applicable.
2.0 SITE DESCRIPTION
The location of the Brownfield Road C&D Landfill is shown on Figure 1. The landfill is located along Brown Field
Road near the town of Garner in Wake County, NC. The Site is located on a parcel approximately 210 acres in
size. Approximately 19 acres are permitted as the Phase 1 waste management unit and approximately 27 acres
are permitted as the Phase 2 waste management unit.
Three northwest-trending unnamed streams traverse the Site to intersect a north-trending unnamed tributary to
the Neuse River that parallels the western property line of the property. The two smaller drainages originate at a
two-acre man-made pond, located south of Phase 2, and at a 4-acre man-made pond, located north of Phase 2,
respectively. The larger stream (i.e., the unnamed tributary of the Neuse River) along the western property
boundary coincides with the location of a regional-scale diabase dike. A constructed storm water basin is located
along the western property boundary of the Phase 1 waste unit, east of the stream.
Based on the topography shown on Figure 2, surface elevations at the Site range from approximately 180 to 320
feet above mean sea level (AMSL). The area where the waste management units are located along the northern
portion of the Site were formerly used by the City of Raleigh (the City) for land application and beneficial reuse
(i.e., fertilizer application) of biosolids (i.e., wastewater sludge) for approximately nine years as described further
in subsequent report sections. Several surrounding parcels upgradient of the Site to the north and east are still
used for this purpose. The unimproved portions of the Site consist of wooded areas, grass, and heavy brush.
2.1 Compliance History
An Alternate Source Demonstration (ASD), approved by the NC DEQ Division of Waste Management (DWM),
Solid Waste Section (SWS) on May 15, 2008, evaluated the source of volatile organic compounds (VOCs; e.g.,
trichlorofluoromethane) in samples collected from MW-3, which is located along the northern Site boundary.
Based on the findings of the ASD, the most likely source of trichlorofluoromethane detected in the samples
collected from MW-3 was landfill gas rather than leachate (WSP 2024). Subsequently, a Landfill Gas
Remediation Plan (LGRP) was submitted to address methane migration in the vicinity of MW-3 and was approved
by NC DEQ on July 1, 2010. As proposed in the LGRP, a cut-off trench was installed prior to the December 2010
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monitoring event. The effectiveness of the corrective measures was to be evaluated two years after the
installation of the cut-off trench, per the requirements of the July 1, 2010, approval letter. The evaluation was
presented in the Second Semi-Annual Water Quality Monitoring Report for 2012. It was determined that based on
the available data and expected groundwater travel times, it was unlikely that the recent samples from MW-3 had
sufficient time to reflect positive effects the cut-off trench may have on groundwater quality. In a letter dated
September 16, 2013, NC DEQ approved an additional three years to re-evaluate groundwater quality at MW-3.
The effectiveness of the cut-off trench was re-evaluated after the December 2015 semi-annual water quality
monitoring event. Based on recent data, the installation of the cut-off trench appears to have positively affected
water quality in the vicinity of MW-3.
During the second semi-annual water quality monitoring event of 2024, tetrachloroethene was detected at a
quantifiable concentration above the NC 2L Groundwater Standard (NC 2L Standard) in samples collected from
MW-2. MW-2 is also located along the northern property boundary. An Assessment Monitoring Work Plan was
submitted on January 16, 2025, in response to this detection.
2.2 Hydrogeologic Setting
Geologically, the Site is located within the southern portion of the Raleigh Belt, which is near the eastern
boundary of the Piedmont Physiographic Province. The bedrock at the Site consists of the granite of the
Rolesville Batholith. The granite observed at the Site is predominantly a medium-grained biotite granite and
biotite-muscovite granite with garnets. Northwest trending Mesozoic diabase dikes are also common in this
region (Stoddard et al. 1991). A magnetometer survey was performed during the initial site investigation and
revealed a regional-scale diabase dike, which is shown on the NC State Geologic Map (NCGS 1985) and
coincides with the stream along the western property boundary. Smaller anomalies were also identified across
the Site and were interpreted to represent smaller dikes (JEI 2001).
The uppermost groundwater beneath the Site is present in a shallow, unconfined aquifer comprised of saprolite,
partially weathered rock, and granitic bedrock (JEI 2001). Groundwater occurs at depths varying between
approximately 25 feet below ground surface (bgs) along the upgradient side of the waste disposal area, and
approximately 10 feet bgs along the downgradient boundary. Groundwater elevations obtained during the second
semi-annual water quality monitoring event in December 2024 are summarized on Table 1 and were used to
prepare a groundwater contour map which is presented as Figure 3.
Surface water and groundwater at the Site generally flow west and northwest, and discharge to the surrounding
tributaries that flow north into the Neuse River. Groundwater beneath the Site flows in three distinguishable and
vertically interconnected hydrogeologic units: saprolite, partially weathered rock, and bedrock.
Based on the December 2, 2024, groundwater contour map, the average hydraulic gradient in the shallow aquifer
underlying the Site, as measured along the conceptual flow path shown on the contour map, was calculated to be
approximately 0.025 feet per foot. Groundwater velocities were calculated using a hydraulic conductivity of
1.20E-04 centimeters per second, which is the geometric mean of the hydraulic conductivities for each of the
hydrogeologic units present at the Site (JEI 2001). The estimated effective porosity of the shallow aquifer is 0.20
(Heath 1982).
Using the above values, the estimated rate of groundwater flow for the uppermost aquifer beneath the Site was
calculated using the following modified Darcy equation:
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𝑉𝑔𝑤=𝐾 𝑥 𝑖
𝑛𝑒

where Vgw = average linear velocity (feet per year), K = hydraulic conductivity (feet per year), i = horizontal
hydraulic gradient, and ne = effective porosity.
The average estimated linear groundwater flow velocity under the waste management unit is approximately 15.7
feet per year, which is consistent with previous estimates (Table 2). The range of groundwater flow is expected to
vary depending on the hydrogeologic unit in which it occurs. The linear velocity equation above makes the
simplified assumptions of a homogeneous and isotropic aquifer. Therefore, this equation represents a likely
average value for the uppermost aquifer and does not account for heterogeneous and/or anisotropic conditions
that may be present in the uppermost aquifer at the Site.
2.3 Sensitive Receptors
A sensitive receptor survey, which included a survey of potable wells, springs, surface water bodies, wetland
features, and surface water intakes within 1,500-feet of the landfill property boundary, was completed by One
Environmental Group (ONE) and submitted to NC DEQ on December 19, 2024 as requested in the November 22,
2024, NORR. Per the Sensitive Receptor Survey completed by ONE, nine potable water wells were identified
within 1,500-feet of the property boundary, the closest of which is approximately 1,200 feet from the edge of the
waste boundary. Of the nine potable water wells identified, three were located upgradient and six were located
downgradient of the landfill. The six downgradient potable water wells are located on the opposite side of the
unnamed tributary of the Neuse River that flows along the western property boundary. As presented, the
unnamed tributary of the Neuse River along the western property boundary coincides with a regional diabase dike
and likely acts as a shallow groundwater divide.
In addition to the potable water wells, four United States Geological Survey (USGS) monitoring wells were
identified during the sensitive receptor survey. However, two of the wells were listed as inactive and were not
located during field reconnaissance completed by ONE and therefore assumed to be abandoned. USGS
monitoring wells are used to evaluate aquifer depth and water quality and are not considered potable receptors
(ONE 2024).
3.0 ALTERNATE SOURCES OF PFAS
In a desktop survey completed as part of this investigation to help determine appropriate PFAS investigation
areas at the Site, several potential alternate sources of PFAS were identified within a one-mile radius of the
Brownfield Road Landfill. These potential alternate sources are presented in detail below.
As presented in Section 2.0, the City operates a nearby Neuse River Resource Recovery Facility (NRRRF),
previously known as the Neuse River Wastewater Treatment Plant (WWTP), to treat wastewater from the
municipalities of Garner, Knightdale, Raleigh, Rolesville, Wake Forest, Wendell, and Zebulon. The NRRRF is
located approximately one mile from the landfill and has operated since 1976. Biosolids generated through the
wastewater treatment process have been land-applied on the surrounding agricultural fields as a beneficial reuse
of the biosolids (i.e., wastewater sludge) since 1980. Land application of biosolids was paused between
September 2002 and September 2013 following the discovery of nitrates in groundwater above the NC 2L
Standard. Currently, the NRRRF manages 75 million gallons of wastewater per day (mgd) and produces 40 dry
tons of biosolids per day. Under the biosolids program, the NRRRF produces and distributes biosolids for land
application to surrounding land permitted for beneficial reuse.
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Biosolids generated by the NRRRF are land applied under Land Application Permit WQ0001730 (the Permit),
which was renewed and reissued in January 2022 and expires April 30, 2028. The Permit allows for the
maximum application of 6,650 dry tons of solids (dts) per year. The monitoring and reporting requirements are
described in Section IV and Appendix A of the Permit and stipulate the analytical parameters and schedule for
testing of the residuals, soils from land application sites, and groundwater from the monitoring well network. In
general, biosolid residuals, soils, and groundwater are routinely tested for metals, nitrate-nitrite as nitrogen,
phosphorus, sodium, pH, pesticides, herbicides, VOCs, and semi-volatile organic compounds (SVOCs). Analysis
for PFAS compounds is not currently required by the Permit and no applicable data were publicly available.
However, since the wastewater influent at the NRRRF comes from numerous municipal and industrial sources it is
very likely that biosolids contain PFAS at detectable concentrations.
In 2023, twenty-three (23) City-permitted fields (field IDs 8, 9, 10, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 44, 45,
46, 47, 48, 70, 511, 519, and 520) spanning 271.4 acres received 2,287,803 gallons of Class B liquid (equivalent
to 282.51 dts), as documented in the 2023 Annual Biosolids Report submitted to NC DEQ on February 20, 2024.
Fields 38, 519, and 520 are located immediately adjacent to and east of the Site (see Figure 4). The biosolids
residuals were tested three times in 2023 (for the constituents noted above); no exceedances of the Ceiling
Concentrations Limits were reported. The soils report did indicate that the concentration of copper and/or zinc in
certain fields have accumulated to levels that may be detrimental to crop production and rotation of those fields
was recommended by the agronomist. The results of groundwater monitoring were reported under separate
cover in accordance with the Permit and the Corrective Action Plan (CAP) for nitrate contamination approved in
July 2006.
As presented, historically, land application fields were located on the Brownfield Road C&D Landfill property.
These are identified as fields 101, 102, 522, 523, and 524 in Figure 4. Biosolids were applied to these fields for
approximately nine years from as early as 1992 through 2001. Land application ceased when the land was sold
to Material Recovery, LLC in 2001. Material Recovery, LLC permitted, developed, and operated the property as a
C&D Landfill until the property was purchased by WR in 2012. One City monitoring well, MW-113D, is located on
the landfill property northwest of the waste management units. MW-113D is sampled by the City three times a
year for analysis of nitrate. MW-113D is a deep aquifer monitoring well and was installed by the City to
approximately 89 feet below ground surface (bgs) in October 2001.
Surface water from the fields located adjacent to the Site, specifically the western parts of fields 519 and 520, is
expected to flow west toward Brown Field Road where it collects in a drainage conveyance ditch that runs along
the road. The conveyance ditch transfers stormwater for discharge into ditches that feed an onsite pond, which
existed prior to landfill development, via a pipe under Brown Field Road (see Figure 2 and Figure 4).
3.1 NRRRF Nitrate Contamination Monitoring and Remediation
Land application of biosolids was temporarily suspended in September 2002 after an ex-employee of the
treatment plant purportedly contacted the Neuse River Foundation Riverkeeper to report that the City had been
over-applying biosolids to the fields. The initial investigation following the overapplication notification focused on
fields 4, 5, 11, 12, 17-22, 47, 48, 74, 75, 519, and 520; however, based on available data, other fields may have
also experienced overapplication. Soil samples collected during the Comprehensive Site Assessment (CSA) from
fields 3, 100, and 500 indicated concentrations of nitrate peak in the 4- to 8-foot depth interval. The maximum soil
nitrate concentrations in field 100 (located on the facility property), were 3 to 4 times above the maximum
concentration found in fields 3 and 500. Subsequent investigations and groundwater quality monitoring data
indicated detections of nitrate above the NC 2L Standard in proximity to and beyond the compliance boundary of
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Raleigh Water-owned application fields (fields 6, 12, 18, 19, 41, 47, 50, 60, 61, 62, 63, 74, 100, 201, 500, and
503). The City paid a $72,500 fine and agreed to remediate the nitrate impacts. A CSA was completed in
December 2002 followed by a Supplemental Site Assessment (SSA) in 2003. In 2005, the CAP was revised and
subsequently approved by NC DEQ on July 19, 2006. Active remediation in accordance with the approved CAP
began in January 2007. In January 2010, the Environmental Management Commission (EMC) granted the City’s
request for a variance from the NC 2L rules but required extensive groundwater and surface water monitoring as
conditions of the variance. As part of the CAP, a monitored natural attenuation (MNA) remedy was approved in
September 2010 based on the variance.
In addition to groundwater, surface water was evaluated by the City for detections of nitrate at various locations
collected from first order tributaries and seeps within biosolids application areas as well as from Beddingfield
Creek and the Neuse River. Nitrate has historically been detected at elevated concentrations in the surrounding
streams and tributaries.
Residential potable wells in the area surrounding the NRRRF biosolids application fields were reportedly impacted
by nitrate above the NC 2L Standard. The City expanded the water system and connected 39 residents to the
municipal water supply and properly abandoned their potable wells. The City also agreed to provide water to the
39 residential properties at no cost for 20 years. Residential properties with potable wells that were located
upgradient or that did not report elevated levels of nitrate remain in place. Ultimately, active remediation of
nitrates was recommended based on groundwater data, flow and transport modeling, and the presence of
downgradient residential properties. A groundwater containment system comprised of extraction wells along the
compliance boundaries for fields 50 and 500 was installed and began operation in January 2007. The recovered
groundwater is collected at a pump station along Old Baucom Road and is discharged at the NRRRF for
treatment. The area of active remediation is located approximately 1.25 miles southeast of the Brownfield Road
C&D Landfill.
Three groundwater and surface water monitoring events were conducted by the NRRRF in March, July, and
November 2023. During each event, 72 shallow and deep monitoring wells were sampled, and 24 surface water
samples were collected. Concentrations of nitrate remain above the NC 2L Standard of 10 milligrams per liter
(mg/L) at 32 shallow monitoring wells and nine deep monitoring wells per the November 2023 monitoring results.
The highest nitrate concentration was recorded at MW-101D at 64.5 mg/L. MW-101D is located at field 30,
approximately 0.75 miles northeast of the Brownfield Road C&D Landfill. Additionally, seven surface water
samples reported concentrations greater than 10 mg/L, including location SW-9, which is located downstream of
the compliance surface water sampling location SW-3 at the Site.
Elevated nitrate concentrations were reported at the monitoring wells and surface water sampling locations
closest to the landfill in 2023, which suggests that current and past application of biosolids is impacting
environmental media in the vicinity of the Brownfield Road C&D Landfill. Nitrate concentrations were reported at
monitoring well MW-113D, located on the landfill property to the northwest of the waste management units,
ranging from 13.64 mg/L to 14.25 mg/L in 2023. Surface water sample location SW-9, located downstream from
the landfill, reported nitrate concentrations ranging from 20.26 mg/L to 22.51 mg/L in 2023. As presented, the
biosolids application fields formerly located on WR property have not been active since the land was sold to
Material Recovery, LLC in 2001. Despite the inactivity over the last 20 years, nitrate concentrations in
groundwater and surface water samples collected by the City from their wells and surface monitoring points on
and in the immediate vicinity of the landfill remain elevated above the NC 2L Standard.
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3.2 Biosolid Application and PFAS Impacts
Biosolids are a recognized potential source of PFAS. On January 14, 2025, the United States (US)
Environmental Protection Agency (EPA) released a draft risk assessment of the potential human health risks
associated with the presence of PFAS compounds in biosolids. The findings of the draft risk assessment show
that there may be human health risks associated with exposure to the “forever chemicals.” Specifically,
perfluorooctanoic acid (PFOA) and/or perfluorooctane sulfonic acid (PFOS), associated with all three common
methods of using or disposing of biosolids including land application. The modeled scenarios include farms with
one application of biosolids at a rate of 10 dry-metric-tons per hectare and 40 consecutive years of biosolids land
application at this same rate (USEPA 2025).
3.2.1 PFAS In Soil and Groundwater Following Historical Land Application of
Biosolids
A study titled Application of WWTP Biosolids and Resulting Perfluorinated Compound Contamination of Surface
and Well Water in Decatur, Alabama, USA was published in 2011 (Lindstrom et al, 2011). This study documented
the land application of PFAS impacted biosolids from a local municipal wastewater treatment plant (WWTP) with
multiple industrial influents. The biosolids from the WWTP were land applied for approximately 12 years resulting
in impacts to groundwater and surface water. The study targeted 10 PFAS including PFOA, PFOS, and
perfluorohexanesulfonic acid (PFHxS). PFOA, PFOS, and PFHxS were detected at concentrations up to 6,410
nanograms per liter (ng/L), 151 ng/L, and 87.5 ng/L, respectively, in groundwater samples and PFOA, PFOS, and
PFHxS were detected at concentrations up to 11,000 ng/L, 83.9 ng/L, and 217.5 ng/L respectively, in surface
water samples. In general, after a comparison of all the date, higher concentrations of PFOA were observed in
groundwater than in surface water and higher concentrations of PFOS were observed in surface water versus
groundwater.
Another study titled Occurrence and Fate of Perfluorochemicals in Soil Following the Land Application of
Municipal Biosolids observed that PFAS concentrations increased linearly with increasing rates of biosolid
applications. These observations were used to develop a model for predicting PFAS concentrations based on
cumulative loading rates in soils amended with biosolids. This study confirmed higher transport rates of short-
chain PFAS in within the soil profile and documented some movement of PFAS within the soil profile over time
(Sepulvado et al, 2011).
Additionally, a study on PFAS in soil and groundwater following historical land application of biosolids was
published in Water Research Edition 211 in 2022 (Johnson 2022). The study evaluated PFAS data collected from
near surface soils, deeper soils in the vadose zone, and immediately underlying groundwater at an agricultural
station with a long record of biosolids applications plus irrigation using treated wastewater.
Thirty-four (34) near surface soil samples were collected during the study and analyzed for 12 target PFAS
compounds. All twelve targeted PFAS compounds were detected at quantifiable concentrations (i.e., 100-percent
detection frequency) in every near surface soil sample collected, with total PFAS concentrations ranging from 73
to 196 micrograms per kilogram (μg/kg).
Soil borings were installed, and samples were collected through the vadose zone to approximately 18 meters
below ground surface (bgs) during well installation. Both PFOA and PFOS were measured at quantifiable
concentrations in the deeper soils of the vadose zone, and in the immediately underlying groundwater located 17
meters bgs. Groundwater concentrations were detected at one to two orders of magnitude less than soil
concentrations, indicating retention in soil systems may be contributing to overall PFAS fate and transport in the
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subsurface. PFOA and PFOS were detected at 29 ng/L and 2 ng/L, respectively, in the groundwater sample
collected in the study (Johnson 2022).
To summarize, there is a well known and recognized relationship between WWTP biosolids and PFAS although
the groundwater data are limited to approximately 10 PFAS compounds. Aside from industrial influents that
contain PFAS, commercial influents (e.g., car washes, commercial launderers, etc.) as well as residential influents
(e.g., laundering of clothing with water resistant sprays or textiles, ski wax, floor finishes, etc.) also contain PFAS.
Biosolids generated through the water treatment process of municipal wastewater with influents from residential,
commercial, and industrial sources have been land applied historically at the Site (prior to Material Recovery,
LLC’s ownership) and both historically and recently on adjacent upgradient/upstream properties.
3.2.2 Surveillance of PFAS In Sludge and Biosolids At 12 Water Resource Recovery
Facilities
A study of PFAS in sludge and biosolids at 12 water resource recovery facilities (WRRF) was published in the
Journal of Environmental Quality in July 2024 (Shubhashini et al, 2024). Samples of pre-stabilized sludge from
primary and secondary treatment processes and samples of biosolids generated after post-stabilization were
collected from WRRFs located in nine states. While the study focused on variability between laboratories and
analytical methods, it also concluded that higher concentrations of PFAS were observed in post-stabilized
biosolids compared to pre-stabilized sludges, regardless of the laboratory or analysis method, even when solids
destruction through solids stabilization was considered.
3.2.3 Preliminary Evaluation of Potential Alternate Sources
As presented, groundwater impacts (i.e., elevated nitrate concentrations) from the beneficial reuse of biosolids via
land application have been observed at the Brownfield Road C&D Landfill. Several industrial permit holders for
the NRRRF include metal finishing, electroplating, industrial laundry, and pharmaceutical manufacturing facilities,
which are potential sources of elevated PFAS as these industries are commonly known to produce PFAS in their
wastewater; these in turn may be present in the biosolids used for land application.
Based on the number of current and/or historical municipal and industrial influent contributors to the wastewater
stream at the NRRRF wastewater treatment works, and the well-documented occurrence of PFAS in materials
from such sources, it is likely that PFAS is currently, and has been historically, present in biosolids generated at
this location during the treatment process. This wastewater from the NRRRF was historically land applied to the
landfill property (prior to Material Recovery, LLC’s ownership) and is still applied on adjacent properties. The
historical and ongoing land application of biosolids from the NRRRF wastewater treatment works has likely
contributed to the detections of PFAS observed in groundwater and surface water at the Site.
4.0 FIELD INVESTIGATION
Per the NORR, a field investigation that includes the characterization and delineation of groundwater and surface
water at the facility is required. The purpose of this section is to summarize the proposed groundwater and
surface water investigation activities. Additional investigation and/or delineation may be required based on the
results of the initial phase of field activities. If additional field investigation is warranted, an addendum to this
PFAS Work Plan will be prepared and submitted to NC DEQ prior to completion of the next phase of the
investigation.
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4.1 Groundwater Investigation
In review of the PFAS groundwater analytical results for this facility, the highest concentrations of PFAS detected
were identified in samples collected from monitoring points along the northern property boundary. As noted
above, historical and ongoing likely sources of relatively low concentrations of PFAS in groundwater and surface
water at the facility likely account for many of the PFAS detections noted elsewhere on Site. As noted above,
there are historical and current low-level VOC impacts at two wells along the northern portion of the facility; the
highest PFAS concentrations detected in groundwater have been at these wells. Therefore, WSP proposes to
focus the groundwater characterization and/or delineation in the northern portion of the Site.
Total PFAS concentrations in groundwater are approximately 2 to 2.5 times higher along the northern boundary
than the PFAS concentrations along the western property boundary. Except for the northern portion of the
property, WR has maintained a detection monitoring program for other groundwater wells.
Groundwater quality issues (i.e., detections of VOCs) historically reported at groundwater monitoring well MW-3,
located along the northern property boundary, were presumably due to landfill gas migration (Golder 2007). In
response to the issues identified prior to the December 2010 water quality monitoring event, assessment
monitoring well AMW-1 was installed to delineated groundwater impacts to the shallow aquifer and a landfill gas
cut-off trench was installed between the waste management unit and MW-3. Following the installation of the
landfill gas cut-off trench, concentrations of VOCs in groundwater decreased in MW-3 and have not been
detected at quantifiable concentrations since 2014.
On January 16, 2025, in response to detections of tetrachloroethene in groundwater samples collected from
MW-2, located along the norther property boundary an Assessment Monitoring Work Plan (AMWP) was submitted
by WR to NC DEQ. The AMWP included the installation of the proposed assessment monitoring well, AMW-2, at
a location downgradient of MW-2 along the northern property boundary. No response to the January 16, 2025,
AMWP has been received to date. In addition to landfill gas impacts, runoff from historical land application on
Field 100 is expected to primarily have occurred in this area as well, see Figure 4.
Monitoring well MW-8 was installed in April 2019 as an additional background monitoring well to further evaluate
inorganic concentrations in groundwater at the Site. Monitoring well MW-8 was sampled over a two-year period
during the first semi-annual monitoring event in 2019 and has not been sampled since June 2021.
To characterize the nature and extent of PFAS in groundwater and to establish trends, WSP proposes to collect
additional samples for analysis of PFAS by EPA Method 1633 from the following monitoring wells on the
scheduled detailed in the table below.
1st Semi-Annual WQM Event 2025 – June 2025 2nd Semi-Annual WQM Event 2025 – December 2025
MW-1, MW-8 (Upgradient)
MW-2, MW-3, AMW-1, AMW-21 (Downgradient)
MW-1, MW-8 (Upgradient)
MW-2, MW-3, AMW-1, AMW-21 (Downgradient)
1st Semi-Annual WQM Event 2026 – June 2026 2nd Semi-Annual WQM Event 2026 – December 2026
MW-1, MW-8 (Upgradient)
MW-2, MW-3, AMW-1, AMW-21 (Downgradient)
MW-1, MW-8 (Upgradient)
MW-2, MW-3, AMW-1, AMW-21 (Downgradient)
1.) AMW-2 was proposed in the Assessment Monitoring Work Plan submitted by WSP to NC DEQ on January 16, 2025.
February 20, 2025 Project No. US0034970.5370

9

WR proposes to complete the groundwater sampling using the same methodology (i.e., low-flow or micro-purge
sampling techniques) and the same equipment (i.e., dedicated bladder pumps) historically used to complete each
monitoring event. To mitigate the risk of cross-contamination the groundwater samples will be collected in
general accordance with Michigan General PFAS Sampling Guidance (EGLE 2024). Clean-hands / dirty-hands
sampling techniques will be utilized. Additionally, non-dedicated sampling equipment (e.g., water-level meter,
water-quality meter, etc.) will be decontaminated between sampling points utilizing Alconox® and a final PFAS-
free water rinse.
Prior to sampling, depth-to-water measurements will be collected from monitoring wells to the nearest 0.01 foot
using an electronic water level indicator prior to purging the wells. Measurements of pH, specific conductivity,
dissolved oxygen (DO), temperature, oxidation-reduction potential (ORP), and turbidity will be recorded at
approximately 3 to 5-minute intervals, depending on the purge rate and flow cell volume. Equipment will be
calibrated in the field per the manufacturer’s instructions at the beginning of each day. In general, the purge rate
will be matched to the yield of the monitoring well, as determined by continuously monitoring the depth to water,
not allowing the purge rate to exceed 500 milliliters per minute. Purging will continue until stabilization is indicated
by the field parameters.
Prior to sampling, the laboratory-supplied sample containers will be prepared. Each sample container will be
labeled with the sample identification number, sampling personnel, date and time of sample collection, project
name and number, and requested chemical analyses. The required groundwater samples will be collected
directly from the discharge lines into the labeled, laboratory-supplied, pre-preserved sample containers after the
stabilization of field parameters. After collection, groundwater samples will be placed in a cooler on ice and
transported under chain-of-custody control to the laboratory for analysis. Field personnel will follow the shipment
guidelines for PFAS samples as provided by the laboratory.
4.2 Surface Water Investigation
To help determine if surface water PFAS impacts at the Site are related to non-landfill activities, additional surface
water samples will be required to characterize run-on impacts. Thus, in addition to groundwater sampling, WSP
proposes to collect surface water samples to be analyzed for PFAS by EPA Method 1633 from four temporary
surface water (TSW) sampling locations in addition to the current compliance surface water sample locations SW-
1, SW-2, and SW-3. The locations of the TSW locations are shown on Figure 2. The table below shows the
proposed surface water sampling schedule.
1st Semi-Annual WQM Event 2025 – June 2025 2nd Semi-Annual WQM Event 2025 – December 2025
SW-1 (Upgradient)
SW-2, SW-3, TSW-1, TSW-2, TSW-3, TSW-4
(Downgradient)
SW-1 (Upgradient)
SW-2, SW-3, TSW-1, TSW-2, TSW-3, TSW-4
(Downgradient)
1st Semi-Annual WQM Event 2026 – June 2026 2nd Semi-Annual WQM Event 2026 – December 2026
SW-1 (Upgradient)
SW-2, SW-3, TSW-1, TSW-2, TSW-3, TSW-4
(Downgradient)
SW-1 (Upgradient)
SW-2, SW-3, TSW-1, TSW-2, TSW-3, TSW-4
(Downgradient)
WR proposes to collect surface water samples directly from the streamflow by lowering the sample containers into
the stream with the opening facing away from the current flow, or by using a decontaminated stainless-steel
dipper, taking care to prevent the overflow of the sample containers and to minimize sample-induced turbidity.
The same sampling and decontamination procedures specified in Section 4.1 will be used to prevent cross-
February 20, 2025 Project No. US0034970.5370

10

contamination during sampling. Following sample collection, field measurements of pH, specific conductivity,
temperature, turbidity, DO, and ORP will be recorded at each sampling location by placing a water quality probe
directly into the stream flow. After collection, groundwater samples will be placed in a cooler on ice and
transported under chain-of-custody control to the laboratory for analysis. Field personnel will follow the shipment
guidelines for PFAS samples as provided by the laboratory.
5.0 ANALYTICAL METHODS
As presented, per the March 13, 2023, memorandum and as clarified in the July 17, 2023, memorandum from the
NC DEQ SWS, WSP proposes to utilize EPA Method 1633 (i.e., 40 PFAS compounds) to analyze PFAS in
groundwater and surface water samples. Groundwater and surface water samples will be submitted to Pace
Analytical (Pace) of Minneapolis, Minnesota (MN) for analysis. For quality assurance (QA) and quality control
(QC), WSP proposes to analyze at least one field blank and method blank for PFAS by EPA Method 1633. The
upgradient groundwater sample collected from MW-1 will act as an equipment blank.
WR will request that the laboratory provide a Level II data report deliverable which will report results to the method
detection limit (MDL). Detections between the method detection limit and the method reporting limit (MRL) will be
reported as estimated concentrations and will be J-flagged by the laboratory. Upon receipt, the data will be
validated in accordance with the US EPA guidelines for data validation.
6.0 REPORT DELIVERABLES
The PFAS results (i.e., laboratory reports and electronic data deliverables) will be reported to NC DEQ with each
corresponding semi-annual water quality monitoring report. Within 120 days of completion of the fourth sampling
event (i.e., tentatively following the 2nd Semi-Annual WQM Event of 2026), WR will submit a report summarizing
the results of the groundwater and surface water sampling. This report will include recommendations for
additional assessment and delineation, if any, and/or may serve as an ASD if additional lines of evidence support
such a conclusion. This report will be submitted under separate cover.
7.0 REFERENCES
City of Raleigh. Annual Biosolids Report, 2023. February 20, 2024.
City of Raleigh. 2023 Annual Monitoring Report, Neuse River Resource Recovery Facility. January 30, 2024.
City of Raleigh. Corrective Action Plan (CAP) for Neuse River Wastewater Treatment Plant Biosolids Application
Fields. February 8, 2005.
City of Raleigh. NPDES Permit Application No. NC0029033 Neuse River Resource Recovery Facility. September
2019.
Golder Associates NC, Inc. (Golder 2007), Material Recovery, LLC C&D Landfill; Alternate Source Demonstration.
November 5, 2007.
Heath, Ralph C., 1982 (Heath 1982), Basic Ground-Water Hydrology, USGS Water Supply Paper 2220.
Joyce Engineering, Inc. (JEI 2001), 2001, Hydrogeologic Report & Groundwater Monitoring Plan; Volume One;
Site Application, Section II; Material Recovery, LLC Construction and Demolition Debris Landfill, Wake
County, North Carolina.
February 20, 2025 Project No. US0034970.5370

11

Johnson, Gwynn R. PFAS In Soil and Groundwater Following Historical Land Application of Biosolids. Elsevier
Waster Research. Issue 2011. March 1, 2022.
Lindstrom, Andrew B., Mark J. Strynar, Amy D. Delinsky, Shoji F. Nakayama, Larry McMillan, E. Laurence Libelo,
Michael Neill, and Lee Thomas. 2011. “Application of WWTP Biosolids and Resulting Perfluorinated
Compound Contamination of Surface and Well Water in Decatur, Alabama, USA.” Environmental Science &
Technology 45 (19):8015-8021. https://doi.org/10.1021/es1039425.North Carolina Department of
Environmental Quality. Final NPDES Permit Renewal Permit NC0029033 Neuse River RRF. Effective August
1, 2020.
Michigan Department of Environment, Great Lakes, and Energy (EGLE 2024), General PFAS Sampling
Guidance. January 2024.
North Carolina Environmental Management Commission (EMC) Department of Environmental Quality (DEQ)
Land Application of Class B Residuals Permit WQ0001730. Granted to City of Raleigh. Issued January 21,
2022.
North Carolina Geological Survey (NCGS 1985), 1985, Geologic Map of North Carolina.
One Environmental Group (ONE 2024), Sensitive Receptor Survey, Wake Reclamation, LLC, Permit No. 9231-
CDLF-2012, Raleigh, NC, 27610, December 19, 2024.
Sepulvado, Jennifer G., Andrea C. Blaine, Lakhwinder S. Hundal, and Christopher P. Higgins. 2011. “Occurrence
and Fate of Perfluorochemicals in Soil Following the Land Application of Municipal Biosolids.” Environmental
Science & Technology 45 (19):8106-8112.
Shubhashini, O., Bell, K., Xu, Z., Wang, Y., Wells, M., Norton, J., Winchell, L., Huang, Q., Li, H. Surveillance of
PFAS in Sludge and Biosolids at 12 Water Resource Recovery Facilities. Journal of Environmental Quality.
July 14, 2024.
Stoddard, Edward F., Farrar, Stewart S., Horton, Jr. J. Wright, Butler, J. Robert and Durhan, Robert M., 1991
(Stoddard et al. 1991), The Eastern Piedmont in North Carolina, in Horton, J. W., Jr., and Zullo, V.A., eds.,
The Geology of the Carolinas: The University of Tennessee Press, p. 59 78.
United States Environmental Protection Agency. Draft sewage sludge risk assessment for perfluorooctanoic acid
(PFOA) and perfluorooctane sulfonic acid (PFOS). Federal Register.
https://www.federalregister.gov/documents/2025/01/15/2025-00734/draft-sewage-sludge-risk-assessment-
for-perfluorooctanoic-acid-pfoa-and-perfluorooctane-sulfonic. January 15, 2025.
WSP USA Inc. (WSP 2024), First Semi-Annual Water Quality Monitoring Report, Wake Reclamation, LLC –
Brownfield Road C&D Landfill, Permit No. 92-31, Wake County, NC, October 18, 2024.
WSP USA Inc. (WSP 2025), Assessment Monitoring Work Plan – Tetrachloroethene at MW-2, Brownfield Road
C&D Landfill, Permit No. 92-31, Wake County, NC, January 16, 2025
February 20, 2025 Project No. US0034970.5370
12
Signature Page
WSP USA Inc.
Matthew D. Scheidt, PG
Lead Consultant
Benjamin S. Draper, PG, PMP
Assistant Vice President
MS/BD/bd
February 2025 Project No. US0034970.5370
Well ID
TOC Elevation
(ft AMSL)
Date Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
Elevation
(ft AMSL)
DTW
(ft)
08/07/02 252.13 27.97 195.39 18.00 191.02 27.41 186.53 15.09 191.82 11.56 ------------------------
06/16/03 257.44 22.66 197.12 16.27 194.98 23.45 191.82 9.80 193.45 9.93 ------------------------
12/01/03 257.32 22.78 197.57 15.82 195.51 22.92 191.98 9.64 194.13 9.25 ------------------------
06/10/04 256.32 23.78 196.91 16.48 194.43 24.00 191.22 10.40 193.43 9.95 ------------------------
12/16/04 255.86 24.24 196.87 16.52 193.82 24.61 190.80 10.82 193.38 10.00 ------------------------
06/05/05 255.88 24.22 196.42 16.97 193.3 25.13 190.23 11.39 193.01 10.37 ------------------------
12/27/05 253.25 26.85 196.18 17.21 191.53 26.90 189.94 11.68 193.38 10.00 ------------------------
06/21/06 253.13 26.97 196.29 17.10 191.96 26.47 189.67 11.95 193.18 10.20 ------------------------
12/01/06 252.26 27.84 196.45 16.94 191.72 26.71 189.54 12.08 193.67 9.71 ------------------------
06/28/07 253.26 26.84 196.31 17.08 192.10 26.33 189.42 12.20 192.83 10.55 ------------------------
12/13/07 250.67 29.43 195.91 17.48 190.70 27.73 188.02 13.60 192.52 10.86 ------------------------
06/19/08 251.07 29.03 195.88 17.51 191.84 26.59 190.01 11.61 192.46 10.92 ------------------------
12/02/08 249.53 30.57 195.88 17.51 190.64 27.79 190.00 11.62 193.09 10.29 ------------------------
01/23/09 --------191.14 27.29 --------------------------------
06/11/09 252.09 28.01 196.17 17.22 191.81 26.62 190.40 11.22 193.38 10.00 ------------------------
12/10/09 251.84 28.26 196.39 17.00 191.31 27.12 191.55 10.07 194.82 8.56 ------------------------
06/15/10 255.14 24.96 196.13 17.26 192.40 26.03 191.20 10.42 193.37 10.01 ------------------------
12/09/10 253.59 26.51 196.00 17.39 191.23 27.20 189.77 11.85 192.56 10.82 ------------------------
06/15/11 253.20 26.90 195.81 17.58 191.22 27.21 190.14 11.48 192.57 10.81 206.81 9.41 206.88 8.56 223.62 13.37 223.54 12.44 --------12/06/11 251.15 28.95 195.84 17.55 190.51 27.92 188.97 12.65 192.60 10.78 206.51 9.71 206.26 9.18 224.11 12.88 224.16 11.82 --------
06/14/12 251.38 28.72 195.88 17.51 191.13 27.30 189.89 11.73 192.57 10.81 207.10 9.12 206.85 8.59 224.39 12.60 224.51 11.47 --------
12/03/12 250.34 29.76 195.81 17.58 190.53 27.90 188.71 12.91 192.37 11.01 206.37 9.85 206.13 9.31 223.97 13.02 224.09 11.89 --------
06/11/13 251.45 28.65 196.53 16.86 191.63 26.80 190.20 11.42 194.19 9.19 208.12 8.10 207.56 7.88 226.42 10.57 226.21 9.77 --------
12/02/13 252.30 27.80 195.85 17.54 191.00 27.43 189.21 12.41 192.61 10.77 207.04 9.18 206.79 8.65 224.22 12.77 224.12 11.86 --------
06/10/14 254.61 25.49 196.02 17.37 192.56 25.87 190.28 11.34 192.56 10.82 207.51 8.71 207.57 7.87 223.59 13.40 223.73 12.25 --------
12/03/14 254.59 25.51 196.07 17.32 191.58 26.85 190.39 11.23 193.01 10.37 207.59 8.63 --------------------
06/08/15 256.45 23.65 196.09 17.30 192.62 25.81 190.49 11.13 192.58 10.80 207.71 8.51 207.49 7.95 224.23 12.76 224.32 11.66 --------
12/02/15 254.96 25.14 196.01 17.38 191.43 27.00 192.53 9.09 193.98 9.40 207.41 8.81 207.14 8.30 224.77 12.22 224.80 11.18 --------
06/07/16 256.43 23.67 195.89 17.50 192.19 26.24 191.86 9.76 192.86 10.52 207.41 8.81 207.32 8.12 223.76 13.23 223.88 12.10 --------
12/13/16 253.99 26.11 195.53 17.86 190.70 27.73 190.15 11.47 192.56 10.82 206.71 9.51 206.49 8.95 223.55 13.44 223.60 12.38 --------06/20/17 253.02 27.08 195.61 17.78 190.93 27.50 190.90 10.72 193.05 10.33 207.28 8.94 207.01 8.43 224.31 12.68 224.28 11.70 --------
11/29/17 252.25 27.85 195.40 17.99 189.97 28.46 189.96 11.66 192.43 10.95 206.21 10.01 206.00 9.44 222.67 14.32 222.31 13.67 --------
06/18/18 252.69 27.41 195.45 17.94 190.59 27.84 190.59 11.03 192.30 11.08 206.51 9.71 206.25 9.19 223.17 13.82 223.24 12.74 --------
12/6-7/18 253.68 26.42 196.38 17.01 191.17 27.26 191.02 10.60 193.39 9.99 207.21 9.01 207.06 8.38 224.23 12.76 224.23 11.75 --------
06/04/19 255.74 24.36 196.17 17.22 192.65 25.78 190.71 10.91 192.49 10.89 207.53 8.69 207.39 8.05 223.35 13.64 223.41 12.57 232.48 14.41 190.19 22.44
12/18/19 254.37 25.73 195.70 17.69 190.61 27.82 190.00 11.62 193.45 9.93 206.92 9.30 206.60 8.84 224.30 12.69 224.25 11.73 232.04 14.85 188.38 24.25
06/02/20 255.35 24.75 195.58 17.81 191.27 27.16 190.40 11.22 192.83 10.55 207.10 9.12 206.97 8.47 223.53 13.46 223.53 12.45 232.17 14.72 189.08 23.55
12/10/20 256.01 24.09 195.69 17.70 191.53 26.90 190.42 11.20 193.36 10.02 207.55 8.67 207.48 7.96 223.90 13.09 223.92 12.06 232.56 14.33 189.65 22.98
06/14/21 256.95 23.15 195.39 18.00 191.73 26.70 189.94 11.68 194.37 9.01 207.21 9.01 207.12 8.32 223.37 13.62 223.39 12.59 232.18 14.71 189.13 23.50
12/20/21 254.65 25.45 195.06 18.33 189.88 28.55 188.32 13.30 192.40 10.98 206.03 10.19 205.57 9.87 221.02 15.97 220.95 15.03 ----187.53 25.10
06/27/22 254.17 25.93 194.99 18.40 189.96 28.47 189.45 12.17 192.33 11.05 205.95 10.27 205.88 9.56 222.91 14.08 222.97 13.01 231.27 15.62 187.67 24.96
12/13/22 252.57 27.53 195.05 18.34 189.68 28.75 190.20 11.42 192.85 10.53 205.69 10.53 205.47 9.97 223.27 13.72 223.30 12.68 230.99 15.90 187.53 25.10
06/13/23 253.35 26.75 195.28 18.11 190.76 27.67 191.62 10.00 192.79 10.59 206.38 9.84 206.30 9.14 224.18 12.81 223.21 12.77 231.54 15.35 188.65 23.98
12/18/23 251.57 28.53 195.11 18.28 189.44 28.99 189.96 11.66 193.31 10.07 206.34 9.88 205.57 9.87 225.04 11.95 223.04 12.94 ----187.20 25.43
06/18/24 251.40 28.70 194.83 18.56 189.91 28.52 190.53 11.09 192.65 10.73 205.90 10.32 205.79 9.65 222.92 14.07 222.95 13.03 230.68 16.21 187.62 25.01
12/02/24 251.61 28.49 194.94 18.45 189.66 28.77 188.74 12.88 192.45 10.93 206.16 10.06 205.91 9.53 223.23 13.76 223.25 12.73 230.87 16.02 187.54 25.09
MEAN 253.58 26.52 195.88 17.51 191.48 26.95 190.17 11.45 193.01 10.37 206.87 9.35 206.63 8.82 223.78 13.21 223.68 12.31 231.68 15.21 188.35 24.28MAXIMUM257.44 30.57 197.57 18.65 195.51 28.99 192.53 15.09 194.82 11.56 208.12 10.53 207.57 9.97 226.42 15.97 226.21 15.03 232.56 16.21 190.19 25.43
MINIMUM 249.53 22.66 194.74 15.82 189.44 22.92 186.53 9.09 191.82 8.56 205.69 8.10 205.47 7.87 221.02 10.57 220.95 9.77 230.68 14.33 187.20 22.44
Notes:
TOC = Top of casing
ft AMSL = Feet above mean sea level
DTW = Depth to water (as measured from TOC)
1)Monitoring well MW-1 is the facility background well.2)Groundwater monitoring wells were re-surveyed by Survey Solutions, PC prior to the June 2014 monitoring event
246.89
AMW-1
212.63280.10 213.39 218.43 201.62 203.38 216.22 235.98236.99215.44
Summary of Historical Groundwater Elevation Data in Monitoring Wells
TABLE 1
MW-1 MW-3MW-2 MW-4 MW-5 MW-6As MW-7AsMW-6Ad MW-7Ad
Wake County, North CarolinaBrownfield Road Construction and Demolition Landfill, Permit No. 92-31
MW-8
Page 1 of 1
February 2025 US0034970.5370
Gradient
Calculation
Segment
Flow
Direction
Gradient
Segment Length
(feet)
Gradient
Segment Elevations
(feet)
Horizontal Gradient
(i, feet/feet)
Effective
Porosity
(ne)
Hydraulic
Conductivity
(K, cm/sec)
Velocity
(Vgw, feet/year)
230
200
250
190
230
200
Notes:
1)Horizontal velocities based on the modified Darcy equation Vgw = Ki/ne.
2)The geometric mean of K from individual well aquifer tests was used to calculate the hydraulic conductivity (tests
conducted by Joyce Engineering Inc. as part of the Site Application, 2001).
3)An effective porosity of 20% was used in velocity calculations.
14.16
NNW
1187
1088
TABLE 2
Summary of Estimated Horizontal Flow Velocities
Brownfield Road Construction and Demolition Landfill, Permit No. 92-31
December 2024
Wake County, North Carolina
i 1
i 2
i 3 0.0276
15.69
17.12
0.20
0.20
1.20E-04
1.20E-04
0.0253NW
NW 2631 0.0228 0.20 1.20E-04
Page 1 of 1
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34970.5370
FIGURE
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2025-02-04
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WAKE RECOVERY / BROWNFIELD ROAD C&D LANDFILL
WAKE COUNTY, NORTH CAROLINA
WAKE RECLAMATIONS, LLC
SITE LOCATION MAP
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2022 QUADRANGLE MAPS FOR GARNER AND CLAYTON OBTAINED FROM USGS
SITE LOCATION
SITE LOCATION
FUTURE
SOUTHERN
DISPOSAL
AREA
PHASE 1A
PHASE 1B
PHASE 1C
PHASE 2B
PHASE 2A
STAGE 2
PHASE 2A
CELL 2
PHASE 2A
CELL 1
LFG-6
LFG-7
LFG-5
LFG-9
LFG-8
LFG-10
LFG-1
LFG-2
LFG-3
LFG-4
MW-3
AMW-1
SW-3
MW-2
MW-8
251.40
MW-1
MW-7ASMW-7AD
MW-6AsMW-6Ad
MW-5
MW-4
SW-2
SW-1
TSW-3
TSW-1
TSW-2
TSW-4
AMW-2MW-113D
CONSULTANT
DESIGN
PREPARED
REVIEW
APPROVED
YYYY-MM-DD TITLE
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34970.5370
FIGURE
20
2025-01-14
SIB
BE
MS
BD
WAKE RECOVERY / BROWNFIELD ROAD C&D LANDFILL
WAKE COUNTY, NORTH CAROLINA
WAKE RECLAMATION, LLC
SITE LAYOUT MAP
EXISTING 10-FOOT GROUND SURFACE CONTOUR
EXISTING 2-FOOT GROUND SURFACE CONTOUR
PROPERTY LINE
APPROXIMATE LIMITS OF WASTE
LANDFILL GAS TRENCH
EXISTING ROAD
LANDFILL GAS MONITORING POINT
GROUNDWATER MONITORING POINT AND GROUNDWATER ELEVATION
SURFACE WATER MONITORING POINT
LANDFILL GAS VENT
TREELINE
TOPOGRAPHIC DIVIDING LINE (SEE NOTE 10)
PROPOSED ASSESSMENT GROUNDWATER MONITORING WELL
(APPROXIMATE LOCATION)
TEMPORARY SURFACE WATER MONITORING POINT
(APPROXIMATE LOCATION)
NRRRF GROUNDWATER MONITORING WELL
(APPROXIMATE LOCATION)
MW-1
SW-3
251.40
1) TOPOGRAPHIC CONTOUR INTERVAL = 2 FEET
2) BASE MAP PROVIDED BY RICHARDSON SMITH GARDNER & ASSOCIATES. TOPOGRAPHY
PROVIDED FROM AERIAL SURVEYS PREPARED BY SURVEY SOLUTIONS P.C., AND COOPER
AERIAL SURVEY COMPANY, PHOTOGRAPHY DATES JANUARY14, 2018, FEBRUARY 05, 2014, AND
JANUARY 22, 2024.
3) LANDFILL GAS MONITORING POINTS AND SURFACE WATER MONITORING POINT LOCATIONS
ARE APPROXIMATE.
4) ELEVATIONS SHOWN IN THIS DRAWING ARE IN FEET ABOVE SEA LEVEL DATUM ("SEA LEVEL
DATUM" REFERS TO THE NATIONAL GEODETIC VERTICAL DATUM (NGVD) OF 1929); AND
COORDINATES ARE EXPRESSED IN TERMS OF THE STATE PLANE COORDINATE SYSTEM.
5) TOPOGRAPHIC DIVIDING LINE SEPARATES BASE MAP TOPOGRAPHIC CONTOURS FROM
UPDATED CONTOURS.
LFG-5
0
FEET
200 400
SCALE
PG C-399
LEGEND
NOTES
TSW-1
AMW-2
MW-113D
WE =200.6
WE =
239.5
WE 268.2
WE 228.1
TANKS
DENSE TREES
ESTIMATED
TANK
RWALL
RWALL
SITE LOCATION
i1
i2
i3
FUTURE
SOUTHERN
DISPOSAL
AREA
PHASE 1A
PHASE 1B
PHASE 1C
PHASE 2B
PHASE 2A
STAGE 2
PHASE 2A
CELL 2
PHASE 2A
CELL 1
250
240
230
220
210
200
190
250
240
230
22
0
21
0
20
0
190
LFG-6
LFG-7
LFG-5
LFG-9
LFG-8
LFG-10
LFG-1
LFG-2
LFG-3
LFG-4
189.66
MW-3
AMW-1
187.54
SW-3
MW-2
194.94
MW-8
230.87
251.61
MW-1
MW-7AS
223.23MW-7AD
223.04
MW-6As
206.16MW-6Ad
205.57
MW-5
192.45
MW-4
188.74
SW-2
SW-1
CONSULTANT
DESIGN
PREPARED
REVIEW
APPROVED
YYYY-MM-DD TITLE
PROJECT No.Rev.
PROJECTCLIENT
Pa
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34970.5370
FIGURE30
2025-02-10
SIB
LR
MS
BD
WAKE RECOVERY / BROWNFIELD ROAD C&D LANDFILL
WAKE COUNTY, NORTH CAROLINA
WAKE RECLAMATION, LLC
GROUNDWATER CONTOUR MAP
DECEMBER 2, 2024
EXISTING 10-FOOT GROUND SURFACE CONTOUR
EXISTING 2-FOOT GROUND SURFACE CONTOUR
PROPERTY LINE
APPROXIMATE LIMITS OF WASTE
LANDFILL GAS TRENCH
EXISTING ROAD
LANDFILL GAS MONITORING POINT
GROUNDWATER MONITORING POINT AND GROUNDWATER ELEVATION
SURFACE WATER MONITORING POINT
LANDFILL GAS VENT
GROUNDWATER SURFACE CONTOURS
APPROXIMATE GROUNDWATER FLOW SEGMENT USED TO CALCULATE
GRADIENT
TREELINE
TOPOGRAPHIC DIVIDING LINE (SEE NOTE 10)
NOT MEASURED
250
i1
MW-1
SW-3
251.61
1) TOPOGRAPHIC CONTOUR INTERVAL = 2 FEET
2) GROUNDWATER SURFACE CONTOUR INTERVAL = 10 FEET
3) GROUNDWATER ELEVATIONS MEASURED ON DECEMBER 02, 2024.
4) GROUNDWATER CONTOURS BASED ON LINEAR INTERPOLATION BETWEEN AND
EXTRAPOLATION FROM KNOWN DATA, TOPOGRAPHIC CONTOURS, AND KNOWN FIELD
CONDITIONS. THEREFORE, GROUNDWATER CONTOURS MAY NOT REFLECT ACTUAL CONDITIONS.
5) GROUNDWATER CONTOUR LINES SHOW THE WATER TABLE SHAPE AND ELEVATION. THESE
CONTOURS ARE INFERRED LINES FOLLOWING THE GROUNDWATER SURFACE AT A CONSTANT
ELEVATION ABOVE SEA LEVEL. THE GROUNDWATER FLOW DIRECTION IS GENERALLY
PERPENDICULAR TO THE GROUNDWATER SURFACE CONTOURS, SIMILAR TO THE RELATIONSHIP
BETWEEN SURFACE WATER FLOW AND TOPOGRAPHIC CONTOURS.
6) BASE MAP PROVIDED BY RICHARDSON SMITH GARDNER & ASSOCIATES. TOPOGRAPHY
PROVIDED FROM AERIAL SURVEYS PREPARED BY SURVEY SOLUTIONS P.C., AND COOPER
AERIAL SURVEY COMPANY, PHOTOGRAPHY DATES JANUARY14, 2018, FEBRUARY 05, 2014, AND
JANUARY 22, 2024.
7) LANDFILL GAS MONITORING POINTS AND SURFACE WATER MONITORING POINT LOCATIONS
ARE APPROXIMATE.
8) ELEVATIONS SHOWN IN THIS DRAWING ARE IN FEET ABOVE SEA LEVEL DATUM ("SEA LEVEL
DATUM" REFERS TO THE NATIONAL GEODETIC VERTICAL DATUM (NGVD) OF 1929); AND
COORDINATES ARE EXPRESSED IN TERMS OF THE STATE PLANE COORDINATE SYSTEM.
9) GROUNDWATER ELEVATIONS FOR MW-6AD AND MW-7AD WERE NOT USED IN THE
CONSTRUCTION OF THE GROUNDWATER CONTOURS SINCE THESE WELLS ARE SCREENED IN
THE BEDROCK AQUIFER.
10) TOPOGRAPHIC DIVIDING LINE SEPARATES BASE MAP TOPOGRAPHIC CONTOURS FROM
UPDATED CONTOURS.
11) N/A = NOT AVAILABLE.
LFG-5
0
FEET
200 400
SCALE
PG C-399
LEGEND
NOTES
NM

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