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Golder Associates NC, Inc. 5B Oak Branch Drive Greensboro, NC. 27407 USA Tel: (336) 852-4903 Fax: (336) 852-4904 www.golder.com Engineering Lic. No. C-2862/Geology Lic. No. C-399 Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation
October 21, 2016 1239-651616.300
Ms. Jackie Drummond
Department of Environmental Quality Division of Waste Management - Solid Waste Section
2090 US Highway 70 Swannanoa, NC 28778
828-296-4706
RE: ASSESSMENT MONITORING NOTIFICATION AND WORK PLAN ADDENDUM
WASTE INDUSTRIES OF HIGH POINT C&D LANDFILL, PERMIT NO. 41-16
GUILFORD COUNTY, NORTH CAROLINA
Dear Jackie:
On behalf of Waste Industries, Golder Associates NC, Inc. (Golder) is submitting the following addendum
to the Assessment Monitoring and Assessment Monitoring Work Plan (Plan), that was submitted to the North Carolina Department of Environmental Quality (NC DEQ) on December 7, 2015, and was approved
by the NC DEQ on January 28, 2016. This addendum is being submitted due to exceedances of the NC 2L Standard for benzene in the samples from downgradient monitoring wells MW-2 and MW-6 during the
second semi-annual water quality monitoring event of 2016. The initial Plan was submitted due to the presence of benzene above the NC 2L Standard in groundwater samples from MW-2.
Based on the analytical results from the second semi-annual water quality monitoring event of 2016, Waste Industries will expand the Assessment Monitoring Program at the Waste Industries of High Point C&D
Landfill to include MW-6. It is Waste Industries’ intent to comply with the requirements of 15A NCAC 13B. 0545.(a) and (b).
15A NCAC 13B .0545(a)(1) and (b)(1):
INSTALLATION OF ADDITIONAL MONITORING POINT:
Rule 15A NCAC 13B .0545(a)(1) requires the installation of at least one additional monitoring well or
methane gas monitoring well at the facility or compliance boundary. Waste Industries intends to install additional groundwater monitoring wells downgradient of MW-2 and MW-6 prior to the January 2017 routine
semi-annual water quality monitoring event, as shown on the attached Drawing 1. The wells will be designated as AMW-1 and AMW-2.
Waste Industries is no longer pursuing the option of adding a surface water monitoring point in lieu of a
groundwater monitoring well downgradient of MW-2, based on data from pore water samples collected during the second semi-annual water quality monitoring event of 2016. These samples indicate there is
limited evidence to support that the stream receives groundwater from the MW-2 location year-round. The pore water results appear to be seasonal, as the February 2016 results supported that the stream receives
groundwater from the MW-2 location.
Additionally, Waste Industries intends to install a methane monitoring well adjacent to MW-2 and the waste
unit to further investigate landfill gas as a source of benzene in groundwater samples from MW-2. Though the headspace of MW-2 is monitored for methane during the quarterly methane monitoring events, the
screened interval of MW-2 is typically submerged. Data collected from the proposed methane monitoring well LFG-1 will be used to help determine the appropriate corrective action to address the benzene
detections in samples from MW-2.
Ms. Jackie Drummond October 21, 2016 Department of Environmental Quality 2 1239-651616.300
NCAC 13B. 0545(a)(2):
NOTIFICATION TO ALL PERSONS WHO OWN LAND OR RESIDE ON LAND WITHIN
THE CONTAMINATE PLUME:
The property adjacent to the northwestern facility boundary near MW-2 is owned by the City of High Point and is utilized as the Kersey Valley Municipal Solid Waste (MSW) Landfill. There are no structures on the
adjacent properties within 700 feet of the property line at MW-2 and no known users of groundwater on the adjacent parcel immediately adjacent to MW-2. A review of recent water quality monitoring reports for the Kersey Valley MSW Landfill indicates that benzene has not been detected in samples from compliance
groundwater monitoring well MW-15, which is located approximately 200 feet northwest of MW-2. Based
on the adjacent land use and because it does not appear that volatile organic compounds (VOCs) occur in groundwater at the property line based on surface water and pore water data, Waste Industries does not
intend to notify the adjacent land owner.
The property adjacent to the western facility boundary near MW-6 is owned by DH Griffin and is utilized for agricultural purposes. There are no structures on the adjacent properties within 700 feet of the property line at MW-6 and no known users of groundwater on the adjacent parcel immediately adjacent to MW-6.
Based on the adjacent land use and because it does not appear that volatile organic compounds (VOCs) occur in groundwater at the property line based on surface water data, Waste Industries does not intend to
notify the adjacent land owner.
15A NCAC 13B .0545(a)(3):
SUBMISSION OF ASSESSMENT MONITORING WORK PLAN:
Waste Industries has submitted an Assessment Monitoring Work Plan as required by Rule and is now providing this addendum to account for the additional NC 2L Standard exceedance of benzene in MW-6.
Once approved by the Division of Waste Management, the addendum will be placed in the facility’s operating record, and all appropriate government officials will be notified.
In order to comply with 15A NCAC 13B .0545 (b), Waste Industries will also complete the following activities:
15A NCAC 13B. 0545(b)(2):
ANALYSIS OF ADDITIONAL PARAMETERS IN GROUNDWATER:
Additional groundwater quality parameters will be performed in downgradient monitoring well MW-6 and proposed assessment wells AMW-1 and AMW-2 during the January 2017 event in accordance to NCAC
13B. 0545(b)(2). A subset of the compliance monitoring wells may be analyzed for Assessment Monitoring Parameters as allowed in 15A NCAC 13B .0545 (b) (6) and data support limited impacts at this time, which
support the subset of wells proposed for Assessment Monitoring. The additional assessment monitoring parameters will include all of the constituents listed in the Appendix II of 40CFR 258 and the required
indicator parameters for C&D landfills (chloride, manganese, sulfate, iron, specific conductance, pH, temperature, alkalinity, total dissolved solids, and tetrahydrofuran). One event for the complete NC
Appendix II list is allowed in 15A NCAC 13B .0545 (b) (6) and is supported by the fact that many of the NC Appendix II parameters (e.g., PCBs, pesticides, and herbicides) are unlikely to be present based on the
acceptable waste in the facility permit. As required by Rule, for any constituent detected in MW-6, AMW-1, and AMW-2 as a result of analyzing the NC Appendix II parameters, a minimum of four independent
samples from the impacted well(s) will be collected and analyzed to establish background for the new constituents. The sampling schedule and list of parameters will proceed as follows:
ENON-MECKLENBURG-CECIL (NC083)
MW-4D
770
780
760
770
780
790
790
800
810
820
830
840780
76
0
750
8
0
0
7
9
0
8
0
0
8
1
0
820
830
840
8
1
0
81
0
810
810
81
0
810
820
8
1
0
800
800
810
820
840
830
820
830
820
810
7
9
0
80
0
790
790
800
790
8
0
0
8
0
0
800
780
790
780
800
800
800
790
800
810
820
830
770
780
760
770
780
780
820
80
0
81
0
85
0
850
790
800
810
820
830
840
780
770
760
750
740
750
74
0
750
730
7
3
0
7
4
0
7
3
0
73
0
74
0
7
5
0
75
0
74
0
760
770
780
830
840
800
790
810
820
7
5
0
760
7
3
0
7
4
0
770
780
790
780
740
750
770
760
74
0
76
0
7
5
0
770
780
780
79
0
780
770
790
79
0
780
790
800
8
0
0
8
1
0
8
1
0
8
0
0
800
80
0
80
0
7
8
0
7
9
0
7
7
0
7
6
0
740
750
760
750
730 740
7
3
0
7
3
0
730
760
750
740
720
720
7
2
0
7
2
0
730
740
720720
7
4
0
7
3
0
7
5
0
74
0
730
750
76
0
77
0
7
8
0
760
770
7
6
0
7
5
0
813.6
811.4
823.3
811.0799.2
817.6
820.4
823.5
810.9
810.3
810.2 811.8
831.1
832.8
820.0
821.1 816.6
WE 792.9'
795.3
795.1
795.5
801.7
804.2
810.4
849.0
849.3
811.4
809.4
809.7 817.1
811.1
809.6
810.7
826.8
798.3
811.0
820.6
804.3
798.9
810.2
797.9
795.4
810.5
804.6
799.3
795.8
801.7
802.9
802.9
800.9802.1
799.1
784.1
784.9
788.8
803.2
801.8
785.4
784.1
850.6
850.4
833.0
830.8
849.5
777.0
753.0
743.3
752.5
744.5
781.3
770.3
779.7
785.7
768.0
772.3
798.3
789.3
784.3
805.0
813.6
809.3
800.1
803.4
802.0
783.0
792.4
744.2
743.7
WE 741.6'
745.1
743.9
740.3
724.1723.2
801.1
809.1
RIP-RAP
RIP-RA
P
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END UNKNOW
601
763.88
78
0
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7
7
0
7
6
0
7
5
0
7
4
0
7
3
0
720
7
2
0
750
760
770
740
730
79
0
7
9
0
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i2
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SW-3
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MW-5
735.75
795.51
737.04
726.89MW-4S
MW-3
MW-1
728.12
747.51MW-2
757.62
MW-8
MW-7S
MW-6
MW-4D
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DRAWING
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2016-10-14
BSD
DYR
DYR
RPK
WASTE INDUSTRIES OF HIGH POINT CONSTRUCTION AND
DEMOLITION DEBRIS LANDFILL AND RECLAMATION FACILITY
GUILFORD COUNTY, NORTH CAROLINA
GROUNDWATER CONTOUR MAP
JULY 14-15, 2016
0
FEET
200 400
SCALE
LEGEND
EXISTING 10' CONTOURS
EXISTING 2' CONTOURS
PROPERTY LINE
STREAM
TREELINE
EXISTING ROAD
PROPOSED OR EXISTING LIMITS OF WASTE
MONITORING WELL LOCATION AND GROUNDWATER ELEVATION
SURFACE WATER MONITORING POINT
BARHOLE PROBE METHANE MONITORING LOCATION
PROPOSED ASSESSMENT MONITORING WELL LOCATION
PROPOSED METHANE MONITORING WELL LOCATION
BENCH MARK
SEDIMENT BASIN
GROUNDWATER SURFACE CONTOURS
GROUNDWATER FLOW SEGMENT USED TO CALCULATE GRADIENTi1
MW-3
SW-1
BM-1
SB-1
760
737.04
1. TOPOGRAPHIC CONTOUR INTERVAL = 2 FEET
2. GROUNDWATER SURFACE CONTOUR INTERVAL = 10 FEET
3. GROUNDWATER ELEVATIONS MEASURED ON JULY 14-15, 2016.
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 CONTOURS 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. THE GROUNDWATER ELEVATIONS FOR MW-4D AND MW-7D WERE NOT USED IN THE
CONSTRUCTION OF GROUNDWATER CONTOURS.
7. DRAWING BASED ON SITE PLAN PLAN PREPARED BY JOYCE ENGINEERING, INC DATED
JULY 7, 2004.
8. UPDATED TOPOGRAPHY PROVIDED FROM AERIAL SURVEY PREPARED BY SURVEYING
SOLUTIONS, P.C., PHOTOGRAPHY DATE JANUARY 13, 2016.
9. PORE WATER SAMPLE LOCATIONS ARE APPROXIMATE.
SITE
SITE LOCATION MAP
NOTES
GOLDER ASSOCIATES NC, INC.
PG C-399
WASTE INDUSTRIES USA, INC.
AMW-1
LFG-1
BH-1