CCB0057_SwiftCreek_CAUpdate_DIN26975_20161103

ERM NC, Inc.

15720 Brixham Hill Avenue
Suite 120
Charlotte, NC 28277
[phone]
[phone] (fax)

November 3, 2016

NCDEQ – Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attention: Ms. Ellen Lorscheider – Solid Waste Section Chief

Via Email

Reference: Groundwater Corrective Action Plan – Implementation Update
Swift Creek CCB Structural Fill, Battleboro, Nash County
CCB0057

On behalf of ReUse Technology Inc. (ReUse)1, ERM NC, Inc. (ERM) is submitting this letter at your
request to update the schedule for implementation of the approved Swift Creek Coal Combustion
By-Product (CCB) Structural Fill Corrective Action Plan project in Battleboro, North Carolina. This
letter is issued pursuant to a conference call on October 26, 2016 with Jaclynne Drummond
(NCDEQ), Elizabeth Werner (NCDEQ), Tom Wilson (ERM) and David Wasiela (ERM) requested
by NCDEQ. Based on our conference call, we are confirming the following information:

 Implementation of the approved Corrective Action Plan is scheduled to begin in 2016
following a delay mandated b y a previously scheduled NCDOT bridge replacement project
on US Highway 301. Following contracting and preliminary planning activities, a project
schedule for the Corrective Action Plan implementation will be developed and provided to
NCDEQ.
 Due to the recent historic flooding events in the area, groundwater level elevations will be
evaluated prior to commencing on site activities to verify that corrective action measures
may be executed without excessive pumping and water management requirements.
 Based on the approved Corrective Action Plan, results of the Hydrologic Evaluation of
Landfill Performance (HELP) modeling results and existing site & subsurface conditions
(prepared by others), the raising of the CCB fill foundation floor above the seasonal high
water table, the re-grading of a condensed CCB fill footprint and installation of a
geosynthetic liner (cap) system will provide source control measures that should be
effective to mitigate the migration of contaminants from the beneficial fill and allow natural
processes to gradually remediate groundwater quality to acceptable conditions and provide
long term protection for the surrounding environment.
 The geosynthetic liner (cap) system proposed is an industry accepted standard for closure
of municipal solid waste facilities and has proven to be effective at other similar sites in
North Carolina for groundwater and surface water corrective measures.

1 We note that ReUse is not the owner of the Swift Creek site. The owner of the Swift Creek site is Full Circle
Solutions, Inc. (Full Circle). As NCDEQ has previously issued notices and orders pertaining to the Swift Creek site to both
Full Circle and ReUse, ReUse has engaged ERM to implement the Corrective Action Plan, notwithstanding ReUse’s position
that Full Circle agreed in writing to assume all liabilities pertaining to the site when ReUse sold the site to Full Circle in
2003.
Ellen Lorscheider
November 3, 2016
Page 2

 The Corrective Action Plan, dated February 2015, will be implemented as approved by
NCDEQ in its March 12, 2015 correspondence. Before implementing the Corrective Action
Plan, ERM will seek access to the subject property from its current owner, Full Circle, which
as noted herein is not participating in the remediation process.
 Former upgradient monitoring wells MW-5S and MW-5D were abandoned by NCDOT in
order for the US Highway 301 bridge replacement project to occur in 2015-2016. These
wells will be replaced for on-going monitoring as part of the Corrective Action Plan
implementation.
 In accordance with the Corrective Action Plan, routine groundwater and surface water
monitoring and reporting will continue at the Site following construction of the corrective
action remedy to evaluate the effectiveness of the corrective measures. The routine
monitoring will include background water quality monitoring and reporting for the
replacement wells for MW-5S and MW-5D.
 The Swift Creek project is exempt from Federal EPA requirements 40 CFR 257 Subpart D—
Standards for the Disposal of Coal Combustion Residuals based on § 257.50 (d) that states
that the rule does not apply to CCR facilities that have ceased receiving CCR prior to
October 19, 2015.

Please contact us if you have any questions or require additional information.

Sincerely,
ERM NC, Inc.

David W. Wasiela, P.E. Thomas M. Wilson, P.G.
Project Engineer Principal-in-Charge

cc: Jaclynne Drummond - NCDEQ
Elizabeth Werner – NCDEQ
David Franchina – K&L Gates LLP