8606_SurryCountyMSWLF_ASD_DIN27391_20161105

Surry County Subtitle D Lined MSWLF
Mt. Airy, North Carolina
November 5, 2016
Permit Number: 86-06
Alternative Source Demonstration-Metals
Prepared for
Municipal Engineering Services Company, P.A.Garner and Boone, North Carolina
MESCO Project Number: G16025.0
P.O. Box 97
Garner, NC 27529
License No. C-0281

November 5, 2016
Ms. Jaclynne Drummond
Solid Waste Section (SWS)
Division of Waste Management/ NCDEQ
2090 US Highway 70
Swannanoa, NC 28778
Re: Alternative Source Demonstration-Metals
Surry County Subtitle D Lined MSWLF
Permit No. 86-06
MESCO Project No. G16025.0
Dear Ms. Drummond,
Introduction
On behalf of Surry County, Municipal Engineering Services Company, P.A. (MESCO) is pleased to
present this Alternative Source Demonstration (ASD) for metals detected in groundwater samples at the
Surry County Subtitle D Lined Municipal Solid Waste Landfill (MSWLF). NC Solid Waste Rule 15A
NCAC 13B .1634 (f)(2) provides that an owner/operator may demonstrate that a source other than a
MSWLF unit caused the exceedance of the groundwater protection standards, or the exceedance resulted
from error in sampling, analysis, or natural variation in groundwater quality. The NC Solid Waste
Section required, through a letter (DIN:26557) dated August 8, 2016, that either an ASD for metal
exceedances be approved or assessment monitoring should be implemented. Assessment monitoring has
already been initiated at the lined landfill in response to detections of volatile organic compounds
(VOCs). This ASD may potentially aid in future decision making concerning the scope of assessments
and/or corrective actions. This ASD provides six lines of evidence supporting that the source of observed
metals at certain concentrations is from natural variation and not from a landfill release. We request that
the SWS approve this ASD and by doing so, not require assessments or corrective actions for levels of
metals that conform to an established statistical criteria, described herein.
Background
The Surry County Subtitle D Lined MSWLF, permit #86-06, is located at 237 Landfill Road, Mount Airy,
North Carolina. The Surry County Subtitle D lined Landfill currently consists of two Phases (1&2) that
are contiguous thus monitored and reported together. The lined landfill initiated site-wide assessment
monitoring in June 2016 in response to detections of VOCs in downgradient wells MW-2, MW-6R and
MW-9S. A recent potentiometric map with monitoring well locations is shown on Sheet 1.
Water quality at this facility has been monitored at least semi-annually since prior to commencement of
operations in 1998 with all historical data reviewed in support of this ASD. Both phases have had a
baseline established by four independent events performed within the first six months of operations
including at least one prior to opening. Baseline water quality monitoring reports were prepared for both
Phases and previously submitted to the SWS (DIN:12909).

Formulation of this ASD involved a review of site specific literature which confirms that the site
conceptual model developed in support of the site’s water quality monitoring plans remain valid.
Comparisons of dissolved metals to total metals were made. A simple statistical comparative analysis
using historical site-wide groundwater data upgradient and downgradient of the landfill and comparisons
to leachate quality were made. The evidence reviewed in support of this ASD concluded that metals are
naturally inherent in the geochemistry of the fractured rock aquifer system.
The site has correctly characterized the hydrogeology over a significant period of time and has an
appropriate number of monitoring wells in place to determine site background conditions. The
upgradient well accurately reflect the concentrations of metals naturally present in the aquifer on site.
At the lined landfill the downgradient results are believed to be a valid reflection of aquifer metal
concentrations at all locations, except for potentially the wells impacted by VOCs. Metal concentrations
have remained stable over time suggesting that the landfill is likely not affecting the natural geochemistry
of the downgradient aquifer. Basically, if the landfill was not there, one would expect to still observe the
same metal concentrations.
Leachate and LFG is a complex mix of mobile compounds. When there is a release, the more mobile
compounds such as VOCs would be detected in the wells before the much less mobile total metals.
Therefore, VOCs may serve as a much better indicator of a release than total metals. Metals were
originally intended to serve as an indicator parameter before low level VOC testing was readily available.
Today quantification of metals is less useful especially downgradient of modern lined landfills. Leachate
and landfill gas may change the geochemistry resulting in increased levels of metals but our experience
has shown that low level VOCs will be detected before an increase in metals is noticed. Since portions
of the aquifer downgradient of the landfill have been impacted by VOCs, the altered geochemistry may
solubilize greater quantities of metals. These areas remain under assessment monitoring. If corrective
action is implemented, focus should be centered on VOCs based on the premise that the metals are natural
but can precipitate in response to the release. Remediation of the leachate and/or LFG has the potential to
collaterally reduce metal concentrations.
In the spring of 2013 groundwater samples MW-12 and MW-13 and in the fall of 2016 MW-9S were
tested for both dissolved metals (lab filtered) and total metals (no filtration). Aqueous phase dissolved
metals comprised between 7% and 78% of total metals Table 1. These findings are consistent with other
sites across NC and also expected to be consistent at other on site wells. The fact that the NC SWS
requires samples to be analyzed for non-filtered total metals but also be compared to NC 2L Standards for
regulatory compliance lends itself to higher prevalence of exceedances. This is because NC Department
of Water Resources refers to the 2L Standards as the total concentration “of any constituent in a
dissolved, colloidal or particulate form which is mobile in groundwater. This does not apply to sediment
or other particulate matter which is preserved in a groundwater sample as a result of well construction or
sampling procedures”.
Total metal concentrations may also appear elevated due to the reaction of acid preservatives and
sediment which may be entrained in the sample containers, as metal solubility is conversely related to
pH. Unpreserved samples would likely be more appropriate to use to quantify aqueous phase metal
concentrations. Extended hold times are unnecessary; however, preservation of samples is required to
conform to laboratory methods.
Well purging prior to sampling involves removal of three well-casing volumes. This action if performed
at high flow rates may stir up metal particulates in well casings and/or neighboring formations, which, in
turn, can potentially lead to elevated total metals results. Since levels of total metals are strongly
correlated to sample turbidity levels, we have transitioned to using sampling methods that minimize
turbidity such as using low-flow sampling and gentler bailing techniques which should yield more
representative results.
2
Each inorganic constituent listed in 40 CFR Subpart 258 Appendix I is a naturally occurring metal. All
Appendix I metals have historically been detected at this facility. Chromium and vanadium are the most
common metals detected above regulatory compliance Standards. Metal detections are largely
inconsistent and concentrations are not increasing over time. This ASD pertains to all Appendix I metals
which include:
antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, nickel,
selenium, silver, thallium, vanadium and zinc
The research performed in support of this report suggests that any Appendix I metal which deviates from
a specific concentration listed on the Metals Concentration Evaluation Table (Table 2) should be able to
differentiate between natural variation and a landfill release, which is explained below.
Proposed Metals Evaluation Procedure
An ASD should not be perpetually and unconditionally valid since metal concentrations may increase
over time which actually may originate or be indicative of a MSWLF release. Rather than
indiscriminately claim all future metals originate from an alternative source, we propose a simple
constructive statistical data evaluation process based on observed concentrations that are summarized in a
table which will be used for comparisons during future events.
A summary of data collected to build the Metals Evaluation Table (Table 2) is outlined below. Graphs of
the highest concentrations of metals observed during the baseline period (intrawell), highest levels ever
recorded within the background well (interwell) and the highest ever observed in leachate samples is also
attached.
1. Intrawell Baseline Comparsion.
Of the samples collected during the baseline period every metal except for antimony and selenium were
detected at least once and 8 of the 13 detected metals (62%) exceeded their respective current 2L/GWP
Standard at least once. The baseline reports and analytical data were evaluated and no seasonal or
cyclical variance was noticed. The highest metal concentration observed at each respective well was
placed in the table. This value is considered as the baseline for each respective well. These baseline
levels represent natural conditions as if the landfill was never constructed. The baseline value is fixed
and should never change.
2. Interwell Background Comparison.
Samples collected from the upgradient background well (MW-1) over the entire period of record (18
years) contained every Appendix I metal except for silver at least once. Nine of the fourteen (64%)
detected metals have exceeded the current 2L/GWP Standard. All historical data from the background
well was evaluated with no outliers suspected and the highest observed metal concentrations were
inserted into the table. This value is considered background and represents conditions hydraulically
upgradient of the landfill and is also representative of water quality that will eventually migrate to
downgradient wells. The background metal concentrations will be updated in the table if unprecedented
levels are observed.
3. Leachate Comparison
Samples of untreated leachate have historically contained ten of the fifteen (67%) Appendix I metals with
40% of the metals eclipsing their respective 2L/GWP Standard at least once. Several potential statistical
outlier concentrations were observed. Since leachate quality is highly variable, a conservative approach
was used which retained all data. Since a leachate release will attenuate and dilute with groundwater a
dilution attenuation factor (DAF) was assigned to the metal concentrations observed in the leachate
samples. A DAF of 20:1 was chosen based on the US EPA default value and the dilution factor used in
the Synthetic Precipitation Leach Procedure (SPLP; EPA Test Method 1312). After applying the DAF
3
the only metal detected in a leachate sample above a 2L/GWP Standard (0.28 uq/L) was thallium (2.9
uq/L) which would be below the SWSL thus “j-qualified”. Most of the historical and all of the most
recent inorganic contaminants could not have resulted from the MSWLF given that leachate
characteristics are generally lower in concentration compared to groundwater samples. Metal
concentrations in the leachate are also generally much lower at this facility compared to published
leachate values from other facilities EPA 1. The metal concentrations from leachate samples will be
perpetually updated when unprecedented values are reported.
The statistical evaluation process will entail comparison of every metal detected in a concentration above
a groundwater Standard to values on the Metals Evaluation Comparison Table 2 which contains the:
1. Highest observed level in particular well (Intrawell).
The highest level observed during its own respective baseline period within the first six months of
operation.
2. Highest observed level in background well (Interwell).
The highest level ever detected in the background well(s) encompassing the entire historical data set..
3. Highest leachate concentration ever observed (Leachate).
The highest level ever calculated based on observed levels of untreated leachate following a DAF.
If the observed metal concentration does not exceed the interwell, intrawell or is above the DAF
adjusted leachate level the metal can be considered to be from a source other than the landfill.
Through implementation of the proposed statistical evaluation, the source of future metal detections could
be effectively and quickly determined as either natural or anthropogenic.
Conclusion
In conclusion, the six lines of evidence to support that natural variation, rather than a MSWLF release, is
the source of metals at specific levels documented within this ASD, is summarized as:
1. An alternate source of metals exist which is natural variation from erosion of native deposits.
Concentrations of total metals may be artificially elevated due to the reaction of solids with acid
preservatives in the container which is required by the laboratory method.
2. A hydraulic connection between the metallic minerals associated with the upper regolith and
metamorphic bedrock that comprise the uppermost aquifer exists. The background well is hydraulically
upgradient and contain species of metals and at comparable or higher concentrations as detected
downgradient.
3. Metals are naturally inherent in the upper bedrock aquifer which underlay the facility along all flow
paths including downgradient of the landfill.
4. Metal concentrations were elevated during the baseline period established through the four events
during the initial first six months operation. Metals would be elevated regardless of the presence of the
landfill. Numbers of metal detections and concentrations have generally remained stable or decreased
over time.
5. Dissolved phase metal concentrations have been significantly lower compared to total metals. The
composite liner system should inhibit metal particulate (total metals) from migrating downgradient
allowing only dissolved phase metals to become mobile.
6. Metals likely did not originate from leachate. The vast majority of metals detected in groundwater
samples are higher compared to leachate samples and only a “j-qualified” concentration of thallium
would be above the 2L/GWP Standard after applying a conservative dilution attenuation factor.
4
A metals evaluation table will be used as a comparative analysis tool going forward to differentiate
natural variation from an anthropogenic source. For clarity, the specific rational(s) for discounting the
metal exceedance will be identified as the preliminary cause in the exceedance summary table contained
in the associated semi-annual monitoring report. An example of a table of detections, taken from the
most recent semi-annual monitoring event, which clarifies that all metal exceedances were below their
own intrawell baseline, below the interwell background levels and/or above the leachate levels is shown
as Table 3. As a contingency, if a metal concentration exceeds a 2L/GWP Standard fails to satisfy any of
the three criteria, further empirical evidence will be evaluated such as dissolved metal analysis and/or
further verification sampling. If further data suggests the metal concentration may be attributed to a
release, additional assessment will be initiated to determine the source which may necessitate another
ASD.
Closing
Surry County landfill management is dedicated to environmental quality and strives to achieve this by
maintaining compliance with all governmental regulations. Sampling methodologies will continue to be
improved to reduce turbidity levels so samples are more representative of mobile metals. If the division
approves this ASD a copy shall be placed in the operating record. If you have any questions regarding
this ASD, please contact us at [phone] or by email at [e-mail].
Sincerely,
MUNICIPAL ENGINEERING SERVICES CO., P.A.
Jonathan Pfohl Steven R. Gandy, Ph.D, P.E.
Environmental Specialist Senior Project Manager
Enclosures

cc: Mr. Dennis Bledsoe
Surry County

1 1988 EPA document-Summary of Data on MSWLFLeachate Characteristics – EPA/530-SW-88-038
5
Formulation of this ASD involved a review of site specific literature which confirms that the site
conceptual model developed in support of the site’s water quality monitoring plans remain valid.
Comparisons of dissolved metals to total metals were made. A simple statistical comparative analysis
using historical site-wide groundwater data upgradient and downgradient of the landfill and comparisons
to leachate quality were made. The evidence reviewed in support of this ASD concluded that metals are
naturally inherent in the geochemistry of the fractured rock aquifer system.
The site has correctly characterized the hydrogeology over a significant period of time and has an
appropriate number of monitoring wells in place to determine site background conditions. The
upgradient well accurately reflect the concentrations of metals naturally present in the aquifer on site.
At the lined landfill the downgradient results are believed to be a valid reflection of aquifer metal
concentrations at all locations, except for potentially the wells impacted by VOCs. Metal concentrations
have remained stable over time suggesting that the landfill is likely not affecting the natural geochemistry
of the downgradient aquifer. Basically, if the landfill was not there, one would expect to still observe the
same metal concentrations.
Leachate and LFG is a complex mix of mobile compounds. When there is a release, the more mobile
compounds such as VOCs would be detected in the wells before the much less mobile total metals.
Therefore, VOCs may serve as a much better indicator of a release than total metals. Metals were
originally intended to serve as an indicator parameter before low level VOC testing was readily available.
Today quantification of metals is less useful especially downgradient of modern lined landfills. Leachate
and landfill gas may change the geochemistry resulting in increased levels of metals but our experience
has shown that low level VOCs will be detected before an increase in metals is noticed. Since portions
of the aquifer downgradient of the landfill have been impacted by VOCs, the altered geochemistry may
solubilize greater quantities of metals. These areas remain under assessment monitoring. If corrective
action is implemented, focus should be centered on VOCs based on the premise that the metals are natural
but can precipitate in response to the release. Remediation of the leachate and/or LFG has the potential to
collaterally reduce metal concentrations.
In the spring of 2013 groundwater samples collected from MW-12 and MW-13 were tested for both
dissolved metals (lab filtered) and total metals (no filtration). Aqueous phase metals comprised between
22% and 93% of total metals and all dissolved concentrations were below established applicable
regulatory Standards Table 1. These findings are consistent with other sites across NC and also expected
to be consistent at other on site wells. The fact that the NC SWS requires samples to be analyzed for
non-filtered total metals but also be compared to NC 2L Standards for regulatory compliance lends itself
to higher prevalence of exceedances. This is because NC Department of Water Resources refers to the
2L Standards as the total concentration “of any constituent in a dissolved, colloidal or particulate form
which is mobile in groundwater. This does not apply to sediment or other particulate matter which is
preserved in a groundwater sample as a result of well construction or sampling procedures”.
Total metal concentrations may also appear elevated due to the reaction of acid preservatives and
sediment which may be entrained in the sample containers, as metal solubility is conversely related to
pH. Unpreserved samples would likely be more appropriate to use to quantify aqueous phase metal
concentrations. Extended hold times are unnecessary; however, preservation of samples is required to
conform to laboratory methods.
Well purging prior to sampling involves removal of three well-casing volumes. This action if performed
at high flow rates may stir up metal particulates in well casings and/or neighboring formations, which, in
turn, can potentially lead to elevated total metals results. Since levels of total metals are strongly
correlated to sample turbidity levels, we have transitioned to using sampling methods that minimize
turbidity such as using low-flow sampling and gentler bailing techniques which should yield more
representative results.
2
Each inorganic constituent listed in 40 CFR Subpart 258 Appendix I is a naturally occurring metal. All
Appendix I metals have historically been detected at this facility. Chromium and vanadium are the most
common metals detected above regulatory compliance Standards. Metal detections are largely
inconsistent and concentrations are not increasing over time. This ASD pertains to all Appendix I metals
which include:
antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, nickel,
selenium, silver, thallium, vanadium and zinc
The research performed in support of this report suggests that any Appendix I metal which deviates from
a specific concentration listed on the Metals Concentration Evaluation Table (Table 2) should be able to
differentiate between natural variation and a landfill release, which is explained below.
Proposed Metals Evaluation Procedure
An ASD should not be perpetually and unconditionally valid since metal concentrations may increase
over time which actually may originate or be indicative of a MSWLF release. Rather than
indiscriminately claim all future metals originate from an alternative source, we propose a simple
constructive statistical data evaluation process based on observed concentrations that are summarized in a
table which will be used for comparisons during future events.
A summary of data collected to build the Metals Evaluation Table (Table 2) is outlined below. Graphs of
the highest concentrations of metals observed during the baseline period (intrawell), highest levels ever
recorded within the background well (interwell) and the highest ever observed in leachate samples is also
attached.
1. Intrawell Baseline Comparsion.
Of the samples collected during the baseline period every metal except for antimony and selenium were
detected at least once and 8 of the 13 detected metals (62%) exceeded their respective current 2L/GWP
Standard at least once. The baseline reports and analytical data were evaluated and no seasonal or
cyclical variance was noticed. The highest metal concentration observed at each respective well was
placed in the table. This value is considered as the baseline for each respective well. These baseline
levels represent natural conditions as if the landfill was never constructed. The baseline value is fixed
and should never change.
2. Interwell Background Comparison.
Samples collected from the upgradient background well (MW-1) over the entire period of record (18
years) contained every Appendix I metal except for silver at least once. Nine of the fourteen (64%)
detected metals have exceeded the current 2L/GWP Standard. All historical data from the background
well was evaluated with no outliers suspected and the highest observed metal concentrations were
inserted into the table. This value is considered background and represents conditions hydraulically
upgradient of the landfill and is also representative of water quality that will eventually migrate to
downgradient wells. The background metal concentrations will be updated in the table if unprecedented
levels are observed.
3. Leachate Comparison
Samples of untreated leachate have historically contained ten of the fifteen (67%) Appendix I metals with
40% of the metals eclipsing their respective 2L/GWP Standard at least once. Several potential statistical
outlier concentrations were observed. Since leachate quality is highly variable, a conservative approach
was used which retained all data. Since a leachate release will attenuate and dilute with groundwater a
dilution attenuation factor (DAF) was assigned to the metal concentrations observed in the leachate
samples. A DAF of 20:1 was chosen based on the US EPA default value and the dilution factor used in
the Synthetic Precipitation Leach Procedure (SPLP; EPA Test Method 1312). After applying the DAF
3
the only metal detected in a leachate sample above a 2L/GWP Standard (0.28 uq/L) was thallium (2.9
uq/L) which would be below the SWSL thus “j-qualified”. Most of the historical and all of the most
recent inorganic contaminants could not have resulted from the MSWLF given that leachate
characteristics are generally lower in concentration compared to groundwater samples. Metal
concentrations in the leachate are also generally much lower at this facility compared to published
leachate values from other facilities EPA 1. The metal concentrations from leachate samples will be
perpetually updated when unprecedented values are reported.
The statistical evaluation process will entail comparison of every metal detected in a concentration above
a groundwater Standard to values on the Metals Evaluation Comparison Table 2 which contains the:
1. Highest observed level in particular well (Intrawell).
The highest level observed during its own respective baseline period within the first six months of
operation.
2. Highest observed level in background well (Interwell).
The highest level ever detected in the background well(s) encompassing the entire historical data set..
3. Highest leachate concentration ever observed (Leachate).
The highest level ever calculated based on observed levels of untreated leachate following a DAF.
If the observed metal concentration does not exceed the interwell, intrawell or is above the DAF
adjusted leachate level the metal can be considered to be from a source other than the landfill.
Through implementation of the proposed statistical evaluation, the source of future metal detections could
be effectively and quickly determined as either natural or anthropogenic.
Conclusion
In conclusion, the six lines of evidence to support that natural variation, rather than a MSWLF release, is
the source of metals at specific levels documented within this ASD, is summarized as:
1. An alternate source of metals exist which is natural variation from erosion of native deposits.
Concentrations of total metals may be artificially elevated due to the reaction of solids with acid
preservatives in the container which is required by the laboratory method.
2. A hydraulic connection between the metallic minerals associated with the upper regolith and
metamorphic bedrock that comprise the uppermost aquifer exists. The background well is hydraulically
upgradient and contain species of metals and at comparable or higher concentrations as detected
downgradient.
3. Metals are naturally inherent in the upper bedrock aquifer which underlay the facility along all flow
paths including downgradient of the landfill.
4. Metal concentrations were elevated during the baseline period established through the four events
during the initial first six months operation. Metals would be elevated regardless of the presence of the
landfill. Numbers of metal detections and concentrations have generally remained stable or decreased
over time.
5. Dissolved phase metal concentrations have been significantly lower compared to total metals. The
composite liner system should inhibit metal particulate (total metals) from migrating downgradient
allowing only dissolved phase metals to become mobile.
6. Metals likely did not originate from leachate. The vast majority of metals detected in groundwater
samples are higher compared to leachate samples and only a “j-qualified” concentration of thallium
would be above the 2L/GWP Standard after applying a conservative dilution attenuation factor.
4
A metals evaluation table will be used as a comparative analysis tool going forward to differentiate
natural variation from an anthropogenic source. For clarity, the specific rational(s) for discounting the
metal exceedance will be identified as the preliminary cause in the exceedance summary table contained
in the associated semi-annual monitoring report. An example of a table of detections, taken from the
most recent semi-annual monitoring event, which clarifies that all metal exceedances were below their
own intrawell baseline, below the interwell background levels and/or above the leachate levels is shown
as Table 3. As a contingency, if a metal concentration exceeds a 2L/GWP Standard fails to satisfy any of
the three criteria, further empirical evidence will be evaluated such as dissolved metal analysis and/or
further verification sampling. If further data suggests the metal concentration may be attributed to a
release, additional assessment will be initiated to determine the source which may necessitate another
ASD.
Closing
Surry County landfill management is dedicated to environmental quality and strives to achieve this by
maintaining compliance with all governmental regulations. Sampling methodologies will continue to be
improved to reduce turbidity levels so samples are more representative of mobile metals. If the division
approves this ASD a copy shall be placed in the operating record. If you have any questions regarding
this ASD, please contact us at [phone] or by email at [e-mail].
Sincerely,
MUNICIPAL ENGINEERING SERVICES CO., P.A.
Jonathan Pfohl Steven R. Gandy, Ph.D, P.E.
Environmental Specialist Senior Project Manager
Enclosures

cc: Mr. Dennis Bledsoe
Surry County

1 1988 EPA document-Summary of Data on MSWLFLeachate Characteristics – EPA/530-SW-88-038
5
Sheets
Tables
Surry County Subtitle D Lined Landfill Page 1 of 1
Table 1
Comparison of Total and Dissolved Metals as Detected in MW-12 and MW-13
Spring 2013 and Fall 2016
Sample ID
MW-12 Cadmium 05/31/13 2 5.2 1.4 3.8 37
35
MW-12 Thallium 05/31/13 0.28 6 <3 ND 3.0 50
MW-12 Barium 05/31/13 700 16.9 9.1 7.8 54
MW-12 Vanadium 05/31/13 3.5 <5 0.85 4.2 7
MW-12 Zinc 05/31/13 1000 <10 2.6 7.4 26
MW-13 Barium 06/01/13 700 36.6 28.6 8.0 78
44
MW-13 Cadmium 06/01/13 2 <1 ND 0.3 0.7 30
MW-13 Chromium 06/01/13 10 2.2 0.58 1.6 26
MW-13 Cobalt 06/01/13 70 5.6 3.9 1.7 70
MW-13 Nickel 06/01/13 100 <5 ND 2.2 2.8 44
MW-13 Vanadium 06/01/13 3.5 <5 0.96 4.0 19
MW-13 Zinc 06/01/13 1000 <10 ND 4.2 5.8 42
MW-9S Barium 12/01/16 700 117 60 57.0 51
53MW-9S Cadmium, total 12/01/16 2 1.6 1 0.6 62
MW-9S Cobalt 12/01/16 70 107 83.9 23.1 78
MW-9S Zinc 12/01/16 1000 17.8 4 13.8 23
< = Not Detected relative to MDL
MDL = Method Detection Limit
ND = Not Detected
ND substituted with MDL for calculations
RED :Above 2L/GWP Standard
Parameter Name Sample
Date
2L/GWP
Standard
Total
Undissolved
Concentration
(ug/L)
Dissolved
Concentration
(ug/L)
Concentration
Difference
(ug/L)

Concentration
Differential
Total to
Dissolved (%)

Concentration
Differential
Total to
Dissolved
Average (%)
Table 2
Total Metal Concentrations
Surry Co. Subtitle D Lined MSWLF
Total Metal An
t
i
m
o
n
y
Ar
s
e
n
i
c
Ba
r
i
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m
Be
r
y
l
l
i
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m
Ca
d
m
i
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m
Ch
r
o
m
i
u
m
Co
b
a
l
t
Co
p
p
e
r
Le
a
d
Ni
c
k
e
l
Se
l
e
n
i
u
m
Si
l
v
e
r
Th
a
l
l
i
u
m
Va
n
a
d
i
u
m
Zi
n
c
SWSL 6 10 100 1 1 10 10 10 10 50 10 10 5.5 25 10
2L/GWP STANDARD
SAMPLE ID
Screened
Lithology Data Period
MW-1 (BG Well)Bedrock ALL TIME HIGH 12.5 18.6 655 8.6 53.4 222 73.9 262 48.3 98.17.8 ND 10.5 147 806.
MW-2 Bedrock Max Baseline <30 <10 <500 2 1 <10 14 <200 <10 <50 <20 <10 <10 <40 <50
MW-3/MW-3R Bedrock Max Baseline <30 <10 <500 2 <1 <10 <10 <200 22 <50 <20 <10 <10 <40 <50
MW-4S Bedrock Max Baseline <30 <10 1860.26 9 146 164 <200 110 80.<20 <10 <10 <40 615.
MW-4D Bedrock Max Baseline <30 <10 <500 <2 13 12 <10 <200 <10 159 <20 <10 <10 <40 175.
MW-5 Bedrock Max Baseline <30 <10 <500 <2 4 29 15.<200 <10 99.<20 <10 <10 <40 107.
MW-6/MW-6R Bedrock Max Baseline <30 <10 <500 <2 2.16 18.<200 17 <50 <20 <10 <10 <40 93.
MW-8 Bedrock Max Baseline <5 15 2000 9.8 <1 154 87.5 108 44.5 99.5 <10 <5 5.4 256 720
MW-9S Bedrock Max Baseline <5 4.7 313 1.4 <1 39.7 10.4 19.2 12.2 21 <10 0.46 4.4 57.9 105
MW-9D Bedrock Max Baseline <5 <5 116 0.46 <1 21.9 7.3 10.1 <5 27.4 <10 0.41 <5.5 20.3 45.9
MW-10 Bedrock Max Baseline <5 <5 150 0.97 <1 25.2 8.8 18.9 7.3 22.4 <10 <5 <5.5 34.6 92.2
MW-11S Bedrock Max Baseline <5 5.6 182 2.4 <1 27.5 23 26.3 17.6 21.4 <10 0.12 <5.5 40.5 67.7
MW-11D Bedrock Max Baseline <5 6.3 119 0.79 <1 26.9 14.6 21.9 8 20.8 <10 0.24 <5.5 35.3 69.7
MW-12 Bedrock Max Baseline <5 <5 155 0.77 2.5 22.4 13.3 25.2 8.2 19.5 <10 <5 <5.5 31.2 47.6
MW-13 Bedrock Max Baseline <5 4.4 114 3.3 <1 16.1 19 20.8 10.5 14.8 <10 <5 <5.5 22.7 59.7
LEACHATE -ALL TIME HIGH 10 <5 847 <2 <1 13.3 137 <10 <5 8.9 13.4 2.4 57 9.5 31.1
LEACHATE Diluted -All Time High D 0.5 <0.25 42.4 <0.1 <0.2 0.7 6.9 <0.5 <0.25 0.4 0.7 0.1 2.85 0.5 1.6
Table contains concentrations of Appendix I metals
All Time High = Highest ever recorded at either the upgradient backgound well or untreated leachate sample. Samples consistantly collected on a semi-annual basis. This value will be kept current.
Diluted D = Extrapolated concentration when untreated leachate is mixed with groundwater. Calculated by a 20:1 dilution ratio (dividing by 20).
When two wells shown together indicates wells that have been replaced so data used for both wells
RED BOLD =
(BG Well) = Background Well Located hydraulically upgradient of Waste Unit
Concentration Exceeded 2L or GWP Standard
PHASE 2 BASELINE 2012
Max Baseline = Maximum concentration detected during the first four events performed within 6 months of commencement of landfill operations including at least 1 before opening. Considered natural intrawell background levels.
< = Not Detected with Detection Limit Indicated
SWSL = Solid Waste Section Reporting Limit
2L = North Carolina 15A NCAC 2L Groundwater Quality Standard (Current as of 10/6/16)
GWP = Groundwater Protection Standard (Current as of 10/6/16)
0.28 3.5 1000
BACKGROUND WELL PHASES 1-2
PHASE 1 BASELINE 1998
UNTREATED LEACHATE (EFFECTIVELY A COMPOSITE OF PHASES 1&2) RESULTS FROM 1998 - 2016
70 1000 15 100 20 201.4 10 700 4 2 10
Surry Co. Subtitle D Landfill Page 1 of 1
Metal Concentrations
Highest Ever Recorded at MW-1 (Background Well) and Leachate. Highest Recorded During Baseline Period at Other Wells
MW-2
MW-3/MW-3R
MW-4S
MW-4D
MW-5
MW-6/MW-6R
MW-8
MW-9S
MW-9D
MW-10
MW-11S
MW-11D
MW-12
MW-13
LEACHATE
An
t
i
m
o
n
y
LEACHATE
MW-1 (BG Well)
NON-DETECTS (ND) Represented at 1/2 Detection Limit
Units in uq/L
Red Detected above 2L/GWP Standard
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
0
2
4
6
8
10
12
14
16
Antimony
ND ND ND ND ND ND
ND ND ND ND
0
2
4
6
8
10
12
14
16
18
20
Arsenic
ND ND ND ND ND
0
500
1000
1500
2000
2500
Barium
ND ND ND ND
0
5
10
15
20
25
30
Beryllium
ND ND ND ND ND ND ND ND ND ND
0
10
20
30
40
50
60
Cadmium
ND ND
0
50
100
150
200
250
Chromium
ND ND
0
20
40
60
80
100
120
140
160
180
Cobalt
ND ND ND ND ND ND
ND
0
50
100
150
200
250
300
Copper
Metal Concentrations
Highest Ever Recorded at MW-1 (Background Well) and Leachate. Highest Recorded During Baseline Period at Other Wells
NON-DETECTS (ND) Represented at 1/2 Detection Limit
Units in uq/L
Red Detected above 2L/GWP Standard
ND ND ND ND ND
0
20
40
60
80
100
120
Lead
ND ND
0.
20.
40.
60.
80.
100.
120.
140.
160.
180.
Nickel
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
0 2 4 6 8
10 12 14
16 18 20
Selenium
ND ND ND ND ND ND ND
ND ND ND ND
0
1
2
3
4
5
6
Silver
ND ND ND ND ND ND ND ND ND ND ND ND
0
10
20
30
40
50
60
Thallium
ND ND ND ND ND
0
50
100
150
200
250
300
Vanadium
ND ND
0. 100. 200. 300. 400. 500. 600. 700. 800. 900.
Zinc
0
100
200
300
400
500
600
700
800
900
An
t
i
m
o
n
y

Ar
s
e
n
i
c

Ba
r
i
u
m

Be
r
y
l
l
i
u
m

Ca
d
m
i
u
m

Ch
r
o
m
i
u
m

Co
b
a
l
t

Co
p
p
e
r

Le
a
d

Ni
c
k
e
l

Se
l
e
n
i
u
m

Sil
v
e
r

Th
a
l
l
i
u
m

Va
n
a
d
i
u
m

Zin
c

LEACHATE
LEACHATE (Diluted)
MW-1 (BG Well)
Surry County Subtitle D Lined Landfill Page 1 of 2
Table 3
June 15, 2016
Result Unit
MW-1 Chromium, total 6/15/16 13.7 2.5 10 10 100 N (Is BG)
MW-1 Vanadium, total 6/15/16 9.8j 2.5 25 NE 3.5 NE N (Is BG)
MW-1 Cobalt, total 6/15/16 12 2.5 10 NE 70 NE
MW-1 Copper, total 6/15/16 15.9 2.5 10 1000 NE
MW-1 Zinc, total 6/15/16 55.9 5 10 1000 NE
MW-4D Cadmium, total 6/15/16 1.1 0.5 1 2 5
MW-4D Zinc, total 6/15/16 10.7 5 10 1000 NE
MW-5 Cadmium, total 6/15/16 2.3 0.5 1 2 5 N (<BL, <BG, >L)
MW-5 Chromium, total 6/15/16 12.1 2.5 10 10 100 N (<BL, <BG, >L)
MW-5 Vanadium, total 6/15/16 18.5j 2.5 25 NE 3.5 NE N (<BL, <BG, >L)
MW-5 Copper, total 6/15/16 10.7 2.5 10 1000 NE
MW-5 Barium, total 6/15/16 156 2.5 100 700 1300
MW-5 Zinc, total 6/15/16 36.7 5 10 1000 NE
MW-6R 6/15/16 1.2 0.97 1 4.6 5
MW-6R Vinyl chloride 6/15/16 1.3 0.62 1 0.03 2 L &/or LFG
MW-8 Vanadium, total 6/15/16 9.4j 2.5 25 NE 3.5 NE N (<BL, <BG, >L)
MW-8 Barium, total 6/15/16 137 2.5 100 700 1300
MW-8 Zinc, total 6/15/16 35.4 5 10 1000 NE
MW-9S Cadmium, total 6/15/16 2.4 0.5 1 2 5 N ( <BG, >L)
MW-9S Cobalt, total 6/15/16 144 2.5 10 NE 70 NE N (<BG, >L)
MW-9S Copper, total 6/15/16 12.2 2.5 10 1000 NE
MW-9S Zinc, total 6/15/16 18 5 10 1000 NE
MW-9S Barium, total 6/15/16 125 2.5 100 700 1300
MW-9S Vinyl chloride 6/15/16 0.72j 0.62 1 0.03 2 L &/or LFG
MW-10 Vanadium, total 6/15/16 10.8j 2.5 25 NE 3.5 NE N (<BL, <BG, >L)
MW-10 6/15/16 1 0.97 1 4.6 5
MW-10 Zinc, total 6/15/16 20.5 5 10 1000 NE
MW-11D Vanadium, total 6/15/16 8.3j 2.5 25 NE 3.5 NE N (<BL, <BG, >L)
MW-12 Chromium, total 6/15/16 10.4 2.5 10 10 100 N (<BL, <BG, >L)
MW-12 Vanadium, total 6/15/16 13.6j 2.5 25 NE 3.5 NE N (<BL, <BG, >L)
MW-12 Copper, total 6/15/16 11.3 2.5 10 1000 NE
MW-12 Zinc, total 6/15/16 28.4 5 10 1000 NE
Detections in Groundwater Samples above SWSL, 2L, GWP or MCL
Sample
ID Parameter Name 1 Sample
Date MDL 2 SWSL 3 2L 4 GWP 5 MCL 6 Preliminary Cause
7
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Methylene Chloride ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Methylene Chloride ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Surry County Subtitle D Lined Landfill Page 2 of 2
A definitive source of the detection was not determined as part of this report. Preliminary cause only listed pursuant to instructions
j =The reported value is between the laboratory method detection limit (MDL) and the laboratory method reporting limit (MRL),
adjusted for actual sample preparation data and moisture content, where applicable
NE = Not Established
<BG = Below the highest level ever observed in the background well (MW-1).
LFG = Landfill Gas
BOLD = Concentration > 2L, GWP or MCL Standard
1 Table contains constituents detected at or above SWSL, 2L, 2B, GWP or MCL
2 MDL = Method Detection Limit
3 SWSL = Solid Waste Section Reporting Limit
4 2L = North Carolina 15A NCAC 2L Groundwater Quality Standard
5 GWP = Groundwater Protection Standard
6 MCL = Primary Drinking Water Standard (not currently applicable for regulatory comparisons)
7 Preliminary Cause = Refers to a preliminary analysis of the cause and/or source of a detection over the respective 2L/2B Standard.
N = Natural originating from erosion of natural deposits. Source not anthropogenic.
<BL = Below it's own BaseLine level established by the highest of the first 4 initial events within the first six months of operation.
>L = Above the highest ever observed in leachate after a 20:1 dilution factor.
L = Leachate