4104_CityHighPointKerseyValleyMSWLFLined_ASD_DIN27385_20160830

August 30, 2016 Sent Via Email: [e-mail]
[e-mail]

Ms. Ellen Lorscheider, Solid Waste Section Chief
NC Solid Waste Section, Department of Environmental Quality
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Re: Alternate Source Demonstration
Appendix I Inorganic Constituent Exceedances
City of High Point MSW Landfill
Permit # 4104-MSWLF-1991

Dear Ms. Lorscheider:

This correspondence is provided in response to a notice from the NC Solid Waste Section dated
August 8, 2016 regarding inorganic constituents detected in groundwater at the Kersey Valley
Landfill operated by the City of High Point. Babb & Associates, P.A. is providing this Alternate
Source Demonstration (ASD) pursuant to 15A NCAC 13B .1633(c)(3) on behalf of the City of High
Point to address the concentration of cadmium in monitoring well 4104-MW4, a compliance well in
the water quality monitoring network.

Background Information

The Kersey Valley Landfill is located approximately five miles east of downtown High Point and
one-half mile east of the intersection of US 70/US 29/I-85 Business on Kivett Drive. The
surrounding area is mixed residential and commercial land uses.

The Kersey Valley Landfill is located in the central Piedmont Physiographic Province, in the northern
portion of the Carolina Slate Belt. Granite is the predominant rock type in the area and outcrops are
observed along the creeks and within the site. Groundwater in the uppermost aquifer generally flows
through unconsolidated sediments and secondary fractures in the underlying bedrock. Recharge
occurs primarily in the northern portion of the site and is limited on slopes. Groundwater flows
generally south where it discharges into two unnamed tributaries of Richland Creek.

The existing groundwater monitoring network consists of fourteen shallow aquifer wells which are
screened across the water table in the partially weathered rock. The current surface water monitoring
network consists of eight monitoring stations along the south side of the landfill. The groundwater
and surface water monitoring locations are shown on Figure 1.

Appendix I Inorganic Exceedance

During the most recent water quality monitoring event conducted in April 2016, the inorganic
compound cadmium was reported at a concentration of 2.32 ug/l in monitoring well 4104-MW4. The
NC 2L Groundwater Standard for cadmium is 2.0 ug/l. The location of 4104-MW4 is shown on the
attached Figure 1.

Historically, monitoring well 4104-MW4 has shown minor concentrations of cadmium over the past
three years, ranging from a low of Below Quantitation Limits (BQL) in May 2014 to a high of 20.3
ug/l in April 2015. No other inorganic compounds have been reported above the NC 2L Groundwater
Standards in monitoring well 4104-MW4. No other wells in the groundwater monitoring network
have reported inorganic constituents in concentrations exceeding the NC 2L Groundwater Standards
during recent water quality monitoring events.

To further evaluate the concentration of cadmium in monitoring well 4104-MW4, the well was re-
sampled on August 16, 2016 as described below:

Water Quality Sample Collection

Prior to groundwater sampling, the depth to water was determined in order to calculate the volume of
standing water in the well casing. This information allowed for the purging of a minimum of three
casing volumes from the well prior to sample collection to assure a fresh groundwater sample was
collected. New nitrile gloves were worn by sampling personnel and the well was purged and sampled
with a new disposable bailer.

Monitoring well 4104-MW4 was dry after purging 3.2 gallons of water. The well was allowed to
fully recover and a sample was collected on August 16, 2016 for total and dissolved cadmium using
containers provided by the analytical laboratory. The samples were immediately placed in a cooler
on ice and shipped via FedEx for next day delivery to the analytical laboratory.

Field measurements collected during the sampling event included: pH – 6.29; Temperature 27.3 oC;
and Conductivity – 44 mhos/cm. The water sample was clear and no turbidity was evident.

Laboratory Analysis

The total and dissolved groundwater samples from monitoring well 4104-MW4 were received by the
analytical laboratory (Environmental Conservation Laboratories, Inc. of Cary, NC) on August 17,
2016. The sample collected for dissolved cadmium was filtered in the laboratory using a 0.45 micron
filter. Both the total and dissolved samples were analyzed for cadmium by EPA Method 6010D. The
samples were analyzed on August 22, 2016.

The result of the laboratory analyses indicates that both the total and dissolved concentrations of
cadmium in monitoring well 4104-MW4 are below the laboratory method detection limit of 0.360
ug/l. The laboratory analytical report was finalized on August 24, 2016 and is attached to this
correspondence.

Hydrogeological Conditions

The groundwater elevation determined from monitoring well 4104-MW4 during this sampling event
(813.90 msl) is consistent with groundwater elevations observed during prior monitoring events. As
noted on the attached Figure 1, the potentiometric surface indicates groundwater flow across the site
is to the south toward an unnamed tributary of Richland Creek. The average horizontal flow gradient
across the site is 0.0234 ft/ft.

The groundwater potentiometric map shows that monitoring well 4104-MW4 is hydraulically
upgradient of the landfill operations and hydraulically downgradient of several commercial and
residential properties along Kivett Drive. As noted in the approved Water Quality Monitoring Plan
for the Kersey Valley Landfill, monitoring well 4104-MW4 is identified as “Upgradient of Phase 3”.
Phases 1 through 3 were part of the original Area 1 landfill as shown on Figure 1.

Conclusions

The laboratory results of additional groundwater samples collected from monitoring well 4104-MW4
indicate the concentration of cadmium in both total and dissolved samples are below the laboratory
method detection limit of 0.360 ug/l. Also, this well is a shallow saprolite monitoring well with
generally less than five feet of standing water in the well casing. Minor amounts of sediment
entrained in the water sample may also contribute to the periodic detection of inorganic compounds as
the sample is normally acidified upon collection in the field.

Based on current and historic groundwater elevations at the site, monitoring well 4104-MW4 is
upgradient of the landfill operations and downgradient of several commercial/residential properties.
This well has been designated as an upgradient groundwater quality monitoring location by the
approved Water Quality Monitoring Plan for the Kersey Valley Landfill.

There is no evidence that the reported concentration of cadmium in upgradient monitoring well 4104-
MW4 is a result of Kersey Valley Landfill operations. Babb & Associates, P.A. recommends
continuation of detection monitoring based on the results of the resampling and the hydraulic position
of monitoring well 41041-MW4 with respect to the Kersey Valley Landfill operations.

We appreciate your consideration of this ASD and look forward to your response to this submittal. If
there are any questions concerning this information, please contact the undersigned at (919) 325-
0696.

Respectfully,

Babb & Associates, P.A.

Gary D. Babb, P.G.
President

Cc: Mr. Mike Spencer, City of High Point
Ms. Jackie Drummond, NC Solid Waste

FIGURE 1
Monitoring Locations
Potentiometric Map
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Laboratory Report
102-A Woodwinds Industrial Court
Cary NC, 27511
919.467.3090 919.467.3515Phone:FAX:www.encolabs.com
Environmental Conservation Laboratories, Inc.
ENCO Workorder(s): CZ11830
Raleigh, NC 27606
Unless otherwise noted in an attached project narrative, all samples were received in
acceptable condition and processed in accordance with the referenced methods/procedures.
Results for these procedures apply only to the samples as submitted.
The analytical results contained in this report are in compliance with NELAC standards, except
as noted in the project narrative. This report shall not be reproduced except in full, without
the written approval of the Laboratory.
This report contains only those analyses performed by Environmental Conservation
Laboratories. Unless otherwise noted, all analyses were performed at ENCO Cary. Data from
outside organizations will be reported under separate cover.
If you have any questions or require further information, please do not hesitate to contact me.
Sincerely,
Enclosure(s)
Project Number: [none], Project Name/Desc: Kersey Valley Landfill- CD Analysis
Attn: Gary Babb
Babb & Associates (BA024)
3605 Country Cove Lane
Bill Scott
Project Manager
Wednesday, August 24, 2016
RE: Laboratory Results for
Dear Gary Babb,
Enclosed is a copy of your laboratory report for test samples received by our laboratory on
Wednesday, August 17, 2016.
The total number of pages in this report, including this page is 9.
www.encolabs.com
SAMPLE SUMMARY/LABORATORY CHRONICLE
4104-MW4 CZ11830-01 Sampled:08/16/16 09:00 Received:08/17/16 10:00Client ID:Lab ID:
Prep Date/Time(s)Hold Date/Time(s)Parameter Analysis Date/Time(s)
EPA 6010D 02/12/17 08/18/16 15:37 8/22/2016 13:34
4104-MW4 Dissolved CZ11830-02 Sampled:08/16/16 09:00 Received:08/17/16 10:00Client ID:Lab ID:
Prep Date/Time(s)Hold Date/Time(s)Parameter Analysis Date/Time(s)
EPA 6010D 02/12/17 08/18/16 15:37 8/22/2016 13:36
Page 2 of 9
www.encolabs.com
SAMPLE DETECTION SUMMARY
No positive results detected.
Page 3 of 9
www.encolabs.com
ANALYTICAL RESULTS
4104-MW4Description:Lab Sample ID:CZ11830-01 08/17/16 10:00Received:
Matrix:Water Sampled:08/16/16 09:00 Work Order:CZ11830
Kersey Valley Landfill- CD AnalysisProject:Sampled By:Tom Lennon
Metals (total recoverable) by EPA 6000/7000 Series Methods
^ - ENCO Cary certified analyte [NC 591]
Analyte [CAS Number]DFUnitsResults MDL Method Analyzed ByMRLFlag NotesNC SWSL
ug/L EPA 6010D 08/22/16 13:34Cadmium [7440-43-9] ^0.360 JDH1.000.360 U 11
This report relates only to the sample as received by the laboratory, and may only be reproduced in full.
Page 4 of 9
www.encolabs.com
4104-MW4 DissolvedDescription:Lab Sample ID:CZ11830-02 08/17/16 10:00Received:
Matrix:Water Sampled:08/16/16 09:00 Work Order:CZ11830
Kersey Valley Landfill- CD AnalysisProject:Sampled By:Tom Lennon
Metals (Dissolved) by EPA 6000/7000 Series Methods
^ - ENCO Cary certified analyte [NC 591]
Analyte [CAS Number]DFUnitsResults MDL Method Analyzed ByMRLFlag NotesNC SWSL
ug/L EPA 6010D 08/22/16 13:36Cadmium [7440-43-9] ^0.360 JDH1.000.360 U 11
This report relates only to the sample as received by the laboratory, and may only be reproduced in full.
Page 5 of 9
www.encolabs.com
QUALITY CONTROL
Metals (total recoverable) by EPA 6000/7000 Series Methods - Quality Control
Batch 6H18043 - EPA 3005A
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:43Blank (6H18043-BLK1)
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.000.360 U Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:49LCS (6H18043-BS1)
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 80-12010220.4 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:54Matrix Spike (6H18043-MS1)
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 75-1251040.360 U20.7 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:58Matrix Spike Dup (6H18043-MSD1)
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 2075-125103 10.360 U20.5 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 13:00Post Spike (6H18043-PS1)
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
mg/L0.00100 0.0200 80-1201000.0001950.0202 Cadmium
Metals (Dissolved) by EPA 6000/7000 Series Methods - Quality Control
Batch 6H18043 - EPA 3005A
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:43Blank (6H18043-BLK1)
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.000.360 U Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:49LCS (6H18043-BS1)
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 80-12010220.4 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:54Matrix Spike (6H18043-MS1)
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 75-1251040.360 U20.7 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:58Matrix Spike Dup (6H18043-MSD1)
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QUALITY CONTROL
Metals (Dissolved) by EPA 6000/7000 Series Methods - Quality Control
Batch 6H18043 - EPA 3005A
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 12:58Matrix Spike Dup (6H18043-MSD1) Continued
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
ug/L1.00 20.0 2075-125103 10.360 U20.5 Cadmium
Prepared: 08/18/2016 15:37 Analyzed: 08/22/2016 13:00Post Spike (6H18043-PS1)
Source: CZ11730-01
RPD%RECSourceSpike
MRL Analyte Notes LimitRPDLimits%RECResultLevelUnitsResultFlag
mg/L0.00100 0.0200 80-1201000.0001950.0202 Cadmium
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FLAGS/NOTES AND DEFINITIONS
B The analyte was detected in the associated method blank.
D The sample was analyzed at dilution.
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.
U The analyte was analyzed for but not detected to the level shown, adjusted for actual sample preparation
data and moisture content, where applicable.
E
MRL Method Reporting Limit. The MRL is roughly equivalent to the practical quantitation limit (PQL) and is
based on the low point of the calibration curve, when applicable, sample preparation factor, dilution
factor, and, in the case of soil samples, moisture content.
The concentration indicated for this analyte is an estimated value above the calibration range of the
instrument. This value is considered an estimate.
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