CCB0057_SwiftCreek_CAUpdate_DIN28329_20170725

Swift Creek Corrective Action Plan Implementation
Monthly Project Update – Prepared by ERM NC, Inc.

Report #3 – July 25, 2017

ReUse Technology, Inc.
Former Swift Creek Coal Combustion By Product
(CCB) Structural Fill, CCB0057

Battleboro, North Carolina

Introduction

ERM NC, Inc. (ERM) has been contracted by ReUse Technology, Inc. (ReUse) to implement the
Groundwater Corrective Action Plan for the Former Swift Creek Coal Combustion By Product
(CCB) Structural Fill, CCB0057 approved by NCDEQ – Division of Waste Management on
March 12, 2015. As requested by NCDEQ, ERM will provide monthly updates to summarize
site activities including any changes in conditions as the project progresses.

ERM has subcontracted Earnhardt Grading, Inc. (Earnhardt) of Lowesville, North Carolina to
provide site preparation, excavation, grading, geosynthetic installation and final site
stabilization. ERM and Earnhardt have been on the Swift Creek site full time beginning April
24, 2017 for construction activities. ERM has compiled weekly update status reports that are
attached for reference.

Summary of Activities

Since the previously issued Monthly Project Update dated June 26, 2017, ERM and Earnhardt
Grading have remained onsite full time conducting corrective action plan activities. These
activities included:

 Removal of CCB materials from the south end (Phase 1 area) of the project site.
 Stockpiling of CCB materials on the north end (Phase 2) area of the project site.
 Maintaining erosion and sedimentation control measures per NCDEMLR – Division of
Land Quality approved plans (approved March 31, 2017).
 Excavation and removal of previously abandoned 24-inch reinforced concrete storm
pipe (partially complete).
 Maintaining previously stockpiled cover soils area at the south end of the project site.
 Using previous stockpile cover soils to establish a raised floor elevation in the Phase 1
area for receipt of CCB materials.
 Surveying as-builts for removal of CCB materials and finished Phase 1 raised floor
grades.
 Removal of previously installed dewatering drain along west side of the project.
 Identification of suitable off site soils for use during corrective action construction. Soils
proposed for use are from a local farm. ERM collected soil samples for offsite borrow
and submitted for laboratory analytical testing (results attached in Weekly Report for
ERM NC, Inc.
15720 Brixham Hill Avenue
Suite 120
Charlotte, NC 28277
[phone]
[phone] (fax)
Swift Creek Monthly Update Report #3 Page 2
July 25, 2017
July 19, 2017). Composite samples were collected for topsoil, sand and clayey soil
sources as all may be candidates for use. In summary, all samples were non-detect (ND)
for volatile organic compounds (VOC’s) and semi-volatile organic compounds (SVOC’s).
Some metals were detected at concentrations that appear typical for this area of North
Carolina. For acceptability purposes, we have compared the results to the NC Inactive
Hazardous Sites Branch standards for Protection of Groundwater. Based on these
standards, metals concentrations are below the standards.

At the end of this third month of construction activities, Earnhardt has completed CCB material
removal of approximately 90% of the Phase 1 footprint area. Due to heavy rains in the vicinity
of the project, there have been several days lost to production due to weather and/or wet
conditions. Approximately 50% of the Phase 1 area floor grades have been raised to meet or
exceed the elevations contained in the approved Corrective Action Plan.

Site Observations

 To date there have been no visual indications of dust migration off site.
 Since arriving on site, approximately 21-inches of rain has been recorded based on the
onsite rain gage and monitoring.
 Erosion and sedimentation control measures are functioning appropriately and there
have been no observations of offsite sediment releases.
 Monitoring wells have been marked with construction fence and maintained throughout
construction activities.
 The abandoned 24-inch diameter reinforced concrete storm pipe located in the Phase 1
area of the project site was encountered on 6/8/17 while performing CCB material
removal along the southeastern portion of the site. At this location the pipe was open
and contained water; not full of grout as previously reported by the site owner. As
removal of ash continues from south to north, the pipe continues to be evaluated and
observed as opened; not abandoned to approximately 100-ft east of the western project
limits. A buried concrete junction box has also been discovered at this location. The
open concrete pipe has been removed east of this junction box. There was no pipe
observed leading into the junction box from the west. As excavation of CCB materials
has continued, a smaller diameter 15-in diameter reinforced concrete pipe was
discovered appearing to align with the discovered junction box and storm drop inlets
along Highway 301. This 15-in pipe is also observed as open. Site observations also
report no flow from this open pipe; potentially abandoned closer to Highway 301. The
locations of pipe, pipe abandonment and results of observations will be recorded.
Reference the attached Weekly Report dated July 19, 2017 for additional information.
 ERM discussed the initial discovery of the pipe and conditions with Jackie Drummond
of NCDEQ on June 12, 2017.

Swift Creek Monthly Update Report #3 Page 2
July 25, 2017
Please let us know if you should have any questions or require additional information
concerning this report or attachments.

ERM NC, Inc.

David W. Wasiela, P.E.
Project Engineer

Attch: Weekly Update Reports
ReUse Technology, Inc.
Swift Creek Project
Weekly Update – June 28, 2017

Key Items Completed Last Week:

Permit Related

1. NCDEQ; DEMLR – Land Quality – Thad Valentine was notified on May 12, 2017 that
erosion and sedimentation control measures are in place for an onsite meeting. Thad
replied that he would stop by next time he was in the area. No visit has occurred yet.
2. NCDEQ – Waste Management
a. On site meeting with NCDEQ is scheduled for August 8, 2017 at 9:00 am.

Vertex / Ace Related

3. No additional requests received from Vertex.

Project Related

4. Earnhardt Grading and ERM remain on site full time since 4/24/17.
5. ERM prepared the second monthly update for NCDEQ and submitted to Jackie
Drummond on June 27th.
6. Excavation of ash materials continues on the south end of the site with transportation to
the north end; excavation of Phase 1 area. The bottom of the beneficial fill continues to
be identified in the south end of the project (see photos).
7. ERM conducted a health and safety audit at the site on 6/21/17 with ERM’s South
Atlantic Health & Safety Director Millard Griffin along with Earnhardt Grading’s Health
& Safety Director Anthony Dohmann. No substantial issues were identified during or
following the audit.
8. Rain and wet conditions hampered production from 6/21 through 6/26. Due to these
conditions production this week was low and the Phase 1 ash removal is approximately
64% complete. Progress Plan attached.
9. Due to rain, no work on site June 21st, 22nd, 23rd and 26th. Photo Log of activities is
attached for reference.
10. Earnhardt continues to evaluate removal of the previously installed french drain system
along the western side of the site. Based on removal of this system in the northwest
corner and visual observations, ash materials may have been used to backfill the
subsurface drain. If this continues to be the case, removal of these ash materials may
require excavation within 10-horizontal feet of an existing reinforced concrete storm
drain line located on the west side. 10 feet within a utility is deemed a “critical zone”
within ERM’s subsurface clearance protocols and would require an internal process
waiver to proceed with excavation within this zone. Earnhardt is in the process of
surveying the location of the storm drain line and establishing a 10-ft buffer to show the
“critical zone” on the ground prior to removing more of the underdrain system. Plan
attached for reference.
11. Progress Plan attached for reference.
Two (2) Week Look Ahead (6/28/17 – 7/12/17):

12. Earnhardt and ERM will remain on site full time.
13. With recent rain events, Earnhardt plans to work through Saturday July 1st and continue
excavating ash working routinely from south to north for preparation of Phase 1 area.
Anticipate completing Phase 1 removal within the next two weeks.
14. Currently discussing an alternate approach including raising the first half of the Phase 1
floor to receive ash materials as the north stockpile is becoming difficult to manage due
to wet conditions. The floor would be raised using on site soils, compacted and
surveyed prior to receiving ash materials.
15. ERM will continue to update Full Circle concerning site activities as needed.
16. Earnhardt is proposing to not work Sunday July 2nd through Tuesday July 4th around
July 4th holiday.
17. ERM will be preparing June invoice next week for submittal.

Schedule

Schedule submitted by Earnhardt completes removal of CCR materials from Phase 1
area 10 weeks from beginning mobilization. Currently at 9-1/2 weeks Phase 1 removal
is 64% complete with production delayed by rain.

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ReUse Technology, Inc.
Swift Creek Project
Weekly Update – July 5, 2017

Key Items Completed Last Week:

Permit Related

1. NCDEQ; DEMLR – Land Quality – Thad Valentine was notified on May 12, 2017 that
erosion and sedimentation control measures are in place for an onsite meeting. Thad
replied that he would stop by next time he was in the area. No visit has occurred yet.
2. NCDEQ – Waste Management
a. On site meeting with NCDEQ is scheduled for August 8, 2017 at 9:00 am.

Vertex / Ace Related

3. No additional requests received from Vertex.

Project Related

4. Earnhardt Grading and ERM remain on site full time since 4/24/17.
5. Excavation of ash materials continues on the south end of the site with transportation to
the north end; excavation of Phase 1 area. The bottom of the beneficial fill continues to
be identified in the south end of the project (see photos).
6. Removal of the underdrain system on the west side of the project continued. Still
identifying ash materials placed above the underdrain system while removal is
occurring.
7. Due to difficulties encountered managing the ash stockpile area on the north end,
Earnhardt began raising the Phase 1 floor area on June 29th using the onsite stockpiled
soils. Soils were placed in approximately 1-foot lifts and compacted as grades were
raised. The Phase 1 area grading was complete on June 30th and surveyed on June 30th.
Proofrolling of the area was performed on June 30th and July 1st to identify any soft or
unstable areas under the observation of ERM. The newly placed fill was acceptable for
ash placement following proofrolling and Earnhardt began placing ash materials in the
Phase 1 area on July 1st.
8. No work was performed on site July 2nd through July 4th due to the Holiday.
9. Progress Plan and photo log are attached for reference.
Two (2) Week Look Ahead (7/5/17 – 7/19/17):

10. Earnhardt and ERM will remain on site full time.
11. With recent rain events, Earnhardt plans to work through Saturday July 8th and
continue excavating ash working routinely from south to north for preparation of the
remaining Phase 1 area. Anticipate completing Phase 1 removal within the next two
weeks.
12. Excavated ash materials will be placed in the completed Phase 1 raised floor area and
the north stockpile area depending on weather and site conditions.
13. ERM will continue to update Full Circle concerning site activities as needed.
14. ERM will be preparing June invoice this week for submittal.

Schedule

Schedule submitted by Earnhardt completes removal of CCR materials from Phase 1
area 10 weeks from beginning mobilization. Currently at 10-1/2 weeks Phase 1 removal
is 64% complete with production delayed by rain. The raising of Phase 1 floor grades
was scheduled for 10 days and 62% of the Phase 1 floor was raised in 2 days.

ReUse Technology, Inc.
Swift Creek Project
Weekly Update – July 12, 2017

Key Items Completed Last Week:

Permit Related

1. NCDEQ; DEMLR – Land Quality – Thad Valentine was notified on May 12, 2017 that
erosion and sedimentation control measures are in place for an onsite meeting. Thad
replied that he would stop by next time he was in the area. No visit has occurred yet.
2. NCDEQ – Waste Management
a. On site meeting with NCDEQ is scheduled for August 8, 2017 at 9:00 am.

Vertex / Ace Related

3. No additional requests received from Vertex. Invoice for June is currently being
developed.

Project Related

4. Earnhardt Grading and ERM remain on site full time since 4/24/17.
5. Excavation of ash materials continues on the south end of the site with transportation to
the north end; excavation of Phase 1 area and to the southern end with Phase 1 floor
elevation raised. The bottom of the beneficial fill continues to be identified in the south
end of the project (see photos).
6. Removal of the underdrain system on the west side of the project continued. Still
identifying ash materials placed above the underdrain system while removal is
occurring.
7. The abandoned 24-in reinforced concrete pipe was encountered approximately 150-ft
from the western edge of the project during ash removal. This section of pipe was
observed as open and does not appear to have been abandoned.
8. Progress Plan and photo log are attached for reference.
Two (2) Week Look Ahead (7/12/17 – 7/26/17):

9. Earnhardt and ERM will remain on site full time.
10. Anticipate completing Phase 1 removal within the next two weeks.
11. Excavated ash materials will be placed in the completed Phase 1 raised floor area and
the north stockpile area depending on weather and site conditions.
12. ERM will continue to update Full Circle concerning site activities as needed.
Schedule

Schedule submitted by Earnhardt completes removal of CCR materials from Phase 1
area 10 weeks from beginning mobilization. Currently at 11-1/2 weeks Phase 1 removal
is 68% complete with production delayed by rain. The raising of Phase 1 floor grades
was scheduled for 10 days and 62% of the Phase 1 floor was raised in 2 days.

ReUse Technology, Inc.
Swift Creek Project
Weekly Update – July 19, 2017

Key Items Completed Last Week:

Permit Related

1. NCDEQ; DEMLR – Land Quality – Thad Valentine was notified on May 12, 2017 that
erosion and sedimentation control measures are in place for an onsite meeting. Thad
replied that he would stop by next time he was in the area. No visit has occurred yet.
2. NCDEQ – Waste Management
a. On site meeting with NCDEQ is scheduled for August 8, 2017 at 9:00 am.

Vertex / Ace Related

3. No additional requests received from Vertex. Invoice for June is currently being
developed.

Project Related

4. Earnhardt Grading and ERM remain on site full time since 4/24/17.
5. Excavation of ash materials continues on the south end of the site with transportation to
the north end; excavation of Phase 1 area and to the southern end with Phase 1 floor
elevation raised. The bottom of the beneficial fill continues to be identified in the south
end of the project (see photos).
6. Removal of the underdrain system on the west side of the project continued. Still
identifying ash materials placed above the underdrain system while removal is
occurring.
7. The abandoned 24-in reinforced concrete pipe and a junction box was encountered
approximately 100-ft from the western edge of the project during ash removal. This
section of pipe was observed as open and does not appear to have been abandoned. The
remainder of the pipe run not encountered yet is beneath an access ramp used to
transport ash from the Phase 1 area.
8. ERM collected soil samples for offsite borrow and submitted for laboratory analytical
testing (results attached). Composite samples were collected for topsoil, sand and
clayey soil sources as all may be candidates for use. In summary, all samples were non-
detect (ND) for volatile organic compounds (VOC’s) and semi-volatile organic
compounds (SVOC’s). Some metals were detected at concentrations that appear typical
for this area of North Carolina. For acceptability purposes, we have compared the
results to the NC Inactive Hazardous Sites Branch standards for Protection of
Groundwater. Based on these standards, metals concentrations are below the standards.
ERM recommends accepting the soils as borrow material based on these results.
9. Progress Plan and photo log are attached for reference.

Two (2) Week Look Ahead (7/19/17 – 8/2/17):

10. Earnhardt and ERM will remain on site full time.
11. Anticipate completing Phase 1 removal within the next week.
12. Excavated ash materials will be placed in the completed Phase 1 raised floor area and
the north stockpile area depending on weather and site conditions.
13. ERM will prepare the next monthly update for NCDEQ next week.
14. ERM will continue to update Full Circle concerning site activities as needed.
Schedule

Schedule submitted by Earnhardt completes removal of CCR materials from Phase 1
area 10 weeks from beginning mobilization. Currently at 12-1/2 weeks Phase 1 removal
is 89% complete with production delayed by rain. The raising of Phase 1 floor grades
was scheduled for 10 days and 62% of the Phase 1 floor was raised in 2 days.
Additionally, some CCR materials have already been placed in the raised Phase 1 floor
area (Activity 6).

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