6013_GreenwayNorthMeckCDLF_20170808_VinylChlorideASD_DIN28646

August 2, 2017

Ms. Jackie Drummond Compliance Hydrogeologist Division of Waste Management - Solid Waste Section North Carolina Department of Environmental Quality
Asheville Regional Office
2090 US Highway 70 Swannanoa, NC 28778 Dear Jackie:

Subject: North Meck C&D Landfill – Permit 60-13 Greenway Waste Solutions of North Meck, LLC Demonstration Letter on Laboratory Analyses for Vinyl Chloride CEC Project 111-370.001

Per 15A NCAC 13B .0544 (b) (1) (I), Civil & Environmental Consultants, Inc. (CEC), on behalf of Greenway Waste Solutions of North Meck, LLC has prepared and is submitting this Demonstration Letter presenting history and recently discovered facts regarding the detections of vinyl chloride in groundwater that is sampled and analyzed per the conditions in the above permit. Vinyl chloride is
groundwater contaminant 145 as listed in 15A NCAC 02L .0202 and has a cleanup standard of 0.03
micrograms per liter (µg/L) or the practical quantitation limit whichever is greater. This letter presents condensed historical information on the detection of vinyl chloride in groundwater at the landfill and then provides a timeline and facts generated during the investigation of higher than expected detection of vinyl chloride. Attachments include selected monitoring well vinyl chloride historical charts, site
plan showing the groundwater monitoring well locations and correspondence from analytical
laboratories certified by the state to perform groundwater organic analyses. Condensed Historical Information
The groundwater-monitoring program at the North Meck C&D Landfill consists of 42 groundwater
monitoring wells and has been ongoing since 1996. Semi-annual sampling takes place and the samples analyzed per the approved groundwater-monitoring plan. Vinyl chloride was first detected in the facility’s groundwater (0.64 µg/L) in the spring sampling event in 2008, but was not confirmed through re-sampling until fall 2012 (0.95 µg/L).

Nineteen monitoring well sample results at the facility contained vinyl chloride at concentrations above the practical quantitation limit during the spring 2016 sampling. Between 2012 and 2013, a significant increase can be seen for most monitoring well sample results with a history of vinyl chloride contamination. (Charts for several of the monitoring well sample results historical vinyl
Ms. Jackie Drummond - NCDEQ
CEC Project 111-370.0001
Page 2 August 2, 2017

chloride concentrations can be found in the Attachment.) After detailed review, the increase
concentrations coincided with a change in analytical laboratories (Pace Analytical to Shealy
Laboratories). A program was then started in the fall of 2016 to obtain split samples from selected monitoring wells with histories of vinyl chloride detections in an effort to confirm the elevated concentrations first seen in 2013.
The results of the fall 2016 split sampling showed a significant difference between the two selected
laboratories in the detected concentrations of vinyl chloride. Because of the discrepancies, CEC performed a second round of split samples between three laboratories with two of the laboratories reporting values generally consistent with the pre-2013 results. All three of the laboratories performed a Quality Assurance/Quality Control review of their sample analytical processes. Their reports were
then shared with the other laboratories involved for review and comment. No significant deviations
as described in EPA Method 8260B were reported by the laboratories due to these reviews. The laboratory (Shealy) with the higher than historical values performed an internal review and provided CEC correspondence stating that the perhaps the elevated vinyl chloride detections were
due an issue with the gas chromatograph (GC).
For the spring 2017 groundwater-sampling event, CEC obtained split samples and these were delivered to TestAmerica and Pace Analytical Laboratories. Again for certain samples, higher than expected values of vinyl chloride were reported by TestAmerica compared to the Pace results.

CEC asked TestAmerica to review the results, analysis methodology, instruments used and interview the analysts in an effort to either validate or discount this first round of 2017 results. TestAmerica brought in their Senior Technical Services Group to review their process. In late May, TestAmerica informed CEC of the following results of their investigation:

1. Search indicated a possibility of conversion of a Freon refrigerant (Freon 151) to vinyl chloride in the GC; 2. Confirmation of this occurred after TestAmerica obtained and ran a Freon 151 standard through their Chicago GCs, resulting only one of the GCs not converting the Freon 151 to
vinyl chloride;
3. A TestAmerica company-wide program was implemented and identified most of their GCs converting the Freon 151 to vinyl chloride; and 4. TestAmerica started, and is continuing, a corrective-action program to identify and change the component(s) of the GCs converting the Freon. (It is reported that the likely cause is the
Purge and Trap mechanism.)
After receiving the information that the analytical procedure and equipment were the cause of the higher than expected groundwater vinyl chloride results, CEC resampled the monitoring wells with spring 2017 vinyl chloride detections at North Meck C&D Landfill in June 2017. The comparison of
the first and second round of 2017 results are presented in Table 1.

Ms. Jackie Drummond - NCDEQ
CEC Project 111-370.0001
Page 3 August 2, 2017

Table 1 – Vinyl Chloride Results Spring 2016 to Spring 2017
Results are shown in µg/L VC = vinyl chloride TA = TestAmerica * = POC Well NS = Not Sampled BOLD = value exceeds the MDL or Standard of 0.03 µg/L for vinyl chloride
The results of the second round of spring 2017 sampling showed two point of compliance wells (Infill
MW-12 and MW-12D) exhibiting vinyl chloride concentrations above the practical quantitation limit. A figure showing the facility’s POC wells. CEC also received from Shealy and their supplier of the silica gel (OI Analytical) in the Purge and
Trap mechanisms that are part of the GC letters documenting the results of their independent testing
Well I.D.
Apr
2016 VC
Shealy
Oct 2016 VC Pace
Apr
2017 VC
TA
June
2017 VC TA Well I.D.
Apr
2016 VC
Shealy
Oct 2016 VC Pace
Apr
2017 VC
TA
June
2017 VC
TA
Closed Portion
MW-1 <1.0 <1.0 <0.2 NS MW-8D* 0.66 <1.0 3.2 <0.5
MW-4* <1.0 <1.0 14.0 <0.5 MW-9* <1.0 <1.0 <0.2 NS
MW-4A* 2.0 <1.0 3.7 <0.5 MW-10 <1.0 <1.0 6.1 <0.5
MW-4D* 0.85 <1.0 1.1 <0.5 MW-10D 11 <1.0 18.0 <0.5
MW-5 3.3 <1.0 7.9 1.6 MW-11 <1.0 <1.0 6.9 <0.5
MW-5D 5.5 2.1 7.2 2.5 MW-11A* <1.0 <1.0 <0.2 NS
MW-6* <1.0 <1.0 0.7 <0.5 MW-11B* <1.0 <1.0 <0.2 NS
MW-6D* 2.7 <1.0 4.7 <0.5 MW-11D-1* <1.0 <1.0 <0.2 NS
MW-7* 2.2 <1.0 9.3 <0.5 MW-11D-2* <1.0 <1.0 <0.2 NS
MW-7A* <1.0 <1.0 3.2 <0.5 MW-4D-1* 0.76 <1.0 3.7 <0.5
MW-7D* 1.1 <1.0 4.0 <0.5 MW-6D-1* 1.6 <1.0 2.1 <0.5
MW-8* <1.0 <1.0 0.45 <0.5
Infill Portion
MW-4 1.6 4.0 1.5 <0.5 MW-11* <1.0 <1.0 <0.5 NS
MW-5 6.5 <1.0 5.0 0.71 MW-11D* 0.66 <1.0 <0.5 NS
MW-7 2.6 <1.0 5.3 1.4 MW-12* 26 1.33 36 2.9
MW-9 33.0 1.4 44 1.1 MW-12D* 32 1.04 32 1.2
MW-9D 37.0 <1.0 3.3 <0.5
Ms. Jackie Drummond - NCDEQ
CEC Project 111-370.0001
Page 4 August 2, 2017

confirming TestAmerica’s results. The various pieces of correspondence from TestAmerica, Shealy
and OI Analytical can be found in the Attachment.
Impacts on Compliance Status While the confirmed conversion of Freon 151 to vinyl chloride explains the higher than expected
historical data on vinyl chloride at the North Meck C&D Landfill, the groundwater as measured at
the POC wells still exhibits vinyl chloride above the practical quantitation limit. Confirmation of these second round results from the spring 2017 sampling will continue to take place for the near future as part of the approved groundwater-monitoring plan. CEC will continue to obtain and analyze split samples and blind duplicates from selected groundwater monitoring wells. TestAmerica and
Pace are continuing to conduct reviews of their GCs to eliminate the issue(s) converting the Freon to
vinyl chloride. Conclusion
The presented data and supporting correspondence from the analytical laboratories directly working
on the project clearly shows the vinyl chloride analytical data prior to the Spring 2017 sampling event has be considered invalid. Reviews of the upcoming efforts to address the two POC wells exhibiting vinyl chloride impacts above the Standards must only be based on sample data from the spring 2017 event and future sampling events.

If you have any questions or comments, please feel free to contact me at [phone]. Sincerely,
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
Bruce D. Reilly, P.E. Scott L. Brown, P.E.
Senior Project Manager Vice President
Attachments Cc: Mr. John Brown – Greenway Waste Solutions

ATTACHMENTS

0.000
0.005
0.010
0.015
MW-4 Closed
Trends (mg/L)
Vinyl Chloride
0.000
0.002
0.004
0.006
0.008
MW-4 Infill
Trends (mg/L)
Vinyl Chloride
0.000
0.005
0.010
0.015
MW-5 Closed
Trends (mg/L)
Vinyl Chloride (mg/L)
0.000
0.002
0.004
0.006
0.008
MW-6 Infill
Trends (mg/L)
Vinyl Chloride
0.000
0.005
0.010
0.015
MW-7 Infill
Trends (mg/L)
Vinyl Chloride
0.000
0.005
0.010
0.015
MW-10 Closed
Trends (mg/L)
Vinyl Chloride
0.000
0.005
0.010
0.015
MW-11 Closed
Trends (mg/L)
Vinyl Chloride
1
Reilly, Bruce
From:Stephens, Ed
Sent:Wednesday, July 19, 2017 8:46 AM
To:Reilly, Bruce
Subject:FW: Vinyl chloride
fyi

Ed Stephens, P.G.
Civil & Environmental Consultants, Inc.
1900 Center Park Drive · Suite A · Charlotte, NC 28217
Toll-Free: 855-859-9932· Fax: [phone]
Mobile: [phone] · http://www.cecinc.com
Senior Leadership · Integrated Services · Personal Business Relationships

From: Dan Wright [mailto:[e-mail]]
Sent: Tuesday, January 10, 2017 8:58 AM
To: Stephens, Ed <[e-mail]>
Cc: Michael Kilpatrick <[e-mail]>; Grant Wilton <[e-mail]>
Subject: Vinyl chloride

Morning Ed,

We have solved the vinyl chloride mystery. All the samples that we are detecting vinyl chloride have the tentatively
identified compound 1-chloro-1-fluoroethane (molecular weight 82.5 aka Freon 151) which is breaking down in the
autosampler metal sample pathway to vinyl chloride (molecular weight 62.5). This is likely occurring in the 6 port valve
of the autosampler where actives site are catalyzing HF which accounts for 20 AMUs. I discussed this with Test America
staff since they had the large discrepancy between the two labs. It appears that some autosamplers are most likely to
have the active sites that cause this degradation of Freon 151. They have witnessed this specific issue first hand at Test
America as well.

We have ordered a single standard of Freon 151 which we will run on several instruments to determine if any do not
cause the degradation. This situation is fairly rare, but due to the presence of Freon 151 in these samples the conditions
were right to form vinyl chloride. I will call you to discuss, but wanted to get you in the loop now so you can pass this on
to your client and the applicable regulators.

Once we analyze the Freon 151 standard we should be able to switch out some components in our autosamplers to
remove the active site thus preventing the formation of vinyl chloride. If we demonstrate we can eliminate the
degradation issue we certainly want to talk to you about systematically getting this groundwater work back. We have
supported these sites for many years and appreciate the scope or requirements.

Thanks,

Dan

NOTICE: The information contained in this email and any document attached hereto is intended only for the
2
named recipient(s). If you are not the intended recipient, nor the employee or agent responsible for delivering
this message in confidence to the intended recipient(s), you are hereby notified that you have received this
transmittal in error, and any review, dissemination, distribution or copying of this transmittal or its attachments
is strictly prohibited. If you have received this transmittal and/or attachments in error, please notify me
immediately by reply e-mail and then delete this message, including any attachments.

Page 1 of 3
TestAmerica Chicago

Corrective Action Report
Client: Civil and Environmental Consultants Inc.
Project: NC Landfills
Site: NC North Mecklenburg Landfill, NC Highway 49 Landifll, NC Apex Landfill, NC
Responsible Parties: TestAmerica Chicago
Date Initiated: 05/24/17
Initiator: JoAnn Petruszak-Kmetty
Description of Problem: The client requested that the vinyl chloride (VC) data for job 500-127404 from the North Mecklenburg Landfill - Infill be re-reviewed because the results were “an
order of magnitude greater than the split samples results”. During the review, it
was observed that each sample that had a positive detect for vinyl chloride also had a tentatively identified compound (TIC) identified as 1-chloro-1-fluoroethane (Freon 151). An inquiry was made of the other TestAmerica laboratories and the technical support personnel within TestAmerica to see if others have seen this
correlation.
After a preliminary investigation was performed at three TestAmerica laboratories, the TestAmerica Technical Support Organization (TSO) determined that false positive or high-biased results for vinyl chloride can occur due to the
degradation of 1-chloro-1-fluoroethane (Freon 151) on some VOA GC/MS
instruments. Freon 151 is not a VOA target analyte and it is not commonly found in the environment, but it is present more frequently in landfill leachates and monitoring wells. All of the vinyl chloride artifacts attributable to Freon 151 that we have identified to date are associated with landfill operations.

When samples containing Freon 151 are analyzed on certain VOA GC/MS instruments that ‘activate’ or promote its degradation, vinyl chloride artifacts will

Page 2 of 3
TestAmerica Chicago

be generated. Some VOA instruments are highly ‘activated’ towards Freon 151 degradation, while others are quite ‘inert’. Freon 151 degradation is believed to
occur on active sites in the VOA instrument ‘sample pathway’ that have
developed over time, and may be difficult to reverse. Freon 151 has a characteristic mass spectrum and is easy to identify by library search. It will usually be evident as a significant peak eluting shortly after vinyl chloride.
Corrective Action Plan:
To correct the immediate problem, the following actions were taken: 1) Analyze a Freon 151 standard at ~ 300 ppb concentration on all VOC instruments.
2) Identify VOC instruments as ‘activated’ if VC is > RL, and ‘inert’ if VC is < RL,
in the analysis of the Freon 151 standard. 3) Monitor each presumptive positive detect for VC on an activated instrument for the presence of Freon 151. If Freon 151 is present, re-analyze samples with presumptive positives for VC on an inert instrument.
4) When/where possible, perform maintenance on activated instruments to
eliminate active sites and ensure inert status. 5) Review previous jobs that were analyzed from these sites and identify samples that had Freon 151 and VC detects.
Status as of 6-12-17: The TestAmerica Chicago laboratory has analyzed a Freon 151 standard on each VOA instrument in the laboratory and has identified which instruments are
‘activated’ and which instruments are ‘inert’.
All analysts have been informed of the situation and instructed to re-analyze samples with positive detects for VC and Freon 151 on an instrument which has been determined to be ‘inert’. The laboratory project manager will be informed of
the situation and the client will be notified if data is impacted.
The project manager will flag each known project site that historically has had Freon 151 with a method comment in TALs computer system so that it will appear on the analyst’s backlog upon arrival of samples to the laboratory.

The following jobs have been reviewed and samples containing VC and Freon 151 have been identified: 500-127325, -127370, -127404, -127480, -127268, and -126939. The results have been flagged with a ‘cn’ flag and narrated.

Page 3 of 3
TestAmerica Chicago

The TestAmerica Chicago laboratory is in the process of performing maintenance on the activated instruments to minimize or eliminate the active sites to ensure
an inert status.
Further Corrective Action Needed: 1. Systematically clean or replace sample pathway to identify location of
active site within the instrumentation.
2. 3.

Reviewed by: _____________
JoAnn Petruszak-Kmetty, GC/MS VOA Supervisor Date Reviewed by: _____________ Robin Kintz, Project Manager Date

Reviewed by: Terese A. Preston, QA Manager Date Reviewed by:
Michael J. Healy, Laboratory Director Date

REFERENCE
8
A
B
34567 12
C
D
E
F
G
H
8 34567 12
A
B
C
D
E
F
G
H
DESCRIPTIONDATENOREVISION RECORDwww.cecinc.com1900 Center Park Drive - Suite A - Charlotte, NC 28217Ph: 980.237.0373 · Fax: [phone]DATE:DWG SCALE:DRAWN BY:CHECKED BY:APPROVED BY:PROJECT NO:SHEET OF
DRAWING NO.:SITE MAP 111-370.00011" = 200'JANUARY 2017JKSEHSEHS
1GREENWAY WASTE SOLUTIONS OFNORTH MECK, LLCNORTH MECKLENBURG LANDFILLHUNTERSVILLE, NCNORTH