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HomeMy WebLinkAbout6301_Moore_CDLF_AssessmentWorkPlan_DIN28724_20180105 Golder Associates NC, Inc. 5B Oak Branch Drive Greensboro, NC. 27407 USA Engineering Lic. No. C-2862/ Geology Lic. No. C-399 Tel: (336) 852-4903 Fax: (336) 852-4904 www.golder.com Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America January 5, 2018 0739615017.300 Ms. Jackie Drummond Department of Environmental Quality Division of Waste Management Solid Waste Section 2090 US Highway 70 Swannanoa, North Carolina 28778 RE: ASSESSMENT MONITORING WORK PLAN MOORE COUNTY CONSTRUCTION AND DEMOLITION LANDFILL, PERMIT NO. 63-01 MOORE COUNTY, NORTH CAROLINA Dear Jackie: On behalf of Moore County, Golder Associates NC, Inc. (Golder) is submitting the following Assessment Monitoring Work Plan (Plan) to the North Carolina Department of Environmental Quality (NC DEQ). This Plan outlines the County’s intention to initiate Assessment Monitoring at its Construction and Demolition (C&D) Landfill, Permit No. 63-01. Pursuant to 15A NCAC 13B .0545, Assessment Monitoring is required when one or more constituents, as listed in Part(b)(1)(D) of Rule .0544, are detected above the current groundwater protection standards during any sampling event. Detections of volatile organic constituents (VOCs) at concentrations above applicable groundwater standards have been documented in samples from groundwater monitoring wells at this facility since 1996. On February 28, 2017, Golder submitted an Alternate Source Demonstration (ASD) documenting the closed municipal solid waste (MSW) landfill (also permitted under 63-01) as the source of VOCs in samples from site groundwater monitoring wells. In a letter dated September 28, 2017, NC DEQ issued a response to the ASD and stated that the Solid Waste Section (SWS) did not approve the ASD at this time and requested the County:  Install an active landfill gas (LFG) remediation system as stated and approved in 2012 at the upgradient closed and unlined MSW landfill to reduce LFG concentrations, and  Demonstrate a decrease in VOC concentrations in samples from the groundwater monitoring wells at both the MSW landfill and the C&D landfill. As a result, Moore County will initiate an Assessment Monitoring Program at the closed C&D landfill, beginning with the 1st semi-annual groundwater sampling event in 2018. The first semi-annual event is tentatively scheduled for April 2018, although it may occur in May or June 2018 to allow time for well installation and development prior to the event. The County is submitting this Plan in accordance with 5A NCAC 13B .0545(a)3. It is Moore County’s intent to fully comply with the requirements of 15A NCAC 13B. 0545.(a) and (b). 15A NCAC 13B .0545(a)(1) and (b)(1): INSTALLATION OF ADDITIONAL MONITORING WELLS: As discussed at the November 30, 2017 meeting between Moore County and NC DEQ, Moore County is proposing to install replacement monitoring wells for MW-11S and MW-11D which are part of the C&D landfill’s compliance monitoring network. The County is concerned that the current monitoring wells are located too close to the limits of waste boundary at the C&D landfill the new locations should allow the County to obtain more representative data. The approximate proposed location of the additional groundwater monitoring well(s) is illustrated/detailed on Attachment 1. By installing a nested pair, the County can obtain assessment data for both the horizontal and vertical extent of potential constituents. Ms. Jackie Drummond January 5, 2018 NC DEQ – DWM – Solid Waste Section 2 0739615017.300 After installation of the replacement monitoring wells MW-11SR and MW-11DR monitoring wells MW-11S and MW-11D will remain for the collection of water levels only. Although unrelated to C&D groundwater assessment activities, MW-15 has been dry or incapable of yielding representative water for sampling during recent events. A replacement well will be installed for MW-15 (i.e., MW-15R) during the same drilling mobilization as MW-11SR and MW-11DR. After the installation of MW-15R, MW-15 will be removed from the groundwater compliance network and a turbine vent will be added to help prevent migration of methane toward the property boundary. If possible, drilling may also be combined with other site drilling activities for the Phase VI C&D expansion. All wells will be installed prior to the first semi-annual monitoring event for 2018. NCAC 13B. 0545(a)(2): NOTIFICATION TO ALL PERSONS WHO OWN LAND OR RESIDE ON LAND WITHIN THE CONTAMINATE PLUME: There is one tract of land that is privately owned located north of the closed MSW landfill. The location of this property is shown on the included Site Map (Attachment 1). Moore County is currently in negotiations with the property owner to purchase this tract of land and the owner is aware of the impacts to their property through verbal conversations with County staff. The private water supply well located on their property has been monitored since 1996 with no impacts noted from the MSW landfill. Also, based on discussions with NC DEQ representatives, the County is not required to make any additional notifications at this time. 15A NCAC 13B .0545(a)(3): SUBMISSION OF ASSESSMENT MONITORING WORK PLAN: The county is submitting this Plan as required by Rule. Once approved by the Division of Waste Management, the approved Plan will be placed in the facility’s operating record, and all appropriate government officials will be notified. In order to comply with 15A NCAC 13B .0545 (b), the County will also complete the following activities: 15A NCAC 13B. 0545(b)(2): ANALYSIS OF ADDITIONAL PARAMETERS IN GROUNDWATER: As part of the Plan, analysis of additional groundwater quality parameters will be performed in the upgradient and downgradient monitoring wells at the C&D landfill in accordance to NCAC 13B. 0545(b)(2). The additional parameters will include all of the constituents listed in the Appendix II of 40 CFR 258 and the required indicator parameters for C&D landfills (chloride, manganese, sulfate, iron, specific conductance, pH, temperature, alkalinity, total dissolved solids, and tetrahydrofuran). The 1st semi-annual groundwater monitoring event (tentatively scheduled for April 2018) will be the first sampling event for these additional parameters. As required by Rule, a minimum of four independent samples from each well will be collected and analyzed to establish background for the new constituents. The sampling schedule and list of parameters for the C&D landfill will proceed as follows: First Semi-Annual Groundwater Sampling Event 2018 Second Semi-Annual Groundwater Sampling Event 2018 NC Appendix II list C&D Indicator list (in C&D wells only) NC Appendix I VOCs and detected NC Appendix II constituents C&D Indicator list (in C&D wells only) Ms. Jackie Drummond January 5, 2018 NC DEQ – DWM – Solid Waste Section 3 0739615017.300 First Semi-Annual Groundwater Sampling Event 2019 Second Semi-Annual Groundwater Sampling Event 2019 NC Appendix I VOCs, and detected NC Appendix II constituents C&D Indicator list (in C&D wells only) NC Appendix I VOCs, and detected NC Appendix II constituents C&D Indicator list (in C&D wells only) The proposed assessment monitoring well network will also include two additional MSW monitoring wells to further assess whether the groundwater impacts seen in C&D monitoring wells are caused by impacts from the MSW landfill. The two additional MSW monitoring wells (MW-6 and MW-7) will be sampled for and analyzed for the same list of assessment parameters. These data will be used to complete an ASD addendum, if data support that groundwater C&D impacts are attributable to the MSW facility. A list of the proposed assessment monitoring well network is shown below. Monitoring Well ID: Monitoring Well Network: Proposed Parameter/Constituents*: MW-5 Background Well (C&D/MSW) NC Appendix II & C&D Indicator List MW-4 C&D/MSW Monitoring Well NC Appendix II & C&D Indicator List MW-11SR C&D Assessment Well NC Appendix II & C&D Indicator List MW-11DR C&D Assessment Monitoring Well NC Appendix II & C&D Indicator List MW-13S C&D Monitoring Well NC Appendix II & C&D Indicator List MW-13D C&D Monitoring Well NC Appendix II & C&D Indicator List MW-14 Upgradient C&D/Downgradient MSW Monitoring Well NC Appendix II & C&D Indicator List MW-16S** C&D/MSW Monitoring Well NC Appendix II & C&D Indicator List MW-16D** C&D Monitoring Well NC Appendix II & C&D Indicator List MW-6 MSW Monitoring Well NC Appendix II MW-7 MSW Monitoring Well NC Appendix II *Note that full NC Appendix II list will be analyzed during the April 2018 event and the current approved list of RCRA metals and Appendix I VOCs plus detected Appendix II parameters will be analyzed for the three subsequent assessment monitoring events, until such time as the C&D water quality monitoring plan may be updated as part of upcoming permitting activities. ** Note that wells MW-16S and MW-16D are within the future waste footprint for the Phase VI expansion and in the current borrow area. These wells will be sampled during the first semi-annual sampling event in 2018 and then decommissioned as part of drilling activities associated with the aforementioned well installation activities and the upcoming Phase VI permitting activities. In addition, until a new groundwater remedy is selected or the ASD is re-evaluated, performance monitoring parameters collected under the current MNA program will continue to be collected as specified in the approved Assessment of Corrective Measures (ACM) submitted by HDR in 2005. Also, MSW monitoring wells not included in the table above will continue to be monitoring in accordance with the approved monitoring plan for RCRA metals and Appendix I VOCs. Upon completion of each of the assessment monitoring events, semi-annual reports will be submitted to the SWS. Upon completion of the fourth background sampling event, a report will be submitted to NC DEQ in accordance with 15A NCAC .0545(b)(7) to be sealed by a licensed geologist, and will be combined with a semi-annual report. The concentrations of NC Appendix II constituents for each background monitoring event will be compared to established 15A NCAC 02L. 0202 groundwater quality standards (2L Standards) and Solid Waste Section Groundwater Protection Standards (SWS GPSs). In the case of metals, comparisons will also be made to background concentrations. Pending the results of background sampling results the County may petition the SWS to return to a Detection Monitoring Program [15A NCAC 13B .0545(b)(9)] and submit an ASD addendum, request selective Assessment ATTACHMENT 1 CATCH BASIN CATCH BASIN i3 i2 i1 GP-10 CLOSED MSW LANDFILL ACTIVE C&D LANDFILL SW-2 SW-4 SW-3 SW-1 TO GP-9 3953953653603703803753853903903853753803703653553604003 5 5 400MW-7 384.69 MW-4360.00 365.69MW-16S 365.50MW-16D GP-12 357.27MW-3 367.06MW-2 381.18MW-1 382.23 MW-9 382.02 MW-8 MW-13S373.25MW-13D 372.53 382.18 MW-14 387.69 MW-6 MW-11D371.85 MW-11S370.68 MW-5 375.99 MW-15 397.17 PW-1 GP-15 GP-16 GP-14 GP-13 GP-11 GP-17 GP-10 MW-11SR MW-11DR MW-15R CONSULTANT DESIGN PREPARED REVIEW APPROVED YYYY-MM-DD TITLE PROJECT No.Rev. PROJECTCLIENT Path: \\greensboro\CAD\_2007\0739615 - Moore\PRODUCTION\_F - 2018 AMWP\ | File Name: 0739615015F002.dwgIF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI D01 in0739615016 PHASE 100 DRAWING 10 2018-01-04 BSD BSD BSD RPK MOORE COUNTY LANDFILL PERMIT NO. 63-01 ABERDEEN, NORTH CAROLINA MOORE COUNTY ASSESSMENT MONITORING WORK PLAN SITE MAP PERENNIAL STREAM INTERMITTENT STREAM EPHEMERAL STREAM POND AND WETLAND LIMITS EXISTING 10 FT GROUND SURFACE CONTOUR EXISTING 2 FT GROUND SURFACE CONTOUR PROPERTY LINE APPROXIMATE LIMITS OF WASTE EXISTING ROAD POTENTIOMETRIC GROUNDWATER CONTOURS (5 FT. INTERVAL) GROUNDWATER FLOW SEGMENTS PROPOSED ASSESSMENT MONITORING WELLS PROPOSED REPLACEMENT MONITORING WELLS MONITORING WELL AND IDENTIFICATION METHANE PROBE AND IDENTIFICATION SURFACE WATER MONITORING POINT AND IDENTIFICATION LANDFILL GAS TRENCH VENTS AND IDENTIFICATION PASSIVE LANDFILL GAS VENTS PRIVATE WELL LOCATION AND IDENTIFICATION WETLAND AREA LEGEND NOTES 1. TOPOGRAPHIC CONTOUR INTERVAL = 2 FEET 2. GROUNDWATER SURFACE CONTOUR INTERVAL = 5 FEET 3. GROUNDWATER ELEVATIONS MEASURED ON APRIL 11, 2017. 4. GROUNDWATER CONTOURS BASED ON LINEAR INTERPOLATION BETWEEN AND EXTRAPOLATION FROM KNOWN DATA, TOPOGRAPHIC CONTOURS, AND KNOWN FIELD CONDITIONS. THEREFORE, GROUNDWATER CONTOURS MAY NOT REFLECT ACTUAL CONDITIONS. 5. GROUNDWATER CONTOUR LINES SHOW THE WATER TABLE SHAPE AND ELEVATION. THESE CONTOURS ARE INFERRED LINES FOLLOWING THE GROUNDWATER SURFACE AT A CONSTANT ELEVATION ABOVE SEA LEVEL. THE GROUNDWATER FLOW DIRECTION IS GENERALLY PERPENDICULAR TO THE GROUNDWATER SURFACE CONTOURS, SIMILAR TO THE RELATIONSHIP BETWEEN SURFACE WATER FLOW AND TOPOGRAPHIC CONTOURS. 6. PROPERTY BOUNDARY SURVEY BY JAMES L. WRIGHT DATED NOVEMBER 1984. ITS LOCATION IS RELATIVE TO TOPOGRAPHY APPROXIMATE BY HDR ENGINEERING, INC. 7. EXISTING TOPOGRAPHY WITHIN ACTIVE AND PROPOSED LANDFILL PROVIDED BY MATTHEWS LAND SURVEYING & MAPPING, PLLC DATED APRIL 17, 2015. 8. MONITORING WELLS MW-1 THROUGH MW-5 SURVEYED JUNE 1987 BY S&ME, INC. MONITORING WELLS MW-6 THROUGH MW-16 SURVEYED APRIL 1995, SEPTEMBER 1996, AND APRIL 2003 BY HDR ENGINEERING INC./ ED BUCKNER RLS APRIL 17, 2015. 9. THE LOCATIONS OF LANDFILL GAS TRENCH VENTS ARE APPROXIMATE. 10. GROUNDWATER WELLS MW-11D, MW-13D, AND MW-16D ARE NOT SCREENED IN THE SHALLOW AQUIFER AND ELEVATION DATA WERE NOT USED IN THE CONSTRUCTION OF GROUNDWATER CONTOURS. 11. A STREAM DETERMINATION WAS CONDUCTED ON APRIL 17, 2013 BY A GOLDER ASSOCIATES NC, INC. REPRESENTATIVE. THE STREAM DETERMINATION WAS CONDUCTED USING NCDWQ'S "METHODOLOGY FOR IDENTIFICATION OF INTERMITTENT AND PERENNIAL STREAMS AND THEIR ORIGINGS, VERSION 4.11". 381.18 MW-1 GP-10 SW-1 PW-1 385 SITE LOCATION MAP NOT TO SCALE SITE LOCATION 0 FEET 200 400 SCALE 382.18 MW-14 MW-15R