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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