1401_Caldwell_MSWLF_NCD086871282_SamplingPlan_FID1817439_202309011

hart '` hickman
SMARTER ENVIRONMENTAL SOLUTIONS
Via Email
September 11, 2023
Department of Environmental Quality
Division of Waste Management
Hazardous Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Mary Siedlecki
Re: Groundwater Sampling Work Plan
Former CSI Landfill Facility — NCDO86871282
Hudson, Caldwell County, North Carolina
H&H Job No. CAL-005
Dear Ms. Siedlecki:
On behalf of Caldwell County, Hart & Hickman, PC (H&H) is submitting a Work Plan for
proposed confirmatory groundwater sampling activities associated with the former CSI Landfill
Facility. The Work Plan has been prepared per the North Carolina Department of Environmental
Quality (NCDEQ) letter dated July 24, 2023, and additional discussions with NCDEQ.
Please do not hesitate to contact us at [phone] if you have any questions.
Sincerely,
Hart & Hickman, PC
Carlin Slusher
Project Manager
cc: Donald Duncan — Caldwell County (via email)
Heather Cox — Caldwell County (via email)
Barry Calloway — Caldwell County (via email)
Robert King, III — Brooks Pierce (via email)
David Lackey — Wilson, Lackey & Rohr (via email)
4J-1�1 a—_
Genna Olson, PG
Principal Geologist
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Groundwater Sampling Work Plan
Former CSI Landfill Facility
1200 Dragstrip Road
Hudson, Caldwell County,
North Carolina
EPA ID N C D 086 871 282
H&H Job No. CAL-005
September 11, 2023
Revision 0
.14
hart O-S• hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Groundwater Sampling Work Plan
Former CSI Landfill Facility
Hudson, North Carolina
NCD 086 871282
H&H Job No. CAL-005
Table of Contents
Section Page
1.0 Introduction.....................................................................................................................................1
2.0 Limited PFAS Groundwater Sampling.......................................................................................3
2.1 Limited Confirmatory Sampling................................................................................................ 3
2.2 Quality Assurance/Quality Control............................................................................................4
2.3 Decontamination.........................................................................................................................5
2.4 Investigation Derived Waste...................................................................................................... 5
3.0 Reporting.........................................................................................................................................6
4.0 Schedule............................................................................................................................................7
List of Tables
Table 1 PFAS Groundwater Analyte List and Reporting Limits
List o Fi ures
Figure 1
Site Location Map
Figure 2
Site Layout Map
Figure 3
Proposed PFAS Groundwater Sampling Map
List ofAppendices
Appendix A PFAS Sampling Checklist
1 hart '` hickman
htV://harthick.sharepOint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan_20230911.docx SMARTER ENVIRONMENTAL SOLUTIONS

Groundwater Sampling Work Plan
Former CSI Landfill Facility
Hudson, Caldwell County, North Carolina
NCD 086 871282
H&H Job No. CAL-005
1.0 Introduction
This Work Plan has been prepared by Hart & Hickman, PC (H&H) on behalf of Caldwell County
for completion of a confirmatory groundwater sampling event for per- and polyfluoroalkyl
substances (PFAS) at the former Caldwell Systems, Inc. (CSI) facility and Caldwell County
landfill (Site) located at 1200 Drag Strip Road in Hudson, North Carolina. A Site location map is
included as Figure 1 and a Site layout map included as Figure 2.
The former CSI facility operated as a hazardous waste management facility on a 1.59-acre parcel
leased from Caldwell County in the west -central portion of an approximately 148-acre parcel of
land owned by Caldwell County. Approximately 103 acres of this property was also utilized as
the Caldwell County landfill. The Site is currently regulated by North Carolina Department of
Environmental Quality (NCDEQ) Division of Waste Management (DWM) Hazardous Waste
Section (HWS) and has been assigned the facility ID number NCD086871282. The hazardous
waste management facility was constructed by Caldwell County, which operated it from April
1976 until January 1977. From March 1977 until 1989, Caldwell County leased the facility to
CSI. During this time, the facility incinerated and/or repackaged, consolidated, blended, and
liquefied waste for off -site shipment or use as fuel. The facility handled hazardous wastes from
the US Navy and other industries, including torpedo fuel, solvents, waste oils, paints, tank bottoms,
glues, and sludges.
Numerous, extensive investigations of potential impacts at the Site have been conducted since
1987, which included RCRA Facility Investigations (RFIs) and subsequent corrective measures,
as documented in previous reports. On June 30, 2023, H&H submitted a Corrective Measures
Study (CMS), Revision 3 to the NCDEQ DWM HWS. The report was submitted in response to a
letter dated November 28, 2022, requesting an update to the CMS, Revision 2. Per NCDEQ's
request, the updated CMS included the following: 1) annual groundwater monitoring data
1
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

(completed by others since 2018); 2) updated receptor survey information; and 3) groundwater
sampling data for PFAS (completed by H&H) as PFAS had not been previously sampled for at the
Site.
Based on results of the 2023 PFAS groundwater sampling, and as documented in the CMS,
Revision 3, dated June 30, 2023, PFAS were determined to be a potential contaminant of concern
for the Site based on analytical results from monitoring wells sampled across the Site. In a
subsequent letter dated July 24, 2023, the NCDEQ DWM HWS concluded that the detected PFAS
concentrations represented minimal risk to potential receptors. Therefore, the letter indicated that
no additional investigation, assessment, or routine monitoring was required at this time. However,
the NCDEQ DWM HWS requested one confirmatory PFAS groundwater sampling event at the
Site to confirm preliminary results on a "subset of monitoring wells characterized by the most
elevated concentrations." NCDEQ DWM HWS further indicated that following receipt of the
confirmatory PFAS analytical results, final comments would be provided on the CMS, Revision
3.
Therefore, this Work Plan has been prepared to describe the proposed scope of work for a limited
confirmatory groundwater sampling event for PFAS to satisfy the requirements of the NCDEQ
DWM HWS request dated July 24, 2023.
is
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

2.0 Limited PFAS Groundwater Sampling
2.1 Limited Confirmatory Sampling
To confirm PFAS concentrations in groundwater, H&H will collect groundwater samples from the
following monitoring wells, as indicated on Figure 3:
• Monitoring wells MW-2A located downgradient of the northern inactive landfill cell;
• Monitoring wells MW-3, MW-3A, GM-5, and FPC-MW-07A located downgradient of the
southern inactive landfill cell;
• Monitoring well GM-6 located north of the former incinerator; and
• Monitoring well FPC-MW-01 located south of the former incinerator.
Prior to sampling, the select monitoring wells will be gauged with a decontaminated electronic
water level meter. The water level meter and other non -dedicated equipment will be
decontaminated as described in Section 2.3.
Groundwater sampling will be performed in general accordance with the USEPA Region 4
Laboratory Services and Applied Science Divisions (LSASD) Operating Procedure
LSASDPROC-301-R6 (Groundwater Sampling), effective April 22, 2023. The shallow
monitoring wells will be purged using a peristaltic pump, high -density polyethylene (HDPE)
tubing, and low -flow techniques until field parameters of temperature, pH, specific conductivity,
and oxidation reduction potential (ORP) stabilize and turbidity readings are less than 10
Nephelometric Turbidity Units (NTUs). Due to the anticipated depth to groundwater in a few
monitoring wells (greater than 35 feet below ground surface), a PFAS-free bailer will be used to
remove at least three well volumes or until the monitoring well is purged dry. Field parameters,
as indicated above, will be collected after each purge volume and purging will be considered
complete when field parameters have stabilized or a maximum of five well volumes have been
removed.
3
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

The groundwater samples will be placed in dedicated laboratory -supplied sample containers and
then shipped in an iced cooler to a certified laboratory (Eurofins) under standard chain -of -custody
protocols for analysis. Samples will be analyzed for the same PFAS compound list included in
the prior sampling event by USEPA Modified Method 537.1. In addition, samples will be analyzed
for 5:3 FTCA by Eurofins Modified Method 537. It should be noted that H&H is proposing the
use of the same analytical method (i.e., USEPA Modified Method 537.1) previously utilized during
the recent sampling events for consistency in analytical results. H&H will request that analytical
results be reported to the laboratory's reporting limits, similar to the prior sampling event. The
PFAS groundwater analyte list with laboratory provided compound reporting limits is summarized
on Table 1.
2.2 Quality Assurance/Quality Control
Quality Assurance/Quality Control (QA/QC) samples will be collected to assess the field sampling
and analytical programs. Two H&H staff will be present on -site during groundwater sampling for
PFAS using an approach similar to USEPA's "Clean Hands Dirty Hands." Additionally,
groundwater sampling will be conducted in accordance with the requirements listed in the PFAS
Sampling Checklist included in Appendix A.
During the limited sampling event, the following QA/QC samples will be collected to assess the
field sampling and analytical programs:
• One equipment rinse blank will be collected by running PFAS and analyte-free water
provided by the laboratory through new sample tubing;
• One field blank will be collected using PFAS and analyte-free water provided by the
laboratory; and
• One duplicate sample will be collected from one monitoring well.
Sample containers will be labeled with a sample identification, sampler's initials, collection time
and date, targeted analyses, and preservative type. Samples will be placed in an iced cooler for
delivery under chain -of -custody protocol to Eurofins for the analysis using the same methods,
2
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

analyte list, and reporting limits described in Section 2.1 above. The laboratory analyses will
include appropriate blanks, laboratory duplicates, continuing calibration standards, surrogate
standards, and matrix spiking standards in accordance with approved methodologies to monitor
both instrument and analyst performance.
2.3 Decontamination
Non -dedicated equipment, such as the water level meter, will be decontaminated in general
accordance with the USEPA Region 4 LSASD Operating Procedure ASBPROC-206-R4 (Field
Equipment Cleaning and Decontamination at the FEC), effective October 3, 2019. Field
equipment will be decontaminated between each well using the following procedures:
• washed with laboratory -provided PFAS and analyte-free water and Alconox; and
• triple rinsed with laboratory -provided HAS and analyte-free water.
2.4 Investigation Derived Waste
Groundwater generated during limited sampling activities will be containerized and properly
labeled in a 55-gallon drum that will be staged in a secure area on the Site property. Based on the
current analytical results, the purge water will be profiled as PFAS-containing purge water and
appropriately transported by an approved waste transporter to an approved facility.
5
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

3.0 Reporting
Following completion of the sampling activities and receipt of the analytical data, H&H will
compile results in a brief groundwater monitoring report to include a description of the sampling
activities, tabulated PFAS data compiled with previous groundwater monitoring results, pertinent
groundwater quality figures, and conclusions and recommendations based upon confirmatory
sampling activities.
0
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

4.0 Schedule
Field activities will be scheduled within approximately three weeks of authorization to proceed. It
is anticipated that HAS analytical data will be received within 30 to 60 days after sampling, but
the laboratory turnaround time may vary. A report will be submitted to the NCDEQ DWM HWS
within 45 days following receipt of analytical results.
7
https://harthick.shmepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/Caldwell County - CAL/CAL.005 - CMS
Update/Confirmatory GW Sampling/Work Plan/Final to DEQ/Caldwell County Work Plan _20230911.docx hart I h i c k m a n
SMARTER ENVIRONMENTAL SOLUTIONS

Table
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

Table 1
PFAS Groundwater Analyte List and Reporting Limits
Former CSI Facility
Hudson, Caldwell County, North Carolina
H&H Job No. CAL-005
CAS Number
Analyte
Reporting Limit
(ng/L)
375-22-4
Perfluorobutanoic acid (PFBA)
5
2706-90-3
Perfluoropentanoic acid (PFPeA)
2
307-24-4
Perfluorohexanoic acid (PFHxA)
2
375-85-9
Perfluoroheptanoic acid (PFHpA)
2
335-67-1
Perfluorooctanoic acid (PFOA)
2
375-95-1
Perfluorononanoic acid (PFNA)
2
335-76-2
Perfluorodecanoic acid (PFDA)
2
2058-94-8
Perfluoroundecanoic acid (PFUnA)
2
307-55-1
Perfluorododecanoic acid (PFDoA)
2
72629-94-8
Perfluorotridecanoic acid (PFTrDA)
2
376-06-7
Perfluorotetradecanoic acid (PFTeA)
2
375-73-5
Perfluorobutanesulfonic acid (PFBS)
2
2706-91-4
Perfluoropentanesulfonic acid (PFPeS)
2
355-46-4
Perfluorohexanesulfonic acid (PFHxS)
2
375-92-8
Perfluoroheptanesulfonic acid (PFHpS)
2
1763-23-1
Perfluorooctanesulfonic acid (PFOS)
2
68259-12-1
Perfluorononanesulfonic acid (PFNS)
2
335-77-3
Perfluorodecanesulfonic acid (PFDS)
2
79780-39-5
Perfluorododecanesulfonic acid (PFDoS)
2
754-91-6
Perfluorooctanesulfonamide (FOSA)
2
2355-31-9
NMeFOSAA
5
2991-50-6
NEtFOSAA
5
757124-72-4
4:2 FTS
2
27619-97-2
6:2 FTS
5
39108-34-4
8:2 FTS
2
756426-58-1
9C1-PF3ONS
2
763051-92-9
11 Cl-PF3OUdS
2
919005-14-4
4,8-Dioxa-3H-perfluorononanoic acid (ADONA)
2
914637-49-3
5:3 FTCA*
2
Notes:
Analytical information provided above, including reporting limits, was provided by Euroflns Sacramento based on USEPA
Method 537 (modified). * 5:3 FTCA to be analyzed/reported using Euroflns Method 537 (modified).
ng/L = nanograms per liter
Table 1 (Page 1 of 1)
Hart & Hickman, PC

Figures
14
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

p
.n
�a
a +e at " cA
I , J � f
k SITE a
r
Rr 5
r�
lL
IN
I� Y
:3
APPROXIMATE
N 0 2000 4000
SCALE IN FEET
U.S.G.S. QUADRANGLE MAP
KINGS CREEK, NORTH CAROLINA, 1997
QUADRANGLE
7.5 MINUTE SERIES (TOPOGRAPHIC)

LEGEND
SITE PROPERTY BOUNDARY
ADJACENT PARCEL BOUNDARY
— — INTERMITTENT STREAM
TREELINE
MONITORING WELL LOCATION
/ MW-2 MW-2A /
/ \ 1
NORTHERN INACTIVE / \ MW-3
LANDFILL CELL l _ — \ �MW-3A
GM-5
GM-6 SOUTHERN INACTIVE /
I / �/ / LANDFILL CELL
GM-3
MWA
FORMER CSI FACILITY G
FPC-MW-06
MW-C 1 II FP6-MW-02 /
DW-1 I /
GM 1 I
/
MW-B2 FPC-MW-OS
FPC-MW-03h
YDW-2# GM-2
#FPC-MW-01 a
0
�4
0
APPROXIMATE
0 400 800
SCALE IN FEET
SITE LAYOUT MAP
112,IF`T FORMER CSI FACILITY
1200 DRAG STRIP ROAD
HUDSON, NORTH CAROLINA
• 2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p)704-586-0373(f
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 4-18-23 REVISION NO. 0
JOB NO. CAL-005 FIGURE NO. 2

C�
GM-6 (4/13/23)
PFOA
11
PFOS
60
GM-1 (1/27/23)
<ESTABLISHED
SCREENING LEVELS
MW-C (4/13/23)
<ESTABLISHED
SCREENING LEVELS
DW-1 (4/13/23)
PFOA 18 FPC-MW-03
FPC-MW-03 (4/13/23)
<ESTABLISHED
SCREENING LEVELS
FPC-MW-01 (4/13/23)
PFOA 17
MW-2 (1/26/23)
PFOA
4.8
PFOS
2.6
FPC-MW-07A (1/27/23)
PFOA
19
PFOS
2.4
/ MW- MW-2A
I
/ I MW-2A (1/26/23) /
PFOA >0 /
I
/ NORTHERN INACTIVE
I LANDFILL CELL l —
3M-6 / / SOUTHERN INACTIVE
LANDFILL CELL
I
i
GM-5 (1/26/23)
GM-3 i�—�__�� PFOA 11
/ FPC-MW-06
FPC-MW-02 /
G 1 I /
M % 62 cFPC-MW-. _
0
GM-4 (4/13/23)
PFOA I 11
MW-3 (1/26/23)
PFOA
140
PFNA
5.8
PFBS
461
PFHxS
48
PFOS
13/
FPC-MW-05 (4/13/23)
PFOA
>.7
PFOS
1.7
LEGEND
SITE PROPERTY BOUNDARY
ADJACENT PARCEL BOUNDARY
— — — INTERMITTENT STREAM
CHAINLINK FENCE
� TREELINE
MONITORING WELL LOCATION
O PROPOSED SUBSET OF
MONITORING WELLS TO SAMPLE
MW-3A (1/27/23)
PFOA 6.1
PFOS 9.1
SAMPLE ID & DATE
FPC-MW-07A (1/27/23)
PFOA 19
PFOS 2.4
CONSTITUENT— `CONCENTRATION
MW-3A
(ng/L)
NOTES:
1.
GROUNDWATER SAMPLES COLLECTED IN JANUARY AND
APRIL 2023 BY H&H PERSONNEL.
2.
E FLAG DENOTES RESULT EXCEEDS ANALYTICAL
CALIBRATION RANGE. I FLAG DENOTES VALUE IS
ESTIMATED MAXIMUM POSSIBLE CONCENTRATION
(EMPC). I FLAG DENOTES VALUE IS ESTIMATED MAXIMUM
POSSIBLE CONCENTRATION.
3.
PFOA = PERFLUOROOCTANOIC ACID
PFNA = PERFLUORONONANOIC ACID
PFBS = PERFLUOROBUTANE SULFONIC ACID
PFHxS = PERFLUOROHEXANESULFONIC ACID
PFOS = PERFLUOROOCTANESULFONIC ACID
ng/L = NANOGRAMS PER LITER
4.
BOLD CONCENTRATIONS INDICATE AN EXCEEDANCE OF
THE EPA PROPOSED MAXIMUM CONTAMINANT LEVELS
(MCL).
5.
ITALIC/ZED CONCENTRATIONS INDICATE AN EXCEEDANCE
OF THE EPA PROPOSED INTERIM OR FINAL HEALTH
ADVISORY LEVEL.
6.
UNDERLINED CONTRATIONS INDICATE AN EXCEEDANCE
OF THE EPA TAPWATER REGIONAL SCREENING LEVEL
(RSL).
7.
FOR PFNA, PFHxS, AND PFBS, THE HAZARD INDEX IS
CALCULATED FOR COMPARISON TO THE EPA MCL.
WHERE THE COMBINED HAZARD INDEX INDICATES AN
EXCEEDANCE, A BOLD CONCENTRATION IS NOTED FOR
THE INDIVIDUAL CONSTITUENT USED IN THE
CALCULATIONS.
APPROXIMATE
N0 400 800
SCALE IN FEET
PROPOSED PFAS GROUNDWATER
SAMPLING MAP
I- IFC.T FORMER CSI FACILITY
1200 DRAG STRIP ROAD
HUDSON, NORTH CAROLINA
`4 2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p)704-586-0373(f)
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 8-31-23
:4w/69[Q011Iowa]
JOB NO. CAL-005
FIGURE NO. 3

Appendix A
PFAS Sampling Checklist
14
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS

PFAS Sampling Checklist
Date:
Weather (temp./precipitation):
Site ID#:
Site Name:
Field Clothing and PPE:
No clothing or boots containing Gore-TexTM
All safety boots made from polyurethane and PVC
No materials containing Tyvek®
_Field crew has not used fabric softener on clothing
_Field crew has not used cosmetics, moisturizers, hand cream, or other related products this morning
_Field crew has not applied unauthorized sunscreen or insect repellant
Field Equipment:
No Teflon® or LDPE containing materials onsite
All sample materials made from stainless steel, HDPE, acetate, silicon, or polypropylene
No waterproof field books on -site
No plastic clipboards, binders, or spiral hard cover notebooks on -site
No adhesives (Post -It Notes) on -site
_Coolers filled with regular ice only. No chemical (blue) ice packs in possession
Sample Containers:
All sample containers made of HDPE or polypropylene (circle one)
_Caps are unlined and made of HDPE or polypropylene (circle one)
Wet Weather (as applicable):
_Wet weather gear made of polyurethane and PVC only
Equipment Decontamination:
"PFAS-free" water on -site for decontamination of sample equipment. No other water sources to be
used.
_Alconox and Liquinox to be used as decontamination materials
Food Considerations:
No food or drink on -site with exception of bottled water and/or hydration drinks (i.e., Gatorade and
Powerade) that is available for consumption only in the staging area If any applicable boxes cannot be
checked, the Field Lead shall describe the noncompliance issues below and work with field personnel to
address noncompliance issues prior to commencement of that day's work. Corrective action shall include
removal of noncompliance items from the site or removal of worker offsite until in compliance. Describe
the noncompliance issues (include personnel not in compliance) and action/outcome of noncompliance:
Field Lead Name:
Field Lead Signature:
Time:
Reference: Checklist is excerpt from PFC Sampling Procedures, Collecting a Leachate Sample for Perfluorinated Chemicals (PFCs) using
Modified Method 537 (PFAS Core Method), NC Solid Waste Section, January 2019