4203_InternationalPaperLF_DetMonRequestResp_DIN27674_20170425

April 25, 2017

Sent Via Email – [e-mail]

Ms. Emily Lee
Environmental Remediation Manager
International Paper
6400 Poplar Ave
Memphis, TN 38119

Re: Request to Modify Detection Monitoring Program
International Paper Company – Low Ground Landfill
Permit ID # 4203-INDUS-1981
Halifax County
DIN 27674

Dear Ms. Lee:

The Solid Waste Section (Section) has reviewed the Request to Modify Detection Monitoring Program
report (DIN 27673) for the International Paper – Low Ground Landfill prepared by EarthCon Consultants
of North Carolina, P.C. (EarthCon). Post closure care at the facility was initiated in 1997 and a groundwater
monitoring system consisting of seven wells is present on-site. Depth to groundwater measurements and
samples are collected from monitor wells MW-LG1, MW-LG3, MW-LG5, MW-LG6, and MW-LG7.
Depth to groundwater is only measured in monitor wells MW-LG2 and MW-LG4. The groundwater
samples are analyzed for arsenic, barium, cadmium, chromium, copper, iron, lead, manganese, mercury,
selenium, silver, and zinc. The groundwater samples are also analyzed for inorganic parameters including
chloride, total dissolved solids (TDS), fluoride, and sulfate. Water quality parameters nitrate as nitrogen,
pH, specific conductivity, biological oxygen demand (BOD), chemical oxygen demand (COD), total
organic carbon, and total organic halides comprise the third group of constituents that are analyzed during
semiannual groundwater monitoring events.

EarthCon conducted a laboratory analytical data review of all groundwater monitoring results from 2007
to 2016. Analytical results were compared to the standards established in 15A NCAC 02L .0202 (2L
Standards) and a time versus constituent concentration graph was generated for each well. Water quality
parameters nitrate as nitrogen and BOD appeared to have increasing concentrations over time. Ph exhibited
a slight downward trend and there was no discernable trend for COD concentrations. The most recent data
for the inorganic parameter TDS indicates an upward trend while there was no apparent trend for chloride,
fluoride, and sulfate concentrations. Total metals parameter copper exhibited a slight upward trend while
a downward trend was observed for cadmium and zinc concentrations. The remaining metals constituents
did not exhibit any apparent trends although total iron and total manganese concentrations were consistently
reported above the 2L Standard.

Based on the analytical data review, EarthCon requested to reduce the water quality parameters to nitrate
as nitrogen, ph, and conductance; reduce the inorganic parameters to TDS and sulfate; remove the total
metals parameters; and reduce the sampling frequency from semi-annual to annual.

The Section will allow International Paper to reduce water quality parameters to nitrate as nitrogen, pH,
and conductance in addition to inorganic parameters to TDS and sulfate. International Paper will be
required to continue monitoring total metals on a semi-annual basis due to continued iron and manganese
2L Standard exceedances. In summary, groundwater samples should be collected and analyzed for nitrate
as nitrogen, pH, conductance, TDS, sulfate, and total metals on a semi-annual basis. The Section will re-
evaluate the required monitoring parameters and frequency after the next four consecutive monitoring
events. Please contact me at [phone] or by email at [e-mail] if you have any
questions or concerns regarding this letter. Thank you for your cooperation in this matter.

Sincerely,

Ervin Lane
Compliance Hydrogeologist
Solid Waste Section

cc: Peter Ramsey, P.G., EarthCon Consultants of North Carolina, P.C.
Jason Watkins, Field Operations Branch Head – Solid Waste Section
Drew Hammonds, Eastern District Supervisor – Solid Waste Section
Mary Whaley, Environmental Senior Specialist – Solid Waste Section
Christine Ritter, Permitting Hydrogeologist – Solid Waste Section