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Home My WebLink AboutWI0400109_Work Plan Correspondance_20090518a -A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Suliins Govemor Director May 18, 2009 Alan Payne CMC Holding Corporation 285 ivy Circle Elkin, NC 28621 RE: CMG Landfill U1C Program Tracking, # W10400109 Dear Mr. Payne: Dee Freeman Secretary The Underground Injection Control (UIC) Program of the Aquifer Protection Section of the Division of Water Quality has reviewed the proposal for injection of HRC 3DMe to stimulate anaerobic bioremediation of chlorinated solvents and petroleum compounds, which was received on April 17, 2009, The proposed injection project as presented in the work plan meets relevant state regulatory requirements (I5A NCAC 2C.0200) for construction and operation of injection wells. Review of the proposed injection activity yielded the following recommendations regarding post -injection groundwater monitoring and sampling: ■ The following previously detected metals should be incorporated into the list of analytical parameters in the monitoring plan: * Antimony * Arsenic * Barium * Cadmium * Chromium * Copper * Lead * Mercury * Nickel *Selenium *Zinc These previously detected metals can exhibit increased mobility in groundwater due to the change in pH and redox conditions resulting from the proposed injection. As the proposed injectant is consumed and used in the degradation of contaminants, oxygen is consumed and carbon dioxide is produced, which can reduce the pH and make the groundwater more acidic. Both of these effects can dissolve minerals that adsorb metals, thereby releasing them into the groundwater. The metals mentioned above should be monitored in case another groundwater problem results from the proposed remediation activity. Metabolic acids. methane. and ethane should be removed from the list of analytical parameters in the monitoring plan. These parameters are most useful for periodically evaluating microbial activity and how the proposed injectant is being consumed-, they are less useful for determining the effectiveness of contaminant degradation. Given the limited funds and number of sampling events, these parameters should be removed and replaced with other, more useful, parameters. AQUIFER PROTECTION SECTION 1636 Mail Service Center, Ralelp, North Carolina 27699.1Q6 Localm 2728 Capital Boulevard. Raleigh. Norm Carolina 2760Y (3RC Pnone; 919-733-3221 FAY 1 91i-71&.05M. FAY ..91�-715-604.8 Customer Zterviu. i ' Z:: 6-4F NoI-t1] Carolina Irntemet www.newateroualitv.om ,.'I �rttrra4r •p- L;;im ni��,r;ur++g =. �F�rntiaiw �CVG+� ifniHOye Add reduced species of nitrogen and sulfur to the list of analytical parameters in the monitoring plan. Coupling these with the oxidized nitrogen and sulfur species already in the plan will enable a more complete evaluation of the site geochemical conditions. ■ Monitoring wells MW-7 and MW-8 should be added to the monitoring well network. Currently four of the six proposed monitoring wells lie outside the contaminant plume. Some of these wells could be replaced with MW-7 and MW-8, which will be more useful to evaluate the effectiveness of the injection project plus be used to detect metals if they are mobilized and moving toward the Yadkin River. Due to the site's coverage under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the state's administrative permitting requirements have been waived for this project. A technical report summarizing the project, including monitoring data, should be submitted to the UIC Program upon completion of the injection project. Please call me at 919-715-6164 or Debra Watts at 919-715-6699 if you have any questions regarding this letter or the UIC Program. Best Regards, �J Thomas Slusser, L.G. Underground Injection Control Program cc: Cheryl Marks. Division of Waste Management Jason Jomp. Piedmont Industrial Services, Inc. Stephen Berry. Winston-Salem Regional Office UIC files CMC Holding ID: NON CD 000 0016 Responsible Party/Contact: Alan Payne CMC Holding Inc. 285 Ivy Circle Ellin, NC 28621 Consultant: Tom Lennon Piedmont Industrial Services Inc. 1670-A Lowery Street Winston-Salem. NC 27101 Phone number: 336-722-6505 Facility: CMG Landfill 580 Main Street Elkin, NC Faeility Summary: Industrial waste disposal occurred from the 1950's through 1982. Waste included: nylon sheets, polypropylene, tyvek, typar, lint and fiber waste, bale bands and wire, latex waste, paint solids, cardboard and cardboard drums, flooring, concrete, bricks, pallets, old fabric rolls, empty drums (plastic and steel), coal ash. The CERCLA site, currently owned by CMC, consists of approximately 27 acres of undeveloped land adjacent to the Yadkin River in the eastern portion of the Town of Elkin, North Carolina. Waste disposal areas include approximately 15 acres. The Elkin Property is currently listed on the North Carolina Department of Environment and Natural Resources, Division of Waste Management, Superfund Section, Inactive Hazardous Sites Branch (hereafter the "NCDENR" ) Inactive Hazardous Waste Sites Priority List as CMC Landfill ID #: NDNCD0000416. This listing results from prior subsurface disposal of material generated at the former Chatham Manufacturing Company, Surface Water: Analytical results from the four surface water samples collected from the Yadkin River did not indicate the presence of any of the volatile organic compounds detected in on site monitoring wells. Groundwater: A total of 20 volatile organic compounds were detected in the collected groundwater samples. Results for the groundwater sampling event detected i I volatile organic compounds in concentrations exceeding 15A NCAC 2L Standards and 11 volatile organic compounds in concentrations exceeding 15A NCAC 2B Standards. The highest levels of groundwater impacts were evidenced in wells MW4 and MW-2S. Volatile organic compounds include 1,1 Dichloroethane, 1,1 Dichloroethene, Tetrachloroethene, Trichloroethene, 1,1,1 Trichloroethane, 1,2 Dichloroethane, 1,1,2 Trichloroethane, Vinyl Chloride, Benzene, Chloroethane, and Methylene Chloride. Based on information obtained from previous site assessments a public water supply is available for the subject site and surrounding areas and no water supply wells are located within 1500 feet of the site. The nearest surface water intake, utilized by the City of Jonesville for a public water supply, is located 7,559 feet west of the subject site. Work Plan Injection Data: Proposed February 2008 Chemical Injection of HRC and HRC-X: Injection within the excavation will be necessary after the exccavation is backfilled to address groundwater impacts in the immediate vicinity of the soil source area. Piedmont proposes to inject 480 lbs of HRC and 720lbs of HRC-X via a GeoProbe at a 10' X 10' grid interval into the filled excavation area at a vertical interval of 15' to 21' bgs for a total of 40 injection points. A total of 18 lbs ofHRC-X and 12 lbs of HRC will be injected over the 6' vertical extent for each injection point, Chemical Injection of HRC-A: 23,396 gallons of 3D Microemulsion consisting of 17,220 lbs of HRC-A and 21,300 gallons of water will need to be injected outside of the excavated area to remediate the groundwater plume in the immediate vicinity of the soil source area. The Microemulsion will be injected via a GeoProbe into 150 injection points on a 10' x 20' grid outside of the excavated area at a vertical interval of 7' to 21 ' bgs (Figure 1 I). A total of 156 gallons of the 3D Microemulsion will be injected for each injection point. The volume of injected chemicals may vary depending on the baseline sampling event. Revised Proposal March 2009 Chemical Injection of HRC-A (3D Microemulsion) Soil Source Area: Injection will be necessary after the 75' x 50' x 13' excavation is backfilled. To address groundwater impacts in the soil source area. 1,894 gallons of 3D consisting of 1,410 pounds of HRC-A and 1,690 gallons of water will be injected inside the filled excavation area. HRC-A will be injected via geoprobe into 20 injection points on a 15' x 15' offset grid with 15' between points and 15' between rows at a vertical interval of 15' to 21' below ground surface for a total of 20 injection points. A total of 93 gallons of the HRC-A will be injected at each point. The injection rate is expected to be 3 gallons per minute. Plume: 22,764 gallons of HRC-A consisting of 17,220 pounds of HRC-A and 20,640 gallons of water will be injected in the plume outside the filled excavation area to remediate the groundwater plume in the immediate vicinity of the soil source area. The HRC-A will be injected via geoprobe into 100 injection points on a 15' x 20' offset grid (15' between points and 20' between rows) with a vertical interval of 7' to 21' below ground surface. A total of 228 gallons of HRC-A injected at each point. The injection rate is expected to be 3 gallons per minute. Water Source: Public water from Chatham Park will be used to mix the HRC products. Certified Well Drillers: Mr. Tom Lennon #1854 Mr. Todd Scott #3335 Mr. Alan Duke #3334 CMC Holding ID: NON CD 000 0016 Responsible Party/Contact: t Alan Payne CMC Holding Inc. 285 Ivy Circle Elkin, NC 28621 Consultant: Tom Lennon Piedmont Industrial Services Inc. 1670-A Lowery Street Winston-Salem, NC 27101 Phone number: Facility: 336-722-6505 CMC Landfill 580 Main Street Elkin, NC Facility Summary: Industrial waste disposal occurred from the 1950's through 1982. Waste included: nylon sheets, polypropylene, tyvek, typar, lint and fiber waste, bale bands and wire, latex waste, paint solids, cardboard and cardboard drums, flooring, concrete, bricks, pallets, old fabric rolls, empty drums (plastic and steel), coal ash. The CERLA site, currently owned by CMC, consists of approximately 27 acres of undeveloped land adjacent to the Yadkin River in the eastern portion of the Town of Elkin, North Carolina. Waste disposal areas include approximately 15 acres. The Elkin Property is currently listed on the North Carolina Department of Environment and Natural Resources, Division of Waste Management, Superfimd Section, Inactive Hazardous Sites Branch (hereafter the "NCDENR") Inactive Hazardous Waste Sites Priority List as CMC Landfill ID #: NGNCDO000016. This listing results from prior subsurface disposal of material generated at the former Chatham Manufacturing Company. Surface Water: Analytical results from the four surface water samples collected from the Yadkin River did not indicate the presence of any of the volatile organic compounds detected in on site monitoring wells. Groundwater: A total of 20 volatile organic compounds were detected in the collected groundwater samples, Results for the groundwater sampling event detected 11 volatile organic compounds in concentrations exceeding 15A NCAC 2L Standards and 1 I volatile organic compounds in concentrations exceeding 15A NCAC 2B Standards. The highest levels of groundwater impacts were evidenced in wells MW4 and MW-2S. Volatile organic compounds include 1,1 Dichloroethane, 1,1 Dichloroethene, Tetrachloroethene, Trichloroethene, 1,1,1 Trichloroethane, 1,2 Dichloroethane, 1,1,2 Trichloroethane, Vinyl Chloride, Benzene, Chloroethane, and Methylene Chloride. Based on information obtained from previous site assessments a public water supply is available for the subject site and surrounding areas and no water supply wells are located within 1500 feet of the site. The nearest surface water intake, utilized by the City of Jonesville for a public water supply, is located 7,559 feet west of the subject site.