Phone: 256.847.0780 Fax: 256.8470905 matrixdesigngroup.com October 3, 2013 Mr. Eric Sanderson Chief, Solid Waste Branch, Land Division Alabama Department of Environmental Management P.O. Box 301463 Montgomery, Alabama 36130-1463 Subject: Fort McClellan Industrial Landfill, Permit 08-02 Explosive Gas Monitoring Plan Dear Mr. Sanderson: Matrix Environmental, LLC (MES) on behalf McClellan Development Authority (MDA) is pleased to submit the updated Explosive Gas Monitoring Plan (GMP) required by the Solid Waste Disposal Facility Permit 08-02 for the Fort McClellan Industrial Landfill, Calhoun County, Section 10, Township 15 South, Range 8 East (Site). This update reflects the changes requested by the minor Permit Modification and approved by the Alabama Department of Environmental Management (ADEM) on August 16, 2013. The GMP includes a site history, a description of the replacement monitoring wells with the installation dates, and a description of the soil gas sampling procedures and frequency. Also included in the new GMP is an updated map with the new well locations and a figure with an actual well description. If you have any questions or comments, please feel free to contact me at 256-847-0780. Sincerely, MATRIX ENVIRONMENTAL SERVICES, LLC Alexander Smith, P.E. McClellan Project Manager Enclosures Cc: Mr. Richard Satkin, MES Denver Colorado Springs Phoenix Anniston Atlanta Parsons Pueblo Sacramento Washington, D.C.
October 3, 2013 Page 2 Mr. Devin Jenkins, ADEM Mr. Robin Scott, MDA Ms. Lisa Holstein, U.S. Army Butler Green, B.G.W.M. Matrix Project File Denver Colorado Springs Phoenix Anniston Atlanta Parsons Pueblo Sacramento Washington, D.C.
Landfill Gas Monitoring Plan McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) McClellan, Anniston, Alabama Prepared for: McClellan Development Authority McClellan, Anniston, Alabama Prepared by: Matrix Environmental, LLC Anniston, AL 36205 October 2013
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 TABLE OF CONTENTS LIST OF ABBREVIATIONS AND ACRONYMS... ii EXECUTIVE SUMMARY... 1 1.0 INTRODUCTION... 1-1 1.1 Purpose and Objectives... 1-1 1.2 Report Organization... 1-1 2.0 BACKGROUND... 2-1 2.1 Site Location and Description... 2-1 2.2 Site Characterization... 2-1 2.2.1 Physical Setting... 2-1 2.2.2 Site Geology and Hydrogeology... 2-2 3.0 LANDFILL GAS MONITORING SYSTEM... 3-3 3.1 Gas Monitoring Frequency... 3-3 3.2 Gas Monitoring Procedures... 3-3 4.0 REFERENCES... 3-5 LIST OF FIGURES 1-1 Site Location Map McClellan 1-2 Parcel Location, Landfill 4, Parcel 81(5) and Industrial Landfill, Parcel 175(5) 3-1 Gas Monitoring Well Locations Appendix A: Gas Monitoring Well Diagrams LIST OF APPENDICIES M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 i
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 LIST OF ABBREVIATIONS AND ACRONYMS ADEM Alabama Department of Environmental Management Army United States Department of the Army Fill Area Definition Report Draft Final Site Investigation and Fill Area Definition Report, Parcels 78(6), 79(6), 80(6), 81(5), 175(5), 230(7), 227(7), 126(7), 229(7), 231(7), 233(7), and 82(7), Fort McClellan, Calhoun County, Alabama, Revision 1 Final EE/CA Final Revision 1 Engineering Evaluation/Cost Analysis Landfills and Fill Areas, Landfills 1, 2, 4, and Industrial Landfill, Parcels 78(6), 79(6), 81(5), 175(5), McClellan, Anniston, Alabama GMP Gas monitoring plan GPS Global positioning system Industrial Landfill McClellan Industrial Landfill, Parcel 175(5) IT IT Corporation Landfill 4 LEL Landfill 4, Parcel 81(5) Lower explosive limit McClellan McClellan, Anniston, Alabama MDA McClellan Development Authority MES Matrix Environmental, LLC Permit Solid Waste Disposal Facility Permit No. 08-02 PVC QAP Polyvinyl chloride Quality Assurance Plan Site Landfill 4, Parcel 81(5) and the Industrial Landfill, 175(5) M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 ii
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 EXECUTIVE SUMMARY Matrix Environmental, L.L.C. (MES) has prepared this landfill gas monitoring plan (GMP) on behalf of the McClellan Development Authority (MDA) to meet the requirements of the Solid Waste Disposal Facility Permit No. 08-02 (permit) for the McClellan Industrial Landfill, Parcel 175(5) located within McClellan, Anniston, Alabama (McClellan), formerly known as Fort McClellan. Figure 1-1 shows a map of McClellan and Figure 1-2 shows the parcel location. As shown in Figure 1-2, the McClellan Industrial Landfill, Parcel 175(5) (Industrial Landfill) is located in the northeast corner of Landfill 4, Parcel 81(5) (Landfill 4). The area was permitted as the McClellan Industrial Landfill (Permit No. 08-02). In this GMP, Landfill 4 and the Industrial Landfill will collectively be referred to as the Site. On July 29, 2013, MES submitted a request for a Permit Modification to address the replacement of the gas monitoring wells at the Site. The Site previously had twenty-two gas monitoring wells made of either 2 stainless steel or 1 polyvinyl chloride (PVC) wells installed at varying depths. The gas monitoring wells (GMP-1 to GMP-22) were spaced at an average of approximately 299 feet apart. Several of the 1 PVC wells were damaged during a routine landfill cap mowing event. The permit modification proposed to replace all the existing gas monitoring wells with 2 PVC permanent wells to provide consistency in the well construction and to provide greater visibility of the well locations. The replacement wells were installed during the week of September 9, 2013. The replacement wells were spaced at a maximum of 300 apart around the perimeter of the Site, and all wells except GMP-22R were installed to a depth of six feet below ground surface (bgs) with a four foot stickup. The monitoring wells were appended with the letter R to designate a replacement well (i.e. GMP-01R). MES will conduct a landfill gas sampling event annually pursuant to the requirements of the Solid Waste Disposal Facility Permit, 08-02 to ensure no explosive gases exceed the lower explosive limit (LEL) at the facility boundary, nor 25% of the LEL in any facility structure other than those which are components of the gas control and/or recovery system. M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 ES-1
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 1.0 INTRODUCTION Matrix Environmental, L.L.C. (MES) has prepared this landfill gas monitoring plan on behalf of the McClellan Development Authority (MDA) to meet the requirements of the Solid Waste Disposal Facility Permit No. 08-02 (permit) for the McClellan Industrial Landfill, Parcel 175(5) located within McClellan, Anniston, Alabama (McClellan), formerly known as Fort McClellan. Figure 1-1 shows a map of McClellan and Figure 1-2 shows the parcel location. As shown in Figure 1-2, the McClellan Industrial Landfill, Parcel 175(5) (Industrial Landfill) is located in the northeast corner of Landfill 4, Parcel 81(5) (Landfill 4). The area was permitted as the McClellan Industrial Landfill (Permit No. 08-02) (ADEM, 2010). In this GMP, Landfill 4 and the Industrial Landfill will collectively be referred to as the Site. 1.1 Purpose and Objectives The purpose of this GMP is to describe the soil gas sampling system and procedures for the site as required by the McClellan Solid Waste Disposal Permit No. 08-02. 1.2 Report Organization Section 2.0 of this report presents a summary of the background information including the parcel location, description, and the physical characteristics of the site. Section 3.0 provides the description of the landfill gas monitoring system and the solid waste permit requirements. Section 4.0 provides the reference page. M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 1-1
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 2.0 BACKGROUND This section provides background information about the Site. Parts of this section have been adapted from the Final Revision 1 Engineering Evaluation/Cost Analysis Landfills and Fill Areas, Landfills 1, 2, 4, and Industrial Landfill, Parcels 78(6), 79(6), 81(5), 175(5), McClellan, Anniston, Alabama (Final EE/CA) (MES, 2006) and the Draft Final Site Investigation and Fill Area Definition Report, Parcels 78(6), 79(6), 80(6), 81(5), 175(5), 230(7), 227(7), 126(7), 229(7), 231(7), 233(7), and 82(7), Fort McClellan, Calhoun County, Alabama, Revision 1 (Fill Area Definition Report) (IT Corporation [IT], 2002). 2.1 Site Location and Description Landfill 4 operated as the main sanitary landfill for McClellan from 1967 to 1994. The unlined landfill used trench and fill as the method of disposal and was not equipped with a leachate collection system. The landfill reportedly received the McClellan household garbage, construction and demolition debris, oil-contaminated soil, and dead animals (i.e. municipal solid waste or MSW). One pound of waste Diazinon dust (pesticide) was also reportedly disposed at Landfill 4 and the Industrial Landfill (IT, 2002). The landfill was closed in April 1994 because of changes in the permit requirements governing MSW (sanitary) landfills, including that MSW (sanitary) landfills be equipped with liners and leachate collections systems. A temporary permit was issued to the United States Department of the Army (Army) in 1993 to dispose of industrial and construction debris at the landfill. A permanent industrial landfill permit allowing the disposal of waste with a 30-ton per day limit in a previously unused section of the landfill property was issued in October 1995. This permit was transferred from the Army to the MDA (MES, 2006). The permit was renewed by the MDA on October 15, 2010. The revised permit for the Industrial Landfill allows 3,204 cubic yards per day of disposal. The total permitted disposal area for the Industrial Landfill is approximately 53 acres. 2.2 Site Characterization This subsection summarizes the physical setting, geology and hydrogeology at the Site. 2.2.1 Physical Setting With the exception of the Industrial Landfill, Landfill 4 is covered with an engineered, lowpermeability clay cover that met the landfill closure requirements at the time of closure. Landfill 4 is devoid of natural vegetation, but is currently covered with seeded grasses and vegetation. A concrete-lined drainage swale runs from east to west across most of the Site. The Site is bound on the north by mixed coniferous/deciduous forest and Reilly Airfield, on the east by mixed coniferous/deciduous forest, on the south by a soil borrow area, and on the west by a road and Landfill 3, Parcel 80(6). Much of the perimeter of the Site is enclosed by chain-link fence that restricts access to the Site (MES, 2006). Surface water is diverted around the Site by concrete ditches that drain into a settling pond at the M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 2-1
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 southeastern end of the Site. Drainage exits the Site to the north into a culvert under Reilly Airfield (MES, 2006). 2.2.2 Site Geology and Hydrogeology The bedrock mapped beneath the Site is the Cambrian Conasauga Formation. The Cambrian Conasauga Formation is comprised of dark gray, finely to coarsely crystalline medium- to thickbedded dolomite with minor shale and chert (IT, 2002). Underlying soils at the Site include the Cumberland loam, Purdy silt loam, Tyler silt loam, and the Anniston Gravelly loam. These soils were derived mainly from limestone, shale, and sandstone and are classified generally as silts to silty and clayey sands. The color of these soils are generally brown to dark brown with lesser amount of reddish-brown, grayish-brown, and yellowish-brown (IT, 2002). M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 2-2
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 3.0 LANDFILL GAS MONITORING SYSTEM Previous monitoring events at the site used the existing bar hole casings or previously installed polyvinyl chloride (PVC) pipes to monitor for the generation or emission of explosive gasses. The distance between the existing bore hole casings varied in distance, with some greater than 400 apart. Over time, the existing borehole casings became difficult to open. During the 2012 landfill cap mowing event, several of the 1 PVC casings were run over and destroyed by the mower. On July 29, 2013, MES submitted a request for a Permit Modification to address the replacement of the gas monitoring wells at the Site. The permit modification proposed to replace all the existing gas monitoring wells with 2 PVC permanent wells to provide consistency in the well construction and to provide greater visibility of the well locations. The replacement wells were installed during the week of September 9, 2013. The monitoring wells were appended with the letter R to designate a replacement well (i.e. GMP-01R). A handheld global positioning system (GPS) unit was used to designate the locations of the replacement gas monitoring wells. The replacement gas monitoring wells were spaced at a maximum of 300 apart around the perimeter of the Site, and all wells except GMP-22R were installed to a depth of six feet bgs with a four foot stickup, as required by ADEM Rule 335-13-4-.4(iii). Due to the lithology in the southwestern corner of the site, GMP-22R was only able to be installed at a depth of approximately two feet bgs. The locations of the replacement monitoring wells are shown in Figure 3-1. The wells were secured with a 2 locking well plug and secured with a dolphin lock. Brass labels with the well identification name and number were attached to each well cap to provide a permanent identification of each well. Well diagrams with boring depths and well coordinates are shown in Appendix A. MES will conduct a landfill gas sampling event annually pursuant to the requirements of the Solid Waste Disposal Facility Permit, 08-02 to ensure no explosive gases exceed the lower explosive limit (LEL) at the facility boundary, nor 25% of the LEL in any facility structure other than those which are components of the gas control and/or recovery system. 3.1 Gas Monitoring Frequency As stated in the Final Determination Permit Renewal and Name Change letter, dated October 15, 2010, and as required by ADEM Rule 335-13-4-.16(2)(c)2., the minimum frequency for explosive gas monitoring shall be yearly for construction/demolition landfills. Gas monitoring shall be conducted annually at the site. 3.2 Gas Monitoring Procedures As required by the Solid Waste Disposal Permit No. 08-02, soil gas monitoring will be conducted to prevent explosive gas from exceed the lower explosive limit (LEL) nor 25% of the lower explosive limit in any facility structure other than those which are components of the gas M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 3-3
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 control or and/or recovery systems. The explosive gas will be monitored using a landfill gas meter such as the GEM 2000 or equivalent. Soil gas sampling will be performed by removing the locking well cap on each of the 22-PVC monitoring wells and inserting the end of the gas meter tubing to collect readings. The tubing will also be inserted into the opening of the two culvert pipes (GMP-23 and GMP-24) and readings collected. The readings will be recorded in the field book and used to generate the explosive gas monitoring report. Levels of landfill gas will be expressed in % LEL and % volume. A report will be submitted to ADEM within thirty (30) days after each monitoring event documenting the explosive levels of the gasses and the site. Should explosive gasses be detected above the LEL, MES shall immediately take steps to ensure protection of human health and property and notify ADEM within 24 hours. Within 7 days of detection, place in the operating record of the facility the explosive gas levels detected and the immediate steps taken to protect human health and property. Within 20 days of detection, submit to the Department for approval a remedial plan for the explosive gas releases. This plan will describe the nature and extent of the problem and the proposed remedy. The plan shall be implemented upon approval by ADEM, but within 60 days of detection. A copy of the plan will be included in the operating record of the facility with the MDA, a copy to be included in MES files, and ADEM notified that the plan has been implemented. M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 3-4
McClellan Industrial Landfill, Parcel 175(5) (Permit No. 08-02) Gas Monitoring Plan, October 2013 4.0 REFERENCES ADEM. 2010. Solid Waste Disposal Facility Permit for the McClellan Industrial Landfill, Permit No. 08-02. Issued October 15, 2010 and modified on August 16, 2013 ; effective from January 9, 2011 through January 8, 2016. IT. 2002. Draft Final Site Investigation and Fill Area Definition Report, Parcels 78(6), 79(6), 80(6), 81(5), 175(5), 230(7), 227(7), 126(7), 229(7), 231(7), 233(7), and 82(7), Fort McClellan, Calhoun County, Alabama, Revision 1. March. MES. 2006. Final Revision 1 Engineering Evaluation/Cost Analysis Landfills and Fill Areas, Landfills 1, 2, 4, and Industrial Landfill, Parcels 78(6), 79(6), 81(5), 175(5), McClellan, Anniston, Alabama. May. M:\Industrial Landfill\2013 Soil Gas Mon Permit Mod\Explosive Gas Monitoring Plan October 2013 3-5
FIGURES
Huntsville ( 20 Birmingham ( ( Tuscaloosa 65 0 4 59 Anniston ( ^_ Montgomery ( 2 Miles 65 21 10 Mobile ( PELHAM RANGE CHOCCOLOCCO CORRIDOR FILE: \\Hemera\G\GIS_Projects\Fort_McClellan\03.094.007\active\apps\Location_Map.mxd, 3/22/2007, jeff_clonts 431 20 TALLADEGA COUNTY McCLELLAN CALHOUN COUNTY CLEBURNE COUNTY 431 78 CALHOUN COUNTY CLEBURNE COUNTY 20 Figure 1-1 McClellan Site Map McClellan Anniston, Alabama
Fort McClellan Legend Reilly Lake Road McClellan Boundry Parcel Building Roads Streams Waterbody «21 Wasteland Road 175(5) 81(5) FILE: G:\gis_projects\Fort_McClellan\03.094.007\active\apps\LF4-81(5)\Figure1-2_LF4_ParcelLocation_2013_10_02.mxd, 10/2/2013, jeff_clonts Figure 1-2 Parcel Location Landfill No. 4 Parcel 81(5) and Industrial Landfill, Parcel 175(5) McClellan, Anniston, Alabama
Legend " ) Soil Gas Sample Locations Culvert Sample Locations Parcel Road GMP-06R GMP-05R GMP-09R GMP-08R GMP-07R GMP-10R GMP-11R GMP-12R GMP-13R 175(5) GMP-04R FILE: \\Tartarus\GIS\gis_projects\Fort_McClellan\03.094.007\active\apps\LF4-81(5)\LF4_SoilGasSampleLocations.mxd, 1/5/2010, jeff_clonts GMP-03R GMP-24 Culvert 81(5) GMP-02R GMP-22R 0 200 GMP-23 Culvert GMP-01R GMP-14R " ) GMP-21R GMP-19R GMP-18R ) " GMP-16R GMP-15R GMP-17R GMP-20R Figure 3-1 Proposed Soil Gas Sampling Locations Landfill No. 4 Parcel 81(5) and Industrial Landfill, Parcel 175(5) McClellan, Anniston, Alabama 400 Feet
APPENDIX A
GMP-01R X coordinate: 669606.367211588 Y coordinate: 1178878.88115384
GMP-02R X coordinate: 669490.389753252 Y coordinate: 1179078.50345801
GMP-03R X coordinate: 669370.328969754 Y coordinate: 1179367.11410126
GMP-04R X coordinate: 669378.417208169 Y coordinate: 1179605.81867635
GMP-05R X coordinate: 669439.281915836 Y coordinate: 1179894.36534334
GMP-06R X coordinate: 669721.615012586 Y coordinate: 1179988.10728184
GMP-07R X coordinate: 670004.240431588 Y coordinate: 1180040.25547151
GMP-08R X coordinate: 670282.119797088 Y coordinate: 1180088.77407526
GMP-09R X coordinate: 670564.409914922 Y coordinate: 1180124.06009392
GMP-10R X coordinate: 670854.326329838 Y coordinate: 1180111.81110267
GMP-11R X coordinate: 671127.550849006 Y coordinate: 1180161.62301093
GMP-12R X coordinate: 671350.87290892 Y coordinate: 1179987.68175776
GMP-13R X coordinate: 671501.326020088 Y coordinate: 1179737.91355651
GMP-14R X coordinate: 671507.617018003 Y coordinate: 1179441.82983109
GMP-15R X coordinate: 671485.196787253 Y coordinate: 1179115.66447292
GMP-16R X coordinate: 671256.161156088 Y coordinate: 1178977.27564209
GMP-17R X coordinate: 671008.772543255 Y coordinate: 1178919.38861876
GMP-18R X coordinate: 670757.389515836 Y coordinate: 1178847.30083643
GMP-19R X coordinate: 670486.821487419 Y coordinate: 1178767.26654767
GMP-20R X coordinate: 670205.437207669 Y coordinate: 1178685.27360143
GMP-21R X coordinate: 669925.983698338 Y coordinate: 1178645.39375993
GMP-22R X coordinate: 669744.125794336 Y coordinate: 1178608.96765167 2 ft.