Old_School_SWMP.doc

SURFACE WATER MONITORING PLAN

OLD SCHOOL LANDFILL

FORT GORDON, GEORGIA

TABLE OF CONTENTS

Section Page I.

INTRODUCTION

II.

REGULATORY APPLICATIONS

1. 397-3-6-.15 Non-Storm Water General Permit Requirements

2. 391-3-6-.03 Water Quality Use and Water Quality Standards

3. 391-3-4-.07 Landfill Design and Operations

III.

SURFACE WATER HYDROLOGY

IV.

HISTORIC SURFACE WATER SAMPLING ACTIVITIES

V.

WELCH”S BRANCH MONITORING PLAN

VI.

SAMPLING PROTOCOL

VII.

7-DAY, 10-YEAR (7Q10) MINIMUM FLOW

FIGURES

Locations of Proposed Surface Water Monitoring Sites, Fort Gordon, Georgia

TABLES

1 Historical Data, Conventional Pollutants and Other Parameters

2 Historical Data, Metals

Proposed Surface Water Monitoring Sites, The Old School Landfill, Fort Gordon, Georgia

Surface Water Sampling Sites, Old School Landfill, Fort Gordon, Georgia

Proposed Monitoring Parameters for Surface Water at the Old School Landfill

I.

Introduction

This Surface Water Monitoring Plan for the Old School Landfill at Fort Gordon is prepared to comply with the surface water monitoring requirements of the Georgia Water Quality Act and the Georgia Solid Waste Management Act. The monitoring results will be used to evaluate the impact to the receiving waters of Welch’s Branch as a result of the landfill. This document has been prepared as a further compliance tool to monitor and assess possible actions.

II.

Regulatory Applications

Several State regulations apply to the monitoring, treatment, and disposal of landfill leachate. These regulations are enforced by the Georgia Department of Natural Resources, Environmental Protection Division (GAEPD).

Chapter 391-3-6 Water Quality Control:

1. 391-3-6-.15 Non-Storm Water General Permit Requirements — This section of the regulation applies to general permits for the discharge of any pollutant into waters of the State and provides for the treatment of pollutant discharges into waters of the State.

2. 391-3-6-.03 Water Quality Use and Water Quality Standards — This section of the regulation applies to landfill leachate discharge and seepage to surface waters. (5)(c) All waters shall be free from material related to municipal, industrial, or other discharges which produce turbidity, color, odor, or other objectionable conditions which interfere with legitimate water use. (5)(e) All waters shall be free from toxic, corrosive, acidic and caustic substances discharged from municipalities, industries, or other sources such as non-point sources, in amounts, concentrations, or combinations which are harmful to humans, animals, or aquatic life.

Chapter 391-3-4 Solid Waste Management:

1. 391-3-4-.07 Landfill Design and Operations - This section of the regulation applies to the discharge of any landfill leachate into waters of the State. The Solid Waste Management Act requires (l) Ground and Surface Water Monitoring Plans to determine the impact of the facility on all adjacent surface waters. (j) Surface Water Requirements, Municipal Solid Waste Shall Not: Cause discharge of pollutants to waters of the State or the United States and cause the discharge of non-point source to waters of the State or the United States.

III.

Surface Water Hydrology

The landfill cover soil is mostly sandy clay and other fine silts and sustains a grassy vegetative cover across its surface. The grassy vegetative cover is not maintained; however, it appears to be stable and in fair condition. Generally, surface drainage at the landfill flows from south to northeast and will continue in this general direction to Welch’s Branch.

Welch’s Branch is located immediately north of the landfill and receives runoff from the landfill (Figure 1) and areas east of the creek. Welch’s Branch originates on Fort Gordon northeast of the landfill and flows southeast along the landfill’s north side. Welch’s Branch is a small tributary with naturally occurring organic constituents. Surface water is contributed Welch’s Branch in the vicinity of the landfill by sheet flow and groundwater seeps.

IV.

HISTORIC SURFACE WATER SAMPLING ACTIVITIES

In June of 2003 the Old School Landfill was subject to an Outfall Discharge Assessment which involved sampling for [biochemical oxygen demand (BOD), total suspended solids (TSS), oil and grease (O&G) and pH], chemical oxygen demand (COD), total dissolved solids (TDS), nitrogen and phosphorus compounds, cyanide, phenol, total petroleum hydrocarbons (TPH), metals, volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and organo-chlorine and organo-phosphorus pesticide compounds. A general summary of the historical data is presented below.

TABLE 1. HISTORICAL DATA, CONVETIONAL POLLUTATNTS AND OTHER PARAMETERS

TABLE 2. HISTORICAL DATA, METALS

*- values assume water hardness of 50mg/L calcium carbonate (CaCo3);

**- the in-stream criterion was lower that the laboratory achieved limit.

The historical water quality data summarized above characterize the water quality of Welch’s Branch and guide the design of the Welch’s Branch monitoring plan presented below.

v.

Welch’s Branch Monitoring Plan

The receiving water area will be monitored by the use of a series of surface water monitoring points. In-stream water quality samples will be used to monitor outfall discharge to surface waters. Six surface water monitoring points will be used to cover the surface waters adjacent to the landfill, which have been selected in compliance with paragraph five of the GAEPD’s Permit Conditions for Surface Water Sampling. That condition requires a minimum of one surface-water monitoring point at the following locations at the landfill:

· Hydraulically up gradient from the site.

· Adjacent to the site.

· Any point where drainage leaves the site.

· Spring and seep locations.

· Hydraulically down gradient from the site.

Table 3 lists the surface water sampling sites along with selected characteristics. Locations are shown on Figure 1.

TABLE 3. SURFACE WATER SAMPLING SITES, THE OLD SCHOOL LANDFILL, FORT GORDON, GEORGIA.

Locations considered to be hydraulically up gradient from the landfill with respect to surface water flow are designated with an “A.” All other locations are assumed to be hydraulically down gradient from the landfill and are designated with a “C.”

Four monitoring sites will be used to assess the affect of the landfill on Welch’s Branch from various surface water inflow sources. Upstream site SW-1A will be used as the primary indicator of background water quality in Welch’s Branch. Two seeps (SW-2C, SW-3C) will be sampled to assess potential impacts of groundwater seeping into Welch’s Branch. The discharge into Welch’s Branch from surface flow (SW-4C) will be sampled to assess its influence on the creek. Two downstream sites in Welch’s Branch (SW-5C, SW-6C) will be used to evaluate the potential impact of the landfill and potential natural attenuation in the creek hydraulically down gradient from the landfill.

VI.

Sampling Protocol

The four surface water sites will be sampled during March and September of each year following approval of this sampling plan. The sampling and analysis protocols will follow the protocols provided in applicable parts of the “Environmental Investigations Standard Operating Procedures and Quality Assurance Manual,” (EISOPQAM) published by the U.S. Environmental Protection Agency Region IV, and the U.S. EPA document “Test Methods for Evaluating Solid Wastes,” (SW-846).

Parameters required by the GAEPD in Section B of the Permit Conditions for Surface-Water Monitoring are included in the proposed monitoring parameter list shown in Table 4.

TABLE 4. PROPOSED MONITORING PARAMETERS FOR SURFACE WATER AT THE OLD SCHOOL LANDFILL, FORT GORDON, GEORGIA

Notes:

1. Parameter measured in the field at the time of sampling.

2. Indicator parameter added by Fort Gordon to those required by GAEPD.

Fort Gordon will evaluate the results of the four sampling events and propose a reduced list based on criteria such as frequency of non detections, decreasing trends in concentrations, concentrations below regulatory limits, and concentrations indicative of background conditions.

Each sampling site will include a staff gage referenced to NGVD which will be read during the sampling event.

Sampling will not be conducted when stream flow conditions are below the 7-day, 10-year minimum flow (7Q10). When this occurs the GAEPD Compliance Officer will be advised and an alternative sampling event will be scheduled and completed (if possible) in place of the missed sampling event.

VII.

7-Day, 10-Year (7Q10) Minimum Flow

Currently, the 7Q10 stage level of Welch’s Branch is unknown. Fort Gordon will attempt to develop this stage value for application to the surface water monitoring plan. The 7Q10 level will be developed (if possible) for the SW-1A location or other appropriate location along Welch’s Branch to allow determination of when Welch’s Branch is below the permitted level for sampling. A staff gage referenced to NGVD and marked with the 7Q10 stage will be set in Welch’s Branch and read prior to each sampling event to confirm acceptable flow in the creek.

Until the 7Q10 stage value is developed, the sampling program presented above will be performed on a semi-annual basis.

PAGE