Toxic Chemical Contamination - Seaboard Chemical / High Point
The North Carolina watershed protection rules ,adopted by the N.C. Environmental Management Commission, do not allow new municipal solid waste landfills within a half mile of public drinking water supplies. Yet the same commission will allow a public drinking water supply reservoir to boarder an abandoned town dump and toxic waste site.
Starting in the 1950s, all forms of industrial and municipal waste from the High Point area was dumped and or burned at the 150 acre site that is located by the Deep River off of Riverdale Road. The facility was permitted by the N.C. Solid Waste Section in 1979, and accepted municipal solid waste until October 1993.1 Landfilled waste now covers most of the area of the site, and some extends as far toward the river as to be in the 500-year flood plain.2
Not only is the toxic groundwater contamination from the 150 acre High Point landfill a concern, but the added mix of toxic contaminants from the bankrupt Seaboard Chemical Corporation solvent recovery site pose a threat to the proposed public drinking water supply.Portions of the Seaboard Chemical site are also located in the 500-year flood plain.3
To address the question of possible drinking water contamination, the latest water quality model for 10 contaminants was developed, with the following extremely conservative assumptions 4
1. Maximum reasonable flow of contaminated ground water from the site.
2. Maximum observed concentrations in the ground water.
The maximum reasonable flow of contaminated ground water from the site was later found to be unreasonable. Published modeling results were revised to reflect an increase in the maximum reasonable flow of toxic contaminants from 5,000 to 50, 000 gallons per day.5
The maximum observed concentrations of groundwater contaminants were provided by the N.C. Division of Water Quality (DWQ) and have not been revised. The chart that follows clearly shows the DWQ maximum observed concentrations that were modeled were not the maximum observed concentrations .
The N.C. Department of Environment Health and Natural Resources (DEHNR) 1994 monitoring results were not reported to the modelers, and reflect toxic groundwater contamination hundreds of times higher than the maximum used in the modeling.
It should be noted that DWQ was a division of DEHNR.
For comparison, the latest groundwater contamination results from the Remedial Investigation (RI) Report.
The latest results from the RI show 1,2-Dichloroethane contamination 2636 times higher than the value used in the model.
In 1998 the N.C. Environmental Management Commission used the DWQ reported maximum observed concentrations modeling results in approving the Randleman watershed protection rules. Rules that excluded any EMC requirements for the protection of the Deep River from toxic contamination. The record states: The potential for contamination of the reservoir from the two adjacent landfills has been an issue of concern to many. Predictive modeling information available to the Division indicates that the concentration of toxicants in drinking water obtained from this lake will not result in any excedences of state or federal drinking water standards. The recommendation of the hearing officers does not include any additional management recommendations for the landfills.9
Another example of water quality issues falling thru the cracks.
Questions concerning the original water quality modeling for five toxic substances from the Seaboard Chemical / High Point Landfill site for the 1991 EIS were made by the N.C.Division of Solid Waste Management staff in written comments .10
The 1997 Draft Environmental Impact Statement for the proposed Randleman Dam project makes the following statement concerning the toxic pollutant threat from the Seaboard Chemical / High Point Landfill groundwater contamination site :
Mean annual concentrations estimated for the five organic pollutants
were all well below NCDEM and Safe Drinking Water Act criteria
( Black & Veatch, 1990, 1991 b ). This analysis was reviewed and
approved by the N.C. Division of Solid & Hazardous Waste
( NCDSHW ) and the NCEMC. 11
For such an inaccurate statement to be made; on this crucial issue
regarding the threat of toxic groundwater contaminating a potential
public drinking water supply, calls into question the validity of the
entire 1997 Draft Environmental Impact Statement.
In truth, the N.C. Division of Solid Waste Management did not approve the evaluation of the five organic pollutants that were submitted for review, and had additional concerns on the effects the proposed impoundment would have on flooding solid waste at the High Point Landfill, raising the groundwater level in the area of the landfill and the changes that would create with the groundwater flow directions and rates of groundwater flow.12
The Honorable Dexter Brooks, Superior Court Judge, in his Order of May 12, 1994, Findings of Facts, found:
Based on formal comments from state and federal agencies with
expertise in the field, the Hearing Officer found that there are serious
water quality problems on the Deep River now and unanswered
questions regarding the magnitude of the groundwater contamination
from the High Point landfill, the Randleman Town Dump, and the
Seaboard Chemical site ( which requires the clean up of hazardous
substances ) .13
1 Preliminary Summary of the Remedial Investigation Project Seaboard Chemical Corporation / Riverdale Drive Landfill Site, Jamestown, North Carolina, October 29, 1998, Blasland, Bouck & Lee., ERM-Southeast, Inc., ERM-Mid-States, Inc. p.1.
2 Site Inspection, High Point City Landfill, Riverdale Road, Grover Nicholson, N.C. Department of Environment, Health, and Natural Resources, Division of Solid Waste Management, 25 February 1993, Sec. 2.2
3 Ibid. Fig. No: 6-2.
4 Draft Nutrient
Reduction Strategy and Implementation Plan, March 1998, Hazen &
Sawyer, Sec 3
Analysis of Potential Water Quality for Toxic Organic Chemicals in the Proposed Randleman Lake, tetra Tech, Inc., March 18, 1998, p.14.
5 Report of Proceedings - Proposed Reclassification of Segments of the Deep River (Proposed Randleman Reservoir) September 1, 1998, Appendix A, Analysis of Potential Water Quality for Toxic Organic Chemicals in the Proposed Randleman Lake, Tetra Tech, Inc., March 26,1998, p.A-15
6 Ibid. p.A-16
7 Sampling and Analysis Plan For the Former Seaboard Chemical Corporation Facility and the City of High Point Riverdale Drive Landfill, June 1995, Geraghty & Miller, Inc. Table 3-4. Groundwater Data Summary, Sampled by North Carolina Department of Environment Health and Natural Resources, March 29,1994.
8 Remedial Investigation Report, Seaboard Group II and City of High Point, North Carolina, March 1999, Blasland, Bouck & Lee, Inc., Sec.3, pages 3-7,3-13,3-20.
9 Report of Proceedings, p.22.
10 MEMORANDUM, Re:Final Environmental Impact Statement for Randleman Lake, Bobby Lutfy, Hydrogeologist, Solid Waste Section, N.C. Division of Solid Waste Management, November 18,1991
11 Draft Environmental Impact Statement - Randleman Lake, Guildford and Randolph Counties North Carolina, June 1997, U.S.Army Corps of Engineers, p. 5-11.
12 MEMORANDUM, Lutfy.
13 Petitioners exhibit 1, p. 2,3.