January 19, Addendum to Drilling Study Report C&H Hog Farms Mt. Judea, Newton County, Arkansas Harbor Project No. ADEQ Dear Mr.

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1 January 19, 2017 Mr. Caleb Osborne Associate Director Office of Water Quality ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 Northshore Drive North Little Rock, AR Re: Addendum to C&H Hog Farms Mt. Judea, Newton County, Arkansas Harbor Project No. ADEQ Dear Mr. Osborne: Harbor Environmental and Safety (Harbor) has prepared an addendum to the for the above referenced project. The addendum provides clarifications and responses to questions and comments raised during the public comment period. Thank you for the opportunity to work on this project. Should you have any questions or require additional information, please do not hesitate to contact me or Thomas Huetter at Sincerely, HARBOR ENVIRONMENTAL AND SAFETY Leslie Davis Principal Thomas Huetter, P.G. Senior Project Manager LYBRAND CONSULTING LLC Mike Lybrand, P.G. Professional Geologist 5800 Evergreen Drive Little Rock, Arkansas Phone Facsimile

2 Addendum Addendum to C&H Hog Farms Report As requested by the Arkansas Department of Environmental Quality (ADEQ), Harbor Environmental and Safety (Harbor) has prepared this addendum to the in response to questions raised during the public comment period. Responses to specific questions and clarification requests via from Caleb Osborne of ADEQ are listed below. List of any deviations from the work plan including details on what they were and why. The work plan was generally followed, with the following exceptions: 1) The work plan specified using temporary 2-inch PVC well casing with a slotted screen for groundwater sampling. Instead, a stainless steel iso-flo sampling screen, which is appropriate for this type sampling, was utilized. 2) ADEQ did not split water sample B-1GW-1 with Harbor because the borehole went dry. Harbor had collected a blind duplicate sample at this time, which was later provided to ADEQ to be used as their split sample. 3) The work plan specified hand augering to a depth of five feet bgs to prevent damage to any subsurface utilities. The borehole was only augered to 2.3 feet due to refusal on subsurface rock fragments. 4) The geophysical contractor ran a conductivity sonde downhole to verify depth to groundwater only. This was done because the water level indicator brought to the site was insufficient to reach the TD of bgs. 5) The work plan specified that one of the analytes of interest was nitrate. This was changed to total nitrogen per ADEQ memo (sent via from Caleb Osborne on 9/20/16). Provide statement/update on how IDW will be handled. The investigation-derived waste (IDW) is tentatively scheduled for removal from the site on January 27, 2017 by Methvin Sanitation of Harrison, Arkansas. The water will be taken to the City of Harrison waste water treatment plant for disposal. Empty drums will be taken to Methvin Sanitation s transfer station for temporary storage prior to recycling at Tenenbaum Recycling Group, LLC in North Little Rock, Arkansas. Provide documentation regarding the survey of the borehole location. Harbor has prepared a document, stamped by an Arkansas licensed surveyor, which is included in Attachment 1 to this Addendum. 1

3 Addendum Provide clarification on difference between Fig. 2 and p. 2 of text regarding the lat/long provided. The latitude and longitude provided on Figure 2 is correct. The latitude on Page 2, Paragraph 1 is incorrect in that a digit is missing should have been This has been corrected and the revised page has been included in Attachment 1 to this Addendum. The longitude on Page 2 and Figure 2 are correct. Provide statement reconciling/clarifying field notes with Section 3.3. The field notes indicated that a void at 25 bgs is taking grout. This was mentioned by the driller at the time of the drilling operations; however, no indications of any voids were observed during downhole drilling operations, or after review of boring logs. Several fracture zones were encountered, which could account for the increased volume of grout required to tremie the borehole. Provide information in the addendum clarifying handling of all split samples, such as whether splits were available for all samples (compare to and Table 5.3). In accordance with the sampling and analysis plan (SAP), all samples were available to be split with ADEQ; however, there was one exception. Water sample B-1GW-1 plus a blind duplicate sample (BD-1) was collected at 10:47am on 9/22/16. The borehole went dry, and ADEQ was unable to collect a split sample. Sample BD-1 was provided to ADEQ to be utilized as their split sample. All other soil and water samples were spilt with ADEQ in accordance with the SAP. Provide confirmation regarding totals in section 5.1 compared to Table 5-1 to ensure consistency (provide updates pages for changes to text or tables) Three errors were discovered in Section 5.1, Page 9, Paragraph 7. Detected sodium concentrations ranged from 1150 to 381 mg/kg. The concentration written as 1150 mg/kg should be 150 mg/kg. Zinc concentrations ranged from 9.21 to 216 mg/kg. All the detected potassium, sodium and zinc concentrations were within the USGS background concentrations. Two of the zinc concentrations exceeded the maximum background concentration of 166 mg/kg for zinc. TOC ranged from 65.1 to 262 mg/kg. The concentration written as 262 mg/kg should be 252 mg/kg. These errors will be corrected and the updated page will be provided in Attachment 1. 2

4 Addendum Provide additional information for E. coli analytical for water samples including text to represent what was in tables (related to 5.3). Added text E. coli was non-detect for all samples. Regarding 6.2 1, please provide information on which matrix is referred to and perhaps more of a lay explanation for what %D1 means. A matrix is the form that the sample takes, i.e. soil or water. A known quantity of an analyte is spiked into the matrix and analyzed for quality control. The flag %D1 is a labdesignated indicator for exceedances that were just outside the acceptable criteria. Provide clarification on time discrepancies on photos 4, 32, and 37 (any corrections please provide replacement pages) Time discrepancies on the photograph pages were transcription errors. Times presented on the photo log (Page 1) are the correct times. Times have been changed on the photograph pages and are included in Attachment 1 below. Provide raw data from Arkansas Analytical (if it is easiest you can provide the Department CD) This information is included on the attached CD. Replacement Pages included in Attachment 1: Report Title/Cover Page Caleb Osborne phone number corrected. Report Page 2, Paragraph 1 Latitude corrected to match Figure 2. Report Page 9, Paragraphs 7-9 Corrections made to sodium, zinc, and TOC results. Report Page 13, Paragraph 10 Reference to E. coli results added. Report Page 23, Table 5-4 Concentrations for manganese and zinc were converted to milligrams per liter (mg/l) Report Pages 26 and 27, Section 6.2 Clarification provided regarding matrix spikes. Photolog Page 4 Photo 4 time corrected. Photolog Page 18 Photo 32 time corrected. Photolog Page 21 Photo 37 time corrected. 3

5 Addendum Attachment 1

6 GESTATION BARN FARROWING BARN SURVEYED BORING LOCATION LAT LONG ELEVATION = ' Certification I hereby certify that the above described and depicted information is true and accurate to the best of my ability and that the positional accuracy is at or above the minimum standards for an Arkansas land survey. JOHNNY R. TWEEDLE SCALE: 1" = 200' 200' 100' 0' 200' SURVEYED BORING LOCATION C & H HOG FARM - SITE LAYOUT MAP MT. JUDEA NEWTON COUNTY, ARKANSAS

7 DRILLING STUDY REPORT Client: ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 Northshore Drive North Little Rock, AR Phone: Contact: Caleb Osborne Associate Director Office of Water Quality C&H Hog Farms Mt. Judea, Arkansas December 2016 Prepared by: Harbor Environmental and Safety 5800 Evergreen Drive Little Rock, Arkansas Phone:

8 To accomplish these project goals, a boring was drilled to a depth of 120 feet in the vicinity of the waste storage ponds to evaluate the subsurface and collect soil, water, and groundwater samples for analysis of potential contaminants. The location of the boring was chosen by ADEQ based on the ERI data ( , ). Downhole geophysical logging was also conducted within the boring to further characterize subsurface conditions. 2

9 5.0 Laboratory Analytical Results All samples were collected in accordance with the SAP and the QAPP. Upon collection, all samples were immediately labeled, individually sealed, logged on a chain-of-custody, and preserved on ice in a cooler for later transport to Arkansas Analytical, Inc. (AAI) in Little Rock, Arkansas. Per the SAP, all samples were split with ADEQ personnel. Laboratory analytical results are presented in Appendix D. Soil Analytical Results As previously referenced, soil samples were collected at five foot intervals or at lithologic changes. Soil samples were collected during this investigation from the following depths: six inches, five feet, ten feet, 13.5 feet, 18.5 feet, and 25 feet. Soil samples obtained by Harbor personnel were submitted to AAI for analysis of calcium (Ca), magnesium (Mg), manganese (Mn), phosphorus (P), potassium (K), sodium (Na), zinc (Zn), percent moisture, total organic carbon (TOC), and Escherichia Coli (E. Coli). The analytical results were compared to a USGS study, The National Geochemical Survey - Database and Documentation, U.S. Geological Survey Open-File Report The results of laboratory analysis of soils are listed in Table 5-1 below. The results of the soil analysis are summarized in the following paragraphs. Calcium concentrations ranged from 627 to 314,000 milligrams per kilogram (mg/kg). With the exception of the sample collected from 25 feet bgs, calcium concentrations were within the background ranges of the USGS study. The detected concentration of 314,000 mg/kg, in the sample collected from 25 feet bgs is not unusual as this sample was collected at the soil-limestone interface. Magnesium concentrations ranged from 896 to 2,650 mg/kg. All the detected magnesium concentrations were within the USGS background ranges. Manganese concentrations ranged from 244 to 1,690 mg/kg. Four of the detected manganese concentrations exceeded the USGS background ranges. These detections were within the same order of magnitude of the highest detected background concentration, 1,110 mg/kg. Phosphorus was detected at concentrations ranging from 119 to 715 mg/kg. All the detected phosphorus concentrations were within the range of the USGS background concentrations. Potassium concentrations ranged from 187 to 4,600 mg/kg. Detected sodium concentrations ranged from 150 to 381 mg/kg. All the detected potassium and sodium concentrations were within the USGS background concentrations. Zinc concentrations ranged from 9.21 to 216 mg/kg. Two of the zinc concentrations exceeded the maximum USGS background concentration of 166 mg/kg for zinc. Percent moisture ranged from 9.90 to 31.7 percent. TOC ranged from 65.1 to 252 mg/kg. No E. Coli was detected in any of the soil samples. No background ranges have been established for these parameters. 9

10 Magnesium concentrations ranged from 3.11 to 8.59 mg/l. One of the detected magnesium concentrations exceeded the ranges measured in the USGS study. All of the detected magnesium concentrations were below the concentration detected in sample PW-2. Manganese concentrations ranged from to mg/l, which were below the ranges measured in the USGS study. Manganese was non-detect (<0.0104) in sample PW-2. Phosphorus concentrations ranged from to mg/l. Phosphorus was not analyzed in the USGS study. Phosphorus was non-detect (<0.026) in sample PW-2. Potassium concentrations ranged from 1.56 to 3.55 mg/l, which were within the ranges measured in the USGS study. Potassium was detected at a concentration of 2.23 mg/l in sample PW-2. Sodium concentrations ranged from 3.67 to 12.6 mg/l, which were within the ranges measured in the USGS study. Sodium was detected at a concentration of 3.37 mg/l in sample PW-2. Zinc concentrations ranged from to 4.34 mg/l, which were below or within the ranges measured in the USGS ambient study. Zinc was detected at a concentration of mg/l in sample PW-2. Ammonia was non-detect (<0.500 mg/l) in all but one of the samples. Ammonia was detected at a concentration of mg/l in sample B-1GW-1 and mg/l in sample PW-2. Both detections exceeded the concentrations measured in the USGS ambient study, but only slightly exceeded the laboratory detection limit of <0.500 mg/l. Specific conductance ranged from 305 to 428 µs/cm. Specific conductance measurements were within the ranges measured in the USGS ambient study. The specific conductance was measured at 233 µs/cm in sample PW-2. Bicarbonate alkalinity ranged from 161 to 456 mg/l. With the exception of the sample measured in B- 1GW-4 (456 mg/l), bicarbonate alkalinity concentrations were within the ranges measured in the USGS ambient study. Bicarbonate alkalinity was detected at a concentration of 99.0 mg/l in sample PW-2. Total nitrogen concentrations ranged from <1.00 mg/l to 1.96 mg/l. Total nitrogen was not detected in PW-2. TOC concentrations ranged from <1.00 mg/l to 2.97 mg/l. TOC was detected at a concentration of 1.97 mg/l in sample PW-2. Carbonate alkalinity was non-detect (<5.0 mg/l) for all samples. E. coli was non-detect for all samples. None of these four parameters were measured in the USGS study. Sample B-1GW-1 was collected at 1047 on 9/22/16 for analysis of the above parameters. Shortly after sampling, the borehole went dry. Subsequent discussions between ADEQ, Harbor, Lybrand and Cascade personnel determined that the water in the borehole could be potable water. It was suggested at the time that THM analysis (chloroform, bromoform, bromodichloromethane, and chlorodibromomethane) could be conducted on a sample from the borehole and a sample from the potable water tank to evaluate whether this was the case. The borehole was allowed to recharge during the lunch hour and samples were collected for THM analysis (B-1GW-2 and PW-1). The results show 13

11 that chloroform was detected in both samples at similar concentrations,16.3 and 26.3 micrograms per liter (µg/l). Bromodichloromethane was detected in sample PW-1 at a concentration of 6.70 µg/l, but was non-detect in sample B-1GW-2. 14

12 Table 5 4 Summary of Hog Waste Pond Analytical Results Parameter Analytical Method Units Sample ID Pond 1 Pond 2 Anions Chloride mg/l Sulfate (SO 4 ) mg/l Total Metals Calcium SW6010C mg/l Magnesium SW6010C mg/l Manganese SW6010C mg/l Phosphorus SM 4500 mg/l 1, Potassium SW6010C mg/l 1,480 1,370 Sodium mg/l Zinc SW6010C mg/l Wet Chemistry Ammonia (N) SM 4500 mg/l 1, Total Nitrogen SM 4500 mg/l 1, Nitrate/Nitrite as N SM 4500 mg/l < 50 < 50 Specific Conductance µs/cm 14,400 7,590 ph SU Salinty SM 2520 B PSU Percent Solids % TOC 5310 mg/l Bicarbonate Alkalinity 2320B mg/l 6,050 2,320 Total Alkalinity mg/l 6,050 2,320 Total Nitrogen 300.0/351.3 mg/l E. Coli E. Coli 1103 CFU/100 ml 145,000 8,000 Field Data ph SU Temperature C Data provided by ADEQ 23

13 blanks, and field blanks collected in the field. The types of QC samples utilized during the soil assessment along with sampling frequency are summarized Table 6-2 below. Collection procedures for the QC samples are discussed in the following sections. Table 6-2 QC Sample Collection Frequency Quality Control Sample Frequency of Collection Blind Duplicates MS/MSD Samples Rinsate Blanks Field Blanks 1 in 10 (10 percent) per matrix 1 in 20 (5 percent) per matrix 1 per day 1 per day Blind Field Duplicates A field duplicate is an identical sample collected from the same location, at the same time, under identical conditions as the investigative sample. Field duplicate samples are analyzed along with the original to ascertain procedural precision and inherent source variability. Field duplicate samples were collected at a rate of 1 in 10 (10 percent) per matrix and analyzed for the same parameters as the associated investigation samples. The field duplicates collected during the Drilling Study were blind field duplicates (i.e., sampling location not disclosed). One blind duplicate soil sample, BD-1, was collected during this investigation. This sample was a duplicate of sample B-1S-5 collected at a depth of 18.5 feet bgs. Generally, the samples compared well; however, magnesium, potassium and zinc were relatively elevated in BD-1 compared to B-1S-5. A blind duplicate for the leachate sample from this interval was also collected. The leachate samples also compared generally well; however, chloride, calcium, potassium, sodium, and specific conductance were slightly elevated in B-1S-5 compared to BD-1. A blind duplicate, BD-2, was collected with water sample B-1GW-1. Due to insufficient groundwater volume, the ADEQ did not split a sample with Harbor. Instead of submitting BD-2 for duplicate analysis at AAI, this sample was transferred to ADEQ for analysis at their laboratory. A third blind duplicate, BD- 3, was collected with water sample B-1GW-3. These samples showed very good correlation between sample and duplicate. Matrix Spike/Matrix Spike Duplicates MS/MSD samples are collected to assess the heterogeneity of concentrations in the soil and groundwater matrices. A matrix is the form that the sample takes, i.e. soil or water. A known quantity of an analyte is spiked into the matrix and analyzed for quality control. MS/MSD samples were analyzed at a rate of 1 in 20 (5 percent) per matrix for the same parameters as the associated investigation samples. Most of the MS/MSD exceedances were flagged as %D1, which indicates that exceedances were just outside the acceptable criteria. Those flagged as masked by analyte were 26

14 flagged as such because the parent sample used as the matrix spike sample was high in the analyte of question and thus masked the recovery of the spike. Rinsate Blanks Rinsate (or equipment) blanks are collected by pouring deionized water over decontaminated sampling equipment (e.g., core barrel, stainless-steel spoon) and into a sample container. These blanks assess cross-contamination from improper decontamination. Equipment rinsate samples were collected at a rate of one per day. As soil sampling occurred on day one only, there was only one Rinsate sample collected during this investigation. RS-1 was collected by pouring deionized water over the decontaminated stainless steel bowl used to mix soil prior to sampling. All of the analyzed constituents were non-detect in the sample. Field Blanks A field blank is a sample container filled with deionized water while in the field. The field blank is prepared, preserved and stored in the same manner as the other investigative samples. Field blanks are analyzed for cross-contamination from containers, source waters, or other ambient sources. Field blank samples were collected at a rate of one per day. Two field blanks, FB-1 and FB-2, were collected during this study. The results for FB-1 were all nondetect for the analyzed constituents. The results for FB-2 were mostly non-detect with the exception of calcium detected at mg/l and bicarbonate alkalinity detected at 9.0 mg/l. Discussions with the analytical laboratory indicated that these concentrations were considered very low and negligible. Laboratory QA/QC AAI prepared detailed data validation packages for each Sample Delivery Group. The data validation packages are included in Appendix F. 27

15 Photo #: 3 Date: 9/21/16 Time: 1010 Photographer: C. Yeatman Description: Utilizing hand auger to advance borehole. Photo #: 4 Date: 9/21/16 Time: 1011 Photographer: C. Yeatman Description: Preparing to collect sample B-1S-1 from the six-inch depth interval. 4

16 Photo #: 31 Date: 9/23/16 Time: 0917 Photographer: M. Lybrand Description: Collecting field blank FB-2. Photo #: 32 Date: 9/23/16 Time: 1023 Photographer: T. Huetter Description: Decontaminating sampling pump. 18

17 Photo #: 37 Date: 9/23/16 Time: 1324 Photographer: T. Huetter Description: Interior of geophysical logging truck showing datalogging instrumentation. Photo #: 38 Date: 9/23/16 Time: 1342 Photographer: T. Huetter Description: Primary datalogging screen. 21