Florida Department of Environmental Protection Northwest District 160 W. Government Street, Suite 308 Pensacola, Florida

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1 Florida Department of Environmental Protection Northwest District 160 W. Government Street, Suite 308 Pensacola, Florida Rick Scott Governor Jennifer Carroll Lt. Governor Herschel T. Vinyard Jr. Secretary June 30, 2011 Sent via to: Mr. Ralph Mills President Waste Pro Freeport, LLC Post Office Box Longwood, Florida Dear Mr. Mills: The Department of Environmental Protection (Department) has reviewed the Second, Third, and Fourth Quarter 2010 evaluation monitoring reports, and the First Quarter 2011 evaluation monitoring report for your facility formerly known as WRH Freeport C&D Disposal Facility and currently known as Freeport C&D Disposal Facility (DEP File No SO; Facility Identification No.15091) located on Highway 20, approximately two miles west of Freeport, Walton County, Florida, The review revealed exceedances of the Florida Primary and Secondary Drinking Water Standards during the quarterly sampling events. However, no exceedances of new parameters were noted. Additionally, in a Department letter dated May 10, 2010 (enclosed), it was determined that site assessment is complete. Therefore, further evaluation monitoring is not necessary and can be discontinued. Information received by the Department is public record and is placed in OCULUS, an electronic database. Documents that have been placed in OCULUS for your facility can be viewed at the following link:

2 If you have any questions, please contact me by telephone at (850) or by at Sincerely, Dawn Templin, P. E. Solid Waste Section Supervisor DKT/dtb Enclosure: Department letter dated May 10, 2010 c: Lee Martin, P.E., Solid Waste Management, Bob Hyres, Waste Pro, Blain Nelson, P.E.,Nelson Engineering, Mark Novokowsky, P.G., Nova Environmental, Peter Dohms, P.G., Terracon Consultants, Inc.,

3 May 10, 2010 Florida Department of Environmental Protection Northwest District 160 Governmental Center, Suite 308 Pensacola, Florida Charlie Crist Governor Jeff Kottkamp Lt. Governor Michael W. Sole Secretary Sent via to: Mr. William R. Cooksey Vice President EWS Landfills WRH Freeport, LLC 100 Landward Drive Gulf Shores, Alabama Dear Mr. Cooksey: This is in response to your March 30, 2010 Site Assessment Report Addendum #10, submitted by Gallet & Associates on behalf of WRH Freeport Construction and Demolition Debris Disposal Facility (FDEP ID No ) located in Freeport, Walton County, Florida. Upon review, we find that the requirements of Rule , Florida Administrative Code, have been adequately satisfied. Therefore, your site assessment is approved. We concur with your consultant s recommendation to prepare a remedial action plan (RAP) at this time. For a complete discussion of concerns noted, please refer to the enclosed memorandum. Unless notified otherwise, we will look to receive your RAP on or before August 10, If you have any questions or need more information, please contact Misty Conner, Project Manager, at (850) , extension 1218 or by at Misty.Conner@dep.state.fl.us. Sincerely, Karen Shea, P.E. Cleanup Section Supervisor KBS/mcb Enclosure: May 7, 2010 Memorandum c: Marshall Seymore, P.E., FDEP, marshall.seymore@dep.state.fl.us Peter H. Dohms, P.G., Gallet & Associates, pdohms@gallet.com Anthony R. Mellini, Jr., P.G., Gallet & Associates, tmellini@gallet.com More Protection, Less Process

4 Memorandum Florida Department of Environmental Protection TO: FROM: Karen B. Shea, P.E. Misty M. Conner DATE: May 7, 2010 SUBJECT: Freeport C&D Disposal Facility Site Assessment Report Addendum #10 WACS ID NWD/66/ Comet Site No. 2049, Project No I have reviewed the March 30, 2010 Site Assessment Report Addendum (SARA) #10 submitted by Gallet & Associates for the WRH Freeport C&D Debris Disposal Facility located on Highway 20 in Freeport, Walton County, Florida. Upon review, it appears that the requirements of Rule , Florida Administrative Code (F.A.C.) have been adequately satisfied. Therefore, the assessment is complete. Brief Site History The subject site operates as a construction and demolition debris disposal facility. Goodwin Creek runs along the western edge of the property. The adjoining property to the west is a vacant sand mining/borrow pit area. Groundwater flows to the south-southwest and discharges into the Creek. Evaluation monitoring began in October 2005 at this site due to elevated constituents of concern (COC) documented in groundwater, primarily in compliance well MW-2R. The COC are total dissolved solids (TDS), sulfate, iron, arsenic, and benzene. Site lithology is primarily sands and silty sands from land surface down to the confining unit, located at approximately 0 feet NGVD. The site elevation slopes from north to south down to the exposed confining unit at the Creek. The horizontal groundwater flow was previously reported to range from 0.3 to 1.2 feet per day. Additional Site Assessment Activities On December 18, 2009, three off-site monitoring wells were installed to depths of 15 to 16 ft bls, with 5 ft of screen. Boring logs, well development logs, and a certified survey was provided for the newly installed monitoring wells. Because FDOT removed material blocking the culvert under Hwy 20, the Creek width has narrowed and the water level has decreased. This created a need to replace stream gauge SW-3, which was no longer within the stream. In addition to installing the three monitoring "More Protection, Less Process Printed on recycled paper.

5 WRH Freeport Site Assessment Report Addendum #10 Page 2 of 3 wells, the consultant installed stream gauge SW-4. SW-4 is located down-gradient of the borrow pit. On January 28 and 29, 2010, depth-to-water measurements and groundwater samples were collected from on-site and off-site monitoring wells and surface water stations. Below is a table that summarizes the results during the past four semiannual events for the COC. Location Date Arsenic Iron Benzene (µg/l) TDS Sulfate Jul-08 BDL 0.11 BDL MW-1 Jan-09 BDL BDL Jul BDL Jan BDL Jul MW-2R Jan Jul Jan Jul BDL MW-3 Jan BDL Jul BDL Jan BDL MW-4 Jan BDL MW-5 Jan BDL MW-6 Jan BDL Groundwater Standard Jul BDL SW-1 Jan BDL Jul BDL Jan-10 BDL 0.46 BDL Jul BDL SW-2 Jan BDL Jul BDL Jan BDL SW-4 Jan BDL Surface Water Standard NA NA The consultant concludes that the extent of impacts is limited to the southwest corner of the landfill and immediate southeast corner of the borrow area. Based on the information provided in the subject report, I concur with the consultant. It appears that the extents of groundwater contamination have been adequately delineated. The consultant recommends that ongoing monitoring of the off-site monitoring wells and surface water station SW-4, be performed in conjunction with the quarterly evaluation monitoring program. Since the assessment is complete and the owner should be working on a remedial plan, it would be appropriate to stop evaluation monitoring if they include Printed on recycled paper.

6 WRH Freeport Site Assessment Report Addendum #10 Page 3 of 3 the off-site monitoring wells and the surface water sampling point in their semi-annual monitoring events. The consultant should provide a discussion with the results regarding the stability of the plume and trends in groundwater flow and quality. The consultant also recommends the preparation of a remedial action plan (RAP). I agree that a RAP should be prepared at this time. However, the consultant suggests that phytoremediation is the redial option that will be proposed for this site and recommends that phytoremediation be pilot tested with consideration of conventional pump and treat as an alternative standby option. Based on site figures, it does not appear that adequate space is available to accommodate a phytoremediation system. The consultant may want to consider alternate remedial technologies. Summary It appears that the Rule requirements of , F.A.C. have been adequately satisfied. Therefore, the site assessment is complete. I concur with the consultant s proposal to monitor the off-site monitoring wells and surface water station SW-4 in conjunction with the quarterly evaluation monitoring. I also concur with the consultant s recommendation to prepare a RAP at this time. KBS/mc Printed on recycled paper.