1203_Burke_JohnsRiver_CDLFOverMSWLF_CAPAddendumResponse_DIN28744_20180207

February 7, 2018

Sent Via Email - [e-mail]
Mr. Miles Champion
Burke County General Services
P.O. Box 219
Morganton, NC 28680

Re: Addendum to Corrective Action Plan
Johns River Waste Management Facility Active C&D Over Closed and Unlined MSW Landfill
Burke County
Solid Waste Permit Numbers 1203-MSWLF-1987 and 1203-CDLF-2014
DIN 28744

Dear Mr. Champion:

The Solid Waste Section (Section) has completed a review of the Addendum to Corrective Action Plan
dated August 2013, Revised January 2018 (DIN 28743) and received on January 12, 2018. The plan was
submitted on your behalf by Joyce Engineering for the Johns River Waste Management Facility Active C&D
Over Closed and Unlined MSW Landfill, Solid Waste Permit Number 1203-MSWLF-1987 and 1203-CDLF-
2014.

The Section approved County’s Corrective Action Plan dated November 2008 (DINs 6585 and 6681) that
included the selected remedy of Monitored Natural Attenuation (MNA), Phytoremediation, and Control
of Landfill Gasses. Due to continued groundwater and landfill gas exceedances and the request to expand
the active C&D Landfill to the east and northeast, the Section requested an Addendum to the Corrective
Action Plan to address those exceedances. The Section approved the County’s Addendum to Corrective
Action Plan dated August 23, 2013 on September 5, 2013 (DINs 19616 and 19655).

Then the County requested a reevaluation of site suitability for Phases 1B, 2B, and 3 of the active C&D
Landfill, the Phases located closest to the adjacent unlined MSW Landfill. In a March 27, 2017 letter to
the County (DIN 27500), the Section stated that given the proximity of landfill gas exceedances and
elevated contaminants still present in the groundwater in the subject area (including within the proposed
landfill footprint), as well as not meeting the permit conditions for ‘successful mitigation and remediation
of groundwater condition’, the request for site suitability approval for Phases 1B, 2B, and 3 is not being
issued by the Section. The letter further stated that the selected remedy does not appear to be working
as effectively as designed, and the County must take all measures necessary to ensure the protection of
public health and the environment. In response, the County submitted the Addendum to Corrective Action
Plan August 2013, Revised January 2018.

Within the Addendum, the County is proposing to control landfill gas migration and lessen cross-media
impacts to the groundwater by converting passive vents to an active landfill gas system with the

installation of a gas extraction unit (GEU) and connecting to the existing passive vents through a below
grade piping system. Based upon the information provided within the Addendum to Corrective Action
Plan August 2013, Revised January 2018, the Section approves the document as described. Please note
that the next Corrective Action Evaluation Report will be submitted in 2021 after the second semiannual
sampling event of 2020. This Report will also include the evaluation of the new active landfill gas system.

If you have any questions, please contact me by email at [e-mail] or by phone
at 828.296.4706. Thank you for your continued cooperation with this matter.

Sincerely,
Jaclynne Drummond
Hydrogeologist
Solid Waste Section, Division of Waste Management
NCDEQ

cc sent via email: Ed Mussler, Section Chief
Adam Ulishney, Environmental Compliance Branch Head
Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Kris Riddle, Environmental Senior Specialist
Allen Gaither, Permitting Branch Engineer
Van Burbach, Joyce Engineering