1203_Burke_JohnsRiver_Expansion_CDLF_MonitoringRequest_FID1418268_20200709

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July 9, 2020
Jaclynne Drummond
Compliance Hydrogeologist
NC Department of Environmental Quality
Division of Waste Management - Solid Waste Section
2090 US Highway 70, Swannanoa, NC 28778
Via email: [e-mail]
RE: Burke County, Johns River C&D Expansion Landfill
Permit Number 12-03
Request to Reduce Water Quality Monitoring Frequency to Annual
Project No. 2192621
Dear Ms. Drummond:
On behalf of Burke County, we are requesting a reduction in the frequency of water quality monitoring
for the C&D Expansion Landfill at the Johns River Waste Management Facility (Permit # 12-03) from
semiannual to annual. Session Law 2018-65, House Bill 573, approved on June 25, 2018, allows for
annual groundwater monitoring frequency at stand-alone C&D landfill facilities in detection monitoring,
as noted in the the NCDEQ Solid Waste Section Memorandum dated July 13, 2018.
The C&D Expansion Landfill is a stand-alone C&D landfill which received its initial Permit to Operate in
August 2014. It is separated from the closed C&D-over-MSW landfill by a 500-800-foot wide buffer and
is primarily upgradient of the closed landfill. There are monitoring wells between the two landfills and
the two landfills have been monitored separately since the C&D Expansion Landfill began operation.
The C&D Expansion Landfill is currently in Detection Monitoring and there are currently no exceedances
of groundwater protection standards (GPS) attributed to the C&D Expansion Landfill. There have been
GPS exceedances for both metals and VOCs in monitoring well MW-38, which is a compliance well for
the C&D Expansion Landfill; however, MW-38 is located between the two landfills and the exceedances
are attributed to the old, closed landfill. An Alternate Source Demonstration (ASD) was approved by
NCDEQ in a letter dated June 9, 2020, which included approval of background -based GPS for the
following metals: Cobalt (11.3 pg/L); Iron (14,182 pg/L); Manganese (535 pg/L); and Vanadium (45.2
pg/L).
We request that the water quality monitoring frequency for the C&D Expansion Landfill be reduce to
annual in accordance with Session Law 2018-65, House Bill 573. This request, if approved, will also
serve as an amendment to the existing Water Quality Monitoring Plan. As we recently completed a
semiannual sampling event for the facility in May 2020, we propose the next sampling event be
scheduled for the 2nd quarter of 2021, and annually thereafter. If you have any questions, please call
me at [phone]. Thank you.
Respectfully submitted,
LaBella Associates
Van Burbach, Ph.D., P.G.
Sr. Technical Consultant
cc: Miles Champion, Burke County
2211 W. Meadowview Road #1o11 Greensboro. NC 27407 p [phone]
www.LabeLLapc.com