1101_Buncombe_MSWLF_CAERUpdate_FID1755922_20221215

BUNNELL
LAMMONS
ENGINEERING
December 15, 2022
Solid Waste Section
Division of Waste Management
NCDEQ-ARO
2090 U.S. 70 Highway
Swannanoa, North Carolina 28778
[via email]
Attention: Ms. Jaclynne Drummond, Hydrogeologist
Subject: Update to the Phase I Phytoremediation Evaluation
Old Buncombe County Landfill
Woodfin, North Carolina
DWM Permit No. 1101-MSWLF-1979
BLE Project No. J22-14175-07P
Dear Ms. Drummond:
Bunnell-Lammons Engineering, Inc. (BLE) is pleased to submit this update to the North Carolina
Division of Waste Management (NCDWM) Solid Waste Section (SWS) for Phase I of the
phytoremediation evaluation for the subject site.
BLE recommended an evaluation of phytoremediation as a voluntary supplemental remedy to address
VOC compliance issues at the site as part of the DWM approved Corrective Action Evaluation Report
dated March 30, 2022 [FID 1661864 (BLE Project No. J20-14175-03)]. The evaluation was
recommended to be conducted in three (3) phases as follows: Phase I may include: 1) an assessment
of the condition, type, and efficacy of the existing flora; 2) an assessment of soil conditions and
groundwater chemistry; and 3) an assessment of water quality at the groundwater -surface water
boundary. Phase II may include selection of remedy in accordance with the solid waste rules. Phase
III may include submittal of a CAP addendum which may include: 1) preparation of design plans;
2) preparation of bid packages and contractor selection; 3) procurement of selected flora; 4) the
installation of flora and irrigation; and 5) ongoing monitoring and maintenance (inspection, testing,
and normal horticultural practices). BLE recommended preparation and submittal of an update to the
status of Phase I of the voluntary supplemental remedy to the SWS on or before December 30, 2022.
Buncombe County retained BLE to perform a limited Phase I evaluation to consist of an assessment
of the condition, type, and efficacy of the existing flora. BLE conducted two rounds of assessment
on August 2, 2022 and October 24, 2022. The results were inconclusive.
Buncombe County and BLE plan to re-evaluate the technical approach to the assessment and
potentially conduct a 3rd assessment in the summer of 2023. We note that these types of assessments
are typically conducted during maximum flora uptake of subsurface water and transpiration (i.e.
summer months).
The next update for this project will be submitted to the SWS on or before October 31, 2023.
'6004 Ponders Court Greenville, SC 29615 t864.288.1265 HB64,288.4430 [e-mail]
BLECORP.COM

1s 1m 1i
Update to the Phase I Phytoremediation December 15, 2022
Old Buncombe County Landfill, Woodfin, North Carolina BLE Project Number J22-14175-07P
We appreciate the continued opportunity to work with the SWS to address regulatory issues. If you have
any questions, please do not hesitate to contact us at [phone].
Sincerely,
BUNNELL-LAMMONs ENGINEERING, INC.
Riley L. Blais, G.I.T.
Staff Hydrogeologist
CC: Ms. Kristy Smith — Buncombe County
Mr. Dane Pedersen— Buncombe County
Mr. Zach J. Downes, PG - BLE
At/
Andrew W. Al ander, P.G., RSM
Consultant Hydrogeologist
Registered, NC #1475
2 of 2