1203_Burke_JohnsRiver_MSWLF_CDLF_CDLFExp_PFASrequest_FID1816856_20230823

LaBeLLa
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August 23, 2023
Ms. Jackie Drummond
Compliance Hydrogeologist
NC Department of Environmental Quality
Division of Waste Management - Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Via email: [e-mail]
RE: Request for PFAS Sampling Subsets
Johns River Landfill, Permit No. 12-03
Burke County, North Carolina
Project No. 2223529/01
Dear Jackie:
The NCDEQ Memo dated July 17, 2023, entitled "Clarification of PFAS Monitoring Requirements for
Solid Waste Landfills" states that for assessment or corrective action wells, the facility may propose
a subset of these wells to be sampled for PFAS. The Memo also states that facilities may propose to
sample a subset for surface water points for PFAS. On behalf of Burke County, LaBella Associates is
submitting this request to establish a subset of sampling locations for PFAS sampling and analyses
during upcoming sampling events at the Johns River Landfill (Permit # 12-03).
Performance and Sentinel Wells: There are four corrective action wells associated with the old C&D-
over-MSW landfill. MW-18 and MW-19 are classified as sentinel wells for the MNA remedy and are
located downgradient of the old landfill in the floodplain of the Catawba River. MW-36 and MW-38
are located between the old C&D-over-MSW landfill and the new C&D expansion landfill and are
considered performance wells for the control -of -landfill -gas remedy; however, MW-38 is also a
compliance well for the new C&D expansion landfill. We propose sampling MW-18 and MW-38 for
PFAS during the upcoming sampling event, in addition to the facility's constituents of concern
(COCs). MW-19 and MW-36 will not be sampled for PFAS but will be sampled for the facility's COCs.
Surface Water Points: There are three surface water points that are routinely sampled at the Johns
River facility, SMP-5, SMP-6, and SMP-7. SMP-5 is a downstream location on the creek located west
of the old landfill and SMP-6 is a downstream location on the creek located east of the old landfill.
SMP-7 is upstream of SMP-6 and the old landfill but is downstream of the new landfill. We propose
sampling SMP-7 and SMP-6 for PFAS during the upcoming sampling event, in addition to their usual
list of constituents. We do not propose sampling SMP-5 for PFAS at this time, but it will be sampled
for its usual list of constituents.
All compliance wells for both landfills will be sampled for PFAS in addition to their usual list of
constituents.
12-D Oak Branch Drive I Greensboro, NC 27407 I p [phone]
www.Labellapc.com

Please feel free to contact me at [phone] if you have any questions.
Respectfully submitted,
LaBella Associates
Van Burbach, Ph.D., P.G.
Senior Technical Geologist
Cc: Mark Delehant, Burke County