7407_Pitt_C&DLandfillInc_CDLF_Phase1_Phase2_GWCA_FID1817248_20230901

�<ve SOt&
W UO
DQ
DN44T a
ELM Site Solutions, Inc.
P. O. Box 97607
Raleigh, North Carolina 27624
[phone]
September 1, 2023
Submitted via Electronic Mail
Ms. Jaclynne Drummond
Hydrogeologist
North Carolina Department of Environmental Quality
Division of Waste Management - Solid Waste Section
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Groundwater Corrective Action Plan Addendum, MNA Screening Model, and
Alternate Source Demonstration for Inorganics
C&D Landfill, Inc.
Pitt County
Solid Waste Permit Numbers 7407-CDLF-2001 and 7407-CDLF-2009
Dear Ms. Drummond:
ELM Site Solutions, Inc. (ELMSS), on behalf of C&D Landfill, Inc., provides the following response
to the department's correspondence of July 6, 2023 for the above -referenced site. The
department's correspondence specifically requires the following three items (in italics) which are
discussed below.
1. Within 60 days, submit a Groundwater Corrective Action Plan Addendum for Phase 1.
C&D Landfill, Inc. and ELMSS are preparing the CAP Addendum and will submit the
document in early September, coinciding with the requested 60-day response.
2. Within 60 days, submit a MNA EPA screening model depicting the attenuation processes
at the landfill.
C&D Landfill, Inc. and ELMSS are working on this analysis and subsequent report. As we
discussed previously, additional data is required to complete the analysis and verify the
site's conceptual site model. We are requesting a 90-day extension (i.e., December 8,

Ms. Jaclynne Drummond
Response to July 6, 2023 Correspondence
September 1, 2023
2023) to obtain new data, complete the technical analysis and submit the associated report
to the department.
3. Within 60 days, submit an Alternate Source Demonstration (ASD) for the inorganic
exceedances as indicated within the approved 2022 Groundwater Corrective Action Plan.
Similar to the MNA evaluation, C&D Landfill, Inc. and ELMSS are working on this analysis
and the subsequent report. As also discussed with the department, additional background
soil data is required to complete the analysis. We are requesting a 90-day extension (i.e.,
December 8, 2023) to obtain new data, complete the technical analysis and submit the
associated report to the department.
Please confirm the information above is acceptable and contact us if you have any questions or
require additional information.
Sincerely,
ELM Site Solutions, Inc.
Rusty Norris, PE, PLS, RSM
Senior Engineer
c Judson Whitehurst, C&D Landfill, Inc.
2