1403_Caldwell_Foothills_MSWLF_PFASRequest_FID1818889_20231002

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C O N S U L T I N G
October 2, 2023
Ms. Jackie Drummond
Compliance Hydrogeologist
North Carolina Department of Environmental Quality
Division of Waste Management - Solid Waste Section
Asheville Regional Office (ARO)
2090 US Highway 70
Swannanoa, North Carolina 28778
Re: PFAS Sampling & Analysis Plan
Foothills Regional Landfill, Permit No. 14-03
Caldwell County, North Carolina
Dear Ms. Drummond:
Submitted via Electronic Mail
On behalf of Republic Services for North Carolina, LLC, Jett Environmental Consulting is providing a letter to
clarify the proposed plan for per- and polyfluoroalkyl substances (PFAS) sampling and analysis at the Foothills
Regional Landfill.
In a March 13, 2023 Memorandum (Memo) from the North Carolina Department of Environmental Quality
(NCDEQ), requirements for PFAS monitoring were outlined. Following discussions with NCDEQ, the Carolinas
Chapter of NWRA and North Carolina Chapter of SWANA provided an April 28, 2023 recommended Sampling
and Analysis Guidance. This included a recommendation that a subset of representative sample points should
be used to fulfill NCDEQ's site screening objectives. In a subsequent July 17, 2023 Memo from NCDEQ,
clarification was provided regarding the PFAS monitoring. The July 17, 2023 Memo specified PFAS samples
should be collected from each monitoring location for two consecutive events based on a facility's current water
quality monitoring schedule. Per the July 17, 2023 Memo, facilities with groundwater assessment or corrective
action wells could propose to sample a representative subset of assessment/corrective action wells for Section
review and approval. In addition, the July 17, 2023 Memo stated facilities may propose to collect samples from
a subset of the current surface water sampling locations, comprising at least one upstream and one downstream
location.
The attached Figure provides a potentiometric surface map utilizing water level data from the First Semi -Annual
2023 event. Groundwater flow direction for the First Semi -Annual 2023 event was to the southwest, which is
consistent with previous interpretations for this facility.
In accordance with the July 17, 2023 memo, each of the groundwater sampling points specified in the NCDEQ-
approved Water Quality Monitoring Plan will be sampled for PFAS. In addition, the two underdrains and
leachate system will be sampled for PFAS.
The site has a surface water monitoring network consisting of one upstream surface water sampling point (SW-
1) and four downstream points (SW-2, SW-3, SW-4, and SW-5). In accordance with the July 17, 2023 memo,
only upstream sample location SW-1 and downstream sample location SW-2 will be analyzed for PFAS.
Location SW-2 is the most direct downstream location from the landfill.
Should you have any questions or concerns, please contact Mr. Stoddard Pickrell at [phone] or Steve
Jett at [phone].
18 Lexington Oaks Court 314-496-4654
Foristell, MO 63348 www.jettenviro.com

Sincerely,
Steve Jett, LG #1825
Owner, Jett Environmental Consulting, PLLC (C-517)
Attachment: Potentiometric Surface Map
cc: Stoddard Pickrell, Republic Services (PDF via Email)
Joe Montello, Republic Services (PDF via Email)
Foothills Regional Landfill (1 Hardcopy)

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1153.24 Groundwater Elevation (fmsl)
—1300 — Potentiometric Surface Contour (fmsl)
Hydraulic Gradient & Inferred
Groundwater Flow Direction
SW-1 Surface Water Sampling Location (Approx)
Landfill Cell Boundary
.,,.mo,00 LFG Trench (Approx)
Water levels collected by Environmental
Sampling & Services, Inc. on February 6, 2023
Basemap provided by Joyce Engineering, with
topographic survey completed by Cooper Aerial
Surveys Co., date of Photography is January 20,
2014.
J ETT
ENVIROmvitNTAL
CONS U LTING
Figure 1
18 Lexington Oaks Court First Semi -Annual 2023 Event Potentiometric Surface Ma
Foristell, MO 63348
314-496-4654
www.jettenvim.com Foothills Regional Landfill, Caldwell County, North Carolina