6001_ROSCANS_1993

State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Division of Sotid Waste Management
Telephone (919)TiS-0692 Jonathan R Howes, Secretary
July 29, 1993
Mr. Gerald G. Fox
County Manager, Mecklenburg County
600 East, Fourth Street
Charlotte, N.C. 28231
Re: Implementation Of Subtitle 'Dr Ground -water Monitoring Program
Dear Mr. Fox,
The purpose of this correspondence is to provide information and
clarification on the changes in ground -water monitoring requirements
for MSWLF facilities that remain in operation after October 9, 1993.
The recently adopted North Carolina Solid Waste Management Rules
reflect significant changes for ground -water monitoring based on
requirements of the E.P.A. Subtitle D Rules.
Attachment A to this letter provides a summary of important
dates and significant activities that must be accomplished in order
to be in compliance with the new rules. Attachment B contrasts
existing and new ground -water monitoring and assessment requirements
based on changes in the rules. Because of significant increases in
costs that will be incurred in order to operate a MSWLF under the new
Subtitle D Rules, including financial assurance and increased costs
for ground -water monitoring and assessment, you may wish to seriously
consider closing your sanitary landfill prior to October 9, 1993,
when the new rules become effective.
Based on past ground -water monitoring data for the Mecklenburg
County landfill (Harrisburg facility), there are already documented
violations of North Carolina Groundwater Quality Standards at some of
the detection monitoring wells. A copy of your most recent sampling
analytical data is attached on which highlighting has been done for
the Appendix I constituents that exceed the Groundwater Quality
Standards. Therefore, when the new rules take effect, Mecklenburg
County will quickly be required to implement assessment monitoring
for all Appendix II constituents. Since the Groundwater Quality
Standards are also used in establishing the ground -water protection
standards, you may also rapidly move into assessment of corrective
P.O. Box 27687, Poleigh, Nonh Carolina 27611-7687 Telephone [phone] Fax [phone]
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Page 2
action alternatives based on a full-scale ground -water investigation
to determine the nature and extent of contamination at the site.
If Mecklenburg County chooses to continue to operate their MSWLF
facility after October 9, 1993, then you need to begin planning and
budgeting immediately for the activities outlined in Attachment A. A
revised Water Quality Monitoring Plan must be submitted as part of
the Transition Plan on or before April 9, 1994. All background
sampling and related activities for the upgraded monitoring system
must be completed and reported to the Division in order to
demonstrate compliance with the new water quality monitoring
requirements on or before October 9, 1994.
Please note that the goals and objectives for ground -water
assessment monitoring and ground -water contamination investigations
are the same under both the current and the proposed rules and shall
be accomplished in a way that is protective of human health and the
environment. However, current rules allow for greater flexibility in
the assessment and investigation activities and the sample analytical
costs could be substantially less using the constituent list required
under current rules and policy as compared to analytical costs
required by the new rules based on Subtitle D, which require sampling
for the Appendix II list of constituents.
I hope this letter has been helpful in providing you more
insight into the actions that will be required by Mecklenburg County
to maintain compliance with the water quality monitoring requirements
of the Solid Waste Management Rules as we make the transition to the
new rules growing out of the E.P.A. Subtitle D Regulations. If you
have any questions or comments regarding this letter, please contact
the Solid Waste Section at [phone].
Sincerely,
Bobby Lutfy, Hydrogeologist
Solid Waste Section
cc: Richard Doby
Attachments
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a STATE Q
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604 . !i
Division of Solid Waste Management
James B. Hunt, Jr., Governor Solid Waste Section Jonathan R Howes, Secretary
Telephone [phone]
February 1, 1993
Keith A. Anthony, PE
Law Environmental, Inc.
4333 Wilmont Road
Suite 300
PO Box 240674
Charlotte, North Carolina 28224-0674
Ref: Harrisburg Road Landfill
Permit Number 60-01
Construction Plan Modification Application
Completeness Review
Mr. Anthony:
The Solid Waste Section has conducted a review of the referenced application for
completeness. At this time the application appears substantially complete. The Section may
require additional information following the technical review. Additional information or
modifications may also be required following review by the Section Hydrogeologist.
If you have any questions or if we can provide any other assistance, please do not hesitate
to contact this office.
Sincerely,
William D. Sessoms, PE
copy: Bill Warren
Jan McHargue
Rick Doby
C:\SESSOMS\PROJECTS\MECKBURG\LTR.2
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax N 919-733-0513
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