9102T_VanceCoTS_LeachateReleaseAssmtRptAppr_FID1838590_20240520

May 20th, 2024

Sent via email – [e-mail]

Mr. John Pfleger
Regional Environmental Compliance Manager
GFL Environmental, Inc.
3301 Benson Drive, Suite 601
Raleigh, NC 27609

RE: Recommended Soil Sampling - Results
Vance County Transfer Station
Permit# 9102T-TRANSFER-1997
Vance County
FID 1838590

Dear Mr. Pfleger:

The Solid Waste Section (Section) has reviewed the Recommended Soil Sampling - Results (FID
1838475) submitted on behalf of GFL Environmental, Inc. by Smith + Gardner, Inc. (S+G). The
sampling was conducted in accordance with the March 26th, 2024, approved Sampling Plan (FID
1833594).

S+G collected two discrete soil samples (SS-1 and SS-2) on April 6th, 2024, at depths ranging from
one to two feet below ground surface in the area of concern following impacted soil excavation.
The soil samples were analyzed for 40 CFR 258 Appendix I constituents, 1,4-dioxane, total
phosphorus, sulfate, nitrate, and pH. SS-1 and SS-2 analytical results were compared to
background soil sample (BG-1, BG-2, and BG-3) results from previous investigations and the
Preliminary Soil Remediation Goals (PSRGs).

Analytical results indicated that cobalt was the only constituent reported above the protection
of groundwater PSRG. As a result, an SPLP analysis was conducted for samples SS-1 and SS-2 and

those results were compared to the 1ppb 2L Standard for cobalt. Estimated cobalt
concentrations of 2ppb and 3ppb were reported for SS-1 and SS-2, respectively via the SPLP
analysis. S+G also reviewed analytical results from BG-1, BG-2, and BG-3 in addition to the USGS
National Uranium Resource Evaluation stream bed samples for Vance County. A review of that
information indicated the natural occurrence of cobalt on-site and in the general vicinity at
concentrations exceeding the protection of groundwater PSRG. Based on the lack of volatile
organic compound detections and apparent natural presence of cobalt at elevated
concentrations, S+G recommends no further action.

The Section agrees with S+G’s conclusion and will not require additional assessment of the March
2024 leachate release. Please contact me at 919-707-8288 or [e-mail] if you have
any questions or concerns regarding this correspondence. Thank you in advance for your
cooperation in this matter.

Sincerely,

Ervin Lane
Hydrogeologist
Solid Waste Section

Cc: Perry Sugg, P.G. – SWS Environmental Compliance Branch Head
Drew Hammonds – SWS Eastern District Supervisor
Amanda Thompson – SWS Environmental Senior Specialist
Joan Smyth, P.G. – Smith + Gardner, Inc.
Randy Deming – GFL Environmental, Inc.