1203_BurkeJohnsRiverCDLF_DesignHydroReview_DIN26650_2016

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Acting Director

August 18, 2016

Mr. Van Burbach, P.G.
Joyce Engineering
2211 W. Meadowview Road, Suite 101
Greensboro, NC 27407

Re: Permit No. 1203-CDLF-2014
Burke County Johns River Waste Management facility
Design Hydro and WQ Plan Reviews for CDLF Expansion – Phases 2a and 4
DIN 26650

Dear Mr. Burbach,
The Solid Waste Section (Section) has completed the technical review of the Design Hydrogeologic Report
(DIN 26500) for the proposed Phase 2a/4 C&D landfill expansion and the updated Water Quality
Monitoring Plan for the facility, both submitted by Joyce Engineering on behalf of Burke County. The
documents were received via FedEx by the Section on June 3, 2016. Joyce indicated a permit-to-construct
application for Phases 2A/4 is planned to be submitted separately to the Section at a later date. Phases
2A/4 cover approximately 6.2 acres and would be an expansion of the currently active Phase 1A C&D
landfill area permitted for operation in August 2014 (DIN 21528).

Design Hydrogeologic Report – ref. 15A NCAC 13B .0538(b)
Based on our review, the Design Hydro Report for the Phase 2A/4 expansion meets the criteria required in
.0538(b)(3) for construction, including the top-of-bedrock datum and seasonal high groundwater table
determinations for vertical separation requirements for construction [15A NCAC 13B .0540(2)]. This
portion of the Permit to Construct is approved.

Water Quality Monitoring Plan – ref. 15A NCAC 13B .0544(b) and (c)
The Burke County CDLF facility is currently operating under a Corrective Action Plan (CAP) Addendum
(DIN 19615) and a Water Quality Monitoring plan (DIN 17215) previously approved by the Section. The
CAP addresses groundwater contamination associated with the closed unlined MSW disposal unit (with a
C&D disposal unit on top) located on the site. Corrective measures being undertaken include monitored
natural attenuation, phytoremediation, and landfill gas extraction. The current monitoring plan includes both
assessment monitoring of the old closed landfill and detection monitoring for the Phase 1A expansion C&D
landfill, as well as surface water monitoring of two adjacent streams.

Page 2

The updated Water Quality Monitoring Plan submitted for review adds four (4) detection monitoring wells
to the existing facility’s overall monitoring network that monitors the closed MSW disposal unit, as well as
the active C&D disposal unit. Together with the Phase 1A detection wells, these newly added wells will
comprise that portion of the detection well network monitoring the new C&D landfill area (Phases 1A,
2A/4). Of the four wells, one will be a newly installed well (MW-30) and three (3) are existing piezometers
that will be converted to detection monitoring wells (MW-30, MW-23s, and MW-24s. Other existing wells
within the footprint of Phase 2A/4 will be abandoned per the plan: MW-1, MW-22s/-22d, and PZ-40/-41/-
42. In addition, two other bedrock piezometers will be converted to monitoring wells MW-23d and MW-
24d, but will not be included in the detection monitoring network. The proposed Phase 2A/4 expansion
detection monitoring wells will be sampled, along with the current facility monitoring network, according the
Water Quality Monitoring Plan. The initial baseline sampling requirements will be included in the Permit‐
To‐Construct to be issued at a later date. Guidelines for water quality sampling and electronic data submittal
can be located at the Section’s web site. http://portal.ncdenr.org/web/wm/sw/envmonitoring

In an August 15, 2016 phone conversation Van Burbach (Joyce Engineering) informed the Section that
facility owner has decided that Phase 2A and 4 will be constructed at the same time rather than in phases as
was described in the permit application submittal. Prior to final approval of the updated WQ Plan, the
following revisions are requested based on our review and the changed construction phasing plan:

 Section 2.2.1 Monitoring Networks for Phases 1A, 2A, and 4: Revise text and table to reflect
current plan to construct phases 2A and 4 simultaneously.
 Section 2.6 Well Abandonment: Revise text to reflect current plan to construct phases 2A/4
simultaneously.
 Table 1: Construction Data for Wells & Piezometers: Update table to reflect current plan to
construct phases 2A/4 simultaneously.
 Plan Sheet WQMP-01: Revise plan sheet to reflect current plan to construct phases 2A/4
simultaneously.
 Appendices: Include the most recent guidance on monitoring data submittal. The November 2014
memo can be downloaded from our website: SWS Electronic Data Submittal Memo - Nov2014

Landfill Gas Monitoring Plan – ref. 15A NCAC 13B .0544(d)
The current LFG plan (DIN 17215) for the facility is dated August 2012 and was submitted with the Phase
1A landfill expansion permit application. While the plan is not expected to substantially change with the
proposed 2A/4 expansion, some minor updates will be necessary to reflect changes in monitoring
requirements since 2012. Please submit an updated Landfill Gas Plan for the facility for review and approval
prior to the Phase 2a/4 permit approval. As applicable, include the following updates in the LFG plan:
 Hydrogen Sulfide (H2S): Due to the nature of materials disposed in them, C&D landfills are also a
source of the explosive gas hydrogen sulfide (H2S). The plan needs to be updated/amended to
include hydrogen sulfide gas (H2S) monitoring. Regulatory action limits for hydrogen sulfide are 4%
by volume for 100 LEL and 1% by volume for 25% LEL, respectively. Please add H2S monitoring
to the plan and forms as appropriate.
 Landfill Gas Monitoring: If additional landfill gas monitoring well locations are necessary and
proposed, please revise maps, tables, forms, text as appropriate.

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Well Abandonment
There are at least six (6) existing piezometers and/or monitoring wells within the footprint of the proposed
Phase 2A/4 expansion. These wells are proposed for abandonment prior to construction activities
commencing for the landfill expansion. (Piezometers, groundwater monitoring wells, and borings, located in proposed
expansion may be abandoned now or after a Permit‐to‐Construct is issued by the Solid Waste Section). Please adhere to
the following conditions:

Prior to construction of cell(s), all piezometers, ground‐water monitoring wells, and borings, located in
the proposed cell(s), shall be properly abandoned by over drilling first (exception for non‐cased borings)
and sealed with grout in accordance with 15A NCAC 2C .0113, entitled “Abandonment of Wells”.

a. In areas where soil is to be undercut, abandoned piezometers, monitoring wells, and borings
must not be grouted to pre‐grade land surface, but to the proposed base grade surface to
prevent having to cut excess grout and potentially damaging the wells.

b. Well abandonment records (GW‐30 form) for each decommissioned piezometer, boring, and
groundwater monitoring well must be certified by a Licensed Geologist in accordance with rule
.1623(b)(2)(1) and submitted to the Solid Waste Section in accordance with 15A NCAC
02C.0114(b).

NOTE: The Permit-to-Construct will include Geologic, Ground Water, and other Monitoring
Requirements.

Please submit the revised WQ Plan and LFG Plan to me once the changes have been completed. An
electronic pdf copy of each will be fine. If you have any questions concerning these comments, please do not
hesitate to contact me via email [e-mail] or phone [phone].

Sincerely,
Perry Sugg, PG
Permitting Hydrogeologist
Solid Waste Section

Cc: Ed Mussler, P.E. – SWS, Permitting Branch Head
Allen Gaither – SWS, Permitting Engineer