4104_Guildford_CityofHighPiontMSW_ASDInorganics_DIN26552_20160808

PAT MCCRORY
Governor DONALD R. VAN DER VAART
Secretary MICHAEL SCOTT
Acting Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

August 8, 2016

Sent Via Email: [e-mail]

Mr. Mike Spencer
City of High Point
3748 East Kivett Drive
High Point, NC 27260

Re: Appendix I Inorganic Constituent Exceedances
City of Hight Point MSW Landfill
Permit # 4104-MSWLF-1991, DIN 26552

Dear Mr. Mike Spencer:

The Solid Waste Section (Section) has reviewed groundwater monitoring data for the City of Hight Point
MSW Landfill. This letter is being sent in regards to all lined landfills. Concentrations of Appendix I
inorganic constituents were reported above the standards established in 15A NCAC 02L .0202 (2L
Standards) in on-site monitoring wells. Detection monitoring is currently being conducted at the facility
in accordance with 15A NCAC 13B .1633 and additional action is necessary based on the inorganic 2L
Standards exceedances. Rule 15A NCAC 13B .1633(c) instructs the facility owner or operator to perform
one of two actions in response to 2L Standard exceedances:

• 15A NCAC 13B .1633(c)(2) states that the owner or operator “Shall establish an assessment
monitoring program meeting the requirements of this Section within 90 days except as provided
for in Subparagraph (3) of this Paragraph.”

Or

• 15A NCAC 13B .1633(c)(3) states that the owner or operator “May demonstrate that a source
other than a MSWLF unit caused the exceedance, or the exceedance resulted from an error in
sampling, analysis, statistical evaluation, or natural variation in ground-water quality. A report
documenting this demonstration shall be approved by the Division. A copy of this report shall
also be placed in the operating record. If a successful demonstration is made, documented, and
approved by the Division, the owner or operator may continue detection monitoring. If after 90
days, a successful demonstration is not made, the owner or operator shall initiate an
assessment monitoring program as required by this Section.”

Based on the results of the aforementioned monitoring data, the Section instructs the City of Hight Point
MSW Landfill to either implement an assessment monitoring program or prepare and submit an alternate
source demonstration within 90 days of receipt of this letter. If the alternate source demonstration is
successful and approved by the Section, the facility may continue detection monitoring. If the Section
does not approve the Alternate Source Demonstration, the facility should initiate assessment monitoring
in accordance with 15A NCAC 13B .1634.

Please contact me at 919-707-8245 or [e-mail] or the hydrogeologist assigned to
your landfill if you have any questions or concerns regarding this correspondence. Thank you in advance
for your cooperation in this matter.

Sincerely,

Ellen Lorscheider
Solid Waste Section Chief
Solid Waste Section