3404_TownKernersville_CAERResponse_DIN27098_20161206

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
Asheville Regional Office | 2090 US Highway 70 | Swannanoa, NC 28778
828 296 4500 T

December 6, 2016

Sent Via Email – [e-mail]
Mr. Doran Maltba
Town of Kernersville Public Services Director
P.O. Box 728
Kernersville, NC 27285

Re: Corrective Action Evaluation Report (CAER)
Closed Town of Kernersville MSW Landfill
Forsyth County
Solid Waste Permit Number 3404
DIN 27098

Dear Mr. Maltba,

The NC Solid Waste Section has completed a review of the Corrective Action Evaluation Report dated
October 2016 (DIN 27097) and submitted on behalf of the Town of Kernersville by Joyce Engineering for
the closed Town of Kernersville MSW Landfill, Solid Waste Permit Number 3404. This is the first Corrective
Action Evaluation Report (CAER) that has been submitted for this landfill, and within this first CAER, it is
stated that subsequent CAERs will be submitted every five years. The next CAER will be submitted in 2021.

The Solid Waste Section approved the County’s selected remedy for this landfill on July 23, 2014 that
included the implementation of Monitored Natural Attenuation (MNA) and Phytoremediation (DINs
21442 and 21443). The Corrective Action Evaluation Report was submitted pursuant to the County’s
Corrective Action Plan dated October 2014 and approved on November 4, 2014 (DINs 22196 and 22198).

MNA baseline sampling concluded with the June 2016 sampling event. It appears that conditions have
remained relatively stable at the landfill over the past two years since the implementation of the selected
remedy.

Within the CAER, the Town of Kernersville has provided requests regarding the modification of the
ongoing corrective action at the landfill. The first request is to remove cis-1,2-dichloroethylene from the
constituent of concern list due to no exceedances of this constituent since 2012. The second request is
to discontinue analyzing for the following MNA parameters during each semiannual monitoring event:
BOD, COD, methane, ethane, ethene, dissolved carbon dioxide, all of the volatile fatty acids, and ferrous
iron. Instead, the Town is requesting to change the frequency of these specific MNA parameters from
semiannual to twice immediately prior to the next submittal of the CAER which would include the fourth
quarter of 2020 and the second quarter of 2021.

As a result, based upon the technical relevance of the requests provided within the Corrective Action
Evaluation Report dated October 2016, the request to remove cis-1,2-dichloroethylene from the

constituent of concern list is approved as described, and the request to modify the sampling frequencies
to every five years is not approved at this time. However, the frequency of the requested MNA
parameters BOD, COD, methane, ethane, ethene, dissolved carbon dioxide, all of the volatile fatty acids,
and ferrous iron may be analyzed on a semiannual basis (both sampling events) every three years.
Therefore, the next sampling events for these specific MNA parameters will be twice in 2019, and the next
Corrective Action Evaluation Report will be submitted in 2021.

If you have any questions or concerns regarding this letter, please feel free to contact me at 828.296.4706
or by email at [e-mail]. Thank you for your continued cooperation with this
matter.

Sincerely,

Jaclynne Drummond
Compliance Hydrogeologist
Solid Waste Section, Division of Waste Management
NCDEQ

cc sent via email: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Susan Heim, Senior Environmental Specialist
Perry Sugg, Permitting Branch Hydrogeologist
Ming Chao, Permitting Branch Engineer
Van Burbach, Joyce Engineering