1302_CabarrusCDLF_DesignHydroReview_DIN27244_Jan2017

ROY COOPER
Governor
WILLIAM G. ROSS, JR.
Acting Secretary

MICHAEL SCOTT
Director

January 10, 2017

Mat Colone, P.G.
CDM Smith Inc.
5400 Glenwood Avenue, Suite 400
Raleigh, NC 27612

Re: Permit No. 1302-CDLF-2006
Cabarrus County CDLF
Design Hydro Report Phase 3/4 CDLF Expansion Review & Monitoring Plans Review
DIN 27244

Dear Mr. Colone,
The Solid Waste Section (Section) has completed the technical review of the Design Hydrogeologic Report
(DIN 27243) for the proposed Phase 3 and Phase 4 C&D landfill expansions. The report was submitted via
email by CDM Smith on behalf of Cabarrus County on January 4, 2017. The Phase 3 permit-to-construct
application (DIN 27206) was submitted separately to the Section and reviewed by the Section Permitting
Engineer. Monitoring plans were included in the Phase 3 expansion application, in Part 5 - Operations Plan.
Only minor revisions were made to the Water Quality Monitoring Plan for the active CDLF or to Landfill
Gas Monitoring Plan for the facility, and both were reviewed for any updates that may be required. Note
that a Phase 4 permit to construct application has not been submitted at this time by Cabarrus County.
Phases 3 and 4 will cover approximately 2 acres each for a total of 4 acres and would be an expansion of the
currently active permitted C&D landfill unit.

Design Hydrogeologic Report – ref. 15A NCAC 13B .0538(b)
Based on our review, the Design Hydro Report for the Phase 3 and Phase 4 expansions meet 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)]. If,
however, the footprint of Phase 4 as depicted in this Design Hydro report changes when the Phase 4
construction permit application is submitted, then a new design hydro approval for Phase 4 will be required.
Otherwise, this portion of the Permit to Construct is approved for both Phase 3 and Phase 4.

Water Quality Monitoring Plan – ref. 15A NCAC 13B .0544(b) and (c)
The proposed WQ Plan for the active CDLF outlines the current groundwater detection monitoring
network and proposed new monitoring locations for the Phase 3 expansion. The monitoring network for the
active CDLF will include 2 background wells (CD-1s & CD-1d, shallow and deep) and three compliance
wells (CD-2, CD-7, & CD-9), as well as one surface water sample location (SW-3). Four of the wells are pre-
existing and one new well, CD-9, will be installed. It is also noted that separate and concurrent monitoring
and corrective action is ongoing for the closed Unit 1 Landfill and the closed Unit 2/3 Landfill (DIN 8021),
respectively. Compliance monitoring activities and corrective actions for these closed units are addressed
separately by the Section, and were considered in developing the monitoring plan for the active CDLF.
Page 2

The proposed detection monitoring wells will be sampled, along with the current facility monitoring
network, according the Water Quality Monitoring Plan. Prior to completion of Phase 3 expansion, an initial
baseline groundwater sample will be collected from the new well CD-9. Following construction, detection
monitoring will begin. Monitoring 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.

Prior to final approval of the updated WQ Plan, the following revisions are requested based on our review
and the changed construction phasing plan:
 Appendices: Update to include three additional Section guidance memos (June 2010, November
2014, and September 2016) for monitoring requirements. These are attached for your convenience.

Landfill Gas Monitoring Plan – ref. 15A NCAC 13B .0544(d)
The current LFG monitoring system covers the entire Cabarrus County facility, which includes the active
CDLF and all inactive/closed disposal units at the site. Both methane and hydrogen sulfide gases are
monitored at the facility. The updated October 2016 LFG Plan was submitted as an appendix B of the
Operation Plan contained in the Phase 3 PTC application (DIN 27206). This plan is essentially unchanged
with exception of the installation of one new landfill gas monitoring well (MGW-17) as part of the Phase 3
expansion. This will bring the total number of landfill gas monitoring wells to seventeen for the facility. The
is no mention in the plan of monitoring enclosed structures or buildings at the facility.

The LFG Plan meets all the requirements and conditions for monitoring explosive gases at the facility with a
few exceptions, noted below. Also, since the facility is comprised of active and closed landfill units, both
MSW and C&D, the Section requests only one comprehensive LFG plan to cover the entire facility, rather
than parse out LFG plans for each individual unit. The combined LFG plan is not expected to substantially
change with the proposed Phase 3 and 4 expansions, but some minor updates will be necessary.

Please submit an updated Landfill Gas Monitoring Plan for the facility for review and approval prior to the
Phase 3 expansion permit approval. As applicable, include the following updates in the LFG plan:
 LFG Plan Title: Revise title to reflect the LFG Plan is for the entire facility, not just the current
active CDLF.
 Section 1 – Introduction: Add sentence(s) as needed to state the plan covers the facility and list the
landfill units, both active and inactive/closed, as well as their associated permit numbers (see
attached figure).
 Landfill Gas Monitoring – Onsite structures: Add monitoring for any buildings or structures located
in the vicinity of any landfill unit. If additional landfill gas monitoring locations are necessary, please
revise maps, tables, forms, text as appropriate.

Page 3

Well Abandonment
There are seven (7) existing piezometers and/or monitoring wells within the footprint of the proposed
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 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
Closed Units 2 and 3
Municipal Solid Waste (MSW)
Landfill
Closed Unit 1
MSW Landfill
0 1000 2000
Figure 1 - Site Map
Cabarrus County Landfill Facility
Alternative Source Demonstration
Facility Property Boundary
(Approximated)
Scale in Feet
C&D
Landfill
Scale House
Iris
h P
o
tat
o R
o
a
d
Maintenance
Buildings
Recycling
Conveinence
Center
T a t e r R i d g e R o a d
B a r r i e r R o a d
T alber t Farm Road
Waste Boundary
(Approximated)
Image obtained from Google Earth Pro – August 15, 2013
Legend
Facility Property Boundary
(Approximated)
Shooting
Range
Waste Boundary - Dashed White
(Approximated)
Permit 1302-CDLF-2006
Permit 1302-MSWLF-1974
Permit 1302-MSWLF-
&
Permit 1302-CDLF-1998
ACTIVE
INACTIVE/CLOSED
INACTIVE/CLOSED
(includes CDLF over MSW)

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
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

September 9, 2016

MEMORANDUM

To: Solid Waste Directors, Public Works Directors, Landfill Operators, and
Landfill Owners

From: The Solid Waste Section

Reference: Guidelines for 14-Day Notification of Groundwater Exceedances Form
Submittal per rule: 15A NCAC 13B .1633(c)(1)

 The 14-day notification form should be submitted whenever a groundwater
protection standard (GWPS) is exceeded for the first time.
o As defined in 13B .1634(g)(h), a GWPS will be either of the following: the 2L
standard (most cases); 2L Interim Maximum Allowable Concentration; a
groundwater protection standard calculated by the SWS; or a site-specific
statistical background level approved by the SWS.

 If a facility is undergoing assessment or corrective action, the 14-day notification
form should be submitted ONLY when the constituent with the reported
exceedance is not being addressed through assessment or corrective action.

 If a facility plans to conduct a re-sampling event to confirm the initial
exceedance, the 14-day notification form should be submitted ONLY when the
re-sampling event analytical data confirms the initial exceedance.

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NC DEQ
Division of Waste Management - Solid Waste 14-Day Notification of Groundwater
Protection Standard Exceedance(s)
Notice: This form and any information attached to it are "Public Records" as defined in NC General Statute 132-1. As such, these documents are
available for inspection and examination by any person upon request (NC General Statute 132-6).
Instructions:
• Prepare one form for each individually monitored unit.
• Please type or print legibly.
• Attach a notification table with values that attain or exceed applicable groundwater protection standards.
• Send the original signed and sealed form, any tables, and Electronic Data Deliverable to: Compliance Unit, NCDEQ-DWM, Solid Waste
Section, 1646 Mail Service Center, Raleigh, NC 27699-1646.
Solid Waste Monitoring Data Submittal Information
Name of entity submitting data (laboratory, consultant, facility owner):
Contact for questions about data formatting. Include data preparer's name, telephone number and E-mail address:
Name: Phone:
E-mail:
Facility name: Facility Address: Facility Permit #
Actual sampling dates (e.g.,
October 20-24, 2006)
Environmental Status: (Check all that apply)
Initial/Background Monitoring Detection Monitoring Assessment Monitoring Corrective Action
Additional Information:
A notification of values exceeding a groundwater protection standard as defined in 15A NCAC 13B .1634(g)(h) is attached. It includes a list of
groundwater monitoring points, dates, analytical values, NC 2L groundwater standard, NC Solid Waste GWPS and preliminary analysis of the
cause and significance of any concentration.
A re-sampling event was conducted to confirm the exceedances.
Certification
To the best of my knowledge, the information reported and statements made on this data submittal and attachments are true and correct.
Furthermore, I have attached complete notification of any sampling values meeting or exceeding groundwater standards or explosive gas
levels, and a preliminary analysis of the cause and significance of concentrations exceeding groundwater standards. I am aware that there
are significant penalties for making any false statement, representation, or certification including the possibility of a fine and imprisonment.
Facility Representative Name (Print) Title (Area Code) Telephone Number
Signature
Affix NC Licensed/Professional Geologist or Professional
Engineer Seal
Revised 6/2016
Date
Facility Representative Address
NC PG/PE Firm License Number (if applicable effective May 1, 2009)
Alternate Source Demonstration(s) have been approved for the following constituents with report date:
per rule: 15A NCAC 13B .1633(c)(1)
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Pat McCrory John E. Skvarla, III
Governor Secretary

1646 Mail Service Center, Raleigh, North Carolina 27699-1646 2090 US Highway 70, Swannanoa, North Carolina 28778-82111 Phone: [phone] Phone: [phone]
http://portal.ncdenr.org/web/wm/
An Equal Opportunity / Affirmative Action Employer

1
November 5, 2014

MEMORANDUM

To: Solid Waste Directors, Public Works Directors, Landfill Operators, and Landfill Owners

From: Solid Waste Section

Re: Groundwater, Surface Water, Soil, Sediment, and Landfill Gas Electronic Document Submittal

The Solid Waste Section is continuing its efforts to improve efficiencies in document management. All
groundwater, surface water, soil, sediment, and landfill gas documents submitted to the Solid Waste Section are
stored electronically and are made readily available for the public to view on our webpage. Please remember that
hard copies/paper copies are not required, and should not be submitted. The submittal of these electronic
documents following a consistent electronic document protocol will also assist us in our review. Please follow
these procedures when submitting all groundwater, surface water, soil, sediment, and landfill gas documents to the
Solid Waste Section.

Submittal Method and Formatting
 All files must be in portable document format (pdf) except for Electronic Data Deliverables (EDDs)
unless otherwise specified by the Solid Waste Section. All pdf files should meet these requirements:
o Optical Characteristic Recognition (OCR) applied;
o Minimum of 300 dpi;
o Free of password protections and/or encryptions (applies to EDDs as well);
o Optimized to reduce file size; and
o Please begin using the following naming convention when submitting all electronic files: Permit
Number (00-00)_Date of Document (YYYYMMDD). For example: 00-00_20140101.
 Please submit all files via email or by file transfer protocol (FTP) via email to the appropriate
Hydrogeologist unless otherwise specified by the Solid Waste Section. If the electronic file is greater
than 20 MB, please submit the file via FTP or on a CD. If submitting a CD, please mail the CD to the
appropriate Hydrogeologist. The CD should be labeled with the facility name, permit number, county,
name of document, date of monitoring event (if applicable), and the date of document.
 Please be sure a signed Environmental Monitoring Data Form is submitted as part of the electronic file for
all water quality and landfill gas documents (monitoring, alternate source demonstration, assessment,
investigation, corrective action). This completed form should be the first page of the document before the
cover/title page and should not be submitted as an individual file. Blank forms can be downloaded at
http://www.wastenotnc.org/swhome/EnvMonitoring/NCEnvMonRptForm.pdf

Monitoring Data
Monitoring data documents may include any or all of the following: 1) groundwater and surface water monitoring;
2) soil and sediment, and 3) landfill gas monitoring. In addition to the above procedures, at a minimum, please
include the following:

Groundwater and Surface Water Monitoring
 A copy of the laboratory report(s).
 A copy of the sampling log(s).
 A separate table of detections and exceedances for each monitoring location.

1646 Mail Service Center, Raleigh, North Carolina 27699-1646 2090 US Highway 70, Swannanoa, North Carolina 28778-82111 Phone: [phone] Phone: [phone]
http://portal.ncdenr.org/web/wm/
An Equal Opportunity / Affirmative Action Employer

2
o All analytical results should be reported in micrograms per liter (ug/L) except for field
parameters and specific Monitored Natural Attenuation (MNA) parameters.
o Please also include the laboratory’s method detection limit (MDL) in ug/L, the Solid Waste
Section Limit (SWSL) in ug/L, the appropriate NC regulatory standard in ug/L (2L, 2B,
GWPS, IMAC), and the Federal Maximum Contaminant Level (MCL) in ug/L.
o Please BOLD each exceedance result.
 A separate table of field parameters for each monitoring location.
 An Electronic Data Deliverable (EDD) spreadsheet for each monitoring event submitted in the correct
format. All analytical results should be reported in micrograms per liter (ug/L) except for field
parameters and specific Monitored Natural Attenuation (MNA) parameters. The blank EDD template
can be downloaded at http://www.wastenotnc.org/swhome/enviro_monitoring.asp. Please pay
attention to the formats within the spreadsheet. Any EDD received that is not formatted correctly will
be emailed back to be resubmitted via email within five (5) days.
 A separate groundwater monitoring well construction table.
o Please also include the date the well was drilled, well diameter, total well depth, depth to top
of screened interval (in feet), screened interval (in feet), geology of screened interval, TOC
elevation, ground elevation, groundwater elevation, GPS coordinates (latitude and longitude),
and depth to water (in feet).
 A separate groundwater table with groundwater flow rate(s).
 A recent facility figure that includes labeled groundwater and surface water monitoring locations.
 A groundwater flow map with an arrow(s) indicating flow direction(s), including date the
measurements were taken.

Soil and Sediment Sampling
 A copy of the laboratory report(s).
 A copy of the sampling log(s).
 A separate table of detections and exceedances for each sampling location.
o Please also include the results in micrograms per liter (ug/L), the laboratory’s method
detection limit (MDL) in ug/L, and the appropriate NC regulatory standard (PSRG) in ug/L.
o Please BOLD each exceedance result.
 A separate table of soil and/or sediment characteristics.
 A recent facility figure that includes labeled sampling locations.

Landfill Gas Monitoring
 A blank Landfill Gas Monitoring Data Form can be found within the Landfill Gas Monitoring
Guidance document and can be downloaded at
http://portal.ncdenr.org/c/document_library/get_file?uuid=da699f7e-8c13-4249-9012-
16af8aefdc7b&groupId=38361.
 A separate table of landfill gas detections and exceedances for each monitoring location. Please
BOLD each exceedance result.
 A recent facility figure that includes labeled landfill gas monitoring locations (both permanent and
temporary).

If you have any questions or concerns regarding electronic submittals, please feel free to contact the
Hydrogeologist overseeing your facility. The Solid Waste Section greatly appreciates your assistance on
this matter. Working together, we can continue to provide excellent customer service to you and to the
public.
 Jackie Drummond, Asheville Regional Office, 828-296-4706, [e-mail]
 Ervin Lane, Raleigh Central Office, 919-707-8288, [e-mail]
 Elizabeth Werner, Raleigh Central Office, 919-707-8253, [e-mail]
 Christine Ritter, Raleigh Central Office, 919-707-8254, [e-mail]
 Perry Sugg, Raleigh Central Office, 919-707-8258, [e-mail]

North Carolina Department of Environment and Natural Resources
Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
June 25, 2010
MEMORANDUM
To: Solid Waste Directors, Landfill Owners/Operators, and North Carolina Certified
Laboratories
From: North Carolina Division of Waste Management, Solid Waste Section
Re: Tetrahydrofuran Analysis at Construction and Demolition Landfills
Based upon historical sampling results, health and environmental concerns, and an ongoing EPA
evaluation of tetrahydrofuran (THF), the Solid Waste Section (Section) is requiring, in
accordance with 15A NCAC 13B .0601, that Construction and Demolition Landfills (CDLFs)
begin analyzing ground and surface water samples collected after January 1, 2011 for THF. The
purpose of this memorandum is to inform CDLF owners and operators and laboratories that are
involved in the collection or analysis of environmental samples of this requirement.
Although the North Carolina Occupational and Environmental Epidemiology Branch previously
established a health based standard for THF, there are currently no established
Maximum Contaminant Levels or 15A NCAC 02L .0202 Standards due to the lack
of historical toxicological data necessary to promulgate regulatory standards. However,
THF analysis is currently required at CDLFs located in several states throughout the U.S. and
has been shown to be a constituent of concern in groundwater at CDLFs for several years. In
addition, THF has been documented as a contaminant associated with CDLF leachate.
Due to the potential health hazards associated with THF and its documented presence at CDLFs,
the Section has determined that CDLFs should begin analyzing ground and surface water
samples for THF to ensure protection of human health and the environment. Although
regulatory standards have not yet been established for THF, its presence in groundwater must be
determined in order to accurately assess the risks at each CDLF and determine if regulatory
standards need to be established. The Section will reevaluate monitoring requirements for THF
in the future after enough data has been collected to determine the extent of THF at C&D
facilities.
Laboratories are advised to contact the Division of Water Quality-Laboratory Section-
Certification Branch prior to initiating THF analysis using Method 8260.
If you have any questions or concerns, please feel free to contact Jaclynne Drummond (919-508-
8500) or Ervin Lane (919-508-8516). Thank you for your continued cooperation with this
matter.