6013_GreenwayNorthMeckCDLF_20170217_GWCA_DIN27430

February 17, 2017

Sent Via Email – [e-mail]
Mr. Mike Griffin
Greenway Waste Solutions at North Meck, LLC
19109 West Catawba Avenue, Suite 200
Cornelius, NC 28031

Re: Groundwater Corrective Action
North Mecklenburg C&D Landfill Infill Area and Closed Phase I Area
Mecklenburg County
Solid Waste Permit Number 6013
DIN 27430

Dear Mr. Griffin:

The NC Solid Waste Section has completed a review of the Fall 2016 Semiannual Groundwater Monitoring
Report For The Infill Expansion Area dated January 7, 2017 (DIN 27428) and the Fall 2016 Fall Groundwater
Monitoring Report For The Closed Phase I Landfill Area dated January 18, 2017 (DIN 27429) both submitted
on your behalf by CEC Consultants, Inc. for the North Mecklenburg C&D Landfill Infill Area and the Closed
Phase I Area, NC Solid Waste Permit Number 6013. Since 2013 in response to the consistent groundwater
exceedances, the Infill area of the landfill has been in the Assessment Monitoring program in accordance
with 15A NCAC 13B .0545 and 15A NCAC 2L, and the closed Phase I area of the landfill has been conducting
an assessment in accordance with 15A NCAC 15A NCAC 13B .0503 and the 15A NCAC 2L.

Greenway Waste Solutions at North Meck, LLC is continuing to delineate the contaminant plume(s) for
the Infill area. Most recently, four groundwater monitoring wells were installed near the property
boundaries. Groundwater monitoring wells MW-11 and MW-11D were installed along the eastern side,
and groundwater monitoring wells MW-12 and MW-12D were installed along the western side.
Groundwater contamination has migrated beyond the relevant point of compliance for this area.

For the closed Phase I area, Greenway Waste Solutions at North Meck, LLC installed a landfill gas
remediation system that has been in operation since 2015. This landfill gas system is showing to be
effective. Also, groundwater contamination has migrated beyond the relevant point of compliance and
beyond the property boundary as indicated within the groundwater samples collected from the
groundwater monitoring wells for this area. As a result of the migration of contaminated groundwater,
public water was provided to residences located downgradient of this area and the water supply wells
were made inactive.

During the Fall 2016 semiannual groundwater monitoring event, several groundwater samples were split
and submitted to different laboratories for comparison analyses. The analytical laboratory results
indicated different concentrations of the constituents at quantifiable concentrations between the

different laboratories at the different dates of collection. Greenway Waste Solutions at North Meck, LLC
requested a meeting with NC Solid Waste Section representatives to discuss the comparison analyses, and
as a result, a meeting was held on February 10, 2017.

As discussed during the meeting, even though different concentrations of the constituents have been
presented, the analytical results are consistent with the fact that:
 groundwater contamination is confirmed beyond the landfill’s relevant point of compliance for
both the Infill area and the closed Phase I area;
 groundwater contamination is continuing to migrate horizontally and vertically in both the Infill
area and the closed Phase I area; and
 the entire landfill continues to be in violation of 15A NCAC 2L .0202.

Based upon the mentioned technical reasons above and in accordance with 15A NCAC 13B .0545(c), the
landfill is required to remain in the Assessment Monitoring Program and both areas of the landfill (Infill
and closed Phase I) are subject to the most protective rule, 15A NCAC 13B .0545. In addition, please
continue to split groundwater samples for at least the next three semiannual groundwater monitoring
events (Spring 2017, Fall 2017, and Spring 2018) to confirm the results of the Fall 2016 semiannual
groundwater monitoring event and to determine any seasonal trends.

Greenway Waste Solutions at North Meck, LLC must take all necessary steps to ensure the protection of
public health and the environment. In accordance with 15A NCAC 13B .0545(b)(10) and 15A NCAC
13B .0545(c), please begin the groundwater corrective action process by submitting an Assessment of
Corrective Measures for the landfill (to include both areas) within 180 days (six months) of receipt of this
letter. Please also contact Sarah Rice, Solid Waste Section Compliance Officer, regarding additional
financial assurance requirements.

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

Sincerely,

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

cc sent via email: Ellen Lorscheider, Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Teresa Bradford, Environmental Senior Specialist
Sarah Rice, Compliance Officer
Ed Mussler, Permitting Branch Head
Perry Sugg, Permitting Hydrogeologist
Larry Frost, Permitting Engineer

John Brown, Griffin Brothers
Ed Stephens, CEC, Inc.
Scott Brown, CEC, Inc.
Joe Hack, Mecklenburg County Solid Waste Management
Charles Dial, Mecklenburg County Solid Waste Management
Jack Simoneau, Town of Huntersville