7407_CandDLandfillInc_20170316_GWLFGResponsePhase_DIN27526

March 16, 2017

Sent Via Email - [e-mail]
Mr. Judson Whitehurst
President
EJE Recycling & Disposal, Inc.
802 Recycling Lane
Greenville, NC 27834

Sent Via Email - [e-mail]
Mr. Wayne Bell
Landfill General Manager
EJE Recycling & Disposal, Inc.
802 Recycling Lane
Greenville, NC 27834

Re: Groundwater Exceedances and Landfill Gas Monitoring
C&D Landfill, Inc.
Pitt County
Solid Waste Permit Number 74-07
DIN 27526

Dear Mr. Whitehurst and Mr. Bell:
EJE Recycling & Disposal, Inc. must take all necessary steps to ensure the protection of public health and
the environment. Based upon the historical and current groundwater exceedances and the lack of
permanent landfill gas monitoring wells to accurately measure landfill gas at Phase 1 and Phase 2 (the
November 2014 Landfill Gas Monitoring Plan is no longer valid), the Solid Waste Section sent a letter dated
January 30, 2017 and required EJE Recycling & Disposal, Inc. to conduct additional activities at the C&D
Landfill, Inc., Solid Waste Permit Number 7407.

The following has occurred since the January 30, 2017 letter was sent:
 Per your environmental consultant’s request, on February 2, 2017, a conference call was
conducted with Solid Waste Section representatives (Jason Watkins, Elizabeth Werner, and
Jaclynne Drummond) to discuss the January 30, 2017 letter;
 On March 2, 2017, your environmental consultant provided an email to a Solid Waste Section
representative (Jaclynne Drummond) stating that a response to the letter will be provided within
the 30-day time frame (March 3, 2017);
 On March 7, 2017, a Solid Waste Section representative (Jaclynne Drummond) sent an email to
your environmental consultant and copied a EJE Recycling & Disposal, Inc. representative (Wayne
Bell) requesting the status of the submittal of the Assessment Monitoring Plan and the Landfill
Gas Monitoring Plan since they have not been received;

 On March 7, 2017, a Solid Waste Section representative (Jaclynne Drummond) received an email
response from your environmental consultant stating that it will be completed that day (March 7,
2017);
 On March 9, 2017, your environmental consultant provided a proposed one-page sampling list
with a site figure (not a monitoring plan) in an email to a Solid Waste Section representative
(Jaclynne Drummond) and requested a response to the sampling list. In addition, within that same
email, your environmental consultant proposed to install permanent soil vapor sampling probes
in lieu of permanent landfill gas monitoring wells;
 On March 9, 2017, a Solid Waste Section representative (Jaclynne Drummond) responded to the
email and copied a EJE Recycling & Disposal, Inc. representative (Wayne Bell) stating the following:
the proposed sampling list will not be approved; since site conditions have changed, the October
4, 2012 letter where monitoring frequencies were approved is no longer valid; and permanent
landfill gas monitoring wells with stopcock valves can be installed in certain locations at the landfill
based upon the groundwater elevations so the Solid Waste Section would be amenable to a
combination of the installation of landfill gas monitoring wells and soil vapor sampling probes
using the proper monitoring equipment to obtain accurate methane gas and hydrogen sulfide
results; and
 On March 10, 2017, a Solid Waste Section representative (Jaclynne Drummond) had a phone
conversation with your environmental consultant regarding additional questions about the March
9, 2017 emails and the January 30, 2017 letter.

An Assessment Monitoring Plan and a Landfill Gas Monitoring Plan were to be submitted to the Solid
Waste Section within 30 days of January 30, 2017 for Solid Waste Section review. To date, the Solid Waste
Section has not received the plans.

If the plans are not submitted, C&D Landfill, Inc. may be entered into Tiered Enforcement to achieve
compliance with penalties up to $15,000 per day for each violation of the Solid Waste Laws, Regulations,
Conditions of a Permit, or Order under Article 9 of Chapter 130A of the N.C. General Statutes and may
also be subject to other enforcement actions including injunction from operation and any such further
relief. If you have any questions, please contact me by email at [e-mail] or by
phone at 828.296.4706.

Sincerely,

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

cc sent via email: Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Drew Hammonds, Eastern District Supervisor
Ray Williams, Environmental Senior Specialist
Elizabeth Werner, Permitting Hydrogeologist
Pat Backus, Permitting Engineer
Sarah Rice, Compliance Officer