4104_CityHighPoint_KerseyValleyMSWLF_ASDResponse_DIN27899_20170608

June 8, 2017

Sent Via Email – [e-mail]

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

Re: Alternate Source Demonstration
Appendix I Inorganic Constituent Exceedances
City of High Point Kersey Valley Subtitle D MSW Landfill
Guilford County
Solid Waste Permit Number 4104-MSWLF-1991
DIN 27899

Dear Mr. Spencer:

The NC Solid Waste Section has completed a review of the Alternate Source Demonstration dated August
30, 2016 (DIN 27385) and submitted on behalf of the City of High Point by Babb & Associates, P.A. for the
City of High Point Kersey Valley Subtitle D MSW Landfill, Solid Waste Permit Number 4104. The Alternate
Source Demonstration was submitted in response to a NC Solid Waste Section letter titled Appendix I
Inorganic Constituent Exceedances dated August 8, 2016 (DIN 26552) and in accordance with 15A NCAC
13B .1633.

Groundwater monitoring well 4104-MW4 is located hydraulically upgradient of the landfill and
hydraulically downgradient of several commercial and residential properties along Kivett Drive. In
response to the cadmium groundwater exceedances within 4104-MW4 at the landfill, total and dissolved
groundwater samples were analyzed. The results indicated that both concentrations of cadmium were
detected below the laboratory’s method detection limit of 0.36 microgram per liter (ug/L) and below the
15A NCAC 02L .0202 groundwater standard of 2 micrograms per liter (ug/L). The City of High Point
recommends continuation of the Detection Monitoring Program in accordance with 15A NCAC 13B .1633.

Based upon the information provided within the Alternate Source Demonstration for the inorganic
cadmium within groundwater monitoring well 4104-MW4, the NC Solid Waste Section is requiring
additional information to be submitted within an Addendum. Within 120 days of receipt of this letter,
please submit an Alternate Source Demonstration Addendum that meets all the criteria described in the
NC Solid Waste Section Guidelines for Alternate Source Demonstration Submittals for Solid Waste
Management Facilities (https://ncdenr.s3.amazonaws.com/s3fs- public/Waste%20Management/DWM
/SW/Field%20Operations/Environmental%20Monitoring/NCSWSGuidelinesForASD2017.pdf).

Within the Addendum, please provide the following: calculate the new background standard for cadmium
at this landfill; include at least one supplementary line of evidence in addition to the total and dissolved
analyses; and determine if the groundwater sampling procedures should be changed for this landfill
and/or if the groundwater monitoring wells at the landfill should be periodically developed during their
lifetime.

If the City of High Point chooses not to submit an Alternate Source Demonstration Addendum, the landfill
will be required to initiate Assessment Monitoring in accordance with 15A NCAC 13B .1634.

If you have any questions or concerns regarding this letter, please feel free to contact me by email at
[e-mail] or by phone at 828.296.4706. 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: Ellen Lorscheider, Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Deb Aja, Western District Supervisor
Christine Ritter, Permitting Hydrogeologist
John Patrone, Environmental Senior Specialist
Ming Chao Permitting Engineer
Gary Babb, Babb and Associates