8606_SurryCounty_MSWLF_ASDInorganicsResponse_DIN28119_20170706

July 6, 2017

Sent Via Email - [e-mail]

Mr. Dennis Bledsoe
Surry County Public Works
P.O. Box 1542
Mt. Airy, NC 27030

Re: Alternate Source Demonstration - Metals
Surry County Subtitle D MSW Landfill
Surry County
Solid Waste Permit Number 8606-MSWLF-1998
DIN 28119

Dear Mr. Bledsoe:

The NC Solid Waste Section has completed a review of the Alternate Source Demonstration dated April
21, 2017 (DIN 27391) and submitted on behalf of Surry County by Municipal Engineering Services
Company, P.A. for the Surry County Subtitle D MSW Landfill, Solid Waste Permit Number 8606. 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 26557) and in accordance with
15A NCAC 13B .1633.

Based upon the information provided within the Alternate Source Demonstration, the NC Solid Waste
Section is requiring additional information to be submitted in an Alternate Source Demonstration
Addendum. Within 120 days of receipt of this letter, please submit an Alternate Source Demonstration
Addendum that meets all the criteria described in the guidance document titled 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/NCSWSG
uidelinesForASD2017.pdf).

Within the Alternate Source Demonstration Addendum, please provide the following:
 Provide a professional stamp in the Alternate Source Demonstration Addendum;
 Due to reported turbidity, determine if a new background monitoring well should be installed
and/or 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.
Statistical background concentrations derived from turbid samples may not accurately reflect
background conditions. Therefore, turbid samples will not be accepted to calculate new

background levels. Turbidity measurements must be submitted along with the sample data to
demonstrate whether suspended sediments are playing a role;
 If utilizing UTLs, determine the new groundwater protection standards for the metals of concern
by the distribution hierarchy normal, gamma, lognormal, and nonparametric;
 Identify the outliers. Screen the data sets visually for potential outliers using the box-and-whisker
and Q-Q plots. Then screen the data sets quantitively using Dixon’s or Rosner’s Outlier tests as
specifically identified within the USEPA March 2009 Unified Guidance. If statistical outliers have
been detected, review the values to determine if they should be removed from the data set or
are representative of background and should be retained for statistical analysis. Provide technical
reasons why a statistical outlier should be included or excluded from either groundwater or soil
background data sets; and
 Determine if seasonality plays a role.

Since the landfill is currently in the Assessment Monitoring program in accordance with 15A NCAC
13B .1634, if Surry County chooses not to submit an Alternate Source Demonstration Addendum, the
landfill will be required to conduct additional assessment in regards to the inorganic exceedances and will
be required to initiate the Assessment of Corrective Measures in accordance with 15A NCAC 13B .1634
and .1635.

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
Perry Sugg, Permitting Hydrogeologist
C.T. Gerstell, Environmental Senior Specialist
Allen Gaither, Permitting Engineer
Jonathan Pfohl, MESCO