1203_BurkeJohnsRiverCDLFOverMSWLF_AlternateSelectedRemedyCA_DIN28395_20170815

2211 W. Meadowview Rd., #101
Greensboro, NC 27409
tel: [phone]
fax: [phone]
www.JoyceEngineering.com

August 15, 2017

Ms. Jackie Drummond
Compliance Hydrogeologist
NCDEQ/Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646

RE: Proposed Alternate Remedy and Schedule
Burke County – Johns River Waste Management Facility
Permit No. 12-03 - C&D-over-MSWLF
JOYCE Project No. 277.1801.12, Task 01

Dear Jackie:

On behalf of Burke County, Joyce Engineering (JOYCE) is submitting this proposed
alternate remedy for groundwater corrective action at the Johns River Waste Management
Facility, including a proposed schedule to implement the new remedy. This letter is in response
to the letter dated March 27, 2017, from Perry Sugg of the North Carolina Department of
Environmental Quality (NCDEQ), which stated:

Based upon the County’s approved Addendum to Corrective Action Plan dated August 23, 2013 (DINs
19615, 19616, and 19655) and the County’s approved Revised November 2008 Burke County John’s River
Waste Management Facility Corrective Action Plan (DINs 6585 and 6681), the selected remedy does not
appear to be working as effectively as designed. Burke County must take all measures necessary to ensure
the protection of public health and the environment. Therefore, in accordance with 15A NCAC 13B
.1637, the Section requests implementation of the County’s corrective action contingency plans. Within 90
days of receipt of this letter, please provide the Section with the proposed alternate remedy and
implementation schedule.

We requested an extension of the due date for our response to July 25th, 2017, which
Perry Sugg approved in an email dated June 12, 2017. The current approved remedies in the
Corrective Action Plan (CAP) and its addendum, as referenced above, are monitored natural
attenuation (MNA) plus phytoremediation for the southern portion of the plume and control of
landfill gas migration for the northeastern part of the plume, between the old landfill and the
C&D expansion.

The approved 2013 CAP Addendum proposed installation of passive gas vents on the
northeast side of the MSW portion of the old C&D-over-MSW landfill. In November 2013,
JOYCE installed seven passive gas vents (GV-1 through GV-7) to implement the CAP
Addendum. In September 2015, four additional passive gas vents (GV-8 through GV-11) were
installed along the top of the landfill as part of closure of the C&D-portion of the C&D-over-
MSW landfill. The locations of these vents are shown on the attached Drawing 13, from the
April 2016 Corrective Action Evaluation Report (CAER). The 2013 CAP Addendum included
Ms. Jackie Drummond
August 15, 2017
Page 2 of 3

the following contingency:

In the event that the proposed passive gas vents prove inadequate to significantly control landfill gas
migration and lessen cross-media impacts to the groundwater, the passive vents may be converted to an
active LFG system with the installation of a gas extraction unit (GEU), connected to the vents through a
subsurface piping system.

In response to the NCDEQ request to implement the contingency remedy, Burke County
proposes to design and install a gas extraction system similar to that proposed in the 2013 CAP
Addendum. We will begin by performing a pilot test with a temporary GEU to determine the
optimum flow rates, blower size, pipe dimensions, etc., in order to properly design a more
permanent system. Based on the pilot test and other factors, we will decide which vents to
connect to a proposed system, with a possible contingency to add additional vents in the future.
We will also develop design specifications and drawings for a gas extraction system. We will
then submit these plans as part of a new addendum to the CAP. After the new CAP Addendum
is approved, we will begin bid-phase services for purchase and installation of the GEU and
associated pipping, well heads, condensate tank, etc. We propose the following implementation
schedule for this remedy:

Activity Schedule Estimated Timeframe
Plan & implement a GEU pilot study Within 90 days of approval of this
proposed remedy by the NCDEQ October 2017
Design the gas extraction system and prepare &
submit a CAP Addendum to NCDEQ
Within 90 days of completing the
pilot study January 2018
Prepare construction plans and bid documents Within 60 days of approval of the
CAP Addendum by the NCDEQ April 2018
Obtain approval of Burke County Board of
Commissioners to go to bid
Within 120 days of approval of the
CAP Addendum by the NCDEQ June 2018
Obtain bids for purchase and installation of the
gas extraction system Within 45 days of Board approval July 2018
Select contractor, negotiate contract, and get
Board of Commissioners' approval of the contract Within 45 days of obtaining bids September 2018
Begin construction/installation of the system Within 60 days of Board Approval November 2018
Complete construction/installation of the system
and bring online
Within 45 days of beginning
Construction December 2018
Prepare Gas Extraction System Construction
Report with construction drawings and
specifications and submit to NCDEQ
Within 30 days of completing
Construction January 2019

Ms. Jackie Drummond
August 15, 2017
Page 3 of 3

If you have any questions regarding the proposed remedy or schedule, please contact me
at [phone]. Thank you.

Sincerely,
JOYCE ENGINEERING

Van Burbach, Ph.D., P.G.
Sr. Technical Consultant

Attachment: Drawing 13 from 2016 CAER

cc: Perry Sugg, NCDEQ
Miles Champion, Burke County
Keith Farris, Burke County