5803_MadisonCounty_ASDResponse_DIN28410_20170817

August 17, 2017

Sent Via Email - [e-mail]
Mr. Sam Lunsford
Madison County Solid Waste
271 Craig Rudisill Road
Marshall, NC 28753

Re: Alternate Source Demonstration
Madison County Subtitle D MSW Landfill
Madison County
Solid Waste Permit Number 5803
DIN 28410

Dear Mr. Lunsford:

The Solid Waste Section has completed a review of the Alternate Source Demonstration dated June 9,
2017 (DIN 28409) and submitted on behalf of Madison County by Anchor QEA of North Carolina, PLLC for
the Madison County Subtitle D MSW Lined Landfill, Solid Waste Permit Number 5803. 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 26569) and in accordance with 15A NCAC
13B .1633.

The metals cadmium, cobalt, and vanadium have been detected above the NC regulatory groundwater
standards, and the Alternate Source Demonstration submitted includes a geological review, a total and
dissolved metals groundwater sampling and analyses, and a review of the USGS LURE database sediment
information.

Based upon the information provided within Madison County’s Alternate Source Demonstration, the Solid
Waste Section is requiring additional information to be submitted in a phased approach within 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 NC Solid Waste
Section guidance document titled NC Solid Waste Section Guidance for Alternative Source Demonstration
Submittals for Solid Waste Management Facilities - 2017.

Within the Alternate Source Demonstration Addendum, Madison County should address the following:
• 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 to reduce the impact of suspended sediment.
• Determine if seasonality plays a role.

• Turbid samples will not be accepted to calculate new background levels, and high turbidity has
been documented within the samples collected from the groundwater monitoring wells for this
landfill. Statistical background levels derived from turbid samples may not accurately reflect
background conditions. Statistical background levels should be calculated using monitoring data
where the turbidity values are less than 10 Nephelometric Turbidity Units (NTUs). Turbidity
measurements must be submitted along with the sample data to demonstrate whether
suspended sediments are playing a role, and Madison County should calculate statistical
background concentrations using analytical data from a minimum of 10 groundwater samples
with turbidity values less than 10 NTUs. If there is an insufficient number of previous background
samples with turbidity values less than 10 NTUs or no field notes to verify the turbidity values,
Madison County should establish a temporary groundwater monitoring schedule to collect the
required minimum number of samples from the background well within a two-year period, and
turbidity values should be recorded and submitted to the Solid Waste Section during the
temporary monitoring period.
• If statistical outliers have been detected at the landfill, 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. Based upon the review, provide technical reasons why a statistical outlier
should be included or excluded from groundwater background data sets.
• If Madison County chooses to utilize the Upper Tolerance Limits to establish new background
levels for the constituents of concern, calculations should follow the distribution hierarchy
preference.

Finally, if Madison County 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
Kris Riddle, Environmental Senior Specialist
Allen Gaither, Permitting Engineer
Perry Sugg, Permitting Hydrogeologist
Brian Gant, Anchor QEA