6301_MooreMSWLF_GWCA_DIN28498_20170928

September 28, 2017

Sent Via Email - [e-mail]
Mr. Chad Beane
Moore County Solid Waste
P.O. Box 1927
Carthage, North Carolina 28327

Re: Groundwater Corrective Action and Landfill Gas Corrective Action
Closed and Unlined Moore County MSW Landfill
Moore County
Solid Waste Permit Number 6301-MSWLF-1979
DIN 28498

Dear Mr. Beane:

Moore County (County) submitted a Corrective Action Evaluation Report dated May 15, 2012 (DIN 17039) to
summarize the ongoing passive groundwater corrective action that has been implemented since 2006 at the
closed and unlined Moore County MSW Landfill for groundwater exceedances of volatile organic compounds
(VOCs). Within the 2012 Corrective Action Evaluation Report, the County proposed to continue implementing
Monitored Natural Attention (MNA) for an additional five years and to implement the Contingency Plan
presented within the Assessment of Corrective Measures report. The Contingency Plan specified the County
would implement an active landfill gas remedy for the landfill. The Solid Waste Section (Section) approved the
2012 Corrective Action Evaluation Report on August 30, 2012 (DIN 17133). On May 16, 2013, the County
submitted a document titled Contingency Plan Update and Implementation Plan - Revised (DIN 19055). Passive
landfill gas vents (GV-30, GV-31, and GV-32) were installed and the document stated that if the landfill gas
vents were not effective in both reducing the migration of landfill gas and the constituent concentrations in
the groundwater within one year of implementation, the installed landfill gas vents would be converted to an
active landfill gas system. The Section approved the Contingency Plan Update and Implementation Plan –
Revised on June 5, 2013 (DIN 19096). As a follow up the County submitted a document titled Contingency Plan
Update Evaluation dated March 16, 2015 (DIN 24035). The County requested that the evaluation be delayed
until after the October 2015 water quality monitoring event. The Section approved the County’s request on
March 24, 2015 (DIN 24038).

To date, the Section has not received an updated evaluation and the County is continuing to implement passive
groundwater corrective action and passive landfill gas corrective action at the closed and unlined MSW Landfill.
The County (1) has not implemented an active landfill gas system as stated and approved in 2012 at the closed
and unlined MSW Landfill to effectively reduce the landfill gas concentrations, and (2) has not selected a
groundwater corrective action remedy that would restore groundwater quality at and beyond the MSW
Landfill’s compliance boundary, would effectively reduce the overall groundwater contamination at the MSW
Landfill, and would control the migration of contaminated groundwater to prevent unacceptable impacts from
the MSW Landfill.

The current passive groundwater selected remedy that was implemented in 2006 does not appear to be
working as effectively as designed. The continued groundwater exceedances at the closed and unlined MSW
Landfill are a violation of the following: 15A NCAC 02L .0103, 15A NCAC 02L .0106, 15A NCAC 02L .0107, 15A
NCAC 02L .0108, 15A NCAC 02L .0202, 15A NCAC 13B .0503(2), 15A NCAC 13B .0601, NCGS 143-214.1, and the
landfill’s December 20, 1996 closure letter. As noted in the September 28, 2017 letter (DIN 28497) responding
to the County’s submittal of an Alternate Source Demonstration at the active and unlined C&D Landfill (Permit
Number 6301-CDLF-1992), the MSW Landfill may or may not be contributing to the VOCs being detected at the
active and unlined C&D Landfill.

Therefore, the Section is requiring the implementation of the County’s corrective action Contingency Plan of
an active landfill gas system as approved in 2012, the selection of an additional groundwater corrective action
remedy, and two new groundwater corrective action contingency plans. Within 90 days of receipt of this letter,
please submit a completed groundwater corrective action application selecting a remedy and two contingency
plans for this landfill. The North Carolina Solid Waste .0500 Groundwater Corrective Action Application is
conveniently located on the Section’s webpage at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/NCSW_0500_GroundwaterCAApplicati
on.pdf.

Also, within 90 days of the approval of the selected remedy, a submittal of a Groundwater Corrective Action
Plan (CAP) Addendum and an implementation schedule will be required. The Section will then review the
submitted Groundwater Corrective Action Plan (CAP) Addendum and approve, or request additional
information prior to its implementation.

Moore County is responsible for addressing both landfill gas exceedances and groundwater exceedances.
Inorganic groundwater exceedances at the MSW Landfill will still need to be addressed to ensure the protection
of public health and the environment. Please plan your County’s budget accordingly to address these critical
post closure care problems at the closed and unlined MSW Landfill.

Failure to 1) implement an active landfill gas system, 2) submit the North Carolina Solid Waste .0500
Groundwater Corrective Action Application within 90 days of receipt of this letter, 3) submit a Groundwater
Corrective Action Plan (CAP) Addendum within 90 days of approval of the new selected remedy, and 4)
implement the approved Groundwater Corrective Action Plan (CAP) Addendum will result in Moore County
entering 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 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 anticipated cooperation
with these matters.

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

cc sent via email: Ellen Lorscheider, Section Chief
Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Drew Hammonds, Eastern District Supervisor
Amanda Freeman, Senior Environmental Specialist
Elizabeth Werner, Permitting Branch Hydrogeologist
Donna Wilson, Permitting Branch Engineer
Ming Chao, Permitting Branch Engineer
Wayne Vest, Moore County Manager
Randy Gould, Moore County Public Works Director
Ben Draper, Golder Associates NC, Inc.
Rachel Kirkman, Golder Associates NC, Inc.