7407_CandDLandfillInc_20171020_ACMResponse_DIN28568

October 20, 2017

Sent Via Email - [e-mail]
Mr. Wayne Bell
Landfill General Manager
EJE Recycling & Disposal, Inc.
802 Recycling Lane
Greenville, NC 27834

Re: Assessment of Corrective Measures
C&D Landfill, Inc.
Closed Phase I and Active Phase II
Pitt County
Solid Waste Permit Number 7407
DIN 28568

Dear Mr. Bell:

The Solid Waste Section (Section) has completed a preliminary review of the Assessment of Corrective
Measures (ACM) Report received in separate emails on October 18, 2017, October 19, 2017, and October
20, 2017 and submitted on your behalf by Amec Foster Wheeler (Wood) for Phase I and Phase II of the
C&D Landfill, Solid Waste Permit Number 7407.

In a letter dated January 30, 2017 (DIN 27312), C&D Landfill, Inc. was instructed to begin the groundwater
corrective action process by submitting an Assessment of Corrective Measures for the landfill within 180
days (six months) of receipt of the letter in accordance with 15A NCAC 13B .0545(b)(10) and 15A NCAC
13B .0545(c). The Section received a Request for Time Extension dated August 17, 2017 (DIN 28407), and
the request was approved on August 17, 2017 (DIN 28408). On September 18, 2017, another Request for
Time Extension (DIN 28471) was submitted, and the Section approved that request on September 18, 2017
(DIN 28472).

Based upon a preliminary review of the Assessment of Corrective Measures (ACM) Report, the document
does not meet all of the requirements described in 15A NCAC 13B .0545(c) and does not follow the Section
Corrective Action Guidance Document titled NC Solid Waste Section Guidelines for Corrective Action At
Solid Waste Management Facilities.

Within 10 days of receipt of this letter, resubmit the Assessment of Corrective Measures. The resubmittal
shall include a complete package in one document in electronic pdf format.

The NC Solid Waste Section Guidelines for Corrective Action at Solid Waste Management Facilities is
conveniently located on our Section webpage at:

https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operations/Environmental%20
Monitoring/SWCorrectiveMeasuresGuidance.pdf.

C&D Landfill, Inc. must take all necessary steps to ensure the protection of public health and the
environment. If the Assessment of Corrective Measures is not resubmitted and if the Assessment of
Corrective Measures does not meet all of the requirements described in 15A NCAC 13B .0545(c) and the
Section corrective action guidance document, C&D Landfill, Inc. will be entered into Tiered Enforcement
in order to come into and/or to maintain compliance with the Statutes, Rules, and/or other regulatory
requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an administrative
penalty of up to $15,000 per day may be assessed 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. Further,
the facility and/or all responsible parties may also be subject to enforcement actions including penalties,
injunction from operation of a solid waste management facility or a solid waste collection service and any
such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste
Management Act and Rules.

If you have any questions, please contact me by email at [e-mail] or by phone
at 828.296.4706.

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

cc sent via email: Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Drew Hammonds, Eastern District Supervisor
Ray Williams, Environmental Senior Specialist
Elizabeth Werner, Permitting Hydrogeologist
David Garrett, Amec Foster Wheeler (Wood)