1403_FoothillsMSWLF_AssessmentResponse_DIN28687_20171212

December 12, 2017

Sent Via Email - [e-mail]
Mr. Derek Bouchard
Environmental Manager
Republic Services of NC LLC
2800 Cheraw Road
Lenoir, North Carolina 28645

Re: Response to October 11, 2017 Alternate Source Demonstration Technical Review
Benzene and Vinyl Chloride in MW-2R
Foothills Regional Subtitle D MSW Landfill
Caldwell County
Solid Waste Permit Number 1403-MSWLF-1998
DIN 28687

Dear Mr. Bouchard:

The Solid Waste Section (Section) has completed a review of the Response to October 11, 2017 Alternate
Source Demonstration Technical Review Benzene and Vinyl Chloride in MW-2R dated November 21, 2017
(DIN 28686) and submitted by Republic Services of NC LLC (Republic) for the lined Foothills Regional
Subtitle D MSW Landfill, Solid Waste Permit Number 1403-MSWLF-1998. In the October 11, 2017 letter
from the Section to Republic (DIN 28532), the landfill was required to initiate Assessment Monitoring in
accordance with 15A NCAC 13B .1634.

Republic is proposing to sample the groundwater monitoring wells MW2R, MW3R2, and MW9 for the
entire 40 CFR Part 258 Appendix II constituent list during the next scheduled sampling event in mid-
January of 2018. After the January 2018 sampling event, the scope of additional assessment activities will
be evaluated, and a plan will be submitted within 90 days of receiving the final laboratory reports from
the January 2018 event.

Based upon the information provided in the Response to October 11, 2017 Alternate Source
Demonstration Technical Review Benzene and Vinyl Chloride in MW-2R, the Section does not approve the
proposal to sample only the three groundwater monitoring wells for the first Assessment Monitoring
event. To be protective of public health and the environment, all groundwater monitoring wells at the
landfill shall be sampled and analyzed for the entire 40 CFR Part 258 Appendix II constituent list during
the initial Assessment Monitoring (Appendix II) sampling event. After the initial Assessment Monitoring
sampling event, for any constituent detected in the downgradient groundwater monitoring wells as the
result of the Appendix II analysis, a minimum of three additional independent samples from each
groundwater monitoring well (background and downgradient) shall be collected and analyzed to establish
background for the new detected constituents. Also, after the initial Assessment Monitoring sampling

event, the Division may specify, as provided for in 40 CFR 258, an appropriate subset of groundwater
monitoring wells to be sampled and analyzed for Appendix II constituents during Assessment Monitoring,
and the Division may delete, as provided for in 40 CFR 258, any of the Appendix II monitoring parameters
if it can be shown that the removed constituents are not reasonably expected to be in or derived from the
waste contained in the unit.

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, Division Deputy Director
Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Deb Aja, Western District Supervisor
C.T. Gerstell, Senior Environmental Specialist
Christine Ritter, Permitting Branch Hydrogeologist
Allen Gaither, Permitting Branch Engineer
Roger Watts, Republic Services
Van Burbach, Joyce Engineering