1403_Caldwell_Republic_FoothillsSubtitleD_MSWLF_DesignHydro_DIN28789_20180308

March 8, 2018

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

Re: Design Hydrogeologic Report Phase 5 (Cells No. 6, 7, and 8B)
Foothills Regional Subtitle D MSW Landfill
Caldwell County
Solid Waste Permit Number 1403-MSWLF-1998
DIN 28789

Dear Mr. Bouchard:
The Solid Waste Section (Section) has completed an initial technical review of the Design Hydrogeologic
Report Phase 5 (Cells No. 6, 7, and 8B) dated October 20, 2017 (DIN 28762). The document was received
in the Raleigh Central Office on October 30, 2017 and was later mailed and received in the Asheville
Regional Office on February 5, 2018. The Design Hydrogeologic Report Phase 5 (Cells No. 6, 7, and 8B)
was submitted on your behalf by Bunnell-Lammons Engineering, Inc. for the Foothills Regional Subtitle D
Landfill, Solid Waste Permit Number 1403-MSWLF-1998. To date, a Permit to Construct Application has
not been submitted to the Section.

Based upon the initial technical review, please have your consultant respond and address the following in
a revised Design Hydrogeologic Report Phase 5 (Cells No. 6, 7, and 8B):
• Please separate the Environmental Monitoring Plan (EMP) into two separate documents, the
Water Quality Monitoring Plan (including groundwater and surface water) and the Landfill Gas
Monitoring Plan.

• For ease of review for the public, the Section recommends designating both the review boundary
(early detection) and the compliance boundary for the groundwater monitoring wells on Figure
3, Figure 5, and Figure 8 in the Design Hydrogeologic Report Phase 5 and on Figure 2 in both the
Water Quality Monitoring Plan and the Landfill Gas Monitoring Plan.

• When final design grades are established, please provide a separate Table designating the vertical
separation in accordance with 15A NCAC 13B .1624(b)(4).

• For the protection of public health and the environment, the Section recommends including the
following current information within a two-mile radius of the landfill: all known private water
supply well users and all potential and existing sources of groundwater and surface water
contamination.

• Water Quality Monitoring Plan
1) The new groundwater monitoring wells, MW-12, MW-13, MW-14, and MW-15,
are proposed to be installed for Phase 5. In the text, these proposed monitoring
wells are located at the relevant point of compliance (compliance boundary) in
accordance with 15A NCAC 13B .1631(a)(2) and 15A NCAC 2L .0107. However,
the proposed locations would not provide an ‘early detection’ of any release as
described in 15A NCAC 13B .1623(b)(3)(C) and 15A NCAC 13B .1631(d)(1). To be
protective of public health and the environment, the new proposed groundwater
monitoring wells should be installed midway between the waste boundary and
the relevant point of compliance (compliance boundary) in accordance with 15A
NCAC 2L .0108. Please also ensure the text matches the approximate locations
of the groundwater monitoring wells on the Figures.

2) In 3.1.5, please provide the following: the rule reference to 15A NCAC 13B .1632(i)
regarding 120 days; please include the review boundary (early detection) in
addition to the relevant point of compliance in the text; and please include
Interim Maximum Allowable Concentration (IMAC) in addition to the 15A NCAC
2L .0202 reference. For your reference, the IMAC table is located at
https://files.nc.gov/ncdeq/documents/files/IMAC%20table_5-22-13.pdf.

3) In 3.1.7.1, please include turbidity to the list of field parameters for consistency.

4) In 3.1.7.3, please include Interim Maximum Allowable Concentration (IMAC) in
addition to the 15A NCAC 2L .0202 reference; please remove ‘at the relevant
point of compliance’ at the end of the first sentence to be consistent with 15A
NCAC 13B .1634(a); and please include the new 14 Day Notification of
Groundwater Protection Standard Exceedance Form. For your reference, the 14
Day Form is in reference to 15A NCAC 13B .1633(c)(1) and is located at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operati
ons/Environmental%20Monitoring/14-
Day%20Groundwater%20Protection%20Standard%20Exceedance%20Notificatio
n%20Form%20and%20Guidance.pdf).

5) In 3.1.8, number one, please change ‘resume’ to ‘return’ to be consistent with the
rule reference 15A NCAC 13B .1634(e). In number two, the Section recommends
including the following language for clarification, ‘submit an Assessment
Monitoring Plan to characterize the nature and extent of the release’, and please
also include the language, ‘initiate an Assessment of Corrective Measures,
conduct a public meeting, submit a North Carolina Solid Waste Groundwater
Corrective Action Permit Modification Application selecting a remedy, and submit
a Corrective Action Plan in accordance with the NC Solid Waste Section Guidelines
for Corrective Action at Solid Waste Management Facilities’. For your reference,
the Groundwater Corrective Action Permit Modification Application is located at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operati
ons/Environmental%20Monitoring/NCSWGWCAPermitMod_20080215.pdf) and
the Corrective Action Guidelines are located at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operati
ons/Environmental%20Monitoring/SWCorrectiveMeasuresGuidance.pdf.

6) In 3.1.9, please include the Solid Waste Section Guidelines For Groundwater, Soil,
and Surface Water Sampling. For your reference, the Guidelines are located at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operati
ons/Environmental%20Monitoring/SolidWasteSamplingGuidance.pdf.

7) In 3.1.10, please provide additional information regarding the statistical
evaluations.

8) In 3.3.2, please include a USGS Topographic Map to the list, and please change
number one to a’ potentiometric surface map for the current sampling event that
also includes surface water sampling locations’. Please also ensure the report
submittal method is consistent throughout the document (Email or CD-ROM).

• Landfill Gas Monitoring Plan
1) In 4.3, number three, to be protective of public health, after observations of areas
around and beyond stressed vegetation are monitored with a bar hole punch to
determine if landfill gas is migrating, please provide additional information
regarding what the next steps will be after the bar hole punch data is collected.

2) In 4.4, please confirm if the combustible gas indicator, E.G. Gascope (Model 62S),
is currently being used to conduct landfill gas monitoring at the landfill gas
monitoring wells. According to the manufacturer, this meter is specifically
designed to be used for indoor air in structures where methane levels are
expected to be low and not for monitoring landfill gases in landfill gas monitoring
wells.

Please provide the information requested in this letter in revised documents, and then the Section can
complete the technical review of the Design Hydrogeologic Report Phase 5 (Cells No. 6, 7, and 8B). If you
have any questions or concerns, please feel free to contact me by phone at 828.296.4706 or by email at
[e-mail]. Thank you for your cooperation with this matter.

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

cc sent via email: Adam Ulishney, Environmental Compliance Branch Head
Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Allen Gaither, Permitting Engineer
Ed Mussler, Section Chief
Mark Preddy, BLE