1101_Buncombe_MSWLF_UIC_FID1395003_20200331

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ENGINEERING
March 31, 2020
Underground Injection Control Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Attention: Mr. Michael Rogers, P.G.
UIC Program Manager
Subject: Request for Extension of UIC Permit Renewal Application
Old Buncombe County Landfill
Woodfin, North Carolina
DWM Permit No. 1101-MSWLF-1979
DWR UIC Permit No. WI0100353
BLE Project No. J20-14175-03
Dear Mr. Rogers:
Bunnell-Lammons Engineering, Inc. (BLE) is pleased to submit this request to the North Carolina
Department of Environmental Quality (DEQ), Division of Water Resources (DWR), Underground
Injection Control (UIC) Program on behalf of Buncombe County for the closed Buncombe County
Landfill (a.k.a. Old Buncombe County Landfill). This document addresses the requirement for
corrective action evaluation reporting as set forth by the DEQ, Division of Waste Management (DWM)
and for permit renewal and interim evaluation reporting by the DWR. Included herein is a brief
description of the background project information, a general description of our plans and schedule to
issue the project documents.
BACKGROUND INFORMATION
The subject landfill site is located in Buncombe County, North Carolina, approximately five miles north
of the city of Asheville with a physical address of 2726 Riverside Drive in Woodfin, North Carolina.
Buncombe County provides post -closure care for the Pre -Subtitle D MSWLF (unlined) which included
waste units designated Area A through Area D. The landfill stopped receiving waste in September
1997 and is now closed.
Groundwater and surface water monitoring is performed at the site in accordance with a DWM
approved Corrective Action Plan (CAP) dated September 3, 2014 [DIN 21838 (SCS Engineers File No
09204072.06)] and a DWM approved Request for Reduction of MNA Parameters dated November 30,
2016 [DIN 27144 (SCS Engineers File No 09204072.14)]. The facility requires semi-annual
groundwater and surface water monitoring and reporting in accordance with the CAP, et seq. Semi-
annual sampling is typically conducted each April and October and those events are designated
"Spring" and "Fall," respectively.
'5004 Ponders Court, Greenville, SC 29615 t,864.288,1255 H864.288.4430 Ninfo@bleeorp,rom
BLECORP.COM

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Request for Extension of UIC Permit Renewal Application March 31, 2020
Old Buncombe County Landfill, Woodfin, North Carolina BLE Project Number J20-14175-03
As part of the correction action at the facility, Buncombe County applied for, and was granted a permit
for subsurface injection of materials for enhanced bioremediation of VOCs in groundwater. The UIC
Permit (No WI0100353) was transmitted by the DWR on September 11, 2015. The permit issue date
was September 15, 2015 and the permit expires on August 31, 2020 (effective dates).
The UIC permit requires groundwater monitoring and reporting. We understand that the semi-annual
monitoring reports prepared as part of the DWM approved sampling and analysis matrix are sufficient
to meet the monitoring requirements of the UIC permit.
In accordance with approved plans, twenty-eight (28) groundwater monitoring wells and five (5)
surface water locations are sampled and groundwater levels are measured at forty-two (42)
groundwater monitoring wells during each semi-annual event.
We understand that sampling and laboratory analytical services have historically been provided by Pace
Analytical Services, Inc. (Pace) under direct contract with other consultants and/or Buncombe County.
The reporting of the water quality data was performed by others through the Spring 2019 event.
The Corrective Action Plan specifies that a Corrective Action Evaluation Report (CAER) will be
submitted to evaluate the site's remedial progress on a 5-year schedule. Buncombe County has retained
BLE to evaluate the remedial actions at the site and to prepare a CAER for submittal to the DWM.
Additionally, Buncombe County has retained BLE to prepare and submit a renewal application for the
UIC permit. The permit renewal includes a requirement for an Interim Evaluation Report (IER). We
have assumed that the CAER will meet the requirements of the IER and will be submitted to the DWR
in place of the IER as part of the permit renewal application.
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Our objective is to evaluate the remedial progress at the facility and to prepare a CAER and UIC permit
renewal application as required by the DWM and DWR, respectively. Please note that the general
requirements for the CAER are included in the DWM Solid Waste Section (SWS) Guidelines for
Corrective Action Evaluation Reports (undated whitepaper). The requirements for the IER and UIC
permit renewal application are in Part VI — Paragraph S of the permit.
The DWM and DWR have indicated that data must be collected and evaluated to support the lines of
evidence specified above. Therefore, a sampling and analysis matrix and schedule was proposed in the
CAP and adopted in the injection plan which should allow Buncombe County to collect and evaluate
contaminant trends and document geochemical conditions which may be favorable for decay processes
and may contribute to attenuation.
We understand that monitoring for corrective action began in 2014 and included four (4) baseline semi-
annual events over a 2-year period. Subsequent monitoring events from 2016 through 2019 have
included performance monitoring on a modified schedule and matrix. The next monitoring event is
scheduled for Spring 2020. These data have been or will be provided to BLE and review and evaluation
of that data will be part of the reporting and permit renewal application.
BLE will prepare a permit renewal application in accordance with the requirements of the DWR as
specified in the Application for Permit to Construct and/or Use a Well(s) For Injection revised 8-28-
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Request for Extension of UIC Permit Renewal Application March 31, 2020
Old Buncombe County Landfill, Woodfin, North Carolina BLE Project Number J20-14175-03
2019. The existing UIC Permit No. WI0100353 expires on August 31, 2020. In accordance with
Part VIII — Permit Renewal, Buncombe County must submit a permit renewal application 120 days
prior to the expiration date (approximately April 30, 2020).
However, the data from the Spring 2020 event will not be collected until late April 2020 and the
results will not be available until May 2020. Buncombe County will be unable to evaluate the data
from the site to prepare the CAER and permit renewal application by the permit deadline. We have
prepared a schedule (below) which outlines the anticipated timetable.
SCHEDULE
Our anticipated timetable is shown below:
Trend Analyses
4 weeks
Evaluation of Geochemical Data
4 weeks
Draft CAER
2 weeks
Review of Draft CAER by Buncombe County
2 weeks
Preparation and Submittal of Final CAER
1 week
Evaluation of UIC Permit (future plans)
1 week
Draft UIC Permit Renewal Application
3 weeks
Review of Draft Permit Application by Buncombe County
2 weeks
Preparation and Submittal of Final Permit Application
1 week
Project completion 20 weeks
The final project deliverables can be prepared and submitted within approximately 20 weeks after
receipt of the Spring 2020 water quality data (from Pace). Based on the current schedule, the UIC
permit application should be submitted to the DWR by about October 9, 2020.
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Request for Extension of UIC Permit Renewal Application March 31, 2020
Old Buncombe County Landfill, Woodfin, North Carolina BLE Project Number J20-14175-03
CLOSING AND REQUEST FOR EXTENSION
On behalf of Buncombe County, we respectfully request an extension of the permit renewal schedule
with a revised deadline of October 9, 2020. In the interim, all required permit activities will be completed
by Buncombe County as approved. This includes the monitoring and reporting programs specified in
the permit. Therefore, we also request that the UIC permit remain in an active state until the DWR is
able to review the permit renewal application and issue an updated permit.
We appreciate the continued opportunity to work with the DWR and DWM to address regulatory issues
and to develop solutions for corrective action and permitting. If you have any questions, please do not
hesitate to contact us at [phone].
Sincerely,
BUNNELL-LAMMONS ENGINEERING, INC.
&&/ djo"Ot-
Andrew W. Alex der, P.G., RSM ark S. Preddy, P.G.
Senior Hydrogeologist Senior Hydrogeologist
Cc: Mr. Dane Pedersen, Director of Solid Waste — Buncombe County
Ms. Kristy Smith, Solid Waste Manager — Buncombe County
Ms. Jaclynne Drummond — DWM - ARO
Mr. Landon Davidson, P.G. — DWR - ARO
Mr. Andrew Moore, P.G. — DWR - ARO
Ilblegvlsvrllsolidwasteprojectslbuncombe county old lf, ncU4175-03 caer 5 yearlpermit renewahext letterlextension letter
obclf uic permit 14175-03. docx
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