1107_BuncombeCountyMSW_ASDInorganicExtension_DIN26687_20160823

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August 23, 2016 File No. 09204072.13

Jaclynne Drummond, Compliance Hydrogeologist
North Carolina Department of Environment Quality Asheville Regional Office 2090 U.S. 70 Highway
Swannanoa, NC 28778

Subject: Buncombe County Landfill Permit # 11-07 Appendix I Inorganic Constituent Exceedances Request for Extension

Dear Jackie:
Buncombe County (County) recently received a letter from the Department of Environmental Quality (DEQ) notifying the County that action on the County’s part is required due to
exceedances reported on the metals in the groundwater at the landfill. SCS Engineers, P.C.
(SCS) was contacted by the County to address the issue for them. The letter outlined two
alternatives for the County’s response, which are:
• Initiate an assessment monitoring program, or
• Initiate an Alternate Source Demonstration (ASD).
Since metals in the monitoring wells have been documented on a continuing basis since before waste was placed in the landfill, we feel that an assessment program is justified. With the only
other option available, the County is planning to respond by conducting the ASD.
Since North Carolina doesn’t appear to have guidelines on conducting that activity, SCS will rely
on conducting this process following the Virginia protocols as detailed in the 2012 Submission Instructions for Groundwater Alternate Source Demonstrations at Solid Waste Landfills. This approach involves the use of filtered and non-filtered sampling in the testing program. The
County is required under permit to conduct their groundwater monitoring in the fourth quarter.
The standard semi-annual program will be initiated in October and the sampling will also be
conducted for the filtered samples at that time. There is not sufficient time to conduct the sampling, retrieve the test results, and prepare a demonstration response within the 90 day limit proposed in the letter. Therefore, on behalf of the County, we are requesting an extension until
January 5, 2017.
Thank you for your consideration of this request. Please provide your response to Mr. Ed Hilton,
P.E., Vice President, SCS Engineers, P.C. at the address on the letterhead. Feel free to also call at 407.514.2766 with any questions concerning this request and/or results of the demonstration.

Jaclynne Drummond
08/23 /2016
Page 2

Sincerely,

Brooke Fait, MPH C. Ed Hilton, Jr. P.E.
Project Manager Vice President
SCS ENGINEERS, PC SCS ENGINEERS, PC
CEH/bf

cc : Ellen B. Lorscheider Jason Watkins Jon Creighton, Buncombe County
Donna Cottrell, Buncombe County