5503_LincolnCDLF_ASDResponse_DIN25847_20160331

PAT MCCRORY
Governor DONALD R. VAN DER VAART
Secretary MICHAEL SCOTT
Acting Director
March 31, 2016

Sent Via Email - [e-mail]
Mr. Mark Bivins
Lincoln County Solid Waste
5291 Crouse Road
Crouse, NC 28033

Re: Alternate Source Demonstration
Lincoln County C&D Landfill
Lincoln County
Solid Waste Permit Number 55-03
DIN 25847

Dear Mr. Bivins:

The Solid Waste Section has completed a review of the Alternate Source Demonstration dated March 11,
2016 (DIN 25846) and submitted on behalf of Lincoln County by S&ME, Inc. for the active Lincoln County
C&D Landfill, Solid Waste Permit Number 55-03. The Alternate Source Demonstration was submitted in
response to consistent PCE exceedances within groundwater monitoring well MW-28 and in accordance
with 15A NCAC 13B .0545. This groundwater monitoring well is located in a buffer area between the C&D
Landfill and the unlined closed .0500 MSW Landfill known as Area E. Detection Monitoring is currently
being conducted at the C&D Landfill.

Based upon Alternate Source Demonstration, groundwater flow directions indicate that the buffer area
and the C&D Landfill receive a partial amount of flow from beneath Area E, and groundwater monitoring
well MW-28 is located hydraulically upgradient from the C&D Landfill. In addition, PCE has been
historically detected downgradient and side gradient of Area E, and PCE was detected in each of the
groundwater monitoring wells during this study within the buffer area. Finally, volatile organic
compounds typically detected within the Area E groundwater monitoring wells were also detected in the
buffer area groundwater monitoring wells. Therefore Lincoln County concludes that the PCE
concentrations present in groundwater monitoring well MW-28 are associated with the migration of
contaminants from the unlined closed .0500 MSW Landfill known as Area E and not from the C&D Landfill.

As a result, the Alternate Source Demonstration is approved as described. The C&D Landfill may remain
in the Detection Monitoring program in accordance with 15A NCAC 13B .0545. However, based upon the
study, action will be required at the unlined closed .0500 MSW Landfill.

Volatile organic compounds have been consistently and historically detected in concentrations exceeding
the regulatory groundwater standards within groundwater monitoring wells that are located beyond the
unlined closed .0500 MSW Landfill’s compliance boundary. The groundwater exceedances are also a
violation of the following: 15A NCAC 02L .0103, 15A NCAC 02L .0106, 15A NCAC 02L .0107, 15A NCAC 02L
.0108, 15A NCAC 02L .0202, 15A NCAC 13B .0503(2), 15A NCAC 13B .0601, NCGS 143-214.1, and the
December 21, 1995 Closure Letter.

State of North Carolina | Environmental Quality | Waste Management
Asheville Regional Office | 2090 US Highway 70 | Swannanoa, NC 28778
828 296 4500 T

Lincoln County will be required to select a remedy to restore groundwater quality at and beyond the
unlined closed .0500 MSW landfill’s compliance boundary, to control the migration of contaminated
groundwater to prevent unacceptable impacts to the adjacent surface waters and to the adjacent
properties, and to reduce the overall groundwater contamination at the landfill. Within one year of receipt
of this letter, please submit a completed groundwater corrective action application selecting a remedy
and two contingency plans for this facility. The North Carolina Solid Waste .0500 Groundwater Corrective
Action Application is conveniently located on our Solid Waste Section Environmental Monitoring webpage
at:

https://ncdenr.s3.amazonaws.com/s3fs-public/Waste%20Management/DWM/SW/Forms/NCSW_0500_
GroundwaterCAApplication.pdf.

After the Solid Waste Section approves the selected remedy and the two contingency plans in writing, a
submittal of a Groundwater Corrective Action Plan (CAP) will be required. The Solid Waste Section will
review the submitted Groundwater Corrective Action Plan (CAP) and approve, or request additional
information prior to its implementation. If you have any questions regarding this letter, please feel free
to contact me at 828.296.4706 or by email at [e-mail]. Thank you for your
cooperation with these matters.

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

cc sent via email: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Kim Sue, Senior Environmental Specialist
Perry Sugg, Permitting Branch Hydrogeologist
Larry Frost, Permitting Branch Engineer
Ed Henriques, S&ME, Inc.
Julie Robertson, S&ME, Inc.