7407_CandDLandfillInc_20170130_SourceDemonstration-ASDResponse_DIN27312

January 30, 2017

Sent Via Email - [e-mail]

Mr. Wayne Bell
EJE Recycling & Disposal, Inc.
802 Recycling Lane
Greenville, NC 27834

Re: Source Demonstration Groundwater Assessment Phase 1
C&D Landfill, Inc.
Pitt County
Solid Waste Permit Number 74-07
DIN 27312

Dear Mr. Bell:

The NC Solid Waste Section has completed a review of the Source Demonstration Groundwater
Assessment Phase 1 dated December 2, 2016 (DIN 27311) submitted on your behalf by SCS Engineers, PC
for the C&D Landfill, NC Solid Waste Permit Number 7407. The landfill has been in the Assessment
Monitoring program since 2009 pursuant to 15A NCAC 13B .0545, and the alternate source demonstration
was submitted in accordance with 15A NCAC 13B .0545(b)(8) and in response to consistent groundwater
exceedances at the landfill.

The volatile organic compounds of concern that have exceeded the NC 2L regulatory groundwater
standards within the groundwater monitoring wells associated with both the closed Phase 1 (since 2007)
and the active Phase 2 (since 2012) have been Benzene and Vinyl Chloride. Other volatile organic
compounds, semi-volatile organic compounds, pesticides, and herbicides have been detected at
quantifiable concentrations within the groundwater monitoring wells, but below the NC 2L regulatory
groundwater standards. In addition, inorganic constituents have exceeded the NC 2L regulatory
groundwater standards within the groundwater monitoring wells at both Phases of the landfill.

Based upon the continued groundwater contamination, on March 22, 2016, the NC Solid Waste Section
approved the Source Demonstration Work Plan Groundwater Assessment Phase 1 dated March 17, 2016
(DIN 25789 and 25790). The work plan included subsurface soil sampling at specific locations. A PID meter
was used to scan the soil samples, and the soil samples were analyzed. Also, past uses of the area included
agricultural, recreational, and a hurricane staging debris site for demolition debris after Hurricane Floyd.

The analytical results from the alternate source demonstration (DIN 27311) indicated that the following
constituents were detected at quantifiable and low concentrations within the soils: Acetone, Benzene,
Methyl ter butyl ether (MTBE), 2-Butatone (MEK), Ethylbenzene, N-Propylbenzene, Styrene, and Toluene.

Acetone was detected within all of the soil samples including the ‘clean’ area where the background
sample was collected, however, Acetone has not been detected within any of the groundwater samples.
Also, Vinyl Chloride was not detected within any of the soil samples, and has been detected within the
groundwater samples.

Within the alternate source demonstration, the landfill requested to revert from Assessment Monitoring
back to Detection Monitoring and to monitor only for Appendix I constituents. In addition, the landfill
requested that the trends of both Benzene and Vinyl Chloride continue to be monitored, and if further
Appendix I data shows different trends from those now recognized, further recommendations will be
considered.

Based upon the following:
 the technical review of the Source Demonstration Work Plan Groundwater Assessment Phase 1
(focusing on the groundwater constituents of concern Benzene and Vinyl Chloride);
 the metal exceedances within the Phase 1 groundwater monitoring wells;
 the detections of Appendix II constituents within the Phase 1 groundwater monitoring wells; and
 the metal and volatile organic compound exceedances within the Phase 2 groundwater
monitoring wells,
C&D Landfill, Inc. has failed to demonstrate that the presence and increase in the constituent
concentrations are the result of a source other than the construction and demolition landfill. The NC Solid
Waste Section does not approve the alternate source demonstration at this time.

In accordance with 15A NCAC 13B .0545, Phase 1 of the landfill is required to remain in the Assessment
Monitoring Program and please continue conducting Appendix II (of 40 CFR Part 258) monitoring. In
addition, in accordance with 15A NCAC 13B .0545(b), please initiate Assessment Monitoring for Phase 2
of the landfill by submitting an Assessment Monitoring Work Plan for Solid Waste Section approval within
30 days of receipt of this letter. The Work Plan should include conducting Appendix II monitoring during
the next semiannual monitoring event. The initial Appendix II monitoring event for Phase 2 should include
all of the groundwater monitoring wells associated with Phase 2. A request may be made to reduce the
number of groundwater monitoring wells sampled for Assessment Monitoring for subsequent semiannual
monitoring events following the initial Appendix II monitoring for Phase 2 based upon the initial
monitoring event results.

In accordance with 15A NCAC 13B .0545(b)(10) and 15A NCAC 13B .0545(c), please begin the groundwater
corrective action process by submitting an Assessment of Corrective Measures for the landfill within 180
days (six months) of receipt of this letter. Please also contact Sarah Rice, Solid Waste Section Compliance
Officer, regarding additional financial assurance requirements.

In accordance with 15A NCAC .0544(d), quarterly landfill gas monitoring is required at both phases of the
landfill. Quarterly landfill gas monitoring records should be maintained and kept within the landfill
operating record.

C&D Landfill, Inc. must take all necessary steps to ensure the protection of public health. Given the right
conditions, landfill gases have the potential to be a significant public health hazard. The dynamics that
influence landfill gas movement and migration vary, and landfill gas concentrations can fluctuate widely
depending on the conditions at the time they were measured and what meter is used to measure them.
Landfill gas also has the potential to impact groundwater in a vapor to aqueous phase transfer.

As a result, within 30 days of receipt of this letter, please provide a revised landfill gas monitoring plan for
both phases of the landfill. The most recent landfill gas monitoring approved was titled Appendix 4A
Landfill Gas Monitoring Plan (DIN 22473) and was located with the Updated PTC Application for Phase 2B
dated November 2014. The new landfill gas monitoring plan should include the installation of permanent
landfill gas monitoring wells with stopcock valves. The NC Solid Waste Section understands that the depth
to groundwater in the vicinity of some of the current bar-hole punch locations is not sufficiently deep
enough to install permanent landfill gas monitoring wells with screens that will more accurately monitor
and detect potential landfill gas generation and migration. However, please try to find locations as close
to the bar-hole punch locations as feasible with sufficient groundwater depth to install permanent landfill
gas monitoring wells.

Please also use the appropriate landfill gas monitoring equipment to conduct quarterly monitoring for
both methane and hydrogen sulfide (a flammable gas associated with the breakdown of construction and
demolition waste). The current landfill gas monitoring meter being used at the landfill is the QRAE II. That
meter is specifically designed to be used for confined space entry and indoor air quality and not for
monitoring landfill gases within landfill gas monitoring wells or bar-hole punches. Therefore, landfill gases
are not being accurately measured at this landfill.

If you have any questions or concerns regarding this letter, please feel free to contact me by phone at
828.296.4706 or by email at [e-mail]. Thank you in advance for your anticipated
cooperation with these matters.

Sincerely,

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

cc sent via email: Judson Whitehurst, EJE Recycling & Disposal, Inc.
Jason Watkins, Field Operations Branch Head
Drew Hammonds, Eastern District Supervisor
Ray Williams, Environmental Senior Specialist
Sarah Rice, Compliance Officer
Ed Mussler, Permitting Branch Head
Elizabeth Werner, Permitting Hydrogeologist
Pat Backus, Permitting Engineer
Michael Cobb, SCS Engineers, PC