9606_WayneCounty_MSWLF_AppendixIIASDResponse_DIN28125_20170707

July 7, 2017

Sent Via Email – [e-mail]

Mr. Tim Rogers
Wayne County
460B South Landfill Road
Dudley, NC 28333

Re: Alternative Source Demonstration-2-Acetylaminoflourene and Cyanide
Wayne County Subtitle D Lined MSW Landfill
Wayne County
Solid Waste Permit Number 9606-MSWLF-1998
DIN 28125

Dear Mr. Rogers:

The NC Solid Waste Section has completed a review of the Alternative Source Demonstration-2-
Acetylaminoflourene and Cyanide dated June 28, 2017 (DIN 28124) and submitted on behalf of Wayne
County by Municipal Engineering Services Co., P.A. for the Wayne County Subtitle D Lined MSW Landfill,
NC Solid Waste Permit Number 9606-MSWLF-1998. The document was submitted in response to two
Appendix II constituent detections.

Wayne County initiated Assessment Monitoring in August of 2016 (DIN 27582). During the August 2016
and the February 2017 semiannual water quality monitoring events, two Appendix II constituents, 2-
Acetylaminoflourene and Cyanide, were detected in groundwater monitoring wells MW-1, MW-2, MW-5,
MW-7, and MW-16R. It was stated within the routine semiannual monitoring reports that it was
laboratory error. Pace Analytical Laboratory provided a letter dated June 22, 2017 that stated the results
for 2-Acetylaminoflourene and Cyanide were qualified as estimated values and found in the method
blanks indicating possible laboratory contribution to the reported value. In addition, Pace Analytical
Laboratory stated that the results below the Practical Quantitation Limit are reported down to the
statistically generated MDL with qualification that the results are estimated. The MDLs approach the
capability of the instrumentation to be free from all laboratory contamination and interferences.

Wayne County must take all necessary steps to ensure the protection of public health and the
environment and is required to remain in the Assessment Monitoring Program in accordance with 15A
NCAC 13B .1634. Based upon a review of the Alternative Source Demonstration-2-Acetylaminoflourene
and Cyanide, the document is approved as described at this time. However, if during a full Appendix II
monitoring event 2-Acetylaminoflourene and Cyanide increase in concentration and/or if the laboratory
quality assurance and control information indicates otherwise, Wayne County should include them as
Appendix II detections. Please note that after each full Appendix II monitoring event in which one or more
new Appendix II constituents are detected, please collect four independent samples from all the

groundwater monitoring wells to establish background concentrations for any of the newly detected
Appendix II constituents. Please also update the list of detected Appendix II constituents as needed.

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 for your continued cooperation
with this matter.

Sincerely,

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

cc sent via email: Jason Watkins, Field Operations Branch Head
Ed Mussler, Permitting Branch Head
Drew Hammonds, Eastern District Supervisor
Wes Hare, Environmental Senior Specialist
Ming Chao, Permitting Engineer
Christine Ritter, Permitting Hydrogeologist
Jonathan Pfohl, MESCO