6013_GreenwayNorthMeckCDLF_20171212_ACMResponse_DIN28685

December 12, 2017

Sent Via Email – [e-mail]
Mr. Mike Griffin
Greenway Waste Solutions at North Meck, LLC
19109 West Catawba Avenue, Suite 200
Cornelius, NC 28031

Re: Assessment of Corrective Measures
North Mecklenburg C&D Landfill Infill Area and Closed Phase I Area
Mecklenburg County
Solid Waste Permit Number 6013
DIN 28685

Dear Mr. Griffin:
The Solid Waste Section (Section) has received the Assessment of Corrective Measures (ACM) dated
November 17, 2017 (DIN 28683) and submitted on your behalf by CEC Consultants, Inc. for the North
Mecklenburg C&D Landfill (Infill Area and the Closed Phase I Area), NC Solid Waste Permit Number 6013.
The intent of this letter is to clarify the process required to implement groundwater corrective action at
this landfill.

The Section will review an ACM to determine if it meets the objectives of the rules. Then the Section will
evaluate and approve a selected remedy and a groundwater monitoring approach after the public meeting
is conducted and a completed application is submitted.

However, an initial review of the ACM reveals the proposed selected remedy and groundwater monitoring
approach are based upon information within other documents submitted to the Section. These
documents include the following: the Demonstration Letter on Background Metals in Groundwater
Samples (DIN 28645), the Demonstration Letter on Laboratory Analyses for Vinyl Chloride (DIN 28646),
and the Water Quality Monitoring Plan (DIN 28684). All three of these documents are currently under
Section review. As such, to move the corrective action process to a public meeting without all of
information being accurate and approved would not be beneficial to the landfill, the community, and the
process itself.

The Section will continue to review all the aforementioned documents collectively, including the ACM,
and may request additional information and/or modifications to said documents as required to meet the
requirements of the rules. The Section will provide written correspondence when it is appropriate for the
landfill to move forward with the corrective action process.

Upon receipt of that correspondence and in accordance with 15A NCAC 13B .0545(d), Greenway Waste
Solutions at North Meck, LLC will then be required to conduct a public meeting to discuss the results of
the ACM. After conducting the public meeting, Greenway Waste Solutions at North Meck, LLC shall select
an effective remedy, and within 30 days of selecting a remedy, submit a completed .0545 Groundwater

Corrective Action Permit Modification Application for Section evaluation and approval. The groundwater
corrective action application is conveniently located on the Section’s webpage at
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/NCSW_0545_GroundwaterCAPer
mitApplication.pdf. The groundwater corrective action application must also include the demonstrations
necessary to comply with the financial assurance requirements.

Greenway Waste Solutions at North Meck, LLC shall choose a selected remedy to restore groundwater
quality, to effectively reduce the groundwater contamination at the facility, and to control the migration
of contaminated groundwater to prevent unacceptable impacts to human health and the environment.
The selected remedy must meet the requirements listed within 15A NCAC 13B .0545 and 15A NCAC 2L.

In accordance with 15A NCAC 13B .0545(e)(2), the selected remedy must:
(A) be protective of human health and the environment;
(B) attain the approved ground-water protection standards;
(C) control the source(s) of releases so as to reduce or eliminate, to the maximum extent practicable,
further releases of constituents into the environment that may pose a threat to human health or the
environment; and
(D) comply with standards for management of wastes.

Once the Section approves the selected remedy after the public meeting is conducted, Greenway Waste
Solutions at North Meck, LLC will then be required to submit a Corrective Action Plan (CAP) within 90 days.
The Section will review the CAP, approve, or request additional information prior to its implementation.
Finally, the implementation of the approved CAP shall take place in accordance with 15A NCAC 13B .0545.
If you have any questions, please contact me by email at [e-mail] or by phone
at 828.296.4706. 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: Ellen Lorscheider, Division Deputy Director
Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Teresa Bradford, Environmental Senior Specialist
Ed Mussler, Permitting Branch Head
Perry Sugg, Permitting Hydrogeologist
Larry Frost, Permitting Engineer
John Brown, Griffin Brothers
Ed Stephens, CEC, Inc.
Scott Brown, CEC, Inc.
Joe Hack, Mecklenburg County Solid Waste Management
Aaron Caudle, Mecklenburg County Solid Waste Management
Jack Simoneau, Town of Huntersville