6013_GreenwayNorthMeckCDLF_20171219_VCASDResponse_DIN28701

December 19, 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: Demonstration Letter on Laboratory Analyses for Vinyl Chloride
North Mecklenburg C&D Landfill Infill Area and Closed Phase I Area
Mecklenburg County
Solid Waste Permit Number 6013
DIN 28701

Dear Mr. Griffin:

The Solid Waste Section (Section) has completed a review of the Demonstration Letter on Laboratory Analyses
for Vinyl Chloride dated August 2, 2017 (DIN 28646) 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.

Since 2013 in response to the consistent groundwater exceedances of volatile organic compounds, the Infill
area of the landfill has been in the Assessment Monitoring program in accordance with 15A NCAC 13B .0545
and 15A NCAC 2L, and the closed Phase I area of the landfill has been conducting an assessment in accordance
with 15A NCAC 15A NCAC 13B .0503 and the 15A NCAC 2L.

The Demonstration Letter on Laboratory Analyses for Vinyl Chloride was submitted in accordance with 15A
NCAC 13B .0545(b)(8) to address groundwater exceedances of the volatile organic compound vinyl chloride
above the standard established in 15A NCAC 02L .0202. The demonstration included a review of historical
information on the detection of vinyl chloride in groundwater at the landfill and then provides a timeline of
the various concentrations of vinyl chloride that coincided with a change in analytical laboratories.

During the Fall 2016 routine semiannual groundwater monitoring event, split samples were collected from
select groundwater monitoring wells with historical concentrations of vinyl chloride and sent to two different
laboratories. The analytical results for vinyl chloride from the two different laboratories indicated different
concentrations.

During the Spring 2017 routine semiannual groundwater monitoring event, split samples were collected again
from select groundwater monitoring wells with historical concentrations of vinyl chloride and sent to one of
the laboratories that conducted the Fall 2016 laboratory analyses and an additional laboratory.
The analytical results for vinyl chloride from the two different laboratories indicated different concentrations
again. Based upon laboratory correspondences, there appeared to be equipment problems with the gas
chromatograph. One laboratory had Freon conversion problems and another laboratory had problems with
the silica gel.

The analytical results for vinyl chloride during the routine Spring 2017 monitoring event indicated exceedances
of the 2L Standard in the following Infill Area wells: MW4, MW5, MW7, MW9, MW9D, MW12, and MW12D.
In addition, the analytical results for vinyl chloride indicate exceedances of the 2L Standard in the following
Phase I Area wells: MW4, MW4A, MW4D, MW5, MW5D, MW6, MW6D, MW7, MW7A, MW7D, MW8, MW8D,
MW10, MW10D, MW11, MW4D-1, and MW6D-1.

A second round of samples were collected from select wells two months after the Spring 2017 monitoring
event, and submitted to one laboratory. Based upon this special sampling event, the analytical results for vinyl
chloride indicate exceedances of the 2L Standard in the following Infill Area wells: MW5, MW7, MW9, MW12,
and MW12D. In addition, the analytical results for vinyl chloride indicate exceedances of the 2L Standard in
the following Phase I Area wells: MW5, MW5D, MW7, MW9, MW12, and MW12D.

Within the Demonstration Letter on Laboratory Analyses for Vinyl Chloride, CEC Consultants, Inc. on behalf of
Greenway Waste Solutions at North Meck, LLC stated that the results of the second round of Spring 2017
sampling showed two point of compliance wells (Infill MW-12 and MW-12D) exhibiting vinyl chloride
concentrations above the practical quantitation limit. Further, CEC Consultants, Inc. stated that the project
clearly shows the vinyl chloride analytical data prior to the Spring 2017 sampling event has be considered
invalid with reviews of the upcoming efforts to address the two point of compliance wells exhibiting vinyl
chloride impacts above the Standards must only be based on sample data from the Spring 2017 event and
future sampling events.

Based upon the information provided within the Demonstration Letter on Laboratory Analyses for Vinyl
Chloride, the Section does not approve the alternate source demonstration for the landfill at this time.
Greenway Waste Solutions at North Meck, LLC has failed to demonstrate that the increase in the constituent
concentrations are the result of a source other than the C&D Landfill. The laboratory data still indicates
exceedances of vinyl chloride above the 2L Standard in both shallow and deep groundwater monitoring wells
which is a violation of NC groundwater rules.

In addition, a review of this document reveals the groundwater monitoring approach utilizing point of
compliance groundwater monitoring wells is based upon information within the Water Quality Monitoring Plan
(DIN 28684) submitted to the Section. This document is currently under Section review. The Section will
continue to review the Water Quality Monitoring Plan and may request additional information and/or
modifications to the plan as required to meet the requirements of the rules.

If you have any questions, please contact me by email at [e-mail] or by phone at
828.296.4706.

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