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DocuSign Envelope ID:730BOEA2-D934-4504-B42A-928DAE22F3FB <br /> Section Seven 38 <br /> Approach and Understanding <br /> Our approach to the environmental monitoring and control programs at OCSWM landfills has been,and <br /> continues to be, based on historical knowledge of conditions at the facility,assessment of data derived from the <br /> groundwater monitoring program,and economic conditions. <br /> For example,the concentrations of certain regulated constituents in groundwater, in certain monitoring wells <br /> at the facility, exceed their respective"Groundwater Protection Standards! As a result, NCDEQ required that the <br /> North landfill enter a Groundwater Corrective Action program. During the several years in which the facility has <br /> been in Corrective Action, our strategy for managing the program has been based on two key concepts: (1) the <br /> quality of groundwater underlying the landfill represents negligible risk to human health and (2)the economic <br /> recession of the last several years has placed severe constraints on the budgets of local governments. For these <br /> reasons,our strategy has been to expend only enough effort on Corrective Action to prevent NCDEQ from <br /> pressing the OCSWM to embark on a more aggressive program of groundwater remediation. <br /> Another example is our Alternate Source Demonstrations (ASDs)that we have prepared on behalf of OCSWM. <br /> Draper Aden Associates has prepared ASDs for arsenic,cobalt, lead, selenium,and vanadium,each of which was <br /> subsequently approved by NCDEQ. ASDs are one of the available regulatory mechanisms to address"suspect" <br /> groundwater exceedances over site-specific background levels or groundwater protection standards. As a <br /> results, our successful demonstrations that sources other than the landfill have caused the apparent exceedance <br /> have allowed OCSWM to avoid unnecessary escalation in the groundwater monitoring program as they pertain <br /> to arsenic,cobalt, lead, selenium,and vanadium. <br /> Below is a brief overview of our experience,as a firm, specifically working on OCSWM environmental <br /> management programs. <br /> Orange County Regional Landfill: North (Closed) Facility <br /> Corrective Action Program(background). In a letter from Mr.Gayle Wilson (OCSWM)to Mr. Ervin Lane <br /> (NCDEQ;dated May 28, 2009),OCSWM accepted the corrective measures remedies presented in the ACM report <br /> (prepared by Draper Aden Associates; submitted October, 2008). The selected remedies include: monitored <br /> natural attenuation (MNA),enhanced bioremediation,direct oxidation. <br /> In a letter from Mr. Ervin Lane to Mr. Mike Meagher(OCSWM;dated September 11, 2009), NCDEQ approved the <br /> Groundwater Corrective Action Permit Modification Application. OCSWM implemented the following measures <br /> at the facility: institutional controls,engineering controls. In order to accelerate the remediation schedule, <br /> Draper Aden Associates assisted OCSWM in advancing from monitored natural attenuation to the more active <br /> components of the primary(phase 1) remedy: direct oxidation, enhanced biodegradation. <br /> Groundwater Injection Program-Hydrogeochemical Assessment. On behalf of OCSWM, Draper Aden <br /> Associates prepared an application to renew a permit to inject potassium permanganate into the groundwater <br /> in selected areas of the North landfill. <br /> Irki <br />