SW_F_2601-MSWLF-1997_2010-11-09_SP_DEMO

225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] \ FAX: [phone] \ Internet: http://portal.ncdenr.org
An Equal Opportunity \ Affirmative Action Employer

November 9, 2010

Robert Howard, Solid Waste Director
Cumberland County Solid Waste MSWLF
698 Ann Street, Fayetteville, NC 28301

Re: Alternative Cover Material Demonstration Authorization Letter
Cumberland County Municipal Solid Waste Landfill
Permit 26-01

Dear Mr. Howard:

This letter is in response to your request for approval to demonstrate the capability of an Alternative Cover Material
(ACM) at the referenced landfill. This Authorization Letter conditionally approves the Demonstration Project as described in
your letter dated April 16, 2010, for a period of 90 days. This period of time provides the operator with 90 days to perform the
Demonstration Project instead of the one month requested to adequately observe the effectiveness of the ACM in various
weather scenarios. The ACM demonstration period will expire on January 10, 2010.

The ACM must comply with 15NCAC .1626(2)(b) which requires the Operator to demonstrate that the ACM will
control disease vectors, fires, odor, blowing litter, and scavenging without presenting a threat to human health and the
environment. The ACM shall not be used more than five consecutive days without placing soil over the previously filled areas
and shall cover all of the exposed waste each time it is used. The use of this product will not be allowed during periods of
inclement weather such as rain.

The demonstration period does not allow for or give exemption to the requirements for Daily Cover. If the use of the
product is not sufficient for daily cover, it must not be used. It is the operator’s responsibility to ensure an adequate cover is
being provided. The use of the ACM must be discontinued if it does not perform as well as soil in the areas of fire prevention,
vector control, blowing waste prevention, odors, and scavenging.

After three months of using the conditionally approved ACM, the facility operator may then either:
(1) within 30 calendar days provide a certified Demonstration Report demonstrating the feasibility to apply for a
permit modification for the use of the ACM on a full-time basis, or
(2) cease use of the ACM, properly dispose of any remaining ACM, and provide a Closure Letter detailing the
findings of the use of the material during the approval period and what actions were taken to dispose of the
material.

The certified Demonstration Project report must be signed by the operator and certified by a professional engineer
licensed in North Carolina. The report shall include documentation addressing the performance and effectiveness of the
material, the number of times the ACM was used, the quantities of the ACM, and other supportive information, including
photographs.

North Carolina Department of Environment and Natural Resources
Division of Waste Management
Beverly Eaves Perdue Dexter R. Matthews
Governor Director
Dee Freeman
Secretary

225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] \ FAX: [phone] \ Internet: http://portal.ncdenr.org
An Equal Opportunity \ Affirmative Action Employer

Alternative Cover Material Demonstration Authorization Letter
Page 2

Following satisfactory demonstration of the ACM and a permit application and modification fee, the Solid Waste
Section may issue a Permit Modification for the facility that includes the ACM operation.

Please note that the continuation of the use of this ACM is performance based. Should the application of the ACM
become impracticable or contribute to conditions hazardous to public health, safety or the environment, the operator is
responsible for immediately terminating the ACM use and applying compacted earthen material cover in accordance with the
Solid Waste Rules. Impracticable conditions are conditions that make the placement of ACM difficult due to adverse climate
such as rain, wind, or frozen precipitation, or other conditions that adversely affects the ability of the ACM to meet the
Performance Standards. The operator must maintain a ready stockpile of earthen material cover material and the equipment
necessary to apply the earthen material cover to respond to an adverse situation. Therefore, approval of the continued use of the
ACM may be revoked at any point in time by the Division.

If you have any questions, please call me at 910-433-3351 at the Fayetteville Regional Office.

Sincerely,

Drew Hammonds
Environmental Senior Specialist
Solid Waste Section

Cc: Dennis Shackelford, Eastern District Supervisor
Geof Little, Regional Permitting Engineer
Michael Brinchek, CDM
Karen Hall, Cumberland County Solid Waste