11-01 050709 NOV

AG;j
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
sLAS
COUNTY: BUNCOMBE
MSWLF
PERMIT NO.: 11-01
Closed
X
EIFIW
white
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Audit: 05/07/09
FACILITY NAME AND ADDRESS:
Buncombe County — Closed MSWLF
Highway 251
Asheville, 28804
Date of Last Audit: 05/27/06
GPS COORDINATES: N: 35.659706 E:-82.600287
FACILITY CONTACT NAME AND PHONE NUMBER:
Jerry Mears [phone]
FACILITY CONTACT ADDRESS:
Buncombe County Solid Waste Management Facility
85 Panther Branch Road,
Alexander, NC 28701
AUDIT PARTICIPANTS:
Jerry Mears, Buncombe County
Kristy Smith, Buncombe County
Andrea Keller, NCDENR — Solid Waste Section
Darlene Kucken, NCDENR — Land Quality Section
STATUS OF PERMIT:
Closed (Area A, B, and C)/ Transition Plan - 1994
Closed (Area D) — 1998
Modification to the Permit for Closure — 2/20/07
PURPOSE OF AUDIT:
COMPREHENSIVE
NOTICE OF VIOLATION(S):
15A NCAC 13B .1627(d) states that: Post -closure criteria includes; (D) maintaining and operating the gas monitoring
system in accordance with the requirements of Rule .1626 of this Section.
15A NCAC 13B .1626(4) Explosive gasses control; (a) Owners or operators of all MSWLF units must ensure that:
(i) The concentration of methane gas generated by the facility does not exceed 25 percent of the lower
explosive limit for methane in facility structures (excluding gas control or recovery system
components); and
(ii) The concentration of methane gas does not exceed the lower explosive limit for methane at the facility
property boundary.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2
15A NCAC 13B .1626(4)(b) states: Owners or operators of all MSWLF units must implement a routine methane
monitoring program to ensure that the standards of (4)(a) are met. A permanent monitoring system shall
be constructed on or before October 9, 1994. A temporary monitoring system shall be used prior to the
construction of a permanent system.
15A NCAC 13B .1625(a) states: The operator of a MSWLF unit shall maintain and operate the facility according
to the operating plan prepared in accordance with this Rule.
During the comprehensive inspection (and the ensuing document search) it was determined that during the time period
in which the landfill gas collection system was installed at the facility (1997-1998), the landfill gas monitoring system
consisting of ten methane monitoring probes (GP-1 through GP-10) were converted and/or "capped" without Section
approval. Following this conversion, no further methane monitoring was performed at the facility. (See detailed
discussion below in comment #8).
Buncombe County is in violation of 15A NCAC 13B .1627(d)(D) for failure to maintain and operate the gas
monitoring system in accordance with the requirements of Rule .1626 of this Section.
Buncombe County is in violation of 15A NCAC 13B .1626(4)(b) for failing to implement their routine methane
monitoring program to ensure that the standards of 15A NCAC 13B .1627(4)(a) are met.
Buncombe County is in violation of 15A NCAC 13B .1625(a) for failing to maintain and operate the facility
according to the operating plan prepared in accordance with this Rule.
In order to achieve compliance, Buncombe County must submit a new permanent methane monitoring plan to
the Section for approval. This methane monitoring plan should satisfy all conditions of Rule 15A NCAC 13B
.1626(4) as exampled by the previously approved Explosive Gas Control Plan (Section 7.9 of the approved Transition
Plan dated April 1994) which discussed the monitoring probe placement (Sheet 7 of 9), monitoring probe construction
(Sheet 9 of 9), and all recordkeeping and monitoring requirements. Note that the previously approved Explosive Gas
Control Plan indicated a network of methane gas monitoring wells such that the final network bordered all waste areas
(A, B, C, and D). The deadline for submittal of the methane monitoring plan is June 29, 2009.
Following approval of the methane gas monitoring plan, a Modification to the Permit for Closure will be required
to fully bring the facility into compliance along with any further requirements deemed necessary by the Section.
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $15,000 per day may be assessed for
each violation of the Solid Waste Statute or Regulations. For the violation(s) noted here, you may be subject to enforcement actions
including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any such
further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
STATUS OF PAST NOTED VIOLATIONS:
None
AREAS OF CONCERN AND COMMENTS:
1. On site for Comprehensive audit of closed MSWLF (Areas A, B, and C closed under the .0500 Rules, Area D
closed under the .1600 Rules).
2. Land Quality Section (D. Kucken) audited site per LQ permit #2006-005 and #2002-013.
3. Sedimentation controls/ponds were intact. Adequate ground cover was in place on closed fill areas.
Ground cover needs to be maintained on all of the previously disturbed areas to include the MSWLF
slopes, the slopes and haul roads, and all other areas that are bare or eroding.
Note: the ground cover in the high point region on Area D (surrounding the tower) appeared to be
thinning, pay close attention to this region during future site maintenance.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 3
Additionally, the areas where the GDS containers were being stored (particularly on the access road
which turns right upon entering the property) were exhibiting ruts/erosion.
If these storage locations
cover must be established.
4. According to the February 20, 2007 Modification to the Permit for Closure, Post -Closure Uses (7):
The owner/operator shall submit a description of the planned uses of the property during the post -
closure period. Post -closure uses approved by the Division, are described in the List of Approved
Documents, Attachment 1, Part B, Documents 1, 2, and 3. Several site activities not captured in the
above -referenced documents were noted during this audit (prior audits did reference these activities).
During the next permit modification, all on site activities not currently captured in the permit
must be added to the permit application. This includes the storage of GDS containers at the
facility, the operation of the model airplane field on Area B/C, and all other site activities not
currently noted in the approved documents and/or the most recent permit modification.
5. Groundwater monitoring records were reviewed. The most recent groundwater sampling event
occurred in April, 2009.
6. Approximately one third of the groundwater monit ring wells were inspected:
MW
- A
OK
MW-2
POUR PAD
MW-7
WEED EAT
MW-
8
OK
MW
- 23 (SHALLOW)
NEEDS NEW NUMBERS
MW
- 23 (DEEP)
CLEAN UP TRASH
MW
- 14
OK
MW
- 4-A
DIG OUT AROUND/POUR PAD
MW
- 12 (SHALLOW)
NEEDS NEW NUMBERS
MW
- 12 (INTERMEDIATE)
NEEDS NEW NUMBERS
MW
- 13 (SHALLOW)
NEEDS PAD

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 4
MW -
13 (INTERMEDIATE)
OK
MW -
13 (DEEP)
NEEDS PAD
7. According to 15A NCAC 13B .1627 Closure and Post -Closure requirements for MSWLF Facilities:
(c) Closure Criteria
(C) Minimize erosion of the cap system and protect the low -permeability barrier from
root penetration by use of an erosion layer that contains a minimum of six inches of earthen
material that is capable of sustaining native plant growth.
While Area D was closed under the .1600 Rules and Areas A, B, and C were closed under the .0500
Rules, all Areas must meet the Post -Closure General Condition stated in the permit such that the
owner or operator shall maintain the integrity and effectiveness of any camp system.
In general, the facility has maintained the cap system well, has established vegetative growth, and
has maintained erosion controls. However, along several of the Area boundaries (waste boundaries)
woody/tree growth is beginning to encroach upon the cap system. As these types of root systems
will most likely extend beyond the erosion layer into the impermeable layer of the cap (thus
destroying the integrity of the cap system and creating a path for water into the landfill), and as trees
both inhibit the proper mowing and necessary maintenance of the cap while impeding on the ability
to visually inspect the cap integrity, this woody shrub/tree growth must be eliminated. Any stumps
and root systems of larger trees must be removed and the cap system repaired.
Additionally, it is suggested that the facility mark the edge -of -waste boundaries on all closed cells
(areas) in order to clearly delineate the regions requiring the above -referenced maintenance and
controls.
8. Methane Monitoring Timeline:
a. Transition Plan (4/7/94): Includes the Explosive Gas Control Plan (EGCP), monitoring
probe placement (10 probes), probe/well construction specs, location of wells, and
monitoring logs.
b. Full approval of the Transition Plan (9/21/95).
c. Modification to Permit (10/3/96): Includes the entirety of the original EGCP with inserts to
address the monitoring of the planned Landfill Gas (LFG) collection system. No mention of
conversion of monitoring wells noted in this plan.
d. Area D Closure Application (8/l/98):
• Section 8.1 (Closure Plan) LFG management system states that the as -built info
replaces the details of Sheet 9 of the Transition Plan figure (well diagrams).
• The Post -Closure Plan in Appendix D, Section 9.3, states that monitoring activities
will include groundwater and surface water monitoring as well as landfill gas
migration monitoring throughout the 30-year post -closure period. This will
provide early detection of any potentially harmful elements to the public or the
environment.
Section 9.4, Maintenance Activities, states: Buncombe County is committed to
maintain this facility to the highest standards. A variety of maintenance and repair
activities will be conducted at the closed landfill on a regular basis. Including:
repair/replace damaged monitor wells. Furthermore, Buncombe County will
perform regular inspections of the closed landfill facility during the long term care
period. Including: Landfill gas migration control and monitoring and

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5
groundwater monitoring systems will be inspected and maintained to ensure that
they operate property.
e. LFG Collection System, Engineering Report (12/7/98): Ten shallow monitoring probes
were placed around the perimeter of the old disposal area during the initial phase of the
LFG monitoring program... Three of the passive vents (P-4, P-5, and P-9) located in the
trench along the roadway have been converted to extraction wellheads and connected to the
active LFG system, as shown on the Record Drawings presented in Appendix A. The
remaining vents [seven] were capped.
This work was most likely conducted in the 1996-1998 timeframe. However, no records
were found to indicate that the conversion/capping of the gas probe monitoring wells had
been approved by the Section. Additionally, the language changes from calling the wells gas
monitoring probes (GP) to passive vents (P) and then states that the converted wells (P-4, 5,
and 9) were located along the trench line (and roadway) whereas GP-9 was located
significantly southwest of the trench along the French Broad River. It appears as though GP-
4, 5, and 6 were the gas probe monitoring wells located in the trench area.
f. Modification to Permit for Closure (2/20/07): States that the approved documents are the
Transition Plan (4/94), Closure Plan for MSWLF Area D (8/98), documents on groundwater
monitoring well changes 1/16/07, 1/22/07, and the Progress Energy Turbine Generation Plant
proposal. Additionally, the permit states, under Methane Gas Remediation Conditions, the
.1627 Rules regarding methane monitoring at facility structures and property boundaries and
that if methane gas levels exceeding these limits are detected, the facility must implement
Condition 8 (Transition Plan). This indicates that the Section was unaware of the
modifications to the LFG monitoring wells and that the only approved gas monitoring
plan was the Transition Plan EGCP (including the permit modifications of 10/3/96)
g. Methane Monitoring, Buncombe County: In immediate response to the preliminary audit
findings (no methane monitoring records available), Buncombe County conducted ambient
methane monitoring at the property boundary (see attached document) on May 12, 2009. No
methane was detected at the twelve perimeter locations. During the inspection, it was
stated that Buncombe County was operating under the assumption that the LFG collection
system, along with the landfill gas collection system monitoring conducted by Enerdyne, was
the approved methane monitoring program. Enerdyne (Steve Allen) confirmed that they were
not conducting methane monitoring outside of the operational monitoring required for the
LFG collection system.
From this timeline (including secondary documents and submittal/approval letters) it appears as
though at some point between the permit modification of (October, 1996) and the engineering
report discussing the as -built of the LFG collection system (December, 1998), the ten EGCP
wells (GP-1 through GP-10) were altered/abandoned and the EGCP plan was not able to be
implemented. Thus, the required methane monitoring did not occur for a period of
approximately 11-12 years.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 6
Please contact me if you have any questions or concerns regarding this audit report.
Phone: [phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Mailed on: 5/28/09 by
Hand delivery
US
Certified No. [7006 2150 0005 2458 9150 1
Mail
cc: Mark Poindexter, Field Operations Branch Supervisor
Deb Aja, Western District Supervisor
Donald Herndon, Compliance Officer
Wanda Greene, Buncombe County Manager