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HomeMy WebLinkAbout4407_ROSCANS_1991State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 • Raleigh, North Carolina 27611-7687 James G. Martin, Governor William W. Cobey, Jr., Secretary November 18, 1991 Mr. Jack Horton, County Manager Haywood County Courthouse Waynesville, NC 28786 RE: Proposed Haywood County Landfill Application Status Dear Mr. Horton: William L. Meyer Director Enclosed please find a copy of the Division of Environmental Management's comments for the 06 Sept 91 Addendum to the permit application. The Section has initiated the review of the Construction Plan Submittal (received 17 Sept 91), which will incorporate these DEM comments. As you know, the EPA published the Final Rule for Municipal Solid Waste Landfills on 09 Oct 91. Currently, the Section is evaluating the impact of the new Federal criteria on all existing and proposed facilities. Policy guidance for interim permitting decisions in North Carolina will be forthcoming. If you have not already received a copy of the Federal Register, please contact me. Sincerely, Ga?'�W. Ahlberg Enri onmental Engineer Solid Waste Section enclosure cc: Tribble & Richardson ✓Jim Patterson Julian Foscue John Runkle Carolyn Gann An Equal Opportunity Affirmative Action Employer n "SrA1F .y State of North Carolina Department of Environment, Health, and Natural Rf Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27604 James G. Martin, Governor William W. Cobey, Jr., Secretary October 24, 1991 Regional Offices Asheville M E M O R A N D U M 704/251-620ti ' OCT 29 1991 George T. Everett, Ph.D. Director Fayetteville TO: William L. Meyer, Director 919/486-1541 Division of Solid Waste Management Mooresville \ Sv 704/663-1699 FROM: George T. Everette Raleigh y 919/733-2314 p woo SUBJECT: Proposed Had County Sanitary Landfill White Oak Site Washington Addendum to the Permit Application 919/9,16-6481 Wilmington 919/395-39W The Division of Environmental Management has reviewed Winston-Salem the subject addendum to Haywood County's White Oak Landfill 919/896-7007 Application and offers the following comments: Groundwater Oualit 1. The site is in a groundwater discharge area evidenced by the spring discharge down the middle of the site, and the Pigeon River bordering the downgradient side. These features should limit groundwater contamination in the event of liner failure. 2. The spring area and the stream flowing from it are to be excavated to a depth of up to 14 feet in the upper section. A drain line will be installed in the bottom of the excavation and covered with gravel to the top of the water table. The gravel will be covered with at least four feet of compacted soil, a one foot thick bentonite and soil liner mixture, a synthetic liner, and gravel. This drain could serve as a point of contaminated groundwater treatment in case of liner failure. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 / Pollution Prevention Pays An Equal Opportunity Affirmative Action Employer 3. After the synthetic liner is installed, the water table on the site should decline as a result of the restricted recharge to the groundwaters. The increased separation distance to the water table should further reduce groundwater contamination potential. 4. There is very limited groundwater use in the area with no groundwater supplies being located directly downgradient. Water Quality 1. The site of this proposed landfill cell is located entirely on the Bill Davis Property with the spring in question found mid cell (laterally) and at the beginning of the bottom third of the cell which lays on a south to north grade toward the west bank of the Pigeon River. The spring is further located approximately 600 feet from the Pigeon River and 1/4 mile north of the nearest occupied dwelling. The map attached to the addendum appears to accurately depict the cell/spring location. 2. The Tribble and Richardson proposal for segregating this stream from interference by the landfill cell appears reasonably sound as described in the addendum with proper monitoring and diversion of all remaining surface water from the proposed cell. Essentially, the spring will be relieved at the point of maximum known flow and transported via an underdrain system under the final 1/3 of the cell (with a two layered liner; clay and composite) to a manhole which can then either divert the flow to the leachate collection pond for proper treatment and disposal (if monitoring shows contamination) or to an erosion control basin for release to the Pigeon River. Collection of the spring, minimization of the recharge area (as will result from development of the upper part of the cell), and construction of an underdrain system to transport this flow from the area is an established means of handing these waters. The question which will remain unknown until actual project development is the extent (volume) of spring flow to be intercepted under the cell and the capability of the leachate collection pond of handling the entire stream flow if larger than expected volumes appear. Haywood County will need to be prepared to deal with such an occurrence as use of this landfill progresses. 3. The proposed addendum to the White Oak Landfill as means of handling spring -fed surface waters on this property (first cell development) and associated permit should include a condition that requires monitoring of parameters normal and specific to landfill wastes on a triannual basis, but not less than once per year. If there are any questions, please advise. GTE:ja/White. cc: Roy Davis Perry Nelson Steve Tedder Permit Files State of North Carolina `� �99� Department of. Environment, Health, and Natural Resoul ` es.,-.1 Asheville Regional Office. ?+ James G. Martin, Governor LETTER OF 8PEROVAL Ann ,B Orr William W. Cobey, Jr., Secretary Regional Manager . October 22, 1991 Mr. -Jack Horton Haywood County Manager 420 N. Main Street Waynesville, NC 28786 Dear Mr. Horton: This office 'has reviewed the erosion and sedimentation control plan submitted for the project listed below. We find the plan to be acceptable and hereby issue this Letter of Approval with modifications and/or performance reservations. A list. of the modifications required and/or reservations is attached. This approval is conditioned upon the incorporation or addition of these items to the 'plan. Please be advised that Title 15A, North Carolina Administrative Code 4B.0017(a), requires; that a copy of the approved soil erosion control plan be on file at the job site. Also, you should consider this letter to give the Notice required by NCGS 113A-61(d) of our right of periodic inspection to ensure compliance with the approved plan. The State's Sedimentation Pollution Control Program is a performance - oriented -program requiring protection of the natural resources and adjoining properties. If, following commencement of this project, it is determined that the plan 'is inadequate to meet the requirements of NCGS 113A-51 to.66, this office may require revisions to the plan and implementation of the revisions to ensure compliance with the Act. Please note that this approval is based in part on the accuracy of the 'information 'provided in. the Financial Responsibility Form which you have provided. You are requested to file an amended form if there is any change in the information included on the form. In addition, it would be helpful if you notify this office of the proposed starting date for this project. Your cooperation is appreciated. Since`cely, Richard A. Phillips, P.E. JOHN D. RUNKLE ATTORNEY AT LAW POST OFFICE BOX 3793 CHAPEL HILL, NORTH CAROLINA 27515 TELEPHONE: 919/942-0600 %1S�1f,Uti °� I'�Oiffl �•It{,�t�a Gary Ahlberg Solid Waste Section Post Office Box 27687 Raleigh, North Carolina 27611 ,G�kt�2 CJc!c� ��yr�IIBII� .. __ OEC 13 1991 �Aecet 1�"N. DIV. OF ENVIRONMENTAL MGMNT. DIRECTORS OFFICE DEC 16 1991 v f-, n t 1TT 1;0J 4 Re: Proposed solid waste landfill -- White Oak, Haywood County Dear Gary: The following comments are for your agency's review of the application of the proposed White Oak landfill: 1. Hydrogeology. I am enclosing a copy of the comments of Mr. Barry Peak on the final hydrogeological report. Although you are reviewing the application for the construction permit, his comments are relevant to the unanswered issues in the conditional site suitability letter of December 10, 1990. 2. Wetlands. In his cover letter to me, Mr. Peak stated that he did not address the wetlands issue in these comments as this was brought to your attention when he met with you in Raleigh earlier this fall. The application for the construction permit is fatally flawed in that the County proposes to pipe and cover the springs, wetlands and streams. The rules require a 50— foot buffer at 15A NCAC 13B.0503(2)(f)(iii) and allow no variance to any of the rules. The first reason for the rule is to protect water quality in surface waters of the state. Even though DEM or the Army Corps would allow the streams to be captured or managed in this instance, there is another primary reason for the rule. That is to prevent the landfill from filling up with water. This is the reason why landfills need caps and engineered barriers between all sources of water and the waste. The tendency of the water in the area is to flow to the surface (note the presence of the many springs). In fact, the present streams and wetlands were much lower in elevation several years ago; efforts to fill them only caused them to rise to the surface. Attempts to capture the water will in all likelihood fail. 3. SEPA requirements. As I mentioned to you the other day, the County is proposing a baling/collection facility which may include some materials recovery operations. This facility will need a license under Section .0200 and may need to comply with the provisions in Sections .0300 and .0400. It t N\ RECYCLED PAPER is my opinion that this facility will need to comply with the State Environmental Policy Act, G.S. 113A-4, and an EIS prepared before it can be licensed. There are several ways to get the agency's position on this; I am willing to defer on whichever way the agency considers the most expedient. This issue should be resolved prior to the the review of the application because the landfill relies on the baling in its black bear mitigation plan and in the protection of groundwater. Please contact me if you wish to discuss any of these matters further. I will contact you next week about the SEPA issue for the baling/collection facility. Sincerely, v John D. Runkle for the White Oak Chapter of the Izaak Walton League Enc. cc. Dr. George Everett Jack Horton, County Manager my clients COMMENTS ON THE REVISED HYDROGEOLOGICAL REPORT -PROPOSED WHITE OAK LANDFILL SITE AND RELATED MATTERS The revised report by Law Engineering of July 1991 is a consider- able improvement over the previous report, but it has some signif- icant discrepencies. For example, the water -level map, although much improved over the original attempt, is not representative of true conditions at the site. The water -level map was constructed on the basis of both wells constructed in the regolith (soil and weathered rock) that repre- sent the water table, and water levels in wells completed in the bedrock, that represent an altogether different set of conditions. Information on the "paired" wells shown in Table 4 of the report, shows thatboth recharge to the bedrock aquifer and discharge from the bedrock occur at three of the well sites, dependent upon seasonal conditions. These sites are near the shifting.boundary between recharge and discharge. The number and distribution of the paired wells and bedrock wells are not adequate to show the extent of the area of bedrock recharge. Information on the relat- ionship betweetegolith and bedrock is absent for the proposed ten -acre landfill site. However, Well AT-1, on the northwest cor- ner ofthe site boundary, shows the water level in bedrock to be about 18 feet below the water table in Well B-101. This large difference in head could be expected in this topographic situat- ion and principal bedrock recharge area. However, this very significant information is completely ignored in the report text and the water -level map. It is evident that the authors of the report did not wish to be confused by the facts, and, thus, do not understand the need for adequate information on the relationship between the regolith and the bedrock aquifer. As stated in my previous comments on the proposed landfill site, the rocks beneath the White Oak area are highly fractured. This has resulted in deep weathering of the rocks, and a thick regolith exists on the ridges where the least amount of erosion has occurred. This regolith generally consists of silty sand and sandy silt and, therefore is quite permeable. The relatively high permeability of both the regolith and the bedrock apparently account for the position of the top of the saturated zone beneath the site. Water levels are near the top of the bedrock- afew feet above or below- during periods when the water levesl are high. During the periods of seasonal low water levels, and particularly periods of drought, the top of the saturated zone is probably below the top of the bedrock beneath much of the site. Therefore, recharge from the regolith to the bedrock would be absent or very limited under these conditions, and availability of groundwater would be largely restricted to the bedrock aquifer. As indicated in the site report, movement of groundwater through the silty,sandy regolith occurs at a rate of several inches per day. Movement of groundwater in the bedrock is entirely different, because the bedrock fractures comprise, in effect, a pipeline system. In this system, groundwater may travel long distances in a short time, with possible rates of tens of feet per day or greater. The principal bedrock fractures in the area are oriented in a northeast -southwest direction. The water -level map of the site report indicates that the natural gradient of the groundwater in most of the site area is generally north toward the river. However, a groundwater divide is indicated by the water table contours near the southern boundary of the site, in the vicinity of Well AT-15 and the highest topographic elevat- ions. Water from this high is moving out in all directions, not just toward the east or southeast, as described in the report. There is no information on water levels in the bedrock in this vicinity, therefore, the position of the groundwater divide in the bedrock is not known. The landfill construction plan shows that the excavation and fill would extend almost to the water - table divide. If this happens, existing conditions can be expect- ed to change considerably. Drawdown of water levels in the fracture system resulting -from the pumping of nearby water -supply wells could, or may already, extend beneath the landfill site, particularly during drought conditions. Pumping of water from a group of bedrock wells a mile or more away could have a similar effect. The possibility and probability of this situation willlincrease as population and development in the White Oak area continues to expand. Landfills, by design, represent very long-term storage of wastes containing a wide range of pollutants. These pollutants eventually enter the groundwater system. In locating landfill sites, consider- ation must be given to the changes that may occur in adjacent areas over a period of decades, and not just the few years that the facility may be active. The proposed landfill may not appear to be an immediate threat to existing groundwater supplies in the area. However there is a potential for future pollution of nearby water supplies, although the magnitude of the risk cannot be evaluated on the basis of existing information. Additional information on water levels in the bedrock and regolith along the southern boundary of the property is needed for this evaluation, especially for periods of low water levels. I agree with Ralph Heath that the complex and expensive design of the proposed White Oak landfill will provide no better pro- tectionof the water resources than a simple and much less expen- sive design. The clay and fabric liners in the design will probably create more problems on this site than they wil.solve. �/;� / Harp M. Peek Prof. Hydrogeologist seal -- licensed 103 geologist COLLECTION GOALS: Prefer a door to door collection system. Consider subsidy or alternative program for low income citizens. Encourage public education about door to door pick up andneed to recycle. COMMENTS: The County Board of Commissioners prefers a door to door collection system. It was generally agreed that this system encour- aged citizens to take more responsibility in the solid waste manage- ment program. The towns have successfully operated door to door collection systems for several years. Such a program could also operate in a rural setting. It was the general opinion that door to door pickup would be convenient, create less littering and provide new job opportunities, especially if operated by a private concern. Franchised hauler program needs to be considered. Meetings need to be set up with existing franchise haulers and the towns to learn how such a system could efficently operate in the county. Such a meeting would also give commissioners a chance to gather valuable input from both parties. It was the consensus of the Board of Commissioners that they want the staff to collect and provide more information about the cost of setting up and operating such a system. Concern was also ex- pressed for those citizens who may not be able to pay the cost for a door to door program. Consideration needs to be given for a free day pick up or green box access point somewhere accessible in the county for those who cannot afford it. Education is critical to the success of a door to door collection system, especially when coordinated with a residential recyclingg program. A door to door program coordinated with recycling 2 require some means of enforcement to encourage waste separation at the source. RECYCLING GOALS: Precycling is important and should be encouraged. Develop a source separation which involves door to door collection program. Begin work on establishing a low -tech composting program. COMMENTS: It was generally agreed that precycling was important and should be considered and promoted in a public education program. County government needs to take the lead in promoting precycling. State government should also be urged to place more recycled products on state contract for purchase by local governments. While precycling is important, it will take a number of other initiatives to develop a successful recycling program which reduces the waste stream and meets state recycling mandates. Since a door to door collection program is preferred, it was generally agreed that source separation would coordinate well with such a program. While everyone agreed that source separation was a major goal, it was generally agreed that such a program would need to be phased in over time but in a manner which meets future recycling mandates by the state. It was agreed that a " blue bag" recycling program needs to be studied instead and incorporated in our planning for a door to door collection program. There was no interest expressed by commissioners to consider mixed waste separation. DISPOSAL GOALS: •. Committed to White Oak site and should move forward as quickly as possible to acquire necessary permits and construct landfill. Acquire necessary land and open a demolition landfill as soon as possible. Encourage recycling to reduce waste stream being landfilled. Start a "limited" composting program immediately. Work with town officials and private haulers to coordinate waste management program. COMMENTS: The Board of Commissioners agreed that a sanitary landfill was the preferred method of disposal and expressed their unified support to proceed with plans to construct and operate a landfill in the site located at White Oak. It was determined that other forms of disposal, with the exception of limited composting, were not viable alternatives for waste disposal. Every effort needs to be made to reduce the waste stream going into the landfill. Every effort needs to be made to educate the public regarding recycling. The commissioners also felt that getting a demolition landfill open was a top priority in the county and should be pursued in a diligent manner. At the same time, the county needs to consider a limited composting program and start it as soon as possible. It was the general belief of the county commissioners that they need to involve the municipalities and private haulers in future M planning sessions. Again, public education on solid waste issues and management concepts will be important. ADMINISTRATION GOALS: Solid waste program should be publicly driven with involvement from the private sector. Encourage public education regarding solid waste management. COMMENTS: The Board of Commissioners felt it was important that the county solid waste management program should be run predominately publicly but every effort needs to be made to involve the private sector in its operation. A combined public/private part- nership allows the county to maintain control of the program but benefit from the expertise, efficiency and cost saving generated by the private sector. Public education was again recognized as critically important for the success of the solid waste management program. COST ANALYSIS GOALS: A tipping/user fee to fund the operation of a the county's solid waste management program. COMMENTS: A tipping / user fee was the preferred method by the Board of Commissioners in paying for the county's solid waste management program. The commissioners also recognized that a combination of taxes (ad -valorem plus user fees will be needed during the start up phase of the program. A tremendous amount of study will be required to determine the best way to levy and collect such user fees. DISPOSAL (continued) INCINERATION STRENGTHS * Diminishes need for landfill space * Maybe could look to regional, or state, for same products * Co -generation of steam or power WEAKNESSES * High start-up costs * Needs high volume * Stigma associated with inceneration * Uncertainty with changing regulations - will most likely get stricter * Maintenance * High operating cost FUEL PELLETS STRENGTHS * Perhaps could move to this in future - leave options open * May have to do this to meet 40% recycling goal - Europeans do this (of some, not all, waste stream) WEAKNESSES * Lack of good information, track record * Must have some separation process * Don't know about regulations - especially air quality * Cost uncertainty - high maintenance ADMINISTRATION PUBLIC STRENGTHS * Full control * Flexibility * Must eliminate politics from government * Be more concerned with public relations * Might be more responsive to citizens concerns * County is non-profit - might be cheaper ultimately WEAKNESSES * Lack of profit motive & efficiency * More costly; up front costs of labor, equipment * Effect on taxes PRIVATE STRENGTHS * Eliminate headaches if run right (phone calls in a.m.) * Lower (or no) up -front costs * Competitive bidding could lead to cheaper cost WEAKNESSES * Less certainty if business decides to cease operations * Quality control - lose direct control * Public perception of paying county or private hauler... TOINT VENTURE STRENGTHS * Familiarity * Flexibility - choose best combination of public & private * Selected areas of expertise WEAKNESSES * Negotiations - may take a while; make lots of decisions * How do you get out of unfavorable contracts? * Economy of scale issue COST ANALYSIS TAXES (AD VALOREM) STRENGTHS * Predictability * Easy to collect WEAKNESSES * Political liability * Taxes not based on how much garbage you produce * Financial limitations of tax base * Competing with programs and services of other county agencies TIPPING/USER FEES STRENGTHS * Everyone pays based on use * Opportunity for self sufficiency * Encourage recycling by incentive programs * Reward for recycling * Driven by waste generators (Industry pay more than residential) * Reduce taxes or prohibit taxes increases * Visitors pay through services received WEAKNESSES * Illegal dumping * Enforcement Bureaucratic system More administrative than property tax What about citizens who cannot pay RECYCLING SOURCE SEPARATION STRENGTHS * Existing education level already good * Saves space, cost in landfill * Possible income source - may defray costs * Cuts down on use of virgin material WEAKNESSES * Markets overloaded * Future mandates * Regulation direction * Storage of excess recyclables * May need extra equipment, depending on system * Must be clean, good quality * Education * High expense MIXED WASTES STRENGTHS * Maybe not such high cost if buy right equipment * Could be less collection cost - less labor * More flexibility to pick-up * Most convenient to citizens * High Point facility reports recyclables still marketable WEAKNESSES * High cost up front * Twice the cost of some source separation * Changing technology * Changing state and federal regulations * Lower quality recyclables * Don't get all recyclables * Liability a possible consideration * Need to worry about plastics? DISPOSAL LANDFILL STRENGTHS * Cheapest method of disposal so far * Simplest, except for regulation (more maybe coming) * Have most experience, knowledge of this system * Size of site * Land usable after landfill closed (School bus garage) WEAKNESSES * Locating a site * Increasingly stringent state and federal regulations * Long-term liability and potential for pollution * Leachate collection Permit process time consuming Methane gas can be a problem PRECYCLING STRENGTHS * Requires education of local citizens * Require fast food to go back to dishes * Less goes into landfill * County must set the example for others * Ask state to put recycled materials on state contract * Precycling should be emphasized WEAKNESSES * May be less convenient to consumers and business COMPOSTING STRENGTHS * Low cost (depends on method) * Good way to get rid of biodegradables * How much of waste stream can you compost? * Creates good topsoil, clean, good for environment * Can sell to nurseries WEAKNESSES * Lack of good data, track record * Potential for contamination * Need way to separate household waste from hazardous material Requires size reduction equipment No history of market for mixes waste compost COLLECTION GREEN BOXES STRENGTHS * Convenience to citizens * Manned, better for appearance * Facilitates recycling * Eliminates rummaging (with fences) WEAKNESSES * High cost * Inconvenient for county government * Not lend itself to source separation * Site availability * NIMBY (not in my backyard) * Future state regulations * Labor intensive ROLL -OFFS STRENGTHS * Need fewer containers compared to green boxes * Cheaper truck * Some counties using * Can haul bulky items * Ease of operation WEAKNESSES * Equipment costs * Can't haul as much as with compacted truck * Need more site area * Cost to convert from green box system to this system DOOR TO DOOR PICKUP STRENGTHS * Good for source separation * Could be less costly to county government * Convenience * Better understanding of waste stream * Easy way to assess costs (user fees vs taxes) WEAKNESSES * Labor intensive * Need to have educated crews to keep waste separated * Access roads * Public education * Could encourage illegal dumping * Enforcement Additionally, Jim Patterson with the Solid Waste Division of the North Carolina Department of Health, En- vironment & Natural Resources was present to update the Board of Commissioners on state and federal solid waste regulations and requirements. Mr. Patterson also presented a slide show and explained some of the new changes that were enacted during the recent session of the North Carolina General Assembly. The result of the process was a comprehensive strength and weakness analysis which directly involved each commissioner. Through direct interaction, the Board of Commissioners were able to reach a consensus on major policy directives for the county's solid waste management program. While the workshop was a public meeting, no official action was taken. This final report is an outline of the planning directive generated at the August 19th workshop and wilrbe presented for official action at the September 19th meeting. On Friday, August 16th,1991, the Haywood County Board of Commissioners gathered for a strategic planning workshop on the issue of solid waste at the Lambuth Inn at Lake Junaluska Assembly. Additional strategic planninworkshops are planned for the Board of Commissioners on Lag nd use planning, infrastructure development and capital improvement planning. The public session was called to order by Mr. Horton who gave the Board of Commissioners a brief overview of the strateggi�c planning workshop. Mr. Horton stated that the worksZiop would examine the solid waste issue in five catego- ries: Collection Recyclying Disposal Administration Cost Analysis The session was broken into three sessions: Session I. Where Have We Been? Session II.- Where Are We Now? Session II. Where Do We Want To Be And How Will We Get There? Session I: "Where Have We Been?" was a presentation by Trudy Messer of Haywood Project Pride. Ms. Messer gave a brief historical overview of the solid waste management pro- gram of Haywood County and its municipalities. Session II: "Where Are We Now?" was led by Rick Webb, Director of Planning and Economic Development, who presented a slide presentation which examined our present solid waste management program. His presentation discussed the areas of collection, recycling, disposal, administration and cost analysis.