4407_ROSCANS_1997

State of North Carolina
Department of Environment,
Health and Natural Resources 1 •
Division of Waste Management a
0"W% 001% 00ft
James B, Hunt, Jr., Governor p E H N FR
Jonathan B. Howes, Secretary
William L. Meyer, Director
July 17, 1997
Mr. Jack Horton
Haywood County Manager
420 N. Main Street
Waynesville, N.C. 28786
RE: Landfill Expansion of the Haywood County White Oak Landfill
Permit Number 44-07
Dear Mr. Horton,
The Solid Waste Section has received the June 16, 1997, submittal
entitled "Permit Modification Landfill Expansion" prepared by
Steffen Robertson and Ki.rsten (NC), Inc. As outlined in the letter
of October 29, 1996, to you from James C. Coffey or our Section,
"If the County proposes to laterally expand the existing lined
MSWLF unit within the 23-acre area, permit renewal is required".
"The permitting requirements for permit renewal are contained in
Rule .1617(e)..."
"Permit Renewal" requirements, Rule .1617(e), are significantly
different from the requirements for "Modifications to the Permit",
Rule .1617(c). "Permit Renewal", in .1617(e)(2), requires "an
engineering plan that is prepared for the initial phase of landfill
development prepared in accordance with Rule .1620 of this
Section". As part of the Engineering Plan, Rule .1620(d)(4)
requires "A copy of the Design Hydrogeologic Report prepared in
accordance with Paragraph (b) of Rule .1623". Therefore, a Design
Hydrogeologic Study according to the requirements of Rule .1623(b)
is necessary for the "area of investigation" associated with the
proposed new phase of landfill development (Waste Cell 4) . The
"area of investigation" includes the proposed expansion footprint
and surrounding area that is subject to water quality monitoring.
The June 16, 1997, "Permit Modification Landfill Expansion" does
not contain a Design Hydrogeologic Report. Until this Report is
prepared and submitted, the hydrogeologic review of the "Permit
Renewal" for "a permit to construct a lateral expansion" can not be
done. Rule .0202(a)(3) requires that "the geologic study shall
bear the seal of a (N.C.) licensed professional geologist".
P.O. Box 27687, Nvfc
y® FAX [phone]
Raleigh, North Carolina 27611-7687 AnEqual Opportunity Affirmative Action Employer
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Mr. Jack Horton
Haywood County Landfill Expansion
Page 2
Haywood County's consulting geologist should meet with me to
discuss a field,investigation plan for the additional hydrogeologic
investigation required for the proposed new phase of development.
In the Oct. 26, 1996, letter from Bob Hessler to Mr. William Meyer,
Mr. Hessler states the following: "In preparing the current
landfill, springs feeding the west branch were covered. Your
department has stated that landfilling will not be allowed over
these spring locations." Please have your consultant discuss past
and proposed soil borrow and stockpile activities at the White Oak
Landfill facility. Specifically address the allegation that
"springs feeding the west branch were covered".
If you or your consultant have any questions about this letter or
the requirements for "Permit Renewal", or if you would like to
arrange for a meeting to discuss these issues, please call me at
[phone], extension 258.
Sincerely,
&4�tl 41�_
Bobby Lutfy
Hydrogeologist
Solid Waste Section
CC: Jim Coffey, Solid Waste Section
Jim Patterson SWS - Asheville
Stephan MacQueen, Steffen Robertson and Kirsten

State of North Carolina
Department of Environment
and Natural Resources
Division of Waste Management
James B. Runt, Jr., Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
December 8, 1997
Mr. Leonard B. Burgess, Jr., PG
Steffen, Robertson, and Kirsten, Inc.
5641 Piper Drive
Fuquay, North Carolina 27526
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RE: Review Of The Revised Design Hydrogeologic Report of September
1997 For The White Oak Landfill Cell 4 Expansion
Dear Mr. Burgess,
The Permit Renewal Landfill Expansion Design Hydrogeologic Report
for the Haywood County White Oak Sanitary Landfill has been
reviewed by the Solid.Waste Section Hydrogeologic Unit. There are
some further clarifications and revisions needed. •Please respond
to the following comments and questions:
Page is There are several incorrect rule references made on the
Contents Page. Many of the rule references for .1623(b) are
incorrectly referenced as .1623(B).
3.1 The Report incorrectly states "Portions of the requirements
for the Site Hydrogeologic Report are required to be included
in this Design Hydrogeologic Report as outlined in Rule
.1623 (b) (2) (A) ". The intent of (b) (2) (A) is that the same
information required in .1623 (a) (4) through (a) (12) will be
obtained for the design study field investigation. It is not
the intent merely that the previous information from the Site
Plan Application be re -presented in the Design Application.
While, because of the small size of the Cell 4 expansion, the
Solid Waste Section (SWS) is allowing use of the previous
information from the Site Study, the information still needs
to be presented in the context of. the Cell 4 "area of
investigation". For example, rather than merely referencing
cross -sections from the Site Plan Application, cross -sections
need to be prepared that specifically focus on the Ce l 4 area
of investigation.
P.O. Box 29603, Raleigh, North Carolina 27611:9603 Telephone [phone] FAX [phone]
An Equel Opportunity Af irmetivo Action ErrVAajcr 50';, P,�ydod 1 10h F'o zl-Con.un'or F'epor

Mr. Leonard Burgess
WOLF Cell 4 Expansion
Page 2
3.1.1 The information required by (a)(4) (A) through (E) needs to
be presented, evaluated, and documented specifically for the
Cell 4 area of investigation. It would be helpful to have the
boring logs and well construction records for MW-05, MW-05D,
MW-06, MW-07, and MW-07D, along with the boring logs for the
borings in the area (B-113, B-113A, B-114, AT-2, etc.).
Information needs to be provided for formation descriptions,
USCS soil classifications, standard penetration, soil particle
size analyses, saturated hydraulic conductivities, porosities,
and effective porosities representative of the various
lithologic (hydrogeologic) units in the Cell 4 area.
It is stated that "AT-2 penetrated a total of 85 feet without
penetrating bedrock". What was the drilling method for AT-2?
For the purposes of the Design Study the SWS defines top of
bedrock as auger refusal or a standard penetration blow count
of 50/0.21, which is generally the limit of what can be ripped
with conventional earth moving equipment. I believe the AT
borings were drilled using an air track rig, without
performing standard penetration testing. It is probable
therefore that bedrock, as defined by the SWS, was penetrated
but not identified in boring AT-2 due to the drilling method.
This would be supported by your next sentence in the report
that goes on to describe "rock types" for boring AT-2. The
uncertainty of the auger refusal depth for boring AT-2 needs
to be reflected in the discussion, evaluation, cross -sections,
etc. of the report.
3.1.2 In addition to the Hatcher Report, reference is made to test
pits made at the site in order to further define top of
bedrock. The location of these test pits needs to be shown on
Figure 1, and field logs (or some form of documentation) needs
to be provided in the Design Hydrogeologic Report.
3.1.3 As previously referenced, some cross -sections specific to the
Cell 4 area need to be prepared. Based on the borings shown
on Figure 1, the following cross -sections may be appropriate:
first MW-07D, B-114, AT-2, and MW-05D; second MW-01, B-114,
and B-113; and third MW-01, AT-2, and MW-06. If there are
other borings that are more appropriate, then these should be
used. (Also note previous comments regarding top of bedrock.)

Mr. Leonard Burgess
WOLF Cell 4 Expansion
Page 3
3.1.4.2 It is stated that "Very little fluctuation ( <2.5 feet) was
observed in the water table elevation from any of the wells".
However the TABLE OF HISTORICAL GROUNDWATER ELEVATIONS
indicates a fluctuation of over three feet for well MW-02 and
a fluctuation of almost seven feet for well MW-04.
3.1.4.3 There is little evaluation and no estimation of "long-term
seasonal high water table" elevations for the Cell 4 area, as
required by .1623 (a) (7) (C) .
3.1.5 The final summary statement relates to "flooding", but there
is no discussion of "natural or man-made activities that have
the potential for causing water table fluctuations". For
example, lining the MSW cell could cut off recharge and
potentially lower ground -water table elevations.
3.1.6 Additional evaluation and discussion is needed on "horizontal
and vertical dimensions of ground -water flow" specific to the
Cell 4 area of investigation. Is the vertical head difference
in the two well nests referenced downward or upward
(indicating recharge or discharge conditions)? What are the
actual vertical gradients? Do the vertical gradients change
over time? They appear to change for MW-07/07D. What are
possible reasons for this? I do not understand the last
statement that "a potential release from the landfill would
not be a threat to groundwater aquifers". Why would the
aquifers between the waste boundary and the discharge point
(the Pigeon River) not be affected?
3.1.7 "The water table elevations or potentiometric data at each
location used to generate the ground -water contours" are not
"shown on the ground -water contour map (s)", as required by
.1623 (a) (9) .
3.1.9 As previously referenced in this letter, please also include
well construction records and boring logs for the monitoring
wells used in the evaluation of Cell 4.
3.4 More specific discussion needs to be provided for rock core
data used in evaluation of the Cell 4 area of investigation.

Mr. Leonard Burgess
WOLF Cell 4 Expansion
Page 4
3.5 No ground -water contour map has been provided "based upon the
estimated long-term seasonal high water table".
3.6 A bedrock contour map needs to be presented that provides the
"top of rock elevations used to generate the upper surface
bedrock contours". What is the basis used to establish the
bedrock contours shown on Figure 1?
3.7 Sheets 4 through 7 are not hydrogeologic cross -sections and do
not "characterize the vertical ground -water flow regime for
this area".
3.8 This paragraph does not address each of the items referenced
in .1623 (b) (2) (H) .
3.9 Have all the borings in the vicinity of the Cell 4 area of
investigation been properly abandoned?
4.1 Provide some discussion on why the existing monitoring system
is adequate to detect a release from Cell 4. Does the
hydrogeologic information indicate that there are existing
monitoring wells located downgradient of Cell 4?
The Design Hydrogeologic Report needs to be formatted and presented
in such a way as to focus on the Cell 4 area of investigation. The
discussion and evaluation should specifically relate to the Cell 4
area of investigation. Broader support documentation may be
included in the report.
If you have any questions regarding this letter or would like to
discuss these issues in more detail, please contact me at (919)
733-0692, extension 258.
Sincerely,
Bobby Lutfy, Hydrogeologist
Solid Waste Section
CC: Bill Sessoms, Solid Waste Section
Jim Patterson,.SWS - Asheville
Jack Horton, Haywood County Manager

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EPA Form 1300-6 (7-72)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
yI`
Type of Faci l ii ty/ r i 4 Y .)Permi t# County 3 "�, j }^:'`0 0
Name of Foci Lity i 6J1�U tQ tS Location V'Y,'%i't bk^L,udYiYr a
Date of Last Evaluation
I_ Permit Conditions Followed Y--Yes No N/A
A. Specific Condition(s) Vio
II. operational Requirements Followed Yes No
15A N.C. Admin. Code 13B Section + �'
A_ Specific Violations) by number and letter.
III. other Violations of Rule or Law
IV. Evaluator's Comments rJ t 1rY'
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V. Continuation Page Required? Yes '"No Receiving Signature
Evaluation Date f^ �. % Solid Waste Section y
DEHNR 3793 (Part I bite: Facility Part II Canary: Central Office Part III Pink: Regional office)
Solid Waste Section (Review 7/%)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid waste Section
SOLID WASTE MANAGE ENT FACILITY EVALII,TION REPORT
(7�.q((
Type of Faci L i ty ` i (1 -) Permit # it � / Canty /) #-h to ra A !
Name of Facility%Qr I t ){ .Y'-J 1,�)((.,•. �nr CU ?vG� J/� Location
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Viol
II. Operational Requirements Followed Yes No
15A N.C. Admin. Code 138 Section
A. Specific Violation(s) by ember and letter.
i[' ii�VGt.� l%%17t11� �t�
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III. Other Violations of Rule or
IV. Evaluator's
V. Continuation Page Required? Yes No Receiving Signature
Evaluation Date Solid Waste Section
DEHNR 3793 (Part I bite: Facility Part I1 Canary: Central Office Part III Pink: Regional office)
Solid Waste Section (Review 7/94)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE NANAGE ENT FACILITY EVALUATION REPORT
Type of Facility. Permit # County r`
14
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Name of Facilityt �,�Z./�!t_ Location ��� !�%f,.,+�»r �.t•�.lj_.
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
1
II. Operational Requirements Followed Yes No
15A N.C. AcImi n. Code 13B Section
A. Specific Violation(s) by number and letter.
III. Other Violations of Rule or Law
IV. Evaluator's Comoents
V. Continuation Page Required? Yes No Receiving Signature (;
Evaluation Date Solid Waste Section f � 'i1
DEHNR 3793 (Part I White: Facility Part II Canary: Central office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

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NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Nanaggrent
Solid Waste Section
SOLID WASTE MANAGEIENT FACILITY EVALUATION REPORT
Type of Facility ; 11 r - Permit # county.
Name of Foci lity ��j2{ wi2od Location
Date of Last Evaluation -) I V / q 7
I_ Permit Conditions Followed j_ Yes No N/A
A_ Specific Cordition(s) Vi
II. Operational Requirements Followed Yes No
15A N.C_ Admin. Code 130 Section
A. Specific Violation(s) by number and letter.
III. Other Violations of Rule or Law
IV. Evaluator's Can•ents
V. Continuation Page Required? Yes No Receiving Signature
Evaluation Date Solid Waste Section
DEHNR 3793 (Part I White: Facility Part II Canary: Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

-,IN
NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid haste Management ---
Solid Waste Section
SOLID WASTE MAMAGElENT FACILITY EVALUATION REPORT
Type of Faci l i ty iI' 'rI .`) � Permit } ...i:, f` minty,
Name of Facility9i/ JV1,� l "Y ! ilk / Location l'[/ ► �%�" _. ijPY+ /Ipii of
Date of Last Evaluation Nr I r r
1. Permit Conditions FollowedYes No N/A
A. Specific Condition(s) Vio
II. Operational Requirements Followed Yes No
15A N.C_ Admin. Code 13B Section tk11 ?,
A_ Specific Violation(s) by number and letter.
III. Other Violations of Rule or Law
IV. Evaluator's Comments r E'.r j• , ?�1 ` ;> ,
Y. Continuation Page Required" Yes No Receiving Signature
Evaluation Date l.' (rt' Fi ' Solid Waste Section
DEHNR 3793 (Part I bite: Facility Part II canary: Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

State of North Carolina
Department of Environment
Health and Natural Resourc
Division of Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L, Meyer, Director
Mr. Joe Walker
e � •� s>
JUN 1997 0
cl SWS.WSRO co
�leoe L`AL�or
June 2, 1997
Haywood County Solid Waste Management
1 Recycle Road
Clyde, N.C. 28721
EDEHNR
RE: Water Quality Monitoring Requirement - White Oak Landfill
Dear Mr Walker:
North Carolina Solid Waste Management Rules (Rule .1632) require a statistical analysis of
monitoring data, and the determination of groundwater flow rate and direction each time the
monitoring wells are sampled at all operating municipal solid waste landfills. The report for the
April 30, 1997 sampling event at the new landfill did not include this information. Please
provide this information to the Solid Waste Section as soon as possible and include it as part of
all future water quality monitoring reports.
Thank you for your cooperation. If you have any questions, please call me at [phone],
ext. 257.
Sinc rely,
Larry ose
Hydrogeological Technician
Solid Waste Section
c: Julian Foscue
Jim Patterson
P.O. Box 27687, ��� FAX [phone]
Raleigh, North Carolina 2761 1-7687 An Equal Opportunity Affirmative Action Employer
Voice 919-733-4996 50% recycled/10% post -consumer paper