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1. 0 Addressee's Address
permit.
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2. 13 Restricted Delivery
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delivered.
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4a. Article Number
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4b. Service Type
Mr. Bobby Co9dill, Director
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Haywood County Solid Waste Department
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278 Recycle Drive
Clyde, NC 28721
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NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
check all that apply to this
audit with same Permit number
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: HAYWOOD
MSWLF
PERMIT NO.: 44-07
Closed
HHW
white
lnein
T&P
FIRM
MS W LF
goods
FILE TYPE: COMPLIANCE
CDLF
X
Tire T&P:
Tire
Industrial
DEMO
SDTF
Collection
Mono611
Landfill
Date of Audit: 8/4/04
FACILITY NAME AND ADDRESS:
Haywood County Construction and Demolition Landfill
State Road 1338, Whiteoak Community
Waynesville, NC 28786
FACILITY CONTACT NAME AND PHONE NUMBER:
Bobby Cogdill, Haywood County Solid Waste Director
Telephone: 828-627-8042
FACILITY CONTACT ADDRESS (IF DIFFERENT):
Bobby Cogdill, Director
Haywood County Solid Waste Department
278 Recycle Drive
Clyde, NC 28721
AUDIT PARTICIPANTS:
Jim Patterson, NCDENR, Solid Waste Section
Jeremy Parker, Haywood County Solid Waste Department
STATUS OF PERMIT:
Active - Permit to operate issued on November 18, 2002.
PURPOSE OF AUDIT:
Inspection of Construction and Demolition Landfill.
NOTICE OF VIOLATIONS) (citation and explanation
None
Date of Last Audit: 4/14/04
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $5,000 per day may be assessed for each
violation of the Solid Waste Statute or Regulations. If the violation(s) noted here continue, 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 (List all noted last audit):
N/A
FACILITY COMPLIANCE AUDIT i '.'ORT
Division of Waste Management
Solid Waste Section
Page 2 of 2
OTHER COMMENTS /SUGGESTIONS:
(1) The edge of waste is exposed along the access road. This area needs to be properly sloped and seeded.
(2) Haywood County must provide an area for disposal or recycling (mulching) of yard waste. This waste cannot be
disposed of in an MSW or C and D Landfill. Either an LCID Landfill needs to be permitted or a treatment and
processing permit must be obtained to properly deal with this waste.
PI e contact me if you have any questions or concerns regarding this audit report.
- Phone: 828-296-4500
Regional Representative/WMS
Mailed on : 5 August 2004 by hand delivery X US Mail Certified No. F I
Distribution: original signed copy to facility — signed copy to compliance officer — email or copy to supervisor
CC: Brent Rockett Mark Poindexter
DENR — Solid Waste Section Division of Waste Mgt.
585 Waughtown Street Solid Waste Section
Winston-Salem, NC 27107 401 Oberlin Road
Raleigh, NC 27605
Bf,ARD OF COMMISSIONERS
BILL D. NOLAND, CHAIRMAN
MARK SWANGER, VICE CHAIRMAN
KEVIN ENSLEY
CARLYLE FERGUSON
J. W. "KIRK" KIRKPATRICK, III
March 29, 2004
Mr. James Coffey, Chief
Solid Waste Section
Division of Waste Management
NC Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, NC 27699-1601
RE: Permit #44-07
Dear Mr. Coffey,
I am writing in response to your letter dated March 18, 2004 and received March 24, 2004,
pertaining to the Haywood County Landfill.
COUNTY MANAGER
C. JACK HORTON
COUNTY ATTORNEY
LEON M. KILLIAN, III
County staff and hired contractors have been working to solve this problem for several
weeks. The sump has been located. The sump was clogged up and only allowed a trickle
of leachate to leave the landfill. The sump has been cleaned out completely by staff and
contractors and the leachate system is working properly. Three- (3) inch stone is being
placed in the sump and on top around it to assure conditions that will allow leachate to
flow. The area will be left open for a period of time to be sure that the system is
operating as designed.
2. The sediment basin will be cleaned out starting no later than Monday, March 291h. The
referenced plan will be followed.
3. The sump area has been corrected and is now operational.
4. The sump is open and operational. Large 3" stone is being placed around the area to
protect the sump from becoming clogged again.
The landfill should be back to its permitted conditions and no permit modification should be
necessary.
215 NORTH MAIN STREET - COURTHOUSE ANNEX - WAYNESVILLE, NORTH CAROLINA 28786
PHONE:828.452.6625 - FAX:828.452.6715
Mr. James Coffey
March 29, 2004
Page 2
If you have any questions, please do not hesitate to contact me or Bobby Cogdill.
Sincerely,
%
Ja&cof
County Manager
cc: Bobby Cogdill
Rick Honeycutt
Wayne Sullivan
Jim Patterson
March 1, 2004
Mr. James C. Coffey, Section Chief
Solid Waste Section
Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
Re: Compliance Order
Haywood County Municipal Solid Waste Landfill- Whiteoak Community
Permit #44-07
Dear Mr. Coffey:
I am writing in reference to the compliance order for the above -referenced landfill issued
February 11, 2004, and received by Haywood County on February 17, 2004. An informal
meeting was held in the County Manager's office on Wednesday, the 25th of February, to discuss
progress to date. Attendees at the meeting were:
Jack Horton, County Manager;
Rick Honeycutt, Assistant County Manager;
Bobby Cogdill, Solid Waste Director;
Jim Patterson, Solid Waste Management Specialist; and,
Wayne Sullivan, Project Manager.
The original plan was to excavate waste so that the sump would be exposed and place additional
stone so that the leachate that was discharging through the berm would have a direct route to the
leachate collection system. Once this was complete, then the County was going to further
excavate the trench that was inside the landfill and that contained leachate.
A contractor was hired by the County to do the excavation. They began their work, which
involved constructing an access to the excavation area, on the IOth of February. On the 1 lth of
February, excavation into the sump began. At the time, leachate was flowing from the berms at a
higher elevation than we were excavating into the sump. This flow had to be diverted from the
working area so that it would not interfer with the excavation. This was done with a trench that
by passed the area being excavated. The excavation into the sump continued through the day
with water coming into the excavation from above and not below. By the end of the day, the
water that was flowing from the berms and the by pass had stopped and was flowing into our
excavation from above. The next day no work was done because of snow; however, water was
still entering the excavation from above and not from below, as if the sump was not flowing.
Fv omen di, Uduiei, rvvnii UdIU1111d uo[a tyly) //L-b3y3 ---
PO Box 828, Morehead City, NC 28557 (252) 726-9481 PO Box 349, Boone, North Carolina 28607 (828) 262-1767
Excavation started back the 10" of February by excavating horizontally into the landfill and not
vertically. Excavation vertically did not start until the next day, at which time stone in the sump
area was exposed. The area exposed was not a large area, but clean stone was observed with no
water standing in the stone. At the time, the intentions were to place additional stone over this
area so that the leachate that was flowing from above would flow into this area. However, in an
attempt to horizontally clean more waste from over the sump, additional perched water was
released. The release of this perched water had a direct effect on the water level that was in the
excavated trench that was within the landfill.
The volume of this leachate was too great for the amount of exposed sump, and it is believed that
it actually blinded the sump area that was exposed when it flowed over it. As a result, some of
this leachate escaped back through the excavated area. At this time, the only additional
excavation that has occurred is to horizontally remove more waste so that more of the sump area
can be exposed. The flow of leachate outside the liner can and has been retained inside the liner
by berming up the excavated area. The leachate is then pumped fiom the excavation into the
nearest manhole where it flows to the leachate lagoon.
At the present time there is no leachate escaping the landfill. Leachate can be pumped faster
than it flows into the excavation; consequently, the County is going to continue pumping until
there is no more flow, at which time vertical excavation into the sump will resume. The plan is
to assure that the sump is free flowing so that the leachate that flows and will continue to flow
from above will have a direct route to the sump. The sump will be excavated and pressure
washed to flush out sedimentation that may have occurred. The excavation over the sump will
then be filled with a combination of the 3-inch washed stone, broken concrete, asphalt, or other
material that will allow flow from the weeping areas above to the sump. Once the excavation is
backfilled, a geotextile will be placed over the area so that sediment from the soil cover cannot
migrate into the fill. No soil cover will be placed over this area until it has been assured that the
leachate flowing through this fill has a free path to the sump and into the lagoon.
As stated earlier, the water that had been in the trench had a direct tie to the perched water that
was released when additional waste was removed from over the sump area. Consequently, this
area is going to be excavated to the top of the protective cover and to at least one leachate trench.
This excavation will also be filled with rock and material that will allow flow directly to the
leachate collection system and stop the horizontal migration of the leachate in this area. In the
remaining area of the landfill where the fill is only one bale deep, the soil cover is going to be
removed, where practical, so that leachate will flow down instead of horizontally along the soil
cover. The process of removing soil cover prior to the placement of the next lift of bales will
continue throughout the filling of this phase of landfill.
Leachate has been pumped from the sediment basin into the nearest manhole leading to the
leachate lagoon. At the present time, no leachate is running into the sediment basin because it is
contained within the landfill. Haywood County will hire Pace Laboratories to sample soil and
water for contamination within the sediment basin and adjoining landfill berm.
The sediment basin is full of sediment and will require cleaning. Haywood County is going to
clean the basin; however, prior to cleaning the basin, soil samples and water samples will be
obtained at the approximate locations shown on the attached map. This map shows the sediment _
basin and the adjoining slope from the landfill. Once these samples have been obtained,
sediment can be removed from the basin. Soil and water samples will be taken in the same
locations to assure that no contaminated soil remains after the basin has been cleaned.
Soil at the excavation site will have to be removed because of the waste that remains in the soil.
This soil will be hauled into the landfill and used for cover soil. The saturated sections of the
exterior berm are surficial because heavy equipment has been using the area as access and has
had no problem traversing these areas. This soil will be removed if it has not dried at the time
the berm is being repaired. If it is dry, it will be used as repair soil for the berm where it has
been disturbed due to the excavation.
The stability within the waste has been shown to be adequate because the excavation to the sump
is approximately 40 feet deep from the top of the fill. The waste is dry for about 25 feet until we
get to the layers where water is perched. This waste is also stable because the water has not been
able to penetrate the bale because its preferential flow path is around the individual bales.
Consequently, the excavation that we have done has not had any failure other than small amounts
of soil and waste that have fallen from above.
The schedule for performing the planned tasks is as follows:
1. Pumping the excavation dry so that the sump can be vertically excavated,
pressure washed and backfilled with stone will be completed by March 19, 2004;
2. Obtaining soil and water samples from the sediment basin and adjoining berm
will be completed by March 26, 2004;
3. Excavation of the trench within the landfill and tying it directly in to the leachate
collection system will be completed by April 1, 2004;
4. Removal of the sediment from the sediment basin and any contaminated soil on
the berm including soil where waste is present, to be completed by April 30,
2004; and,
5. Obtain additional soil and water samples, assuring that all contaminated soil has
been removed, by May 15, 2004; and,
6. Re -grade berm area in excavation location and previous wet areas.
If you have any questions or need additional information, please do not hesitate to call.
Sincerely yours,
D. Wayne Sullivan
Cc: Jack Horton
Rick, Honeycutt
Bobby Cogdill
Jim Patterson
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MEMORANDUM
Date: February 3, 2004
To: Mark Poindexter, Jim Barber
From: Bill Sessoms
Ref: Haywood County Landfill
Site Visit Observations
Exterior of Landfill — Liner Bench to Sedimentation Basin
There are approximately 5 flowing leachate outbreaks along the base of the waste berm
at the intersection of the exterior bench.
Numerous additional areas along the intersection of the waste berm and exterior bench
were saturated — suggesting that leachate was migrating over the liner but had not
broken through the surface.
4 areas where slope failure had occurred due to leachate saturated soil.
Leachate flow observed down slope from the landfill berm / bench towards the sediment
basin.
Erosion rills initiated by leachate flow start at the liner bench and continue to the
sediment basin. Erosion is initially caused by leachate flow — but is exacerbated by rain
runoff.
Interior of Landfill — Within Cell Liner
Daily cover appears to be dense clay like material.
Excavated trench — filled to within a couple of feet with leachate / liquid.
Unknown trench depth — but was told that it was about 16 feet deep.
I have serious concerns about the stability of the waste cover and berm at the low end
of the landfill where leachate is escaping. The soils in that area are mostly saturated
with leachate. However, the nature of the waste placement, in bales, is possibly helping
to keep the waste slope stable. And, while leachate is escaping the lined cell — its
release may be helping to relieve hydrostatic pressure within the landfill.
The Municipal Engineering (ME) letter dated January 19, 2004 gives a general outline of
their plans to remove leachate from the landfill — and to handle the leachate leaks.
ME has only communicated a time frame for getting a contractor to the site to contain
the leachate leaving the lined area.
Recommendations
Short term recommendations
Leachate escaping the lined area should be contained immediately. The flat bench
area on the exterior of the berm should be looked at to see if it can be
utilized/graded to construct a sump to capture leachate that is escaping the lined
cell. Leachate could be captured and pumped to the nearest manhole. However,
the ability to do this is dependent upon saturation of the bench area soils. Haywood
County should use extreme caution when investigating if this is practical. Possibly a
small berm on the down streamside could be constructed, the bench graded to slope
to a low point near the center, and a small pump placed there to evacuate the
leachate. Consideration should also be given to placing a temporary liner in this
bench/swale to help facilitate capturing the leachate and draining it towards a sump.
However, it cannot be stressed enough that extreme caution in construction in this
area is necessary to avoid slope failures and weakening of the entire berm structure.
2. Pumping in the trench within the landfill should begin immediately. Effects of
pumping this trench may only be localized. However, any and all efforts should be
undertaken to remove leachate from the landfill to reduce head and hydrostatic
pressure.
Municipal Engineering's letter dated January 19, 2004 proposed removing waste,
soil, and possibly stone within the landfill to expose the sump and to allow leachate
to drain into the sump for pumping. This plan should be implemented as soon as
possible.
4. Leachate appears to be collecting in the sediment basin. While the
amounts/proportions are unknown, the Solid Waste Section recommends that the
liquid in the sediment basin be considered leachate until proven otherwise. Pumping
of the sediment basin should begin immediately until it is emptied. Then, assuming
that leachate flow out of the landfill has been contained, an assessment can be
made on surface rain water run off into the basin to determine how much
contamination has been accumulated within the saturated soils.
Longer range recommendations
5. The landfill leachate drainage system is not working. That is not to imply that the
drainage system is defective. It appears that leachate is somehow prevented from
reaching the drainage system. Once the landfill has been sufficiently pumped
(assuming the short-term repairs to the sump area are effective), the landfill should
be evaluated to determine why the overall leachate collection system is not
performing as intended.
6. Corrective action should be undertaken as soon as possible to get the leachate
drainage system operable. This may require removing waste above the collection
line trenches and extending the permeable stone trenches up through the waste to
allow leachate flow through the various layers of baled waste.
7. The cover soil should be examined to determine if the cover soil is preventing
leachate from flowing through the landfill to the drainage system. It may be that
operations might have to be modified to allow leachate flow.
8. The extent of soil and groundwater contamination due to the leachate escaping the
landfill should be determined. Once the extent of contamination is defined,
decisions can be made on corrective action/remediation.
9. The existing berm should be evaluated for stability due to leachate saturation.
10. The soil down the slope of the berm should be evaluated for stability due to leachate
saturation.
11. The sedimentation pond should be examined to determine the extent of leachate
contamination.
OPERATION/CONSTRUCTION MANAGERS
Municipal
Services
January 19, 2004
Mr. Bill Sessoms
Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
Re: Haywood County Landfill
Permit Number 44-07
Dear Mr. Sessoms:
01
CIVIUSANITARY ENGINEERS
Engineering
Company, P.A.
I am writing to report on the drilling that was performed through the waste at the above
referenced landfill in an attempt to promote drainage through the intermediate soil
layers. The idea was that we could penetrate an intermediate soil layer in several points
to allow perched water a path into the leachate collection system.
I We surveyed four (4) points to know how deep we could go before we were at the
protective cover. Our drilling depth was based on the top of the bale that was on the
bottom of the landfill. We drilled three (3) holes at three (3) of the survey points and to
the depth that we determined that would be at the top of the bottom bale. At each
location there was a considerable amount of water on top of the bottom bale particularly
at Point Number 3, which is near the low point in the landfill. The bottom layer of bales
around the sump had been covered with intermediate soil and water was perched on top
of the lower bales. We did not want to take the chance of advancing the drilling any
further than the top of the bottom bale; consequently, we stopped drilling. We did drill a
hole back from the sump area to determine if the waste had the high moisture content at
approximately the same elevation as had been determined by the previous three (3)
drilled holes. High moisture had been detected at approximately 23 feet in the previous
three (3) holes. The same was true in the last hole that was drilled.
The first three (3) holes were filled with stone so they could act as a temporary gas vent
and the last hole was filled with the waste that had been drilled out of it.
Once we completed the drilling, we decided to see if we could determine whether or not
the leachate system could be clogged. The County had a tanker truck full of leachate
that we decided to unload into one of the cleanouts. Prior to the unloading of the tanker,
I was at a down stream manhole to observe whether or not I could determine if the flow
changed while we were unloading the leachate. The tanker truck holds approximately
6,000 gallons and it takes approximately 45 minutes for it to empty. There was already a
good flow coming through the collection system of Phase 2 and I could not tell whether
or not the flow increased while I was at the manhole. However, I did observe a decrease
PO Box 97, Garner, North Carolina 27529 (919) 772-5393
PO Box 828, Morehead City, NC 28557 (252) 726-9481 PO Box 349, Boone, North Carolina 28607 (828) 262-1767
Mr. Bill Sessoms
Page —2-
January 19, 2004
in the flow not knowing whether or not the tanker had been emptied. As I was walking
away from the manhole, the tanker truck was pulling up to the leachate lagoon to get
another load. Consequently, I made the assumption that the decrease I observed was
that the leachate from the tanker truck has stopped. Along with the fact that there was
presently a substantial flow from Phase 2 and what I observed, the leachate system
cannot be clogged to the point that no flow gets thru it.
When the weeps were originally observed they were high on the east bank at the north
end of the embankment. The solution to the problem was to pull back the cover that was
over the bales at the weeps and replace the cover soil with washed stone. This was
done at the weeps that were present at the time and the washed stone was put down at
the toe of the slope to a point near the sump. The point near the sump had some waste
removed so that the washed stone could replace it. The area near the sump was not
wet and the water that was flowing down to this area from the weeps would flow back
into the landfill at this point. Eventually washed stone was placed in the low point and
several feet of loose fill was placed over the entire area. The surface of the loose fill was
compacted with a bulldozer and the entire area was seeded.
Everything seemed to be working until a large storm passed through the area. Within a
few days of the storm, the County observed weeps in the same area as before and at
the bottom of the slope where the stone had been placed near the sump. Water was
wicking back up through the loose fill and eventually creating sloughs where it was
failing on the slopes. Also, the seepage that was meant to go into the landfill may have
been taking the point of least resistance, which is the opposite way through the washed
stone. Also, the gas that is migrating from the bank of the landfill is following the washed
stone and bubbling out through the water or in a couple of instances, the soil that is
covering the stone.
As soon as the weather permits and the berm is relatively dry, we propose that the
County remove the soil and if necessary, the washed stone that has been filled along the
back berm. Once this has been removed, we propose to construct a berm to retain the
leachate within the lined landfill area and pump this leachate to the nearby manhole that
drains to the lagoon. The timing of the pumping will have to be monitored and operated
manually. We propose to continue to do this until late spring or when the embankment
appears dry enough to support equipment. This will allow for an excavation to be made
through the waste to the sump to clear a path where washed stone can be placed so
that the washed stone at the weeps has a direct route or at least the most direct route to
the leachate collection system.
Mr. Bill Sessoms
Page —3-
January 19, 2004
Attached is a drawing of the landfill showing the survey points (3, 8, 9 &10) and the
location of the wet areas with their elevations. The borings were placed at survey points
3, 8 & 9. If you have any questions or need additional information, please do not
hesitate to call.
Sincerely yours,
MUNICIPAL ENGINEE G SERVICES CO., PA
D. Wayne Sullivan
Project Manager
Enclosure
Copy: Mr. Bobby Cogdill
Mr. Jim Patterson
DRAFT
January 13, 2004
Mr. Bill Sessoms
Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
Re: Haywood County Landfill
Permit Number 44-07
Dear Mr. Sessoms:
I am writing to report on the drilling that was performed through the waste at the above
referenced landfill in an attempt to promote drainage through the intermediate soil
layers. The idea was that we could penetrate an intermediate soil layer in several points
to allow perched water a path into the leachate collection system.
We surveyed four (4) points to know how deep we could go before we were at the
protective cover. Our drilling depth was based on the top of the bale that was on the
bottom of the landfill. We drilled three (3) holes at three (3) of the survey points and to
the depth that we determined that would be at the top of the bottom bale. At each
location there was a considerable amount of water on top of the bottom bale particularly
at Point Number 3, which is near the low point in the landfill. The bottom layer of bales
around the sump had been covered with intermediate soil and water was perched on top
of the lower bales. We did not want to take the chance of advancing the drilling any
further than the top of the bottom bale; consequently, we stopped drilling. We did drill a
hole back from the sump area to determine if the waste had the high moisture content at
approximately the same elevation as had been determined by the previous three (3)
drilled holes. High moisture had been detected at approximately 23 feet in the previous
three (3) holes. The same was true in the last hole that was drilled.
The first three (3) holes were filled with stone so they could act as a temporary gas vent
and the last hole was filled with the waste that had been drilled out of it.
Once we completed the drilling, we decided to see if we could determine whether or not
the leachate system could be clogged. The County had a tanker truck full of leachate
that we decided to unload into one of the cleanouts. Prior to the unloading of the tanker,
I was at a down stream manhole to observe whether or not I could determine if the flow
changed while we were unloading the leachate. The tanker truck holds approximately
6,000 gallons and it takes approximately 45 minutes for it to empty. There was already a
good flow coming through the collection system of Phase 2 and I could not tell whether
or not the flow increased while I was at the manhole. However, I did observe a decrease
Mr. Bill Sessoms
Page —2-
January 13, 2004
in the flow not knowing whether or not the tanker had been emptied. As I was walking
away from the manhole, the tanker truck was pulling up to the leachate lagoon to get
another load. Consequently, I made the assumption that the decrease I observed was
that the leachate from the tanker truck has stopped. Along with the fact that there was
presently a substantial flow from Phase 2 and what I observed, the leachate system
cannot be clogged to the point that no flow gets thru it.
When the weeps were originally observed they were high on the east bank at the north
end of the embankment. There was very little cover over the bales at that time. The
solution to the problem was to pull back the cover that was over the bales at the weeps
and replace the cover soil with washed stone. This was done at the weeps that were
present at the time and the washed stone was put down at the toe of the slope to a point
near the sump. The point near the sump had some waste removed so that the washed
stone could replace it. The area near the sump was not wet and the water that was
flowing down to this area from the weeps would flow back into the landfill at this point.
Eventually washed stone was placed in the low point and several feet of loose fill was
Placed over the entire area. The surface of the loose fill was compacted with a bulldozer
and the entire area was seeded.
Everything seemed to be working up until a large storm passed through the area. Within
a few days of the storm, the County observed weeps in the same area as before and at
the bottom of the slope where the stone had been placed near the sump. Water was
wicking back up through the loose fill and eventually creating sloughs where it was
failing on the slopes. Also, the seepage that was meant to go into the landfill may have
been taking the point of least resistance, which is the opposite way through the washed
stone. Also, the gas that is migrating from the bank of the landfill is following the washed
store and bubbling out through the water or in a couple of instances, the soil that is
covering the stone.
As soon as the weather permits and the berm is relatively dry, we propose that the
CoUntyremove the soil and if necessary, the washed stone that has been filled along the
back berm. Once this has been removed, we propose to construct a berm to retain the
leachate within the lined landfill area and pump this leachate to the nearby manhole that
drains to the lagoon. The timing of the pumping will have to be monitored and operated
rn a nually. We propose to continue to do this until late spring or when the embankment
aPPears dry enough to support equipment. This will allow for an excavation to be made
th rough the waste to the sump to clear a path where washed stone can be placed so
th at the washed stone at the weeps has a direct route or at least the most direct route to
the leachate collection system.
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