4407_ROSCANS_2010

HAYWOOD COUNTY MSW LANDFILL
PERMIT # 44-07
HAYWOOD COUNTY, NORTH CAROLINA
FACILITY COMPLIANCE AUDIT REPORT
June 11, 2010
STATUS OF PAST NOTED VIOLATIONS:
ONGOING: 15A NCAC 13B .1626 (2)(c) for failure to replace the minimum of one,foot of
intermediate soil cover over exposed waste resultingfrom activities in August 2009.
In order to achieve compliance, Haywood County must, within 14 days, submit, in writing, a
plan to address the lack of intermediate soil cover. This plan should be submitted to the Solid
Waste Section Permitting Branch, Allen Gaither, at the Asheville Regional Office.
RESPONSE:
The following description/plan of action describes the steps Haywood County intends to
undertake to remedy the apparent exposed waste material along the interface tie-in between the
existing Phase 2 Landfill Cell and the newly constructed Phase 3 Landfill Cell:
Once the Permit To Operate is received for the Phase 3 Landfill Cell, the County intends to begin
activities necessary to permanently remediate the apparent exposed waste material located along
the Phase 2/Phase 3 interface. At the present time access to the area in question is somewhat
limited and poses safety issues for the landfill staff and therefore only temporary measures have
been attempted. In order to safely access the area in question, the County intends to construct a
working platform, comprised of waste material and adequate daily cover, within the Phase 3 cell
and along the entire length of the Phase 2 tie-in. This platform will provide working room and
safe access to the apparent exposed waste along Phase 2. Once the platform within Phase 3 is
constructed, waste material will be worked up and against the Phase 2 Landfill Cell to cover the
apparent exposed waste as well as provide a gradual slope on which cover material can be placed
to adequately cover any exposed waste and allow the controlled run off of stormwater. The
County intends to complete all remediation activities associated with this plan of action within
sixty (60) days fiom the date waste placement activities begin in Phase 3. However, additional
time may be required depending on the volume and characteristics of the present daily waste
stream. It should also be noted that the County may be required to operate two active working
faces (Phase 2 and Phase 3) simultaneously due the makeup of the present waste stream. The
County presently receives C&D type waste in its daily waste stream and this type of waste
material should not be utilized for the construction of the initial layer of waste within a newly
activated cell. C&D waste and other types of waste unacceptable for the construction of the
initial waste layer will continue to be disposed of in Phase 2 until such time as the initial layer of
waste within Phase 3 is complete.

The initial step, after receiving the Permit To Operate, will be to remove a section of the
temporary rain cover in Phase 3 along the western -most tie-in with Phase 2. This will be done in
order to access the Phase 3 Landfill Cell and begin the placement of waste material in Phase 3
along the interface with Phase 2. The removal of the temporary rain cover will progress to the
east as the initial layer of waste material is placed across the designated area. Daily cover will be
placed at the end of each day's work, or more often as field conditions dictate. The amount of
temporary rain cover to be removed will be detenxnined in the field each day as work progresses.
Care will be exercised to ensure the initial layer of waste material does not contain any waste
material that may cause damage to the liner system in Phase 3.
Once the initial layer of waste is placed in Phase 3, subsequent layers of waste material will be
placed and compacted until such time as the surface of the working platform reaches at least the
elevation of the tie-in to Phase 2. Daily cover will be placed at the end of each day's work or
more often as field conditions dictate. This will be done along the entire length of the Phase
2/Phase 3 tie-in.
After the working platform is completed izf the Phase 3 Landfill Cell, the initial layer of waste
material will be placed along the tie-in berm and worked up and against the exposed Phase 2 tie-
in slope. Subsequent layers of waste will be place and compacted against the tie-in to Phase 2 to
construct a slope generally matching the existing slope of the Phase 2 Landfill Cell; however, the
slope shall be no steeper than two horizontal to one vertical (2:1). Daily cover will be placed at
the end of each day's work or more often as field conditions dictate. Once the construction of
the slope is complete, adequate cover material will be placed to ensure the complete coverage of
waste and measures will be installed to control storinwater runoff.
Sheet 1 of 2, included as an attachment to this description/plan of action, depicts a general layout
of the working platform to be initially constructed within the Phase 3 Landfill Cell and the
proposed tie-in to the existing exposed edge of the Phase 2 Landfill Cell. Sheet 2 of 2, also
included as an attachment to this description/plan of action, depicts a general cross-section of the
proposed working platform and subsequent tie-in to the exposed edge of the Phase 2 Landfill
Cell. Exact .dimensions, elevations and slopes, etc. will be determined in the field as work
progresses.
The North Carolina Department of Environment and Natural Resources (NCDENR) will be
notified when work on this particular plan of action begins and will be kept updated on the work
as it progresses. NCDENR will also be notified when the work is complete.
Once this operation has been completed, the County will resume waste disposal operations in the
Phase 2 Landfill Cell until such tune as available disposal space dictates moving the disposal
operation to the Phase 3 Landfill Cell area.

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A S S O C I A T E S
Engineering • Planning C Finance
McGill Associates, P.A. P.O. Box 2259, Asheville, NC 28802
55 Broad Street, Asheville, NC 28801 828-252-0575 Par 828-252.2518
PROJECT: AW W
PROJECT NO.: 7,Q*
DESCRIPTION:
CALCULATED BY: CHECKED BY:
DATE: 1e116 SHEET NO./ OF

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PROJECT NO.:mc H1
A S S O C I A T E S DESCRIPTION: eno--, AcA
Engineering m Planning m Finance CALCULATED BY: &N-T CHECKED BY:

RECEIVED
MAR 10 2010
,AICSOLID WASTE SECTION
A Transmittal
SNEVILLE REGIONAL OFFICE CM
5400 Glenwood Avenue Suite 300
Raleigh, North Carolina 27612
919 787-5620 Phone
919 781-5730 Fax
To: Andrea Keller From: Mat Colone
Organization/ NCDENR — Division of Waste
Address: Management Date: March 8, 2010
2090 US Highway 70
Swannanoa, North Carolina 28778
Re: Buncombe County Substantial Amendment and Phase 5 PTC Application
Job #
Via:
Response to Comments — Landfill Gas Monitoring Plan
6447-65973
Mail. XX Overnight:
Enclosed please find:
For your information
For your review
For your signature
It
Courier. -
Approved
Approved as noted
Returned to you for correction
Message:
Andrea,
Attached, please find 1 copy of the Response to Review Comments from Zinith Barbee's February 12, 2010 letter with
applicable revisions and attachments for your files.
If you have any questions, please feel free to call me at 919 787-5620 or email to [e-mail]
Thanks,
Mat Colone
i' /l W
Signed

5400 Glenwood Avenue, Suite 300
Raleigh, North Carolina 27612
tel: [phone]
fax: [phone]
March 5, 2010
Mr. Zinith Barbee
Solid Waste Section
North Carolina Department of Environment
and Natural Resources
401 Oberlin Road
Suite 150
Raleigh, North Carolina 27605-1350
MAR 10 2010
SOLID WASTE SECTION
ASHEVILLE REGIONAL OFFICE
Subject: Site Hydrogeologic Report, Design Hydrogeologic Report, Water Quality
Monitoring Plan, and Landfill Gas Monitoring Plan
Buncombe County Solid Waste Management Facility
Permit to Construct Application
Substantial Amendment and Phase 5
C&D Landfill
Response to Review Comments
Permit No. 11-07
Dear Mr. Barbee:
Camp Dresser & McKee (CDM), on behalf of Buncombe County, is pleased to submit this letter in
response to the comments received in your letter dated February 12, 2009 (Doc ID 9634).
Although not stated in the February 12th letter, CDM assumes this letter replaces your letter dated
December 30, 2009 (Doc ID 9082) and includes responses to the comments presented in the
February 12th letter.
This letter contains responses and revisions as they apply to the Landfill Gas Monitoring Plan. The
comments are addressed individually with discussions and references within this letter and the
attachments. Solid Waste Section comments are provided in italics with CDM response directly
following. A complete revised Landfill Gas Monitoring Plan is attached.
Section 1
1. Revise the introduction to include the following information. Insert "aerobic" in the discussion to
account for conditions in which explosions ignite and fires propagate. Identify gases expected to be
generated from waste at this type of landfill. Correct the statement in which "no structures" are
reported, since structures depicted on engineering drawings contradicts the statement.
RESPONSE:
T;\BunScombe-6447165973 C&D Substantial Amdmt\ReportsV4CDENR Response\PTC Responses\LGMP\Barbee_ Response_ Letter March 2010.doc
COnSUILIng • engineering • COnStrUCtlOn • opera

Mr. Zinith Barbee
March 5, 2010
Page 2
1a. A sentence regarding aerobic conditions and the relation to ignitability and fire hazard has
been added to Section 1.
lb. A discussion was added to Section 1 identifying methane and hydrogen sulfide as gases
that could potentially be generated from wastes in a C&D landfill. However, given the
type of waste placed in a C&D landfill, the presence of methane is unlikely. Also, the
amount of drywall in the Buncombe County waste stream that could potentially generate
hydrogen sulfide is minimal.
1c. This sentence has been deleted. As stated in the report, the structures shown on the
engineering drawings are currently monitored as part of the approved Subtitle D landfill
gas monitoring plan. This plan is intended to monitor the C&D landfill only.
1.2 Include in the discussion hozv the composition of C&D landfill gas varies from MSW landfill gas, and
list asphyxiation among the effects of "pollution" from landfill gas.
RESPONSE: Section 1.2 has been revised to the following: "Landfill gas from MSW landfills is
typically composed of 50 to 55 percent methane; 45 to 50 percent carbon dioxide; and, less than
one percent non -methane organic compounds. These individual gases remain co -mingled and
do not naturally separate. Because C&D wastes do not contain large quantities of organic
matter, methane and carbon dioxide should not be a concern. However, if a significant amount
of gypsum wallboard is present in C&D waste, hydrogen sulfide may potentially be produced,
particularly if moisture is introduced into the waste." For the purpose of this response and the
revised C&D landfill gas monitoring plan, "landfill gas" will include: Methane, hydrogen
sulfide, carbon dioxide, carbon monoxide, oxygen, and nitrogen (as balance gas).
Asphyxiation has been added to the discussion of potential effects of pollution from landfill
gas.
Section 2
2.1 Tzvo revisions are necessary. Somezvhere in the section; one, list Regulation 15ANCAC 13B .0554(fl to
emphasize submission of "any other monitoring plan or program" and clarify that monitoring is not
solely for methane; tzvo, explain that the generation of hydrogen sulfide and/or other gases is anticipated
more than methane, unless there are particular reasons for high methane emissions too.
RESPONSE:
2.1a A statement addressing Rule .0544(f) has been added indicating that the Landfill Gas
Monitoring Plan is part of the Monitoring Plan for the C&D landfill. In addition to the
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Mr. Zinith Barbee
March 5, 2010
Page 3
Landfill Gas Monitoring Plan, the Facility Monitoring Plan includes the Water Quality
Monitoring Plan.
2.1b Hydrogen sulfide has been added as a potential gas of concern for the C&D landfill.
Section 3
3. In the introduction, replace "methane" with "landfill gas". In the second paragraph, explain that both
federal and state regulations apply to the landfill.
RESPONSE: The introduction stated landfill gas correctly. A sentence stating that both
federal and state regulations apply to the landfill has been added.
3.1 Replace "'methane" with "methane gas or other explosive gases". Methane is stated in the cited "Rule
however, in the regulation containing that "Rule" is also "other explosive gases" and "mixture of
explosive gases in air that will propagate aflame".
RESPONSE: Section 3.1 has been revised accordingly.
3.2 In both paragraphs, replace "methane" with "methane and other explosive gases"
RESPONSE: Section 3.2 discussed personnel and staffing and was not applicable to the Plan
as discussed in the Solid Waste Section rules. As such, it has been removed entirely. Following
portions of Section 3 have been re -numerated accordingly in the revised Plan, however, for the
purpose of this response letter they are discussed as referenced in the SWS review comments.
3.3 Three revisions are necessary. One, in the first sentence add that "the instrument" will be calibrated
according to the manufacturer's instruction. Two, in the first and second paragraphs replace "methane"
with "landfill gases". Three, correct the statement about structures and report that they are adjacent to
the landfill.
RESPONSE:
3.3a The first sentence has been revised accordingly.
3.3b All references to "methane" have been replaced with "landfill gas," where appropriate.
3.3c This sentence has been deleted. Structures are currently monitored under the approved
monitoring plan for the Subtitle D landfill.
3.3.1 Required are several revisions to the text and referenced figure. One, either delete the last sentence in
the section on page 3-1, since the referenced well is not pertinent to the current monitoring plan, or
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Mr. Zinith Barbee
March 5, 2010
Page 4
show the well on Sheet 1 and include it in the plan for Phase 5. Two, throughout the section, replace
"methane" with "landfill gas". Three, specifij that well depths will equal the thickness of waste strata.
Four, explain that all the vadose zone, including bedrock above the watertable, will be screened; that
screens will extend to seasonal high water elevations; and flooded wells will be replaced with dnj
wells. Five, specifij well joints to be connected using threaded couplings in lieu of slip couplings,
screwed couplings, and glued couplings. Six, specifij for wellheads caps with a stopcock hjpe valve that
controls gas flow, that have a barb connection fitting the sampling instrument specified in the plan,
and are of sufficient quality to facilitate sampling and calibration in accordance with industnj and
federal standards.
RESPONSE:
3.3.1a The last sentence on page 3-1 has been removed.
3.3.1b Throughout the section, "methane" has been replaced with "landfill gas" as
appropriate.
3.3.1c Well depths equal to thickness of waste strata is not practical for the Buncombe County
C&D landfill. The C&D landfill is a valley fill and there is little to no excavation beyond
natural topography. Based on the topography, the base grades of the C&D landfill, the
filling sequence and geology at the C&D landfill, the top of well casing elevations will
be lower than the base of the C&D landfill.
3.3.1d At the C&D landfill, selected well locations are in or adjacent to low-lying drainage
feature areas down -gradient of the landfill unit where seasonal high groundwater
elevations are typically within the partially weathered rock or alluvium. The
Buncombe County C&D landfill is being constructed such that there is little to no
excavation and the bottom of waste will be at or near existing grade. As such, well
screens in some cases will be 50-feet or more below the base of the C&D landfill. CDM
believes that in the case of the Buncombe County C&D landfill, it is unreasonable to
install landfill gas monitoring wells into the fractured bedrock. If groundwater data in
fractured bedrock or other indicators such as distressed vegetation indicate that a
landfill gas migration problem may exist, additional deeper monitoring wells may be
installed to assess gas migration. Flooded wells will be replaced with dry wells, if
necessary.
3.3.1e Reference that wells will be constructed with threaded joints has been added.
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k I J
Mr. Zinith Barbee
March 5, 2010
Page 5
3.3.1f Wellheads will be fitted with a quick -connect stop -cock -type fitting that is of sufficient
quality to facilitate sampling in accordance with industry and federal standards. Figure
3-2 has been revised to show the wellhead completion.
3.3.2 Three revisions are necessary. One, everywhere in the section, replace "methane" with "methane and
other explosive gases". Two, since specififing a particular instrument, state that, at a minimum,
common landfill gases detectable by that instrument -CH4 and H2S -will be measured. Three, since
conveying a sampling plan, explain that wells compromised by flooding will not be sampled.
RESPONSE:
3.3.2a Throughout the section, "methane" has been replaced with "landfill gas," as
appropriate.
3.3.2b The section has been revised to indicate that a GEM-2000 landfill gas meter or
equivalent and an Industrial Scientific M-40 4-gas meter or equivalent will be used to
monitor landfill gas in the wells. The 4-gas meter will be attached to the exhaust port of
the GEM-2000. The GEM-2000 will detect CH4, CO2, 02, and the 4-gas meter will detect
CH4 LEL, H2S, CO, and 02.
3.3.2c Given the historical groundwater data at the C&D site, it is not anticipated that well
flooding will be an issue. If, however, it is determined that a well is flooded above the
well screen elevation, that well will not be sampled and a new dry well will be
installed in its place.
3.4 Replace "methane" with "methane and other explosive gases".
RESPONSE: Section 3.4 has been revised such that "methane" has been replaced with
"landfill gas," as appropriate.
Sheets
Sheet 1- Show more monitoring. Space landfill gas monitoring wells no further than 500 feet apart along a
perimeter around the waste boundary. Because the landfill contains no excavation beside which wells can be
installed,. show wells on the nearest high elevations -ridges, knolls, etc -adjacent to waste placed in valleys
and lozv terrain. Show at least one well among the structures next to the landfill. Show wells placed on the
review boundary already depicted and utilized on the drawing. If you have any questions, please contact me.
RESPONSE: CDM has installed monitoring wells M-10 and M-11. Well locations are provided
on the revised Figure 3-1. Current well spacing is approximately 650 feet. Well locations were
selected based on the topography and the fact that the drainage features act as preferential
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Mr. Zinith Barbee
March 5, 2010
Page 6
pathways for both groundwater and gas. Arbitrary well placement at 500-foot intervals is not
practical for this site. Additional wells are not necessary to the east of the C&D unit, as there
are currently wells between the C&D and the Subtitle D landfill that are monitored under the
approved Subtitle D plan. Adjacent wells are shown on Figure 3-1.
Placement of a monitoring well adjacent to a structure is not an appropriate way to monitor
structures. As stated previously, the structures are currently monitored under the approved
Plan for the Subtitle D landfill. As such, quarterly monitoring is conducted within the
structures themselves. No additional monitoring locations are necessary.
The review and compliance boundaries shown on Figure 3-1 are in reference to groundwater
and have been removed. According to Rule .0544 (d) (1) (B), the owner or operator of the landfill
must ensure that the concentration of methane or other explosive gases does not exceed the
lower explosive limit for methane or other explosive gases at the facility property boundary.
The existing wells at the C&D landfill are approximately 125-feet from the landfill. The
location of these wells will facilitate early detection of landfill gas migration, if present, before
it reaches the facility property boundary.
Figgres
Figure 1 - Revise the detail to convey applicable criteria listed in comment for Section 3.2.1.
RESPONSE: Figure 3-2 has been revised to show a well cap with a quick disconnect sampling
port, as described in the revised Section 3.3.1.
Forms
Revise the forms. Form I is entitled "Methane Monitoring Log Form"; Form 2, "Methane Monitoring Data
Sheet". Neither form specifies recordation of constituents other than methane; therefore, both should be
revised for recording other explosive gases at the landfill.
Form 1 Everywhere replace "methane" with "methane or other explosive gases", and, in Item #1, list each
well instead of total number of wells.
Form 2 Three revisions are necessary. One, in the title, replace "methane" with "methane or other explosive
gases". Two, list the wells of a revised landfill gas monitoring plan. Three, expand the table to include
measured explosive gases listed in comment for Section 3.3.2.
RESPONSE: Both Page 1 and 2 of the Form have been revised to read "Landfill Gas
Monitoring Form." References to "methane" on Page 1 have been revised to "landfill gas."
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Mr. Zinith Barbee
March 5, 2010
Page 7
As mentioned, the Page 2 title has been revised to read 'Landfill Gas Monitoring Form." The
current revised well list (M-10 and M-11) has been updated accordingly. In addition to %CH4
and % LEL CH4, columns have been added for H2S, %CO2, %02, and %N (as balance gas).
Section 4
In the introduction, replace "methane" with "landfill gas
RESPONSE: "Methane" has been replaced with "landfill gas" as requested.
4.1 Everywhere in the section, replace "methane" with "landfill gas".
RESPONSE: "Methane" has been replaced with "landfill gas" as requested.
4.2 Replace "methane" with "landfill gas."
RESPONSE: "Methane' has been replaced with "landfill gas."
4.2.1 Everywhere in the section, replace "methane" with "methane and landfill gas".
RESPONSE: "Methane" has been replaced with "landfill gas" throughout the section.
4.2.2 See comment for Section 4.2.1.
RESPONSE: "Methane" has been replaced with "landfill gas" throughout the section.
4.3 Include asphyxiation from landfill gases in the "dangerous situation" about which "the public, public
service agencies, and the media" will be informed. Also, include the SWS among the notified agencies.
RESPONSE: Asphyxiation from landfill gases has been included in the dangerous situation
about which public notice will be provided. The SWS has been added to the distribution list.
Section 5
In the introduction, replace "methane" with "landfill gas"
RESPONSE: Section 5 has been removed.
5.1, 5.11, 5.1.2 Understood is that this option pertains to controlling releases from interior wells. However,
the option is already the proposed landfill operation. Interior wells are already "passive venting wells"
comprising a "passive removal system" described in the application. Hence, should that system fail,
remedial options will begin with addressing features inherent in that design -inadequate pressure in the
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Mr. Zinith Barbee
March 5, 2010
Page 8
landfill, air intruding the system, untreated atmospheric releases, etc. Also, installing trenches as proposed
in the option will necessitate destruction of the landfill cap and may require a permit modification with a fee.
That proposal will require review by a SWS environmental engineer. Therefore, options for controlling
landfill gas releases should either address failure of the passive removal system presented in the application,
or conversion the system to an active gas collection system. Propose an option that accomplishes one of these
objectives and relate its effect to landfill gas monitoring.
Section 5 was intended to provide options for remediation for landfill gas migration if necessary,
and was not intended to serve as Corrective Action Plan. If remediation is required, a Plan with
the best alternative will be provided, as described in Rule .0544(d) (3) (C). Section 5 has been
removed.
We hope that you find that the additional information and revisions provided in this letter
sufficient to answer your questions and address your comments. If you have any questions,
please do not hesitate to contact me at [phone] or by email at [e-mail].
Very truly yours,
-Nja4l-t-
Mathew F. Colon, P.G.
Camp Dresser & McKee
cc: Ed Mussler, , SWS
Mark Poindexter, SWS
Allen Gaither, SWS Asheville Regional Office
Andrea Keller, SWS Asheville Regional Office
Jerry Mears, Buncombe County
Kristy Smith, Buncombe County
Kenton Yang, CDM
File
5 MWW-" 201°
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Attachment
Landfill Gas Monitoring Plan

Contents
Landfill Gas Monitoring Plan - C&D Landfill
Section 1 Introduction
1.1 Purpose.......................................................................................................................1-1
1.2 General Characteristics of LFG and Methane Generation..................................1-1
Section 2 Regulatory Background
2.1 C&D Landfills and North Carolina Regulations..................................................2-1
Section 3 Gas Control Plan
3.1 Frequency of Routine Monitoring..........................................................................3-1
3.2 Monitoring Procedures............................................................................................3-1
3.2.1 Monitoring Well Installation and Construction....................................3-1
3.2.2 LFG Monitoring.........................................................................................3-2
3.3 Record Keeping.........................................................................................................3-2
Section 4 Detection Plan
4.1 Actions If Regulatory Limits Detected at Monitoring Wells..............................4-1
4.2 C&D Compliance Action Plan................................................................................4-1
4.2.1 Immediate Action......................................................................................4-1
4.2.2 Actions Within Seven Days......................................................................4-2
4.2.3 Actions Within Sixty Days........................................................................4-2
4.3 Public Relations and Information...........................................................................4-2
Figures
Figure 3-1
Figure 3-2
Landfill Gas Monitoring Well Locations................................................3-3
Typical Landfill Gas Monitoring Well Construction Diagram ...........3-4
B
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Section 1
Introduction
Landfill gas (LFG) is a natural by-product of the anaerobic decomposition of
landfilled bio-degradable waste. Under aerobic conditions, LFG can ignite and
propagate fires, presenting a danger to human health and the environment and
therefore must be monitored. For these reasons, LFG is regulated by Federal and
North Carolina state legislation. This Plan describes the systems and programs
needed to fulfill federal and state regulations concerning LFG. Methane and hydrogen
sulfide are two gases that could potentially be generated from wastes in a C&D
landfill. Since this plan is for the C&D landfill, it is noted that LFG, particularly
methane, generation is expected to be minimal based on the lack of organic matter in
the waste stream. Also, the amount of drywall in the Buncombe County waste stream
that could potentially generate hydrogen sulfide is minimal.
This Plan is intended for the C&D Landfill only. An explosive gas control plan is
already in -place for the Subtitle D Landfill. The Plan for the C&D Landfill includes
LFG monitoring at or near the facility boundary through monitoring wells. All
structures at the Site are monitored under the plan already in place for the Subtitle D
landfill.
1.1 Purpose
This Plan fulfills the requirements set forth in Rule .0544(d) for monitoring LFG. This
Plan:
• is intended for the C&D Landfill only,
• describes the necessary LFG monitoring systems,
• sets forth the monitoring procedures and programs, and
• identifies the actions needed if levels of methane or hydrogen sulfide exceed
regulatory limits.
1.2 General Characteristics of LFG and Methane
Generation
LFG is composed of approximately 50 percent methane in contrast to natural gas
which consists of approximately 95 percent methane. What makes LFG a source of
environmental pollution is its odor, its potentially explosive properties, its potential
for asphyxiation, and its contribution to global warming. LFG programs which focus
on the environmental hazards of landfill gas include systems to monitor the migration
of gas and control or neutralize its environmental impacts.
Landfill gas from MSW landfills is typically composed of 50 to 55 percent methane, 45
to 50 percent carbon dioxide, and less than one percent non -methane organic
compounds. These individual gases remain co -mingled and do not naturally separate.
1-1
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Section 1
Introduction
Because C&D wastes do not contain large quantities of organic matter, methane and
carbon dioxide should not be a concern. However, if a significant amount of gypsum
wallboard is present in C&D waste, hydrogen sulfide may potentially be produced,
particularly if moisture is introduced into the waste.
1-2
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Section 2
Regulatory Background
Because of the real and potential dangers from LFG, particularly hydrogen sulfide or
to a lesser extent methane in LFG generated from C&D landfills, to the public health
and safety and to the environment, existing state regulations, as described in Rule 15A
NCAC 13B .0544 (d) (1 through 5), require owners of C&D landfills to monitor and, if
necessary, control it.
2.1 C&D Landfills and North Carolina Regulations
Methane gas is explosive when present within the range of 5 to 15 percent by volume
in air. When present in concentrations greater than 15 percent, the mixture will not
explode. The 5 percentage mixture is referred to as the Lower Explosive Limit (LEL)
while the 15 percentage concentration is referred to as the Upper Explosive Limit
(UEL). Hydrogen sulfide is explosive when present within the range of 4 to 44
percent by volume in air. In addition, hydrogen sulfide can be immediately
dangerous to life and health at concentrations of 100 parts per million. The State of
North Carolina, through its 15A NCAC 13B .0544(d)(1), requires owners or operators
of all C&D landfills to ensure that the facility:
A) Does not exceed 25 percent of the LEL for methane or other explosive gases in
facility structures;
B) Does not exceed the LEL for methane or other explosive gases at the facility
property boundary; and
C) Does not release methane gas or other explosive gases in any concentration
that can be detected in offsite structures.
The LEL means the lowest percent by volume of a mixture of explosive gases in air
that will propagate a flame at 25 C and atmospheric pressure per Rule .0544(d)(5).
Rule .0544(d)(2) requires that a routine methane monitoring program be implemented
to ensure that these standards are met. The type of monitoring will be determined
based on soil conditions, hydrogeologic conditions under and surrounding the
facility, hydraulic conditions on and surrounding the facility, the location of facility
structures and property boundaries, and the location of all off -site structures adjacent
to property boundaries. Additionally, frequency of monitoring shall be quarterly.
Rule .0544(d)(3) requires that if methane or explosive gas levels exceed the specified
limits, the owner or operator must:
A) Immediately take all necessary steps to ensure the protection of human health
and notify the Division;
2-1
PABuncombe - 644A65973 C&D Substantial Amdml\ReporlsWCDENR Response\PTC Responses\LGMRRevised LFG Monitoring Plan_March 2010.doc (Revised March 2010)

Section 2
Regulatory Background
B) Within seven days of detection, place in the operating record the methane or
explosive gas levels detected and a description of the steps taken to protect
human health;
C) Within 60 days of detection, implement a remediation plan for the methane or
explosive gas releases, place a copy of the plan in the operating record, and
notify the Division that the plan has been implemented. The plan must
describe the nature and extend of the problem and the proposed remedy.
As described in Rule 15A NCAC 13B .0554 (f), this Landfill Gas Monitoring Plan is
part of the Monitoring Plan for the C&D facility. In addition to the Landfill Gas
Monitoring Plan, the Facility Monitoring Plan includes the Water Quality Monitoring
Plan.
2-2
PA13uncombe- 644AS5973 C&D Substantial Amdnnt\Reports\NCDENR Response\PTC Responses\LGMP1Revised LFG Monitoring Plan_March 2010.doc (Revised January 2010)

Section 3
Gas Control Plan
The gas control plan includes a schedule for reading or monitoring LFG emission
levels at designated locations quarterly and a system for reporting the concentration
levels.
The requirements for quarterly monitoring, and the plan for actions if readings exceed
safe levels should, at a minimum, be based on compliance with federal and state
regulations.
3.1 Frequency of Routine Monitoring
Rule .0544(d)(1) and (2) states that a quarterly methane monitoring program be
implemented to ensure that the concentration of methane or other explosive gases do
not exceed regulatory limits.
3.2 Monitoring Procedures
Each quarterly monitoring procedure shall begin by verifying that the instrument has
been calibrated. The instrument shall be calibrated per the manufacturer's instruction.
Monitoring shall be completed with a GEM-2000 or equivalent in conjunction with an
Industrial Scientific M-40 4-gas meter or equivalent. Monitoring wells around the
C&D landfill shall be checked. Currently there are two landfill gas monitoring wells at
the C&D landfill (M-10 and M-11). Well locations for the C&D landfill are provided
on Figure 3-1.
3.2.1 Monitoring Well Installation and Construction
Wells M-10 and M-11 will be used to monitor the C&D landfill for LFG migration.
The landfill gas monitoring wells are constructed with 2-inch diameter schedule 40
PVC with threaded couplings with a minimum of 10 feet of 0.010-inch slotted screen
with a #2 sand filter pack extending 1 foot above the top of the screen. A 1 to 2-foot
thick bentonite seal was placed on top of the sand filter pack and hydrated. The
remainder of the borehole annulus was completed with a Portland cement/bentonite
grout. Screen length was selected based on groundwater and bedrock elevations
observed during well installation.
Similar to the groundwater monitoring wells at the C&D facility, the landfill gas
monitoring wells were installed within the dominant drainage features associated
with each Phase of C&D landfill development. Well locations are in or adjacent to
low-lying drainage feature areas down -gradient of the landfill unit where seasonal
high groundwater elevations 'are typically within the partially weathered rock or
alluvium. The Buncombe County C&D landfill is being constructed such that there is
little to no excavation and the bottom of waste will be at or near existing grade. As
such, well screens in some cases are 50-feet or more below the base of the C&D
landfill. CDM believes that in the case of the Buncombe County C&D landfill, it is
unreasonable to install landfill gas monitoring wells into the fractured bedrock. If
3-1
P1Buncombe - 644T65973 C&D Substantial Amdmt\Reports\NCDENR Response\PTC Responses\LGMP\Revised LFG Monitoring Plan_March 2010.doc (Revised March 2010)

Section 3
Gas Control Plan
groundwater data in fractured bedrock or other indicators such as distressed
vegetation indicate that a landfill gas migration problem may exist, additional deeper
monitoring wells may be installed to assess gas migration.
All landfill gas monitoring wells were constructed in accordance with the North
Carolina Well Construction Standards described in 15A NCAC 2C and were
completed with locking above grade protective covers and 2-foot by 2-foot concrete
pads. Following installation, the wells will be surveyed to State Plane coordinates.
The wellhead caps will be fitted with a stopcock type fitting that is of sufficient
quality to facilitate sampling in accordance with industry and federal standards.
Figure 3-2 includes a typical landfill gas monitoring well detail.
Flooded wells will be replaced with dry wells, if necessary.
3.2.2 LFG Monitoring
An initial landfill gas reading for % methane, % lower explosive limits for methane, %
carbon dioxide, and % oxygen was collected from each of the newly installed landfill
gas monitoring wells with a GEM-2000 landfill gas monitoring meter or similar 24-
hours after installation. Following the initial reading, readings will be collected from
each well on a quarterly basis. A GEM-2000 landfill gas meter or equivalent and an
Industrial Scientific M-40 4-gas meter or equivalent will be used to monitor landfill
gas in the wells. The 4-gas meter will be attached to the exhaust port of the GEM-2000.
The GEM-2000 will detect CH4, CO2, 02, and the 4-gas meter will detect CH4 LEL, H2S
(ppm), CO (ppm), and % 02. If landfill gas levels detected at the monitoring wells
exceeds the LEL, the technician shall immediately follow the action plan presented in
Section 4.1.
Given the historical groundwater data at the C&D site, it is not anticipated that well
flooding will be an issue. If, however, it is determined that a well is flooded above the
well screen elevation, that well will not be sampled and a new dry well will be
installed in its place.
3.3 Record Keeping
All readings will be recorded on a standard landfill gas monitoring log form. A
sample landfill gas monitoring log is provided at the end of this section. This form or
similar will be used. These forms will be reviewed by the landfill supervisor or the
County's environmental consultant and placed on file at the landfill with other
landfill records. These readings should be available for review by the State upon
request.
3-2
PABuncombe - 644A65973 C&D Substantial Amdmt\Reports\WDENR Response\PTC Responses\LGMP\Revised LFG Monitoring Plan_March 2010.doc (Revised March 2010)

0
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Landfill Gas Monitoring Plan
Buncombe County
C&D Landfill
"Steel, Locking Protective Cover
Finished Grade I I I I I Wellhead cap with quick disconnect sampling port
2'x2'x6" Concrete Pad
Type I Cement Grout
2' Bentonite Seal ­4,41 4 6161 2" Schedule 40 PVC Blank Casing
8" +/- Borehole Diameter
Silica Sand Filter Pack
2" Schedule 40 PVC 0.010 inch Slotted Well Screen
Threaded, PVC End -Cap
Notes:
Stick-up will extend between 2.5 and 3 feet above finished grade.
All PVC well material will be threaded joint.
Silica sand filter pack will extend at least 2 feet above top of screen elevation.
Anticipated screen length will vary depending on depth to groundwater or bedrock.
cm Figure 3-2
Typical Landfill Gas Monitoring Well Construction Diagram

Section 3
Gas Control Plan
LANDFILL GAS MONITORING LOG FORM
(this report must be completed quarterly)
Buncombe County C&D Landfill
Buncombe County, North Carolina
Technician Name:
Date: (mo/day/year)
General weather conditions:
Temperature:
Barometric condition pressure:
MONITORING INSTRUCTIONS
1. Measure landfill gas levels at C&D landfill gas monitoring wells M-10 and M-11
located around the C&D landfill. The landfill gas reading must not exceed 100%
of the methane L.E.L. If landfill gas measurements exceed 100% of the L.E.L.,
contact the landfill supervisor and follow the outlined plan in Appendix B of the
operations manual.
2. If landfill gas levels exceed the above -mentioned levels at any monitoring
location, report the measurements to the County for further action as described in
the Gas Control Plan — C&D Landfill.
3. File this landfill gas monitoring log sheet in the landfill office in the appropriate
record keeping section with other landfill records.
ai r
3-5
PABuncombe - 644A65973 C&D Substantial Amdmt\ReportsWCDENR Response\PTC Responses\LGMRRevised LFG Monitoring Plan_March 2010.doc (Revised March 201u)

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Section 4
Detection Plan
The North Carolina Solid Waste Management Rules, .0544(d)(3), require a detection
plan for action if landfill gas levels exceed the regulatory concentration limits. The
plan for action includes the specific step by step actions needed should regulatory
limits be detected.
4.1 Actions if Regulatory Limits Detected at Monitoring
Wells
If any of the landfill gas monitoring wells measure a level equal to or more than the
LEL as defined by in the Rules, the technician should:
• immediately contact the landfill supervisor; and
• recheck the landfill gas levels at each well.
The equipment used to take the readings should be tested to verify it is giving
accurate readings.
This information, the current readings, and the levels for the previous three quarters
should be provided to the Buncombe County landfill supervisor who will make the
decision to: return to business as usual; temporarily evacuate the site; or, follow the
plan proposed in Section 4.2.
4.2 C&D Compliance Action Plan
If upon verification as described in Sections 4.1, the landfill gas monitoring levels are
equal to or exceed the regulatory limits as defined by state and federal regulations,
the following actions are proposed to comply with state regulations as well as protect
the health and safety of the individuals at or near the C&D landfill.
4.2.1 Immediate Action
If landfill gas levels exceed the specified limits, the landfill operator or the landfill
supervisor will take immediate action to ensure the protection of human health and
safety. This will include:
• monitor all structures at the facility;
• if landfill gas levels are detected in the onsite structures, open all doors and
windows in buildings on the landfill site;
• if warranted by the degree of intensity of the landfill gas concentration in the
onsite structures, evacuate all buildings on the site;
• notify the Buncombe County Manager Office's about the concentration levels;
4-1
PABuncombe. 644A65973 C&D Substantial AmdrnAReports\NCDENR Response\PTC Responses\LGMPtRevised LFG Monitoring Plan —March 201 O.doc (Revised March 2010)

Section 4
Detection Plan
• if warranted by the degree of intensity of the landfill gas concentration in the
wells, check the landfill gas levels in structures on adjacent properties to the
facility boundary;
• if warranted by the degree of intensity of the landfill gas concentration, evacuate
the landfill area or evacuate the area adjacent to the landfill;
• notify the Division about the reading;
• begin to identify or narrow down the source of the landfill gas causing the
readings exceeding the regulatory limits (i.e. the path that the landfill gas is taking
to the monitoring location);
• begin to identify the extent of the landfill gas problem; and
• as appropriate, begin to take corrective action to control the landfill gas levels in
building at the landfill site, at the boundaries to the landfill, and at the landfill site.
4.2.2 Actions Within Seven Days
If landfill gas levels exceed the regulatory limits, the County must, within seven days,
place in the operating record the gas levels detected and a description of the steps
taken to protect human health.
It is also suggested that at this time, the operator begin to develop a plan which:
• describes the nature and extent of the problem and
• proposes a remedy for the problem.
4.2.3 Actions Within Sixty Days
If methane levels exceed the specified limits, the County will take the following
actions within 60 days:
• implement a remediation plan for the landfill gas release;
• place a copy of the plan in the operating record of the landfill; and
• notify the Division that the plan has been implemented.
4.3 Public Relations and Information
As with any potentially dangerous situation, including asphyxiation from landfill
gases, it is important to keep the public, public service agencies, regulatory agencies,
and the media informed. False information, inaccurate information, or the lack of
information concerning potential explosions at a public facility could create panic.
4-2
P1Buncombe - 6447\65973 C&D Substantial Amdmt\Reports\NCDENR Response\PTC Responses\LGMRRevised LFG Monitoring Plan_March 2010.doc (Revised March 2010)

Section 4
Detection Plan
If it is determined that a potentially dangerous situation exists, it is recommended
that a one page explanation of the situation be written and distributed to all homes
and businesses within a one-half mile radius of the landfill. This should be done
within the first two to four hours of making the determination that a potential danger
to human health and safety exists.
It is recommended that the County Manager appoint one individual to provide
information to: the appropriate regulatory agency; the media; the police authorities
with jurisdiction in the area; and area medical facilities. Area hospitals and police
departments may receive calls once the local media releases the story. Centralizing
the flow of information will avoid conflicting information and inaccurate information.
Providing detailed and honest facts about the situation being under control is critical.
4-3
PABuncombe - 644A65973 C&D Substantial Amdmt\ReportsXNCDENR Response\PTC Responses\LGMP\Revised LFG Monitoring Plan_March 2010.doc (Revised March 2010)

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Landfill Gas Measurements Field Worksheet
Francis Farm Landfill - Permit #44-03
Haywood County, North Carolina
Name of Person Taking Readings: Jeff Bishop
Weather Conditions: Sunny,
Atmospheric Pressure., 27.08"
Gas Monitoring Equipment: Land -Tee GEM 2000
Factory Calibration Date: September 2009
Date: October 1, 2010
Ambient Temp: 64
Serial #: GM05480
Field Calibration Date: September 30, 2010
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MM-1
Stable
Not Installed
MM-2
Stable
Not Installed
MM-3
Stable
14.40
4.0
0.2
0.0
21.0
Replace 1" PVC Ca
MM-4
Stable
14:29
>100
1 63.6
28.5
0.7
MM-5
Stable
14:25
0.0
0.0
4.5
16.2
MM-6
Stable
14:20
620.0
31.0
24.3
0.7
MM-7
Stable
14:15
2.0
0.1
3.8
17.0
MM-8
Stable
15:15
0.0
0.0
1.8
18.6
need quick connect
MM-9
Stable
13:34
0.0
0.0
3.2
17.9
MM-10
MM-11
Stable
13:26
1118.0
55.9
38.2
0.7
need quick connect
Stable
13:10
946.0
47.3
35.4
1 0.8
need quick connect
MM-12
Stable
12:55
1212.0
60.6
38.9
0.6
need quick connect
MM-13
Stable
12:50
0.0
0.0
15.1
4.6
need quick connect
SM-1a
Stable
14:12
0.0
0.0
0.0
21.1
Need plastic sign
SM-1b
Stable
14:09
0.0
0.0
0.0
21.2
Need plastic sign
SM-1c
Stable
14.00
0.0
0.0
0.0
21.0
Need Plastic sign
SM-2
Stable
13:65
0.0
0.0
0.0
21.1
Need plastic si n
SM-3
Stable
13:60
0.0
0.0
0.0
21.2
Need plastic sign
SM-4�
Stable
15:40
0.0
0.0
0.0
20.9
Sam led underdrain at house.
VI3-1*
Stable
15:03
190.0
9.5
3.4
17.9
MW-4*
Stable
13:45
24.0
1.2
0.7
20.6
MW-5*
Stable
13.38
0.0
0.0
0.0
21.0
Notes:
1. If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes, contact
Haywood County Solid Waste Director immediately.
2. *To be monitored from 11/16/10 to 11/15/11. May be dropped from monitoring after assessment
period is complete.
Field Observation Notes:

Landfill Gas Measurements Field Worksheet
Francis Farm Landfill - Permit #44-03
Haywood County, North Carolina
Name of Person Taking Readings: Jeff Bishop Date: October 1.2010
Weather Conditions: Sunny Ambient Temp: 64
Atmospheric Pressure: 27.08"
Gas Monitoring Equipment: land -Tee GEM 2000 Serial #: GM06480
Factory Calibration Date: September 2009 Field Calibration Date : September 30, 2010
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MM-1
Stable
Not Installed
MM-2
Stable
Not Installed
MM-3
Stable
14:40
4.0
0.2
0.0
21.0
Replace V PVC Ca
MM-4
Stable
14:29
>100
63.6
28.5
0.7
MM-5
Stable
14:25
0.0
0.0
4.5
16.2
MM-6
Stable
14:20
620.0
31.0
24.3
0.7
MM-7
Stable
14:15
2.0
0.1
3.8
17.0
MM-8
Stable
15:15
0.0
0.0
1.8
18.6
need quick connect
MM-9
Stable
13:34
0.0
0.0
3.2
17.9
MM-10
MM-11
Stable
13:26
1118.0
55.9
38.2
0.7
need quick connect
Stable
13:10
946.0
47.3
35.4
0.8
need quick connect
MM-12
Stable
12:56
1212.0
60.6
38.9
0.6
need quick connect
MM-13
Stable
12:60
0.0
0.0
15.1
4.6
need quick connect
SM-1a
Stable
14:12
0.0
0.0
0.0
21.1
Need plastic sign
SM-lb
Stable
14:09
0.0
0.0
0.0
21.2
Need plastic sign
SM-1c
Stable
14.00
0.0
0.0
0.0
21.0
Need plastic sign
SM-2
Stable
13:55
0.0
0.0
0.0 1
21.1
Need plastic sign
SM-3
Stable
13:50
0.0
0.0
0.0
21.2
Need plastic sign
SM-4*
Stable
15:40
0.0
0.0
0.0
20.9
Sampled underdrain at house.
VB-1 *
Stable
16:03
190.0
9.5
3.4
17.9
MW-4*
Stable
13:45
24.0
1.2
0.7
20.6
MW-5*
Stable
13:38
0.0
0.0
0.0
21.0
Notes:
1. If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes, contact
Haywood County Solid Waste Director immediately.
2. *To be monitored from 11/16/10 to 11/15/11. Maybe dropped from monitoring after assessment
period is complete.
Field Observation Notes:

Landfill Gas Measurements Field Worksheet
White Oak MSW Landfill
Haywood County, North Carolina
Name of Person Taking Readings: J Bishop/ D Pasko Date: Decmebr 29, 2010
Weather Conditions: Overcast Ambient Temp: 360
Atmospheric Pressure: 27.42"
Gas Monitoring Equipment: Land-Tec GEM 2000 Serial #: GM11944109
Factory Calibration Date: August 27, 2010 Field Calibration Date: December 29, 2010
y 5�
ti
� r
LFG-1
Yes
13:22
0.0
0.0
6.0
15.4
LFG-2
Yes
13:30
0.0
0.0
2.6
19.4
LFG-4r
Yes
13:39
0.0
0.0
0.3
20.4
LFG-7
Yes
13:42
0.0
0.0
2.8
19.4
LFG-8
Yes
13:53
0.0
0.0
0.9
20.2
LFG-9
Yes
14:15
0.0
.0.0
0.1
20.6
LFG-10
Yes
14:07
0.0
&0
1.5
19.5
Need to add quick coupler
Maint Bldg
Yes
14:34
0.0
0.0
0.1
20.6
need plastic sign
Scale House
Yes
14:29
0.0
0.0
0.1
20.6
need plastic sign
Note: If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes contact
Haywood County Solid Waste Director immediatley
Field Observation Notes:

l
Landfill Gas Measurements Field Worksheet
White Oak MSW Landfill
Haywood County, North Carolina
Name of Person Taking Readings: Jeff Bishop Date: September 30, 2010
Weather Conditions: Overcast Ambient Temp: - Deg•
Atmospheric Pressure: IM
Gas Monitoring Equipment: Land-Tec GEM 2000 Serial #: GM06480
Factory Calibration Date: September 2009 Field Calibration Date: September 30.2010
LFG-1
Yes
10:55
2.0
LFG-2
Yes
10:50
0.0
LFG-4r
Yes
10:40
2.0
LFG-7
Yes
10:45
0.0
LFG-8
Yes
10:36
2.0
LFG-9
Yes
10:25
2.0
LFG-10
Yes
10:15
2.0
Maint Bldg
Yes
11:00
0.0
Scale House
Yes
11:05
0.0
Note: If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes contact
Haywood County Solid Waste Director immediatley
Field Observation Notes:

Landfill Gas Measurements Field Worksheet
White Oak MSW Landfill
Haywood County, North Carolina
Name of Person Taking Readings: J Bishop/ D Pasko Date: Decmebr 29. 2010
Weather Conditions: Overcast Ambient Temp: 360
Atmospheric Pressure: 27.42"
Gas Monitoring Equipment: Land-Tec GEM 2000 Serial #: GM11944109
Factory Calibration Date: August 27, 2010 Field Calibration Date: December 29, 2010
'-r;x�r
LFG-1
Yes
13:22
0.0
0.0
6.0
15.4
LFG-2
Yes
13:30
0.0
0.0
2.6
19.4
LFG-4r
Yes
13:39
0.0
0.0
0.3
20.4
LFG-7
Yes
13:42
0.0
0.0
2.8
19 A
LFG-8
Yes
13:53
0.0
0.0
0.9
20.2
LFG-9
Yes
14:15
0.0
.0.0
0.1
20.6
LFG-10
Yes
14:07
0.0
0.0
1.5
19.5
Need to add quick coupler
Maint Bldg
Yes
14:34
0.0
0.0
0.1
20.6
need plastic sin `
Scale House
Yes
14:29
0.0
0.0
0.1
20.6
need plastic sign
Note: If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes contact
Haywood County Solid Waste Director immediatley
Field Observation Notes:

,-Landfill Gas Measurements Field Worksheet
Francis Farm Landfill - Permit #44-03
Hayuv®od County, North Carolina
Name of Person Taking Readings: J Bishop/ D Pasko
Weather Conditions: Clear/ 8" snow
Atmospheric Pressure: 27.20"
Gas Monitoring Equipment: Land-Tec GEM 2000
Factory Calibration Date: August 27, 2010
Date: November 22, 2010
Ambient Temp; 28°
Serial #: GM11944109
Field Calibration Date: December 29, 2010
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MM-1
Stable
12:00
596.0
29.8
24.3
0.6
Need to replace lock/ label
MM-2
Stable
11:54
1012.0
50.6
35.1
0.1
Need to replace lock/ label
MM-3
Stable
11:49
876.0
43.8
33.0
0.4
MM-4
Stable
11:44
442.0
22.1
24.2
2.7
MM-5
Stable
11:41
0.0
0.0
5.5
18.0
MM-6
Stable
11:37
198.0
9.9
14.9
5.7
MM-7
Stable
11:33
0.0
0.0
2.7
18.8
MM 8
Stable
11:23
0.0
0.0 .
2.7
19.2
need lock
MM-9
Stable
12:43
0.0
0.0
2.8
18.3
MM-10
Stable
-
-
-
-
covered w1 snow, could not sample
MM-11
Stable
10:31
1030.0
51.5
34.1
0.2
MM-12
Stable
10:24
1216.0
60.8
38.9
0.2
MM-13
I Stable
-
-
-
-
covered w/ snow, could not sample
SM-1a
Stable
11:25
0.0
0.0
0.2
21.2
Need plastic sign
SM-lb
Stable
11:27
0.0
0.0
0.2
21,2
Need plastic sign
SM-1c
Stable
11:29
0.0
0.0
0.1
21.2
Need plastic sign
SM-2
Stable
11:21
2.0
0.1
0.2
21.1
Need plastic sign
SM-3
Stable
-
-
-
-
could not access building
MW-12
Stable
10:57
0.0
0.0
0.2
21.0
Could not access SM-4
VB-1*
Stable
-
-
-
-
could not access due to snow
MW-4*
Stable
11:15
220.0
11.0
10.0
15.0
MW-5*
Stable
12:"1
0.0
0.0
0.8
20.9
Notes:
1. If methane gas readings exceed 25% of LEL in structures or 100% of LEL in probes, contact
Haywood County Solid Waste Director immediately.
2. *To be monitored from 11/15/10 to 11115/11. Maybe dropped from monitoring after assessment
period is complete.
Field Observation Notes:

RIE'CEIVED
•
C
A S S O C I A T E S
June 3, 2010
Ms. Andrea Keller
Environmental Senior Specialist
Solid Waste Section
Division of Waste Management
North Carolina Department of Environment and Natural Resources
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Dear Ms. Keller:
J U N B 2010
SOLID WASTE SECTION
ASHEVILLE REGIONAL OFFICE
RE: Facility Compliance Audit Report
White Oak Municipal Solid Waste Landfill
Permit # 44-07
Haywood County, North Carolina
On behalf of Haywood County, North Carolina, we are providing this response to the
Facility Compliance Audit Report received May 12, 2010. Based on McGill Associates review
of the specific site conditions, we have prepared this response to generally correspond with the
indentified Noted Violations and Areas of Concern.
Noted Violations
15A NCAC 13B .1626 (1)(g)(ii) for waste placement outside of the base liner system
and 15A NCAC 13B .1626 (8)(d) failure to contain leachate on -site, within the base
liner system, that was not properly treated prior to discharge.
As part of the construction of the new Phase 3 waste area, the existing Phase 1 and Phase
2 liner edges had to be exposed to allow connection of the Phase 3 liner system. During the
construction, it was discovered that waste was beyond the existing liner limits and, in addition, it
appeared that leachate had been discharged outside the liner limits. Upon discovery, the County
immediately reported the situation to the Solid Waste Section on August 6, 2009. The Audit
Report accurately documents the timeline of events.
The County took the following remediation steps to remedy the above violation:
1. Immediately contracted with Thalle Construction to remove the waste from
outside liner limit to an area near the working face. Additional waste material
was removed to allow an adequate area for the control of leachate. The waste
material was removed by August 25, 2009. Approximately 6,350 cubic yards of
waste material was relocated.
E n g i n e e r i n g P l a n n i n g e F i n a n c e
McGill Associates, P.A. • P.O. Box 2259, Asheville, NC 28802 55 Broad Street, Asheville, NC 1,Y801
828-252-0575 • Fax: [phone]

Ms. Andrea Keller
June 3, 2010
Page 2
2. Haywood County contacted Ervin Lane on August 10, 2010 to discuss suitable
mitigation measures for the contaminated soil and an action plan was approved.
To determine the extent of leachate contamination, soil testing was completed on
soils in the area where waste and leachate were found on outside of liner edge.
Soil material was removed until a clean soil sample was obtained. Approximately
2,500 cubic yards of soil material was removed and placed into the permitted
waste area. Soil samples of the affected area were obtained on October 7 (Area 1)
and October 26 (Area 2), 2009 and results were submitted to the North Carolina
Department of Natural Resources (NCDENR), Solid Waste Section. On
November 9, 2009, approval was given by the Solid Waste Section to resume
Phase 3 construction.
3. In order to control leachate from leaving the existing liner limits, the County
instituted the following additional operational measures:
• Established temporary sumps within the existing liner limits to provide
points to pump out excess leachate.
• Utilized existing landfill gas vents as leachate sumps to remove leachate
from the lined waste area.
• Utilized diesel pump, purchased 2 electric pumps and rented a portable
generator to supplement existing leachate system.
• Rented three "frac" (storage) tanks to increase leachate storage capacity
during Phase 3 construction.
• Pumped out and hauled off -site more than 5.6 million gallons of leachate
to an approved wastewater treatment facility from August 2009 through
April 2010 (previous highest yearly total was 3.8 million gallons for a 12-
month period in 2004/2005).
4. Through the Phase 3 construction contract, established a permanent leachate sump
and pump station within the Phase 1 waste area to assist existing leachate
collection system.
5. Established new operational and training procedures with landfill staff to prevent
waste being placed beyond the liner limits.
• All existing liner limits have been identified and liner edge markers will
be installed by June 30, 2010.
• Concrete liner edge markers have been installed around new Phase 3
waste area.
• Additional training with landfill operators will be held during the month
June 2010 to show where the liner limits are and stress the importance of
proper setbacks of waste placement. A copy of the training record will be
included in the Operational Record.

Ms. Andrea Keller
June 3, 2010
Page 3
I5A NCAC 13B .1626 (2)(c) for failure to replace the minimum of one foot of cover
intermediate soil cover over all exposed waste in Area I and Area 2.
As described above, waste was relocated from the Areas 1 and 2, as depicted in the Audit
Report, for the construction of the new Phase 3 waste area. During the waste removal, a portion
of the area was not re-covered with the required soil cover. Haywood County has now covered a
majority all of the area with soil cover with the exception of the area noted as Area 2 (along the
northern limits of Phase 2), as shown on the attached photos.
In area along the Phase 2 limits, a proper soil cover can not be established at this time due
to the existing steep slope and inaccessibility to the location by construction equipment. As
noted above, waste had to be relocated to construct the Phase 3 waste area tie-in to the Phase 2
liner. Due to the existing condition of the Phase 2 waste fill, it was not feasible to relocate
enough waste to establish a slope suitable for placement of soil cover material. Based on the
current condition, the County proposes to cover the exposed waste along the northern slope of
Phase 2 with a plastic tarp. The plastic tarp will remain in -place until such time as the Phase 3
area is permitted to receive waste and access can be established through Phase 3 to the uncovered
waste along Phase 2. Once access is established a proper soil cover can be placed. The Phase 2
soil cover will be established with 60 days of issuance of the Permit to Operate for Phase 3.
I5A NCAC 13B .0203 (d) states that: by receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.
As part of the Permit to Construct MSW Phase 3 and 4, several groundwater monitoring
wells (MW's) and landfill gas monitoring wells (LFG's) were abandoned in order to construct
MSW Phase 3 and its associated grading for access roads and soil stockpiles. New MW's and
LFG's were shown on the Permit to Construct drawings and approved by the Permitting Section
of the Solid Waste Section. An "Explosive Gas Control Plan" was included in Appendix 3 of the
approved Operations Plan. Haywood County will construct the approved MW's and LFG's as
shown on the Permit to Construct drawings and in accordance with the approved plans. The
County will provide an updated as -built map which shows the location of the MW's and LFG's.
The County is in the process of working with Bunnell-Lammons Engineering, Inc. (BLE)
to finalize the contract for the installation of the proposed MW's and LFG's, as shown in the
Permit to Construct. In addition to these proposed wells, the County must replace three MW's
(MW 3, MW 31), and MW 9) and LFG 4, which were inadvertently covered by filling operations
during the construction of MSW Phase 3. Zinith Barbee, the reviewing NCDENR
Hydrogeologist for this project, was notified on April 30, 2010 of the fact that the wells were
covered with fill dirt during construction. A subsequent email to Mr. Barbee pertaining to MW 9
was sent June 3, 2010. Mr. Barbee responded with a letter, dated May 5, 2010, which outlined
the steps necessary to remedy the situation. To summarize, MW's 3, 31), 9 and LFG 4 will be
replaced in close proximity to their original location, and shall be renumbered MW 3r, MW 3Dr,
MW 9r, and LFG 4r. Mr. Barbee had additional concerns regarding surface water monitoring
point SW-2 and MW 4A. The original location of SW-2 was in the area permitted to be filled by

Ms. Andrea Keller
June 3, 2010
Page 5
Like most County -operated solid waste disposal facilities, Haywood County is facing
funding challenges. The County is restructuring personnel assignments in their Solid Waste
Department to accommodate additional positions at the White Oak Landfill. The County
continuously seeks applicants for positions at the landfill. The County will continue to provide
the necessary resources to ensure that the White Oak Landfill is properly operated and
maintained.
The construction of MSW Phase 3 was a challenge to all involved. The discovery of
waste outside the liner limits of existing MSW Phase 1 and very close to the liner limits of MSW
Phase 2 presented difficulties to the Contractor in connecting to the existing liner edge and to the
County in keeping wastes covered and leachate under control. In addition, the extreme amount
of rainfall during the construction period and the rock encountered within the Phase 3 limits
added to the complexity of the project. But now, the Contractor is working on the final punch
list items and we expect to submit the necessary Construction Quality Assurance information to
the NCDNER in the coming weeks in order to obtain a Permit to Operate MSW Phase 3. Having
MSW Phase 3 on line will allow the County better opportunities for the proper management and
disposal of MSW waste and control of leachate at the White Oak Landfill.
Haywood County is committed to addressing the issues raised in the Facility Compliance
Audit Report and will work diligently to correct the noted deficiencies. The County appreciates
your consideration of their response to the deficiencies noted in the Facility Compliance Audit
Report received May 12, 2010, and should you have any questions or require additional
information please give us a call.
Sincerely,
McGILL ASSOCIATES A.
fJE(FO.El R. BISHO , PE
Senior Project Manager
Enclosure
cc: Mr. Marty Stamey, Haywood County Assistant County Manager, w/enc
Mr. Stephen King, Haywood County Solid Waste Director, w/enc
Mr. Paul Crissman, NCDENR, w/enc
Mr. Ed Mussler, NCDENR, w/enc
Mr. Zinith Barbee, NCDENR, w/enc
Mr. Allen Gaither, NCDENR, w/enc
Ms. Deb Aja, NCDENR, w/enc
Mr. Donald Herndon, NCDENR, w/enc
Mr. Mark Poindexter, NCDENR, w/enc
P:\2007\07518\Letters\akljunel0-Audit Report Response.doc

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RECEIVED
Haywood County Department of Solid Waste J U N - 8 2010
Management SOLID WASTE SECTION
278 Recycle Road, Clyde, North Carolina 28734, Ph.: [phone], Fax: (828)6 ,7,1g 114- REGIONAL OFFICE
June 4, 2010
Ms. Andrea Keller, Waste Management Specialist
Solid Waste Section
Division of Waste Management
North Carolina Department of Environment and Natural Resources
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Request for Demonstration Period for Mulch/Soil Material as an Alternate Daily Cover
Haywood County White Oak MSW Landfill, Permit # 44-07 (Resubmit due to
availability of material on site)
Dear Ms. Keller,
The Haywood County Department of Solid Waste Management is formally requesting the use of
an Alternate Daily Cover (ADC) at the White Oak Landfill. The Department proposes a 180 day
demonstration period, during which Field Specialists with the Solid Waste Section will be able to
verify the ADC's effectiveness in meeting the requirements of Rules .1626(2)(a) and (b).
The proposed ADC will consist of six inches of a mixture of soil and mulch material such that a
proportion of 3:1, soil to mulch, will be used in place of six inches of cover soil materials. The
County will use the mulched material on an availability basis primarily in wet landfill access
areas. The mulched material will be generated on site at the proposed grinding and mulching
treatment and processing facility, which is currently under permit review by the Permitting
Branch of the Solid Waste Section of the North Carolina Department of Environment and
Natural Resources. All operations of the treatment facility will be in accordance with Section
.0300 of the Solid Waste Rules, as described in the Mulching and Grinding Treatment and
Processing Operations Plan submitted to the Permitting Branch. The ADC mulch will be applied
to the landfill as described below. The County would like to begin the ADC demonstration
period as soon as possible. This demonstration period will offer the County the opportunity to
review grinding and mulching treatment and processing procedures as well as ADC mulch
application procedures prior to finalizing the Operations Plan for each.

Operations Plan: ADC Mulched Material
At the discretion of the landfill operator, in place of six inches of cover soil materials, by the end
of each day of operations, the horizontal or lateral expansion of the working face will be covered
with at least six inches of a mixture of mulched material and cover soil materials. The
mulch/soil mixture will consist of a ratio of 1: 3, mulched material to soil. Mulched material will
be transported to the landfill and stockpiled in an area out of the way of current operations and
access. Three stockpiles of dirt equal to the size of the mulch stockpile will be placed with the
mulch. An excavator or bulldozer will be used to mix the soil and mulch materials by rolling the
material together as it covers.
Thank you for your time and consideration of this request. Please contact me at your
convenience should you need any additional information or have any additional requirements of
this department with regards to the request. I look forward to your response.
Sincerely,
Stephen King
Director of Solid Waste Management, Haywood County
cc: David Cotton, Haywood County Manager
Jeff Bishop, McGill Associates
Allen Gaither, Regional Engineer, NCDENR