4501_ROSCANS_2000

JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
WILLIAM L. MEYER
DIRECTOR
NORTH CARc,._INA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
April 12, 2000
Mr. Gary Tweed, P. E.
County Engineer
Henderson County
802 Stoney Mountain Road
Hendersonville, NC 28791
RE: Henderson MSWLF Facility, Proposed Construction and Demolition
Landfill, Permit Number 45-01
Dear Mr. Tweed:
This letter is in response to your request for clarification concerning the
possibility of disposing of construction and demolition waste vertically over the
closed, pre -Section .1600 landfill areas within the referenced MSWLF facility. I
apologize for the delay in responding and the rather lengthy response. However;
the Solid Waste Section(Section) gave due consideration to your request and felt
that it was important to explain the reasoning behind the decision not to consider
the proposed expansion at this time.
On March 1, 1997, the Section implemented a policy entitled "Closure
Considerations for Unlined Municipal Solid Waste Landfills." This policy allowed
an owner and operator of a closed municipal solid waste landfill(MSWLF), who
wished to dispose of construction & demolition waste vertically over the closed
MSWLF unit, to apply for a construction/demolition landfill (CDLF) permit under
a simplified and expedited procedure. This policy was a short-term solution to the
CDLF capacity shortage created by the closure of many unlined county MSWLFs
prior to the January 1, 1998 deadline. The permit application consisted of a simple
operations plan indicating a five-year disposal capacity with annual development
phases. The purpose of the limited five-year permit was twofold: (1) to provide
adequate construction & demolition waste disposal capacity during the transition
period following the closure of the unlined MSWLFs, and (2) to allow the Section
to evaluate any adverse impacts as a result of these vertical expansions and to
evaluate the effectiveness of the current requirements for CDLFs.
This policy was limited to so-called Section .1600 MSWLFs, ones that met
the new state and federal requirements for MSWLFs operating after October 9,
1993. These rules required: an upgraded operations plan in accordance with Rules
.1625 and .1626; an upgraded closure and post -closure plan in accordance with
Rule .1629, including a final cap system which meets the requirements of Rule
.1627 and financial assurance which meets the requirements of Rule .1628; and an
upgraded water quality monitoring plan in accordance with Rules .1630-32. These
landfills are also subject to the water quality detection and assessment monitor'
1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE ISO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

Mr. Tweed
April 12, 2000
Page 2
requirements as well as the corrective action requirements of Rules .1633-1637. The Section
recently began the difficult task of evaluating the need for revised permitting policies and
requirements for CDLFs. In regards to landfill design, the study will address the adequacy of the
current landfill design, so-called naturally -attenuating sites, i.e. ones without any type of
engineered devices. The desired surface and subsurface characteristics of naturally -attenuating
site are difficult to determine, measure and evaluate. It should be noted that these characteristics
are virtually impossible to evaluate for landfills proposed over and laterally adjacent to closed
unlined MSWLFs. In addition to a thorough evaluation of the effectiveness of the current rules,
this study will evaluate the potential adverse impacts of the operation of a CDLF over or
adjacent to a closed MSWLF, including the potential impacts on assessment and corrective
action at MSWLFs and the potential impacts on leachate generation and migration as a result of
the operation of a CDLF over a MSWLF.
The Section anticipates that this study will be completed and recommendations made
regarding revisions to the CDLF rules by May 1, 2001. Until this evaluation is completed, the
Section will not revise the current policy to allow consideration of the vertical expansion over or
lateral expansion of pre-1600 MSWLF units. Accordingly, the Section has determined that the
proposed expansion at the referenced site can not be considered for a permit until the study is
completed.
If there are any questions or comment, please contact me at [phone], extension
255.
Sincerely,
ames C. Coffey, H
Permitting Branch
Solid Waste Section
cc: Brent Rockett
Jim Patterson
Tim Jewett

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
Type of Facilityf "}Y;3 t:� l yY 1, Y Ei>%iri Tin'' Permit
Name of FacilityLocation Ur/�
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
II. Operational Requirements Followed Yes .rNo
r*
15A N-C. Admin. Code 13B Section a 11 U ^1 " j) Ui
A. Specific Violation(s) by number and letter.
v1;e> C7 ( ) c�...) coty���e.%. C��/�ol��, e'jr=17`�'t
III. Other Violations of Rule or Law
IV. Evaluator's Comments
V. Continuation Page Required? Yes No Receiving Signature
Evaluation Date Solid Waste Section
DEHNR 3793 ((Part I White: Facility Part lI Canary: Central Office
Solid Waste Section (Review 7/94)
Part III Pink: Regional Office)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE KAMAGENENT FACILITY EVALUATION REPORT
Type of Facility Permit v countyTP,y) A C. y
-
Name of Foci Lity. ljo'fjcy, t"', chuJk' Location > P, 1 1/1 (y
Date of Last Evaluation 000
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
11. Operational Requirements Followed Yes No
15A N-C. Admin. Code 138 Section C'.-) o 5
A. Specific Violation(s) by number and Letter.
III- Other Violations of Rule or Law
IV. Evaluator's Caments 41 kilt
ZVI t2k /1(/4 .61)"/
L)
' yV. Continuation Page Required? Yes No Receiving Signature
Evaluation Date Solid Waste Section 117111w III
DEHUR 3793 (Part I White: Facility Part 11 Canary- Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

1
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CONCLUSIONS, ACTION TAKEN OR REQUIRED
INFORMATION COPIES
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EPA Form 1300-6 (7-72)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
Type of Facility �� Permit ` J i Canty
Name of Facility. ) f`? f Location
i
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated _
II. Operational Requirenents Followed '1 Yes No
15A N-C. Admin. Code 13B Section (,r?
A. Specific Violation(s) by number and Letter.
III. Other Violations of Rule or Law
IV. Evaluator's Comments
i ;
V. Continuation Page Required? Yes No Receiving Signature
r }
Evaluation Date Solid Waste Section
DEHNR 3793 (Part I Fite: Facility Part II Canary: Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 71%) / lr
A