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- Marcus ]ones, Director
Henderson County -
Engineering& Facility Services
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Hendersonville, NC 28792
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AAla
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
UNIT WE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: HENDERSON
MSWLF
PERMIT NO.: 45-01
Closed
X
HHW
White
mein
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
Closed
X
Closed
X
Asbestos
X
TVA
X
DEMO
X
SDTF
CDLF
CDLF atop
Disposal
Industrial
Closed
Area(s)
Landfill
MSWLF
Date of Audit: 03/10/2010
FACILITY NAME AND ADDRESS:
Henderson County Solid Waste Landfill
Date of Previous Site Visit: 02/11/09,
GPS COORDINATES: N: 35.35558, E:-82.49531
FACILITY CONTACT NAME AND PHONE NUMBER:
Marcus Jones — Henderson Co. Director of Engineering
100 N. King Street
Hendersonville, NC 28792
FACILITY CONTACT ADDRESS:
Henderson County Solid Waste Transfer Facility
802 Stoney Mountain Road
Hendersonville, NC 28971
[phone]
AUDIT PARTICIPANTS:
Andrea Keller — DENR Solid Waste Section
Bill Wagner — DENR Solid Waste Section
Will Sagar— Henderson Co. Solid Waste Director
Natalie Berry — Henderson Co. Asst. County Engineer
Rebecca Coplin — Henderson County SW Dept.
STATUS OF PERMIT:
MSWLF Transition Plan Approval — November 13, 1995
MSWLF stopped receiving waste — December 31, 1997
MSWLF and C&DLF on top of closed MSWLF Closure Permit — April 11, 2006
C&DLF stand-alone PTO — October 4, 2001
C&DLF stand-alone — Inactive (waiting on formal closure letter from the Section)
PURPOSE OF AUDIT:
COMPREHENSIVE
NOTICE OF VIOLATION(S):
Closed stand-alone C&DLF
15A NCAC 13B .0531 Applicability (c) states: that Owners and operators of C&DLFfacilities and units must
conform to the requirements of Rules .0531 through .0547 of this Section as follows: C&DLF units permitted to

15A NCAC 13B .0510 of this section requires that a disposal site be closed in accordance with rule. 0505 of this
Subchapter.
15A NCAC 13B .0505(4)(a) states: Adequate erosion control measures shall be practiced to prevent excessive on -site
erosion.
15A NCAC 13B .0505 (6)(a) states: Within six months after final termination of disposal operations at the site or a
major part thereof or upon revocation of a permit, the area shall be stabilized with native grasses.
During the comprehensive inspection it was determined that the stand-alone closed C&DLF exhibited excessive rills,
discharge, and uncovered waste with little to no stabilization with native grasses. See items 1, 2, and 3 noted below in
the Areas of Concerns and Comments section.
Henderson County is in violation of 15A NCAC 13B .0505(4)(a) for failure to prevent excessive on -site erosion at the
stand-alone C&DLF unit.
Henderson County is in violation of 15A NCAC 13B .0505(6)(a) for failure to stabilization the site with native grasses
within six months of final termination of disposal operations.
In order to achieve compliance, Henderson County must, by June 4, 2010, correct the settlement, subsidence,
erosion, and vegetation requirements at the C&DLF unit. The seepage/leachate release issue must be addressed
immediately to ensure that leachate does not leave the site.
Closed MSWLF
15A NCAC 13B .1627 (d) Post -closure criteria (1)(A) states: Maintaining the integrity and effectiveness of any cap system,
including making repairs to the cover as necessary to correct the effects of settlement, subsidence, erosion, or other events,
and preventing run-on and run-off from eroding or otherwise damaging the cap system;
During the comprehensive inspection it was determined that the MSWLF with a C&DLF on top exhibited erosion
rills, discharge, and uncovered waste. The surface water drainage in the drainage ditch; as it passes through solid
waste, is considered leachate and must be treated accordingly. Additionally, woody tree growth was established on the
lower slopes of the MSWLF. See items 2 and 4 noted below in the Areas of Concerns and Comments section.
Henderson County is in violation of 15A NCAC 13B .1627(d)(1)(A) for failure to maintain the integrity and
effectiveness of the closed MSWLF cap system.
In order to achieve compliance, Henderson County must, by May 7, 2010, submit a plan to the Section detailing
how the County intends to achieve compliance regarding the settlement, subsidence, erosion, and woody
vegetation at the closed MSWLF unit and the closed C&DLF unit atop the MSWLF unit. This plan must
include a reasonable timeline for corrective actions. The seepage/leachate release issue must be addressed
immediately to ensure that leachate does not leave the site.
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $15,000 per day may be
assessed for each violation of the Solid Waste Statute or Regulations. For the violation(s) noted here, you maybe 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.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 10
2. Future site maps submitted to the Section, including proposed site plans regarding the new Transfer Station,
access roads, Material Recovery Facility, and convenience center drop off locations should indicate all site fill
areas in relation to the proposed activities. In addition, per the memorandum dated May 29, 2009 (Subject:
Permanent Edge -of -Waste Markers at Construction and Demolition Debris Landfill, Industrial Solid Waste
Landfills, and Municipal Solid Waste Landfills), owners and operators of all active, inactive and closed landfill
units should install and maintain permanent edge -of -waste (EOW) markers for all landfill units. (See attached
memo). Further discussion regarding EOW issues are found below.
3
In addition to the above -noted fill activities, there is an active beneficial fill area located south of the current
white goods area (governed under the 45-04T permit). The beneficial fill area must be controlled in order to
03/10/2010 photos #1: painted block, rebar, porcelain and some plastics were noted.
15A NCAC 13B .0562 Beneficial Fill (1) states: the fill material consists only of inert debris limited to
concrete, brick, concrete block, uncontaminated soil, rock, and gravel.
While most of the material noted at the site conforms with the above -stated definition, this area is not
considered a disposal site for solid waste and thus all non -conforming materials must be sorted and
removed from this fill area for proper disposal.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 10
2. Future site maps submitted to the Section, including proposed site plans regarding the new Transfer Station,
access roads, Material Recovery Facility, and convenience center drop off locations should indicate all site fill
areas in relation to the proposed activities. In addition, per the memorandum dated May 29, 2009 (Subject:
Permanent Edge -of -Waste Markers at Construction and Demolition Debris Landfill, Industrial Solid Waste
Landfills, and Municipal Solid Waste Landfills), owners and operators of all active, inactive and closed landfill
units should install and maintain permanent edge -of -waste (EOW) markers for all landfill units. (See attached
memo). Further discussion regarding EOW issues are found below.
In addition to the above -noted fill activities, there is an active beneficial fill area located south of the current
white goods area (governed under the 45-04T permit). The beneficial fill area must be controlled in order to
03/10/2010 photos #1: painted block, rebar, porcelain and some plastics were noted.
15A NCAC 13B .0562 Beneficial Fill (1) states: the fill material consists only of inert debris limited to
concrete, brick, concrete block, uncontaminated soil, rock, and gravel.
While most of the material noted at the site conforms with the above -stated definition, this area is not
considered a disposal site for solid waste and thus all non -conforming materials must be sorted and
removed from this fill area for proper disposal.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 10
4. Surface water runs between the closed MSWLF and the fill area listed at 1982 Disposal Area (may also be
MSWLF), and then passes along the east border of the TVA 1978 fill area. This drainage/creek area appears to
have a build up of surface waste (metals and plastics), windblown material, and/or possible uncovered waste
(unable to determine fill areas on older, closed fill units as there are no EOW markers in place).
03/10/2010 photo #2
This material should be removed for proper disposal as this activity could be considered the establishment of
an illegal open dump site. It is recommended that this clean up be conducted before visibility is lost due to
vegetation growth over the spring/summer months.
INACTIVE (stand-alone) C&DLF CONEAENTS:
The stand-alone C&DLF had met closure requirements at the time of the required engineering submittal. However,
in the months following this documentation of final cap thickness and grading at the closed C&DLF the landfill
unit cap has suffered considerable erosion and slumping.
1. The erosion ditch pictured below had exposed waste and appeared to be outside of the existing EOW markers
in place at the C&DLF. This may be due to erosion of a previous fill area, or of transport of waste off the
2. EOW markers will need to be re-established for the closed C&DLF. The wooden stakes currently in place are
not stable. It is recommended that EOW markers be: visible in line of site from marker to marker, made of
materials able withstand the elements, and labeled `BOW" or similar.

FACILITY COMPLIANCE AUDIT REPORT
Division `of Waste Management
Solid Waste Section .
Page 6 of 10
0/10 EOW markers
Slumping was visible on the southwestern slope of the landfill. Additionally, several leachate seeps were
noted. This area requires soil cover and vegetation for erosion control. The leachate seeps appeared to stay
ze should be investigated by the county to verify.
03/10/10
The access road on the C&DLF is slumping and eroding and the ground cover appears unstable (visible
cracking). The EOW markers are on the outside edge of the access road are being pushed along with the
03/10/10
Items 1, 2 and 4 need to be addressed as required in the Notice of Violation section within this audit
report. The seepage/leachate release issue must be addressed immediately to ensure that leachate does
not leave the site.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 10
CLOSED MSWLF COMMENTS:
The closed MSWLF footprint is considerably larger than the current area marked with EOW markers. Correct
the EOW markers as soon as possible. Due to the planned site construction activities, and with reference to
the attached memorandum regarding EOW markers, a survey of EOW should be conducted for all fill
areas.
2. The access road located on the MSWLF waste fill area (leading up to the white goods, closed C&DLF, and
grinding operation areas) currently shows EOW markers to the "outside" or left of the road (see photo below).
Per Mr. Sagar and site maps referenced earlier, the EOW is actually 100-300' past these EOW markers. In this
region, significant vegetation has taken root. This area must be accessible, mowed regularly, and must not
contain any woody vegetation (trees).
03/10/10 photo 43
While the MSWLF was closed under the .1600 Rules and the C&DLFs, Demolition LF, and TVA disposal area
were closed under the .0500 Rules, all Areas must meet the Post -Closure General Condition stated in the permit
such that the owner or operator shall maintain the integrity and effectiveness of any cap system.
The woody/tree growth is encroaching upon the cap system. As these types of root systems
will most likely extend beyond the erosion layer into the impermeable layer of the cap (thus
destroying the integrity of the cap system and creating a path for water into the landfill), and as trees both inhibit
the proper mowing and necessary maintenance of the cap while impeding on the ability to visually inspect the
cap integrity, this woody shrub/tree growth must be eliminated. Any stumps and root systems of larger
trees must be removed and the cap system repaired.
3. The closed MSWLF Post -Closure Conditions (April 11, 2006) in the Letter of Closure and the .1600 Rules are
the governing regulations for this landfill unit. The list of Approved Documents includes Closure Plans, Post -
Closure Use Plan, Methane Gas Remediation Plan, and a Ground Water Corrective Action Plan. During the
next scheduled site visit, the Section wishes to review these documents, in particular Part C: Methane Gas
Remediation Plan — please have this available at the landfill at the time of the site inspection.
4. The closed MSWLF has a drainage ditch running on the "inside" of the access road. This drainage ditch
exhibited erosion to the extent that solid waste was exposed and the landfill cap exhibited erosion such that
rills had formed and discharge was draining into the drainage ditch.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 10
03/10/10
Rills/discharge from landfill into drainage ditch, photos #4
Drainage ditch/waste #.5
03/10/10
Post Closure General Condition #2 states that the owner or operator shall maintain the integrity and
effectiveness of any cap system, including making repairs to the cover as necessary to correct the effects of
settlement, subsidence, erosion, or other events, and preventing run-on and run-off from eroding or otherwise
damaging the cap system.
Item number 2 and 4 need to be addressed as required in the Notice of Violation section within this
audit report. The seepage/leachate release issue must be addressed immediately to ensure that leachate
does not leave the site.
5. The groundwater monitoring data was available and currently under review by the Section hydrogeologist.
6. The landfill gas (LFG) monitoring plan was unavailable at the time of the audit. However, the collected data
was available. Henderson County utilizes Enerdyne for maintenance of the gas extraction system and for the
collection of LFG monitoring data. While monitoring data was available for review, due to the lack of a Plan it
was difficult to determine the following: Number of wells and location of wells, whether the methane data was
in %Volume or % LEL, and what the other data points on the spreadsheet represented (structures on/off
property?). Additionally, two of the LFG monitoring wells located on the north side of the property (in the
region where, historically, methane migration had occurred) were not capped, locked, or labeled.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 9 of 10
03/10/10 LFG Monitoring well. #6
7. No data was available that appeared to represent monitoring in the facility site structures (office buildings,
scale house, etc.) as required in both Rule and in Closure Condition #12:
The owner or operator shall maintain and operating the gas monitoring system to ensure that:
(a) The concentration of methane gas generated by the facility does not exceed 25% of
the lower explosive limit for methane in facility structures (excluding gas control or
recovery system components); and
(b) The concentration of methane gas does not exceed the lower explosive limit for
methane at the facility property boundary.
Please provide evidence that all facility structures have been monitored for LFG. If the LFG
Monitoring Plan does not include all structures, or is out of date with current site activities and future
plan, an updated LFG Monitoring Plan should be submitted during the next permit
application/amendment/renewal cycle.
8. During the site inspection, it was stated (W. Sagar) that groundwater monitoring wells had been screened for
methane as part of an assessment activity pertaining to groundwater contamination at the site. It was also
stated that the %Vol of methane in at least one of these wells was >35% methane. Depending on the actual
readings and the location of this well(s), this information should have been immediately communicated to the
Section hydrogeologist (Jaclynne Drummond, 919-508-8500) to determine a potential course of action. Per
Closure Condition #13: If methane gas levels exceeding these limits are detected, the owner or operator must
take all steps required in Rule .1642(4)(c). Methane gas remediation plans approved by the Division are
described in the list of Approved Documents, Attachment 1, Part C.
Please provide the LFG data collected from this assessment activity to Ms. Drummond.
Please contact me if you have any questions or concerns regarding this audit report.
Phone: [phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Mailed on : 04/08/10 by
Hand delivery
US Mail
Certified No. [ 7006 2150
0005 2458 9228
ec: Mark Poindexter, Field Operations Branch Supervisor
Deb Aja, Western District Supervisor

Page 10 of 10
Donald Herndon, Compliance Officer
Larry Frost, Permit Engineer
Jaclynne Drummond, Section Hydrogeologist
Natalie Berry, Assistant County Engineer: nber;[e-mail]
Steve Wyatt, County Manager: snatta,hendersoncouniync.org
Rebecca Coplin, Admin. Asst. Solid Waste Division: rcopliii@,hendersoncountync.org

NCDEN
North Carolina Department of Environment and
Division of Waste Management
Beverly Eaves Perdue Dexter R. Matthews
Governor Director
May 29, 2009
Memorandum
Natural Resources
To: Construction and Demolition Landfill Owners and Operators
Industrial Solid Waste Landfill Owners and Operators
Municipal Solid Waste Landfill Owners and Operators
From: Solid Waste Section
Dee Freeman
Secretary
Subject: Permanent Edge -of -Waste Markers at Construction and Demolition Debris Landfills,
Industrial Solid Waste Landfills and Municipal Solid Waste Landfills
15A North Carolina Administrative Codes (NCAC) 13B .0540(1) and (2) and 13B .1619(d)(1) require
operators and owners of construction and demolition (C&D) landfills, industrial solid waste landfills
(ISW) and municipal solid waste (MSW), respectively, to establish and maintain buffers. This
requirement is intended to prevent accidental disposal of waste outside permitted disposal units
during the active life of the facility and to be able to identify the boundaries of the disposal unit
during the post -closure period.
In order to comply with this requirement, effective January 1, 2010 owners and
operators of all active, inactive and closed C&D landfill units, ISW landfill units and MSW
landfill units shall install and maintain permanent edge -of -waste markers for all landfill
units.
Markers shall be placed to clearly delineate the edge -of -waste around the perimeter of every active,
inactive and closed disposal area. All markers must be maintained throughout the life of the landfill
and throughout the required period of post -closure care. In addition, facility staff should be aware of
and be able to show Division staff the permitted boundary of the facility. A compliance survey may
be required as per NCAC 13B .0542 (m) and .1604 (b) (2) (M).
If you have any questions concerning this requirement, please contact the Environmental Senior
Specialist in your area. See www.wastenotnc.org/swhome/FieldOpMapC.pddf for contact information.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] FAX: [phone] Internet: www.wastenotnc.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Aahlrall'l� f

N
gMcGill
A S S O C I A T E S
May 5, 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:
MAY - 5 2010
SOLID WASTE SECTION
ASHEVILLE REGIONAL OFFICE
RE: Facility Compliance Audit Report
Henderson County Solid Waste Landfill
Henderson County, North Carolina
Permit # 45-01
On behalf of Henderson County, North Carolina, we are providing this response to the
Facility Compliance Audit Report dated March 10, 2010 and the subsequent Partial/ Follow-up
Facility Compliance Audit Report dated April 28, 2010. Based on McGill Associates review of
the specific site conditions, we have prepared this response to generally correspond with the
indentified Notice of Violations in the audit report as well as the Areas of Concern for each
identified facility.
Closed Stand -Alone C&DLF
15A NCAC 13B .0505 (4)(a) - Failure to prevent excessive on -site erosion at the stand-
alone C&DLF unit.
15A NCAC 13B .0505 (6)(a) — Failure to stabilize the site with native grasses within six
months of final termination of disposal operations.
In order to achieve compliance, Henderson County must, by June 4, 2010, correct the
settlement, subsidence, erosion, and vegetation requirements at the C&DLF unit. The
seepage/leachate release issue must be addressed immediately to ensure that leachate
doe not leave the site.
E n g i n e e r i n g e P l a n n i n g F i n a n c e
McGill Associates, P.A. • P.O. Box 2259, Asheville, NC 28802 • 55 Broad Street, Asheville, NC 28801
828-252-0575 • Fax: [phone]

Ms. Andrea Keller
May 5, 2010
Page 3
Closed MSWLF
15A NCAC 13B .1627 (d)(1)(A) — Failure to maintain the integrity and effectiveness of
the closed MSWLF cap system.
In order to achieve compliance, Henderson County must, by May 7, 2010, submit a
plan to the Section detailing how the County intends to achieve compliance regarding
the settlement, subsidence, erosion, and woody vegetation at the closed MSWLF unit
and the closed C&DLF unit atop the MSWLF unit. This plan must include a
reasonable timeline for corrective actions. The seepage/leachate release issue must be
addressed immediately to ensure that leachate does not leave the site.
The County has been addressing the seepage/leachate releases on the closed MSW
Landfill facility. Some of the seepages/leachate releases have been repaired in general
conformance with the enclosed detail titled "Leachate Weep Repair" and the County is in
process of completing the remainder. Continued periodic inspections of the closed MSW
Landfill facility will be conducted to ensure that other apparent leachate
seepages/releases are promptly noted and repaired to prevent leachate from leaving the
site.
The County will begin repairs to the closed MSW Landfill cap system relative to any
settlement, subsidence and erosion upon completion of the cap repair activities associated
with the stand-alone C&D Landfill. This repair activity associated with the closed MSW
Landfill should be complete by August 16, 2010.
Activities will initially include repairing those areas specifically noted in the March 10,
2010 Facility Compliance Audit Report. The cap system will then be assessed by the
appropriate County/landfill staff to identify other areas of the cap system that appear to
have suffered some degree of settlement, subsidence or erosion. Each area will be
assessed and an appropriate repair method will be selected. This may be as minor as
simply filling with appropriate soil material, compacting, regrading and grassing and
mulching. Other areas may require more extensive regrading to reestablish the required
lines and grades to ensure the proper runoff of surface water. Erosion protection matting
may be required in some areas until the reestablishinent of a substantial vegetative cover
has occurred. Drainage channels along the access roads will be reestablished to ensure
proper coverage of waste material while still providing the necessary drainage patterns to
control surface runoff and prevent the ponding of surface water on the landfill cap
system. Various types of drainage channel armament and/or check dams or other types
of erosion control devises may need to be installed to stabilize the channel and minimize
further erosion until such time as a substantial vegetative cover is reestablished.

Ms. Andrea Keller
May 5, 2010
Page 4
The County acknowledges that certain areas of the closed MSW Landfill have been
encroached upon by the uncontrolled growth of woody type vegetation. In certain areas
this growth is of a type and/or size that may be mowable by a tractor pulled rotary type
cutter/mower. The County is in the process of attempting to mow all accessible areas of
the closed MSW Landfill cap system at this time. Other areas encroached upon by larger
woody shrub/tree growth may require the expertise of a grading contractor in order to
adequately remove the vegetation, associated stumps/root systems and repair the cap
system to its original condition. The County proposes to include the more extensive
vegetation removal as a part of the upcoming planned capital improvement project
associated with the upgrading/relocation of the commercial entrance and citizen's
convenience center. This project is proposed to be out for bid sometime during the
summer of 2010 with work beginning late summer or early fall. The clearing and
grubbing of the landfill cap system for the closed MSW Landfill would be stipulated as
an initial project in the construction phase.
The edge of waste (EOW) markers will be established and are addressed for the facility
as a whole in a subsequent paragraph under General Comments.
Landfill Gas Monitoring Plan — Please provide evidence that all facility structures have
been monitored for LFG. If the LFG Monitoring Plan does not include all structures,
or is out of date with current site activities and future plan, an updated LFG
Monitoring Plan should be submitted during the next permit
applicatioiz/ainendment/renewal cycle.
The County is still in the process of reviewing their records to attempt to locate a Landfill
Gas Monitoring Plan for the facility. The County has apparently located a loose copy of
a Methane Gas Remediation Plan; however, this plan will need to be further reviewed
and compiled into a readable format. While the County's subcontractor for the operation
of the landfill gas extraction system has been collecting landfill gas readings from the
known monitoring points, strategically located around the closed MSW Landfill, they
apparently have not been monitoring the facility site structures. The existing site
structures will be monitored and the readings recorded during the next scheduled
landfill gas monitoring cycle — in particular the activity building, landfill office, scale
house, landfill shop, transfer station structures and the Trace barn. Should the
County not be able to locate a Landfill Gas Monitoring Plan in their records then a plan
will be prepared and submitted during the next permit application/amendment/renewal
cycle.

Ms. Andrea Keller
May 5, 2010
Page 5
The County has addressed the issue of LFG monitoring wells not properly capped, locked
or labeled with their subcontractor responsible for operating the landfill gas extraction
system. Monitoring points MP-5 and MP-6 have been capped and the other noted
deficiencies will be promptly addressed. In addition, the six approved landfill gas
monitoring points and the three remaining Trace property monitoring points will be fitted
with a port system similar to that of the landfill gas extraction wells.
During the site inspection, it was stated (W. Sagar) that groundwater monitoring wells
had been screened for methane as part of an assessment activity pertaining to
groundwater contamination at the site. Please provide the LFG data collected from
this assessment activity to Ms. Drummond.
The County is presently reviewing their records for this data. Should this information be
found, it will be properly compiled and promptly submitted to Ms. Drummond.
GENERAL COMMENTS:
Edge of Waste Markers (EOW)
The County proposes the following plan to establish the edge of waste for all disposal
sites known to exist within the facility's property boundary. There are presently several
drawings available that depict the general boundaries of the waste facilities. The County,
with the assistance of their consultant, will review these drawings in conjunction with the
latest aerial photography and prepare a single drawing depicting the best fit for areas
known to contain waste material. This drawing will be submitted to the Department of
Environment and Natural Resources (DENR) for general concurrence by June 15, 2010.
Once general concurrence is received, the County intends to have the boundaries
preliminarily staked in the field. The County's Staff, in conjunction with their consultant,
will review the boundaries in the field and make any adjustments deemed appropriate due
to actual field conditions. The waste boundaries will then be resurveyed as necessary to
incorporate any adjustments and the data recorded on an updated site map drawing. The
County intends to provide the DENR with an updated waste boundary map within forty-
five (45) days of receipt of concurrence with the preliminary waste boundary map. The
permanent EOW markers, meeting the requirements of the DENR, will be installed based
upon the final determination of the waste boundaries. The existing wooden stakes that
were erroneously placed to mark the edge of waste will be immediately removed.

Ms. Andrea Keller
May 5, 2010
Page 6
Beneficial Fill Area
15 NCAC 13B .0562 Beneficial Fill (1) states: the fill material consists only of inert
debris limited to concrete, brick, concrete block, uncontaminated soil, rock, and gravel.
While most of the material noted at the site conforms with the above -stated definition,
this area is not considered a disposal site for solid waste and thus all non -conforming
materials must be sorted and removed from this fill area for proper disposal
The County will attempt to remove the visible and more readily accessible non-
conforming materials from the beneficial fill area to include the painted block, rebar,
porcelain and plastics. The removed items will be disposed of in an appropriately
permitted disposal facility. Steps will be taken to more closely inspect incoming loads
destined for the beneficial fill area to ensure non -conforming materials are not disposed
of in this area. Future haulers of beneficial material waste will be required to remove
non -conforming materials at the time of disposal for proper disposal in a properly
pennitted disposal facility.
Surface Water Drainage Path
The Facility Compliance Audit Report noted a surface water drainage area between the
closed MSW Landfill and the fill area listed as the 1982 Disposal Area that passes along
the eastern border of the TVA landfill area as containing a buildup of surface waste. The
cleanup of this area is presently being addressed by the landfill staff and should be
completed within the next couple of weeks.
April 28, 2010 Facility Compliance Audit Report, Areas of Concern and Comments
Item No. 12: Conversations with the County and with Mr. Pasko indicated that the
drainage ditch (detailed in comment #4 of the Closed MSWLF Comment section in the
previous audit report) follows the inside of the LF access road until it reaches a point
at which it can potentially discharge into surface water.
As this drainage ditch has exhibited exposed waste and potential leachate seeps,
the County must contact the Section Hydrogeologist (Jackie Drummond, 919-508-
8599) to discuss assessment activities in order to determine if leachate has left the
MSWLF site.
The County will be in contact with Ms. Drummond to discuss the situation and work with
her to reach an agreeable course of action to determine if leachate, if any, has possibly
migrated off the MSW Landfill site.

Ms. Andrea Keller
May 5, 2010
Page 7
Henderson County is sincere in their efforts to address the issues raised in the Facility
Compliance Audit Report and will work diligently to correct the noted deficiencies. The County
is intent on operating the facility in full compliance with all applicable rules and regulations. To
facilitate this course of action, the County is presently advertising for the position of Solid Waste
Manager. Once this position is filled, it will be their ongoing responsibility to ensure that the
facility and all applicable records are maintained in an orderly fashion. Currently assistance with
compliance assurance has been tasked to the Assistant County Engineer, Natalie Berry, PE. The
County appreciates your consideration of their response to the deficiencies noted in the March
10, 2010 Facility Compliance Audit Report and should you have any questions or require
additional information please give us a call.
Sincerely,
McGILL ASSOCIATES, P.A.
WILLVanager
Proje
Enclosure
cc: Mr. Marcus A. Jones, PE, Director, Henderson County Engineering and Facilities
Services, w/enclosure
Ms. Natalie J. Berry, PE, Assistant County Engineer, Henderson County, w/enclosure
P:\2009\09.00728\Letters\10 0505 - A Keller - NOV Response.doe

1T o
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: HENDERSON
MSWLF
PERMIT NO.: 45-01
Closed
X
HHW
White
Incin
T&P
FMM
MSWLF
goods
FILE TYPE: COMPLIANCE
Closed
X
Closed
X
Asbestos
X
TVA
X
DEMO
X
SDTF
CDLF
CDLF atop
Disposal
Industrial
Closed
Area(s)
Landfill
MSWLF
Date of Audit: 03/10/2010
FACILITY NAME AND ADDRESS:
Henderson County Solid Waste Landfill
Date of Previous Site Visit: 02/11/09,
GPS COORDINATES: N: 35.35558, E:-82.49531
FACILITY CONTACT NAME AND PHONE NUMBER:
Marcus Jones — Henderson Co. Director of Engineering
100 N. King Street
Hendersonville, NC 28792
FACILITY CONTACT ADDRESS:
Henderson County Solid Waste Transfer Facility
802 Stoney Mountain Road
Hendersonville, NC 28971
[phone]
AUDIT PARTICIPANTS:
Andrea Keller — DENR Solid Waste Section
Bill Wagner— DENR Solid Waste Section
Will Sagar — Henderson Co. Solid Waste Director
Natalie Berry — Henderson Co. Asst. County Engineer
Rebecca Coplin — Henderson County SW Dept.
STATUS OF PERMIT:
MSWLF Transition Plan Approval — November 13, 1995
MSWLF stopped receiving waste — December 31, 1997
MSWLF and C&DLF on top of closed MSWLF Closure Permit — April 11, 2006
C&DLF stand-alone PTO — October 4, 2001
C&DLF stand-alone — Inactive (waiting on formal closure letter from the Section)
PURPOSE OF AUDIT:
COMPREHENSIVE
NOTICE OF VIOLATION(S):
Closed stand-alone C&DLF
15A NCAC 13B .0531 Applicability (c) states: that Owners and operators of Cc&DLF facilities and units must
conform to the requirements of Rules . 0531 through. 0547 of this Section as follows: C&DLF units permitted to

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 10
operate prior to January 1, 2007, and which do not receive solid waste after June 30, 2008, must comply with the
Conditions of the Solid Waste Permit and Rule.0510 of this Section
15A NCAC 13B .0510 of this section requires that a disposal site be closed in accordance with rule. 0505 of this
Subchapter.
15A NCAC 13B .0505(4)(a) states: Adequate erosion control measures shall be practiced to prevent excessive on -site
erosion.
15A NCAC 13B .0505 (6)(a) states: Within six months after final termination of disposal operations at the site or a
major part thereof or upon revocation of a permit, the area shall be stabilized with native grasses.
During the comprehensive inspection it was determined that the stand-alone closed C&DLF exhibited excessive rills,
discharge, and uncovered waste with little to no stabilization with native grasses. See items 1, 2, and 3 noted below in
the Areas of Concerns and Comments section.
Henderson County is in violation of 15A NCAC 13B .0505(4)(a) for failure to prevent excessive on -site erosion at the
stand-alone C&DLF unit.
Henderson County is in violation of 15A NCAC 13B .0505(6)(a) for failure to stabilization the site with native grasses
within six months of final termination of disposal operations.
In order to achieve compliance, Henderson County must, by June 4, 2010, correct the settlement, subsidence,
erosion, and vegetation requirements at the C&DLF unit. The seepage/leachate release issue must be addressed
immediately to ensure that leachate does not leave the site.
Closed MSWLF
15A NCAC 1313.1627 (d) Post -closure criteria (1)(A) states: Maintaining the integrity and effectiveness of any cap system,
including making repairs to the cover as necessary to correct the effects of settlement, subsidence, erosion, or other events,
and preventing run-on and run-off from eroding or otherwise damaging the cap system;
During the comprehensive inspection it was determined that the MSWLF with a C&DLF on top exhibited erosion
rills, discharge, and uncovered waste. The surface water drainage in the drainage ditch, as it passes through solid
waste, is considered leachate and must be treated accordingly. Additionally, woody tree growth was established on the
lower slopes of the MSWLF. See items 2 and 4 noted below in the Areas of Concerns and Comments section.
Henderson County is in violation of 15A NCAC 13B .1627(d)(1)(A) for failure to maintain the integrity and
effectiveness of the closed MSWLF cap system.
In order to achieve compliance, Henderson County must, by May 7, 2010, submit a plan to the Section detailing
how the County intends to achieve compliance regarding the settlement, subsidence, erosion, and woody
vegetation at the closed MSWLF unit and the closed C&DLF unit atop the MSWLF unit. This plan must
include a reasonable timeline for corrective actions. The seepage/leachate release issue must be addressed
immediately to ensure that leachate does not leave the site.
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $15,000 per day may be
assessed for each violation of the Solid Waste Statute or Regulations. For the violation(s) noted here, 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.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 10
STATUS OF PAST NOTED VIOLATIONS:
NONE
AREAS OF CONCERN AND COMMENTS:
GENERAL COMMENTS:
1. On site to conduct comprehensive audit of the closed MSWLF, closed C&DLF located on top of the closed
MSWLF, and the inactive stand-alone C&DLF (awaiting formal closure from the Section). In addition to these
three fill areas, the following fill activities are located within the facility boundary (a 1992 Gas Monitoring
Probe Location Map, sheet one; a 1992 Base Area Existing Solid Waste Disposal Facility map, sheet 1; and a
1993 Site Plan Proposed Final Contours/Existing Contours sheet 2):
a. Closed TVA Disposal Area (1978)
b. Closed Disposal Area 1982 Permit
c. Demolition Landfill (inactive)
d. Asbestos disposal site (inactive)
e. Asbestos disposal site (proposed)
Asbestos Disposal Site v`
partial 1992 site map
Closed Demolition
Landfill
Area of Closed
stand-alone
C&DLF
KWYl4SSiet3'.'r4'..:?i. 1�1f
Closed NA
Disposal Area

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 10
2. Future site maps submitted to the Section, including proposed site plans regarding the new Transfer Station,
access roads, Material Recovery Facility, and convenience center drop off locations should indicate all site fill
areas in relation to the proposed activities. In addition, per the memorandum dated May 29, 2009 (Subject:
Permanent Edge -of -Waste Markers at Construction and Demolition Debris Landfill, Industrial Solid Waste
Landfills, and Municipal Solid Waste Landfills), owners and operators of all active, inactive and closed landfill
units should install and maintain permanent edge -of -waste (EOW) markers for all landfill units. (See attached
memo). Further discussion regarding EOW issues are found below.
3. In addition to the above -noted fill activities, there is an active beneficial fill area located south of the current
white goods area (governed under the 45-04T permit). The beneficial fill area must be controlled in order to
03/10/2010 photos MI.: painted block, rebar, porcelain and some plastics were noted.
15A NCAC 13B .0562 Beneficial Fill (1) states: the fill material consists only of inert debris limited to
concrete, brick, concrete block, uncontaminated soil, rock, and gravel.
While most of the material noted at the site conforms with the above -stated definition, this area is not
considered a disposal site for solid waste and thus all non -conforming materials must be sorted and
removed from this fill area for proper disposal.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 10
4. Surface water runs between the closed MSWLF and the fill area listed at 1982 Disposal Area (may also be
MSWLF), and then passes along the east border of the TVA 1978 fill area. This drainage/creek area appears to
have a build up of surface waste (metals and plastics), windblown material, and/or possible uncovered waste
(unable to determine fill areas on older, closed fill units as there are no EOW markers in place).
03/10/2010 photo #2
This material should be removed for proper disposal as this activity could be considered the establishment of
an illegal open dump site. It is recommended that this clean up be conducted before visibility is lost due to
vegetation growth over the spring/summer months.
INACTIVE (stand-alone) C&DLF COMMENTS:
The stand-alone C&DLF had met closure requirements at the time of the required engineering submittal. However,
in the months following this documentation of final cap thickness and grading at the closed C&DLF the landfill
unit cap has suffered considerable erosion and slumping.
1. The erosion ditch pictured below had exposed waste and appeared to be outside of the existing EOW markers
in place at the C&DLF. This may be due to erosion of a previous fill area, or of transport of waste off the
2. EOW markers will need to be re-established for the closed C&DLF. The wooden stakes currently in place are
not stable. It is recommended that EOW markers be: visible in line of site from marker to marker, made of
materials able withstand the elements, and labeled `BOW" or similar.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 10
0/10 EOW markers
3. Slumping was visible on the southwestern slope of the landfill. Additionally, several leachate seeps were
noted. This area requires soil cover and vegetation for erosion control. The leachate seeps appeared to stay
within the footprint of the C&DLF but this issue should be investigated by the county to verify.
03/10/10
4. The access road on the C&DLF is slumping and eroding and the ground cover appears unstable (visible
cracking). The EOW markers are on the outside edge of the access road are being pushed along with the
03/10/10
Items 1, 2 and 4 need to be addressed as required in the Notice of Violation section within this audit
report. The seepage/leachate release issue must be addressed immediately to ensure that leachate does
not leave the site.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 10
CLOSED MSWLF COMMENTS:
The closed MSWLF footprint is considerably larger than the current area marked with EOW markers. Correct
the EOW markers as soon as possible. Due to the planned site construction activities, and with reference to
the attached memorandum regarding EOW markers, a survey of EOW should be conducted for all fill
areas.
2. The access road located on the MSWLF waste fill area (leading up to the white goods, closed C&DLF, and
grinding operation areas) currently shows EOW markers to the "outside" or left of the road (see photo below).
Per Mr. Sagar and site maps referenced earlier, the EOW is actually 100-300' past these EOW markers. In this
region, significant vegetation has taken root. This area must be accessible, mowed regularly, and must not
contain any woody vegetation (trees).
03/10/10 photo #3
While the MSWLF was closed under the .1600 Rules and the C&DLFs, Demolition LF, and TVA disposal area
were closed under the .0500 Rules, all Areas must meet the Post -Closure General Condition stated in the permit
such that the owner or operator shall maintain the integrity and effectiveness of any cap system.
The woody/tree growth is encroaching upon the cap system. As these types of root systems
will most likely extend beyond the erosion layer into the impermeable layer of the cap (thus
destroying the integrity of the cap system and creating a path for water into the landfill), and as trees both inhibit
the proper mowing and necessary maintenance of the cap while impeding on the ability to visually inspect the
cap integrity, this woody shrub/tree growth must be eliminated. Any stumps and root systems of larger
trees must be removed and the cap system repaired.
3. The closed MSWLF Post -Closure Conditions (April 11, 2006) in the Letter of Closure and the .1600 Rules are
the governing regulations for this landfill unit. The list of Approved Documents includes Closure Plans, Post -
Closure Use Plan, Methane Gas Remediation Plan, and a Ground Water Corrective Action Plan. During the
next scheduled site visit, the Section wishes to review these documents, in particular Part C: Methane Gas
Remediation Plan — please have this available at the landfill at the time of the site inspection.
4. The closed MSWLF has a drainage ditch running on the "inside" of the access road. This drainage ditch
exhibited erosion to the extent that solid waste was exposed and the landfill cap exhibited erosion such that
rills had formed and discharge was draining into the drainage ditch.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 10
03/10/10
Rills/discharge from landfill into drainage ditch, photos #4
Drainage ditch/waste #5
03/10/10
Post Closure General Condition #2 states that the owner or operator shall maintain the integrity and
effectiveness of any cap system, including making repairs to the cover as necessary to correct the effects of
settlement, subsidence, erosion, or other events, and preventing run-on and run-off from eroding or otherwise
damaging the cap system.
Item number 2 and 4 need to be addressed as required in the Notice of Violation section within this
audit report. The seepage/leachate release issue must be addressed immediately to ensure that leachate
does not leave the site.
5. The groundwater monitoring data was available and currently under review by the Section hydrogeologist.
The landfill gas (LFG) monitoring plan was unavailable at the time of the audit. However, the collected data
was available. Henderson County utilizes Enerdyne for maintenance of the gas extraction system and for the
collection of LFG monitoring data. While monitoring data was available for review, due to the lack of a Plan it
was difficult to determine the following: Number of wells and location of wells, whether the methane data was
in %Volume or % LEL, and what the other data points on the spreadsheet represented (structures on/off
property?). Additionally, two of the LFG monitoring wells located on the north side of the property (in the
region where, historically, methane migration had occurred) were not capped, locked, or labeled.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 9 of 10
03/10/10 LFG Monitoring well. #6
7. No data was available that appeared to represent monitoring in the facility site structures (office buildings,
scale house, etc.) as required in both Rule and in Closure Condition #12:
The owner or operator shall maintain and operating the gas monitoring system to ensure that:
(a) The concentration of methane gas generated by the facility does not exceed 25% of
the lower explosive limit for methane in facility structures (excluding gas control or
recovery system components); and
(b) The concentration of methane gas does not exceed the lower explosive limit for
methane at the facility property boundary.
Please provide evidence that all facility structures have been monitored for LFG. If the LFG
Monitoring Plan does not include all structures, or is out of date with current site activities and future
plan, an updated LFG Monitoring Plan should be submitted during the next permit
application/amendment/renewal cycle.
8. During the site inspection, it was stated (W. Sagar) that groundwater monitoring wells had been screened for
methane as part of an assessment activity pertaining to groundwater contamination at the site. It was also
stated that the %Vol of methane in at least one of these wells was >35% methane. Depending on the actual
readings and the location of this well(s), this information should have been immediately communicated to the
Section hydrogeologist (Jaclynne Drummond, 919-508-8500) to determine a potential course of action. Per
Closure Condition # 13: If methane gas levels exceeding these limits are detected, the owner or operator must
take all steps required in Rule .1642(4)(c). Methane gas remediation plans approved by the Division are
described in the list of Approved Documents, Attachment 1, Part C.
Please provide the LFG data collected from this assessment activity to Ms. Drummond.
Please contact me if you have any questions or concerns regarding this audit report.
Phone: [phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Mailed on: 04/08/10 by
Hand delivery
US Mail
Certified No. 17006 2150
0005 245 8 92281
ec: Mark Poindexter, Field Operations Branch Supervisor
Deb Aja, Western District Supervisor

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 10 of 10
Donald Herndon, Compliance Officer
Larry Frost, Permit Engineer
Jaclynne Drummond, Section Hydrogeologist
Natalie Berry, Assistant County Engineer: nbeM�nheiidei-soncouiiiyiic.org
Steve Wyatt, County Manager: swyattcuhendersoncountync.or),
Rebecca Coplin, Admin. Asst. Solid Waste Division: rcoplin e,hendersoncount.�ny c.org