8806_ROSCANS_2010

Harrison, Troy
From: Gaither, Allen
Sent: Monday, July 12, 2010 9:53 AM
To: Wilkins, Mark
Cc: Aja, Deborah- Harrison, Troy
Subject: RE: Dupont Brevard
Hey Mark,
Sorry I missed you last week! The "operational" concerns are actually being addressed by Ms. Deb Aja and Mr. Troy
Harrison in the Field Operations Branch. They are meeting to discuss Dupont this morning. I believe they will be
contacting you directly with their concerns. I have carbon copied them on the reply to ensure they have your contact
information.
Thanks,
Allen
Allen Gaither - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Waste Management - Solid Waste Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice:
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore
may be disclosed to third parties.
_.._-._ .... ......... ....... .... ...... __ .........
From: Wilkins, Mark
Sent: Thursday, July 08, 2010 4:30 PM
To: Gaither, Allen
Subject: Dupont Brevard
Allen,
The Haz Waste Section met with Paul Crissman and Mark Poindexter yesterday to discuss the proposed conversion of
the old East Landfill to a CAMU at the Dupont Brevard site. We discussed the previous comments you had sent
concerning the cap and post -closure care issues. Paul indicated that there were some additional comments you might
have concerning requirements that should be included in the workplan for DuPont to follow during the "operational'
portion of the project (i.e. working face restrictions, daily/weekly cover, etc.). Paul suggested I contact you and get any
additional comments you might have concerning the proposed CAMU. I will try to call you sometime tomorrow so we
can discuss if you are available. Or, if you already know what comments you would have, you could email them to me.
Thanks
Mark
Mark Wilkins, Hydrogeologist
Hazardous Waste Section

Ph - 919-508-8571
mark.wilkins(c).ncdenr.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

DIVISION OF WASTE MANAGEMET
SOLID WASTE SECTION
ASHEVILLE REGIONAL OFFICE
March 25, 2010
MEMORANDUM TO: File
FROM: Troy Harrisoov.
Environmental Senior Specialist
SUBJECT: DuPont Landfills (88-06)
The audit report for the DuPont Landfills (Permit Number 88-06, North & East Landfills) was not
sent to the facility and served to record the Solid Waste Section inspection of the site on June 2,
2010. A final report will not be sent.

WA
1, •
rr0�
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: Transylvania
MSWLF
PERMIT NO.: 88-06
Closed
x14W
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
X
DEMO
X
SDTF
Collection
Monofill
Landfill
Date of Audit: June 2, 2010
FACILITY NAME AND ADDRESS:
DuPont Industrial Waste Landfill
State Road 1593
Cedar Mountain, NC 28718
Date of Last Audit: July 12, 2006
GPS COORDINATES: N: 35.182328 E:-82.61284
FACILITY CONTACT NAME AND PHONE NUMBER:
Jamie Van Buskirk
DuPont Corporate Remediation
6324 Fairview Road
Charlotte, NC 28210
Chet Meinzer, Technical Consultant
Parsons Environmental
[phone]
FACILITY CONTACT ADDRESS:
P.O. Box 267
Brevard, NC 28718
AUDIT PARTICIPANTS:
Troy Harrison, NC DENR DWM/Solid Waste Section
Deb Aja, NC DENR DWM/Solid Waste Section
Chet Meinzer, Parsons Environmental
STATUS OF PERMIT:
August 26, 1993 - Closure Audit of North Landfill
December 11, 1996 — Closure Audit of East Landfill
Closure letter issued May 21, 2001
PURPOSE OF AUDIT:
Partial Audit of Closed Industrial Landfill and of Closed Demolition and Asbestos Landfill
NOTICE OF VIOLATION(S):
N/A
STATUS OF PAST NOTED VIOLATIONS:
N/A

FACILITY COMPLIANCE AUDI' :PORT
Division of Waste Management
Solid Waste Section
Page 2 of 2
AREAS OF CONCERN AND COMMENTS:
1. All Photographs were taken by Troy Harrison on June 2, 2010.
2. The permitted solid waste facility consists' of two units called the North Landfill and East Landfill on
property formerly used as an industrial facility. DuPont is the owner of the property. All industrial buildings
have been demolished.
3. The North Landfill ceased received waste on August 26, 1993. The East Landfill ceased received waste on
December 11, 1996. The Closure Plan was submitted on June 28, 1996. The Closure Letter was issued on
May 21, 2001.
4. A Memorandum from Ms. Elizabeth Cannon, Hazardous Waste Section Chief to Mr. Jim Coffey, Solid Waste
Section Chief on June 30, 2004 stated that regulatory oversight of contamination at the closed solid waste
landfills at this facility would be the responsibility of the Hazardous Waste Section. The Memorandum also
recognized that the Solid Waste Section may have physical inspection responsibilities remaining.
The company is in the process of an application for a Corrective Action Management Unit (CAMU) with the
Hazardous Waste Branch. According to the application waste from the East Landfill will be removed and
recycled. Waste from several solid waste management units (SWMU) are to be placed in the displaced area
of the East Landfill. 15A NCAC 13B .0510 (d) requires a new permit for any future disposal.
North Landfill (SWMU-12)
6. The North Landfill was observed. This landfill consists of two distinct cells (demolition and asbestos)
separated by a small wooded area. The edge of waste was not marked in either cell. The edge of waste
must be permanently marked. The cap of this landfill has not been maintained and several pine
saplings were observed growing in an area that appeared over waste. The cap of the landfill must be
maintained as required by 15A NCAC 1313 .0510(c). Post Closure Condition 4 states: "The integrity
and effectiveness of the final cover system and any permanent erosion devices must be maintained.
This could include making repairs to the cover as necessary to correct the effects of settlement,

FACILITY COMPLL4,NCE AUDIT ;PORT
Division of Waste Management
Solid Waste Section
Page 3 of 3
subsidence, erosion, or other events. The Hazardous Waste Section has taken over regulatory oversight
of the landfill and all future activity must be coordinated with them.
Entrance to Asbestos Unit
Sign near entrance to Asbestos Unit
Cap of Demolition Unit
East Landfill (SWMU-11)
7. The East Landfill was observed. This unit last received industrial waste on March 29, 1996 according to the
Closure Plan, dated June 28, 1996. The top of the landfill and the northwestern side slope were being
maintained.
The remaining side slopes of the landfill had years of tree growth. Waste was observed at the surface on the
landfill side slopes in several areas. The Solid Waste Section understands that there is a long term plan
to recap and shape the East Landfill; however, an interim plan would be needed for removing trees,
reshaping the slope and covering waste. The Hazardous Waste Section has taken over regulatory
oversight of the landfill and all future activity must be coordinated with them.

FACILITY COMPLIANCE AUDI" ,PORT
Division of Waste Management
Solid Waste Section
Page 4 of 4
Steep Wooded slope of East Landfill
Exposed Material at slope of East Landfill Exposed Material at slope of East Landfill
8. The edge of waste was not permanently marked. This must be done to accurately determine compliance with
buffer requirements.
9. As part of future ongoing activities at the East Landfill, waste material that has been placed is to be removed
for recycling. In addition, several test pits were dug into the landfill and filled back in. In the CAMU
application, it is proposed that waste materials from other SWMUs are to be consolidated into this landfill.
North and East Landfills
10. Based on document review and on -site discussions, it appears that no landfill gas monitoring was conducted
at this facility following closure of both landfills. The Hazardous Waste Section has taken over
regulatory oversight of the landfill and all future activity must be coordinated with them.
Post Closure Condition 1 "Management of Landfill Gas" states: "the owner and/or operator shall take the
measures necessary to ensure that the closed site shall continue to meet the design standards for landfill gas
found in Rule .0503(2)(a). "
Rule .0503(2)(a) states: "The concentration of explosive gases generated by the site shall not
exceed:
(i) twenty-five percent of the limit for the gases in site structures (excluding gas control
or recovery system components); and

FACILITY COMPLIANCE AUDI7 ,PORT
Division of Waste Management
Solid Waste Section
Page 5 of 5
(ii) the lower explosive limitfor the gases at the property boundary"
11. DuPont has conducted surface and groundwater monitoring. These reports are reviewed by the Hazardous
Waste Section.
Please contact me if you have any questions or concerns regarding this audit report.
*7/13/10 Note: This audit report was not sent to the facility and serves to record the Solid Waste Section
inspection of the site on June 2, 2010. A final audit report will not be sent.
828-296-4701
Phone:
Troy Harrison
Environmental Senior Specialist
Regional Representative
Delivered on : Report not delivered by Hand delivery US Mail Certified No. f j
cc: Mark Poindexter, Field Operations Branch Head
Deb Aja, Western District Supervisor