8806_ROSCANS_2001

Worth Carolina
Department of Environment and Natural Resources` •
Division of Waste Management NCDENR
Michael F. Easley, Governor
William G. Ross Jr., Secretary
William L. Meyer, Director
May 21, 2001
Mr. Jamie Van Buskirk
DuPont Corporate Remediation
6324 Fairview Road
Charlotte, NC 28210
Re: Closure of the DuPont Industrial Waste Landfill, Permit Number 88-06
Dear Mr. Buskirk:
Based on the closure information received, the Solid Waste Section (Section) has
determined that the referenced industrial waste landfill has been closed in accordance with the
applicable requirements.
The landfill is considered closed subject to the following post closure conditions. The
owner and/or operator of the facility, Dupont, is responsible for compliance with these
conditions. In particular, Condition # 7 requires that, if the permit has not been previously
recorded in accordance with Rule .0204, documentation shall be provided that a statement that
the property has been used as a sanitary landfill is contained in the legal description of the
landfill site. The legal description should be sufficient as a description in an instrument of
conveyance and the statement shall be in no smaller type than that used in the body of the of the
deed or instrument. Condition #8 addresses continued water quality monitoring for the existing
ground water monitoring system.
Rule .0510 also states that when a disposal unit is closed, the permit to operate that unit
is terminated and any future disposal operations will require approval by the Section.
If there are questions regarding this closure letter, please contact me at [phone],
extension 256.
ncerely,
�yre.22
J mes C. Coffey, Acti C ief
Solid Waste Section
cc: Jim Patterson
Bobby Lutfy
Mark Poindexter
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: 919 —733-0692 \ FAX: [phone]\ Internet: www.enr.state.nc.us/
AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER — 50% RECYCLED / 10% POST CONSUMER PAPER

POST CLOSURE CONDITIONS
1. MANAGEMENT OF LANDFILL GAS: 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).
2. MANAGEMENT OF SURFACE WATER: The owner and/or operator shall
take the measures necessary to ensure that the closed site shall meet the
requirements of Rule .0503(2)(c). In addition, the landfill unit shall be
maintained such that surface water runoff occurs in a controlled manner, and
surface water shall not be impounded over waste.
3. AIR QUALITY: The owner/operator shall ensure that landfill units do not
violate any applicable requirements developed under a State Implementation Plan
approved or promulgated by the U.S. EPA Administrator pursuant to Section 110
of the Clean Air Act, as amended.
4. FINAL COVER SYSTEM: The integrity and effectiveness of the final cover
system and any permanent erosion control devices must be maintained. This
could include making repairs to the cover as necessary to correct the effects of
settlement, subsidence, erosion, or other events.
5. PROPOSED USES: The owner/operator shall submit a proposal for the
Section's review and approval addressing post closures uses of the facility.
Proposed post closure uses shall not violate any post closure conditions found in
this letter. In particular, plans for post closure uses shall avoid possibilities for
the entrapment of methane gas. Routine landfill gas monitoring within structures
and at the facility boundary may not be sufficient to detect potentially dangerous
situations.
6. ONGOING SOLID WASTE MANAGEMENT ACTIVITIES: Continuing
solid waste management activities, if any, shall not violate any post closure
conditions found in this letter, and must meet any other applicable requirements.
7. RECORDATION: The owner/operator shall ensure that the recordation
requirements for land disposal sites found in Rule .0204 are met.

WATER QUALITY MONITORING AND REPORTING REQUIREMENTS:
a. Groundwater quality at this facility is subject to the "Classification and
Water Quality Standards Applicable to the Groundwaters of North
Carolina," 15A NCAC 2L. This includes, but is not limited to, the
provisions for detection monitoring, assessment, and corrective action.
b. The permittee shall sample the detection monitoring wells and surface
water sampling location(s) at a minimum on a semi-annual basis.
C. Water quality detection monitoring shall continue for a minimum of five
years from the date of the initial sampling of the East landfill monitoring
wells, June, 1998. After five years, the Section will determine if further
monitoring is to be required.
d. Sampling equipment and methods shall conform to specifications in
Attachment 1, "North Carolina Water Quality Monitoring Guidance
Document for Solid Waste Facilities." The sampling parameters and
methods shall be those found in Attachment 2, "Sampling and Analysis
Requirements for Construction and Demolition Landfills and Closed
Sanitary Landfills", or an alternate list of sampling parameters as
approved by the Solid Waste Section. The Spring 2003 sampling event
shall include sampling and analysis for the semi -volatile organic
compounds using the EPA Method 8270, in addition to the other routine
detection sampling parameters.
The permittee shall maintain a record of all monitoring events and
analytical data. Reports of the sampling events and analytical data shall
be submitted to the Section in a timely manner.

North Carolina
Department of Environment and Natural Resources y�
Division of Waste Management
Michael F. Easley, Governor NCDENR
William G. Ross Jr., Secretary
William L. Meyer, Director
May 18, 2001
Mr. Jamie Van Buskirk
DuPont Corporate Remediation
6324 Fairview Road
Charlotte, N.C. 28210
RE: Post Closure Water Quality Monitoring At The DuPont Industrial
Landfill In Transylvania County (Permit #88-06)
Dear Mr. Van Buskirk,
The purpose of this letter is to follow up and confirm some of the
issues we discussed in our meeting earlier this week. I have
reviewed our files and talked with other members of our staff and
determined that .the DuPont Landfill has not yet received an
official Closure Letter from the Solid Waste Section. Such a
letter is being prepared and will be sent out within the next
couple of weeks.
Since the time the Solid Waste Section began requiring water
quality monitoring at Sanitary Landfills and Industrial Landfills,
it has consistently been our policy to require a minimum of five
years of post -closure monitoring, after which the need for
additional monitoring is evaluated. Most unlined landfills have
required additional monitoring beyond the five year period,
although some of the monitoring requirements may be changed
(sampling parameters, frequency, etc.). The five year period
typically begins when official closure has been recognized by the
Solid Waste Section and is documented in writing.
Although DuPont has not yet received an official Closure Letter,
they stopped receiving waste and placed final cover in 1996.
Monitoring wells were installed in May of 1998 and sampled in late
June of 1998. Since DuPont was in the process of selling this
facility and the DuPont Remediation Group was also reorganizing and
downsizing during this time, there has apparently been some
confusion about some of the closure requirements. Therefore, even
though DuPont has not yet received an official Closure Letter, the
Solid Waste Section will begin the five year post -closure
monitoring period at the time of the initial sampling in June 1998.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER — 50% RECYCLED / 100,10 POST CONSUMER PAPER

Jamie Van Buskirk
DuPont # 88-06
Page 2
DuPont will therefore be required to continue semi-annual water
quality monitoring through the Spring of 2003. The sampling should
be done for the parameters listed in my letter of September 21,
2000, to Mr. David Epps of The W-C Diamond Group. The Spring 2003
sampling event shall include sampling and analyses for semi -
volatile organic compounds using EPA Method 8270, in addition to
the other routine detection monitoring parameters. After the
results of the Spring 2003 sampling event are reported to the Solid
Waste Section, all data will be evaluated and a determination of
the need for further sampling will be made.
I have checked the N.C. Groundwater Standards, 15A NCAC 2L .0202,
and verified that the current standard for Chloroform is 0.00019
mg/l. While there has been a recommendation to change this
standard, to my knowledge there is no change currently being
considered by the Environmental Management Commission.
Due to EPA requirements, purge water having constituents at or
above hazardous levels must be treated and/or disposed at an
approved Hazardous Waste Facility. The Solid Waste Section has no
specific requirements regarding disposal of purge water having
constituents at levels below hazardous levels. Since we regulate
non -hazardous waste, the levels of hazardous constituents at most
of our facilities do not require special handling. At some of our
facilities purge water is poured out on -site. Since a number of
our landfills have on -site leachate lagoons, tanks, and/or pre-
treatment facilities or nearby waste water treatment plants, they
will utilize these facilities for disposal of purge water having
levels of contaminants that exceed the N.C. Groundwater Standards.
I hope this information will be useful to you as you plan the
official closure and post -closure activities at the DuPont Landfill
sites. If you have any questions regarding this letter, please
contact me at [phone], extension 258.
Sincerely,
Bobby Y
Hydrogeologist
Solid Waste Section
cc: Jim Coffey, Solid Waste Section
Jim Patterson, SWS - Asheville
Chris Oakes, URS Corporation