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HomeMy WebLinkAbout0803_EastCarolinaLF_PermitFiles_19970101State of North Carolina Department of Environment, W4 Health and Natural Resources • • Division of Waste Management James B. Hunt, Jr„ Governor «- Jonathan B. Howes, Secretary � � �....� William L. Meyer, Director June 24, 1997 Mr. John Murray Addington Environmental, Inc. 771 Corporate Drive Suite 900 Lexington, KY 40503 RE: Approval to Receive Waste in Cell 7, Phase II, East Carolina Regional Landfill, Permit Number 08-03 Dear Mr. Murray: The Solid Waste Section has reviewed the CQA documentation for construction of Phase II, Cell 7, of the East Carolina Landfill. The Section has received and reviewed the documentation for the placement of drainage/protective cover in the remaining subcells of cell 7. As certified by the Project Engineer and the Quality Assurance Consultant, Cell 7, has been completed in accordance with the project specifications. The Section has determined that East Carolina Environmental has met pre -operative conditions of the Permit to Construct, issued April 18, 1997, for this cell. In accordance with G.S. 130A-294, Cell 7 is hereby approved to receive waste. If you have any questions regarding the terms of this approval, please contact me at (919) 733- 0692. Sincerely, Gf4w. C ames C.-Coffey, ervisor Permitting Branch Solid Waste Section cc: Bill Hodges, HHN&T Ed Mussler Terry Dover Jim Barber Chuck Boyette P.O. Box 27687, �� FAX 919-715-3605 Raleigh, North Carolina 27611-7687 Nvf C An Equal Opportunity Affirmative Action Employer Voice 919-733-4996 E-4 9P 1 700M 50% recycled/10% post -consumer paper State of North Carolina Department of Environment, WA Health and Natural Resources y • 0 Division of Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director April 21, 1997 Mr. John Murray Addington Environmental, Inc. 771 Corporate Drive Suite 900 Lexington, KY 40503 RE: Approval to Receive Waste in Cell 7A and 7B, Phase II, East Carolina Regional Landfill, Permit Number 08-03 Dear Mr. Murray: The Solid Waste Section has reviewed the CQA documentation for construction of Phase II, Cell 7, Subcell A and B of the East Carolina Landfill. As requested by East Carolina Environmental, the Section will review documentation for the placement of drainage/protective cover in the remaining subcells separately in order to facilitate placement of waste in Subcell A. As certified by the Project Engineer and the Quality Assurance Consultant, Cell 7, Subcell A and B has been completed in accordance with the project specifications. The Section has determined that East Carolina Environmental has met pre -operative conditions of the Permit to Construct, issued April 18, 1997, for this subcell. In accordance with G.S. 130A-294, Cell 7 is hereby approved to receive waste in Subcell Aand B. If you have any questions regarding the terms of this approval, please contact me at (919) 733- 0692. GUM2 James C. Coffey, S ervisor Permitting Branch Solid Waste Section cc: Bill Hodges, HHN&T Ed Mussler Terry Dover Jim Barber Chuck Boyette P.O. Box 27687,NOf FAX 919-715-3605 Raleigh, North Carolina 27611-7687 C An Equal Opportunity Affirmative Action Employer Voice 919-733-4996 - 50% recycled/10% post -consumer paper State of North Carolina Department of Environment, Health and Natural Resources • Division of Waste Management James B. Hunt, Jr., Governor. Jonathan B. Howes, Secretary � H N FZ William L. Meyer, Director FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 1 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT P.O. BOX 27687 RALEIGH, NC 27611 MUNICIPAL SOLID WASTE LANDFILL FACILITY PERMIT EAST CAROLINA ENVIRONMENTAL, INC. is hereby issued a PERMIT to OPERATE a MUNICIPAL SOLID WASTE LANDFILL FACILITY AND PHASE 1 AND PHASE 2, CELL 7 located on NCSR 1225 (Republican Road), north of Windsor, Bertie County, North Carolina, in accordance with Article 9, Chapter 130A, of the General Statutes of North Carolina and all rules promulgated thereunder and subject to the conditions set forth in this permit. The facility is located and described by the legal description of the site or the property map contained within the approved application. James C. Coffey, Supervisor Permitting Branch Solid Waste Section P.O. Box 27687, W�y4F FAX 919-715-3605 NlmfcRaleigh, North Carolina 27611-7687An Equal Opportunity Affirmative Action Employer Voice 919-733-4996 - 50% recycled/10% post -consumer paper FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 2 ATTACHMENT 3 Approved Documents PART I: GENERAL FACILITY CONDITIONS PART II: MUNICIPAL SOLID WASTE LANDFILL CONDITIONS 1. Letter Hodges to Mussler, April 2, 1997, re changes to leahcate collection system. 2. Construction Quality Assurance Report, East Carolina Landfill, Cell No. 7, Bertie County, North Carolina. Prepared For Hodges, Harbin, Newberry, &Tribble, Inc., Macon, Ga. Prepared By Bunnell-Lammons Engineering, Inc., Greenville, SC. BLF Project Number J96-1001.08. April 12, 1997. 3 Vols. PART III: CONSTRUCTION AND DEMOLITION LANDFILL CONDITIONS (NOT APPLICABLE) PART IV: LAND CLEARING AND INERT DEBRIS LANDFILL CONDITIONS (NOT APPLICABLE) PART V: YARD WASTE CONDITIONS (NOT APPLICABLE) PART VI: MISCELLANEOUS TREATMENT AND PROCESSING FACILITIES CONDITIONS (NOT APPLICABLE) FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 3 ATTACHMENT 4 Conditions of Permit to Operate PART I: GENERAL FACILITY CONDITIONS 1. This operation permit shall be effective until February 20, 1999, consistent with the franchise agreement. Upon extension of operation approval, pursuant to the franchise, this operation permit shall remain effective and this permit shall be reviewed, pursuant to 15A NCAC 13B.0201(e), five (5) years from the issuance date of this permit to operate or the latest amendment. 2. In the event of conflicts between this Permit to Operate and previously issued conditions, the conditions of this Permit to Operate shall supersede previously issued conditions. 3. The solid waste management units within this facility shall conform to all operating procedures described in the approved plans, 15A NCAC 1313, and the conditions specified herein. 4. Additional conditions and revision of the approved documents or changes during the operation of the landfill require approval by the North Carolina Solid Waste Section. 5. On or before August 1 of each year, the permittee shall report the amount of waste received (in tons) at this facility and disposed of in the landfill units to the Solid Waste Section, on forms prescribed by the Section. This report shall include the following information: a. The reporting period shall be for the previous year, beginning July 1 and ending on June 30. b. the amount of waste received and landfilled in tons, compiled on a monthly basis by county or transfer station of origin and by specific waste type if diverted to a specific unit within the permitted facility; and C. The completed report shall be forwarded to the Regional Waste Management Specialist for the facility. A copy of the completed report shall be forwarded to the County Manager of each county from which waste was received. 6. Ground water quality at this facility is subject to the "Classifications and Water Quality Standards Applicable To The Groundwater of North Carolina", 15A NCAC 2L. This FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 4 includes, but is not limited to, provisions for detection monitoring, assessment, and corrective action. PART II: MUNICIPAL LANDFILL UNIT SPECIFIC CONDITIONS GENERAL CONDITIONS 1. This permit approves the continued operation of Phase I and operation of Phase 2, Cell 7 of the municipal solid waste landfill unit as well as the on -site environmental management and protection facilities as described in the approved plans. Operation of Cell 8 will require written permission from the Division and will be subject to the conditions of the Part1-Permit to Construct. 2. This permit is for operational approval of a permitted disposal capacity of approximately 2,500,000 cubic yards, consistent with the final contours as shown on sheet 15 of Document 3, Attachment 1. This capacity is based on an average annual disposal rate of approximately 365,000 tons (approximately '1000 tons per day based on 365 operating days per year, with a maximum variance of 10%) facility total as set forth in Document 1, Attachment 1. MONITORING AND REPORTING 3. Ground water monitoring at this unit shall be as prescribed by the appropriate requirements of 15A NCAC 13B .1630-.1637 and the approved monitoring plan. 4. A readily accessible unobstructed path shall be cleared and maintained so that four- wheel drive vehicles may access monitoring well locations at all times. 5. A field log book which details all development, sampling, repair, and all other pertinent activities associated with each monitoring well and all sampling activities associated with each surface water and leachate sampling location shall be kept as part of the permanent facility record. 6. Records of all ground -water, surface water and leachate analytical data shall be kept as part of the permanent facility record. 7. Ground water monitoring wells and surface water sampling locations must be sampled for Appendix I constituents at least semi-annually according to the specifications outlined in the approved water quality monitoring plan and the current policies and guidelines of the Section in effect at the time of sampling. FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 5 B. Reports of the analytical data for each water quality sampling event shall be submitted to the Section within 60 days of the respective sampling event. Analytical data shall be submitted in a manner prescribed by the Section. 9. The four independent samples which comprise the initial baseline sampling event shall be collected from each ground water monitoring well and the report shall be submitted to the Section within six months after issuance of the Permit to Operate. 10. Untreated leachate shall be sampled and analyzed at least semi-annually concurrently with the ground and surface water sampling. The leachate shall be analyzed for all Appendix I constituents, pH, specific conductance, BOD,COD, nitrates, sulphates, and phosphates. Test results shall be submitted to the Section along with ground and surface water test results. In the event leachate is recirculated, additional leachate sampling may be required. OPERATIONAL CONDITIONS 11. The landfill unit shall conform to all operating requirements described in the approved plans, 15A NCAC 13B .1626, and the conditions specified herein. 12. The use of tarps as alternative daily cover is approved. Use shall be consistent with prior approved plans . The use of different alternative daily cover requires approval, prior to implementation, by the Solid Waste Section. Requests for alternative daily cover approval must include a comprehensive use and demonstration for the effectiveness plan developed according to Section guidelines and consistent with the approved plan. Plans which are approved by the Section will be incorporated into, and made a part of, the approved documents found in Attachment 3. 13. The use of leachate recirculation as a leachate management tool requires is approved. Leachate recirculation will be conducted according to the approved plan found in Document 1, Attachment 1. 14. The MSWLF unit is permitted to co -dispose of wastewater treatment sludges generated within the facility's approved service area, and subject to the terms and procedures of the approved plan. 15. Closure or partial closure of any MSWLF unit shall be in accordance with the Closure Plans described in the approved plans and 15A NCAC 13B .1629. Final Closure Plans shall be submitted to the Division at least 90 days prior to implementation. Closure and Post -closure plans, including financial instruments shall be updated annually pursuant to 15A NCAC 13 B..1628. FACILITY PERMIT NO:08-03 Part 2-Permit to Operate Date of Original Issue: October 8, 1993 Date Permit Modified: December 2, 1994 Permit Renewal Date: April 18, 1997 Page 6 PART III: CONSTRUCTION AND DEMOLITION DEBRIS UNIT SPECIFIC CONDITIONS PART IV: LAND CLEARING AND INERT DEBRIS UNIT SPECIFIC CONDITIONS PART V: YARD WASTE UNIT SPECIFIC CONDITIONS PART VI: MISCELLANEOUS TREATMENT AND PROCESSING UNIT SPECIFIC CONDITIONS (Specify Unit Type) State of North Carolina Department of Environment, Health and Natural Resources 4 • Division of Waste Management James B. Hunt, Governor ED[— H N Jonathan B. Howes, Secretary William L. Meyer, Director April 18, 1997 Mr. James D. Martin, P.E. Regional Engineer Addington Environmental, Inc. 2343 Alexandria Drive, Suite 400 Lexington, Kentucky 40504 RE: Financial Assurance East Carolina Regional Landfill Permit #08-03 Dear Mr. Martin: The Solid Waste Section has received the Amendment to Letter of Credit number 00382318, dated April 15, 1997, issued by the First National Bank of Chicago at the request of Republic Industries, Inc. The Amendment has increased financial assurance coverage for the East Carolina Regional Landfill to $3,245,293.00. As the above LOC constitutes adequate financial assurance for the East Carolina Regional Landfill, I have enclosed the previously issued LOC number 50061151 and Amendments, issued by the Bank of Boston. I understand from our discussions that Addington Environmental, Inc. will be cancelling this LOC. Thank you for your efforts to coordinate this. Please call me at (919) 733-0692 extension 270 if I can assist in any other way. V Truly Yours, Lee a asso �Fl Compliance Officer Enclosures cc: Ed Mussler P.O. Box 27687, W * FAX 919-715-3605 Raleigh, North Carolina 27611-7687 a C An Equal Opportunity Affirmative Action Employer )AWf Voice 919-733-4996 50% recycled/ 10% post -consumer paper Sent by: WorkCenter 250 53 03/12/97 15:09 Job 126 Page 1/3 14ODGE , 1IARBIN, ' EVVBERRY & TRI BLE, INC. 484 MULBERRY STREET, SUITE 265 PHONE: 912-743-7175 MACON, GA 31201 FAX: 91.2-743-1703 FAX LEAD SHEET DATE: 1 t j -)r TOTAL NUMBER OF PAGES INCLUDING LEAD SHEETTO: FROM: B ■ t]()lxitiS.I•Is•1RSiti, NFW'iittRliY & TRIRHI,I3. INC. SUBJECT: Per your request [I For your review ❑ Please Comment D Reply ASAP F-1 Urgent COMMENTS: The documents accompanying thistelecopy transmission contain information from the firm of Hodges, Harbin, Newberry, & Tribble, Inc, which may be confidenti of and/or legally privileged, and regardless of the nature of the use of the individual or entity to whom the documents are addressed. if you are not the intended recipient. you are hereby notified that any disclosure, copying, distribution of the taking of any action in reliance upon the contents of the telecopied i1tif0rntat1or1is strictly prohibited, and all documents should ba returned to this firm immediately_ In this regard, if you have received thistelecopy in error, please notify us bytelephons immediately so that we can arrangeforthe return of the documents to us at no cost to yoke, FAX NUMBER. Sent by: WorkCenter 250 53 03/12/97 15:09 Job 126 Page 2/3 HODG Es, HARBIN, NEWBERRY & TRIBBLE., INC. CONSULTi1tiC.: ENCGINEERS 494 M� LEiESiRY St121°:Ifl', tiE.11'►'G: 205 0 1'0,1, C)f�l ICF ROX 974 M:�CON, CF(MCIA 1'12Q•1 H. LUWRV �RlfiFSLF..JR.. PF. Wlf.t.lAM F. F101x:ly PE HAROLU L. i uvURRY, PH I. SrrxrN F• ARRIN, PF .Mr. Ed Mussler NC Solid Waste Division P.O. Box 27687 Raleigh, NC 27611 March 12, 1997 Mr. Jim Barl)er NC Department of'Envircn1n1e11ta,1 ilealth &. Natural resources VtWachovia Building 225 Careen Struct, Sui:tc 601 Fayettevillc, NC 28301 Re: East C.trolina Regional MSWLF' Cell No. 7 1IIIN T Project No. 1001-212-01 Dear Mr. Mussler and Mr. Barber: The constniction crews on the subject prujcct have been borrowing soil from an area t)n tliu silo identified on the ,attached sketch. In accord with the note on sheet 4 of 20 on the approved constniction plans, this is in area that potentially can be used for soil borrow. Within the next week, we will provide plans for the redesi&m of this portion of the facility to Mr. Mussler for review. Should you have any questions, }Tease call_ Sincerely, HODGES, HARBIN, NEWBERRY &. TRIBBLE, INC. William F. Ilodges, P.F:_ Principal cc: John Mun-ay, 1'.E., w/encl. Rick Sampson, w/encl. James Ma.rti.n, .P.E,, w/encl. Jack C .dings, w/encl_ C'1nick 13oyette, w/encl. State of North Carolina Department of Environment, C (D P, Y Heaith and Natural Resources r Division of Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director February 12, 1997 Mr. John E. Murray Vice -President Addington Environmental, Inc. 2343 Alexandria Drive, Suite 400 Lexington, Kentucky 40504 Dear Mr. Murray: 1) E H N F;Z The Solid Waste Section has completed review of the request of January 28, 1997, to perform a demonstration project on the use of petroleum contaminated soils as alternative soil cover. The proposed demonstration project if hereby approved. Conditions of approval are attached. If you have any questions, please contact me at (919) 733-0692, ext.343. Sincerely l! Edward F. Mussler, III P.E. Environmental Engineer Solid Waste Section cc: Bill Hodges, Hodges, Harbin, Newberry and Tribble Mark Fry Terry Dover Jim Barber P.O. Box 27687,%y� FAX 919-715-3605 Raleigh, North Carolina 27611-7687 Nrc An Equal Opportunity Affirmative Action Employer Voice 919-733-4996 - 50% recycled/10% post -consumer paper State of North Carolina Department of Environment, Health and Natural Resources • Division of Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 1 SOLID WASTE PILOT DEMONSTRATION APPROVAL East Carolina Environmental, Inc. is hereby issued an approval to perform a Solid Waste Pilot Demonstration on the use of petroleum contaminated soils for alternative cover soil at the East Carolina Landfill Facility accessed via NCSR 1225, North of Windsor, Bertie County, North Carolina, in accordance with Article 9, Chapter 130A, of the General Statutes of North Carolina and all rules promulgated thereunder and subject to the conditions set forth in this approval. C. Coffey, rmitting Branch Solid Waste Section P.O. Box 27687, i AFAX 919-715-3605 Raleigh, North Carolina 27611-7687 1An Equal Opportunity Affirmative Action Employer Voice 919-733-4996 W1111150% recycled/ 10% post -consumer paper PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 2 ATTACHMENT 3 Approved Documents 1. Operations Plan, Petroleum Contaminated Soil Usage as Alternative Cover Soil for East Carolina Regional MSW Landfill, Windsor, North Carolina, Submitted by Hodges, Harbin, Newberry and Tribble, Inc., January, 1997. PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 3 ATTACHMENT 4 Conditions For Demonstration GENERAL CONDITIONS 1. This approval is effective for 180 days from the issuance date of the demonstration project approval. At the end of 180 days, East Carolina Environmental, Inc. shall provide a report on the Demonstration to the Division. If the report indicates that the demonstration is successful, then East Carolina may request a change in status from pilot demonstration project to a facility approved activity. Such a request will require a modification to current Permit# 08-03. Should the demonstration indicate that the process is unsuccessful, the demonstration will be deemed complete and over on the 180th day. 2. The Division may revoke approval due to any of the following: a. Failure to comply with the approved operation plan, the conditions of this approval, or applicable rules of 15A NCAC 13B (Notification of deficiencies and an opportunity to respond in a timely manner may be given before approval is terminated.) ; b. Failure to demonstrate that the soils may be safely and effectively handled and used as alternative cover soil in landfill operations. C. Acceptance and/or treatment of materials not coverad by this approval (i.e.. hazardous wastes, chlorinated solvents, PCB's, pet: olqum contaminated soils with TPH exceeding 250 ppm, etc.); PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 4 3. A successful demonstration will demonstrate that i. Petroleum contamination (not exceeding 250 ppm TPH) in the soil does not adversely affect the use of the soil in a lined landfill, nor does it present a threat of contamination to surface waters, groundwater, or the health of the public. ii. Run-off from soils applied to slopes will not present or create a threat of contamination to surface waters, groundwater, or the health of the public. 4. This landfill facility is approved to receive and utilize petroleum contaminated soils with TPH less than 250 ppm, generated within the State of North Carolina, and consistent with the service area of the current facility permit, Permit No. 08-03. 5. At the end of the demonstration, a final report shall be prepared and submitted to the Division. The report shall include: a. A description of the process used, a discussion of results of the project, a final operations manual which shall include a list of "do's and don't's", a discussion of any changes made to the proposed plan, and a discussion of the benefits of the process. b. A summary of the amounts and types of petroleum contaminated soils treated, initial levels of contamination, target levels achieved, and the results of any additional test performed to demonstrate the effectiveness of the process and the suitability of the soil to be used in a lined landfill environment. OPERATION CONDITIONS 6. This landfill is approved to receive and utilize petroleum contaminated soils with TPH less than 250 ppm, generated within the State of North Carolina, and consistent with the service area of the current facility permit, Permit No, 08-03. 7. The pilot demonstration shall conform to all operating procedures described in the approved plan, and the conditions specified herein. PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 5 8. All pertinent landfill operating personnel shall receive training and supervision necessary to properly operate this pilot demonstration project. Specifically, training must be provided in operational procedures that will prevent damage to the liner and leachate collection and removal systems. 9. Additional conditions and revisions to the approved document or changes during operation of the project require approval by the North Carolina Solid Waste Section. East Carolina may immediately implement changes to the approved plan, if the changes are necessary for the protection of the employees, or to protect the public health or the environment. 10. The project shall be effectively maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting from the operation of the project. 11. Storage of Soils: a. All soils with any level of petroleum contamination (though not exceeding 250 ppm TPH) must be stockpiled or stored within the limits of Cell No. 1 A of the current .acility. Soil stockpiling of petroleum contarr.inated soils, of any type, outside the lined cell, is expressly prohibited without written permission from the Division. b. Soils being transported to the facility and awaiting transfer to the lined cell must be covered in or on the transport vehicle in a manner sufficient to prevent run- off due to precipitation. 12. Usage of Petroleum Contaminated Soil: a. Petroleum contaminated soils which meet acceptance criteria of Operation Condition No. 6 may be used as daily or intermediate cover only in areas or on slopes of the MSWLF cell which are in the confines of the base liner system. These soils may not be used on the exterior side slopes of the MSWLF cell, without written permission of the Division. PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 6 b. Soils at the levels defined in this approval may be used at the discretion and liability of East Carolina Environmental, Inc. 13. Recordkeeping: Records shall be kept on -site and made available to the Division upon request. 14. Noncompliance Notification: East Carolina Environmental, Inc. shall report by telephone to the Solid Waste Section, telephone number 919-733-0692, and the Fayetteville Regional Office, telephone number 910-4E' 191, as soon as possible, but in no case rrare than 24 hours or on the next working day following the occurrence, or first knowledge of the occurrence of any of the following: a. The containment and treatment of significant amounts *or types of wastes which are not in accordance with the terms and conditions of this approval. b. Any failure of the containment and treatment program resulting in a discharge of wastes to the groundwaters or surface waters of the State in contravention of applicable assigned water quality standards. C. Any system failure, due to known or unknown reasons, that render the facility incapable of adequate containment of the soils containing petroleum products. d. Any spillage or discharge from a vehicle transporting contaminated soil to the lined cell. Persons reporting such occurrence by telephone shall also file a written report in letter form within 15 days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. PILOT DEMONSTRATION PROJECT FACILITY PERMIT NO. 08-03 February 12, 1997 Page 7 15. Monitoring: At a minimum, monthly TPH tests will be performed on the leachate and the stormwater in the sediment pond. These test results shall be reported in the Demonstration Project Report.