4407_HaywoodCo_MSWLF_PH4&5EngTechReview_DIN27022_20161118

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

November 18, 2016

Sent Via Email – [e-mail]
Mr. Ron Vail
Vice President of Engineering
650 25th Street, N.W., Suite 100
Cleveland, Tennessee 37311

Subject: Engineering Technical Review
Haywood County White Oak Landfill
Haywood County, Permit # 4407-MSWLF-1993, Document ID 27022

Mr. Vail,

The Division of Waste Management, Solid Waste Section (Section) has completed the technical
review of your application submittal titled Phase 4 and 5 Permit to Construct (DIN 26425)
including the Report of Subgrade Settlement and Slope Stability Evaluation (DIN 26849) and the
revised Facility Drawings and Engineering Drawings (DIN 26916). The application was received
in the Asheville Regional Office on July 5, 2016, the geotechnical report on October 13, 2016 and
the revised drawings on October 19, 2016.

Based on this review, the Section requires clarification or additional information in order to
complete the permitting activity. Please provide a response to each of the items listed below:
Facility Plan
1. Rule .1619(d)(1)(A) requires site development drawings which incorporate the buffer
requirements set forth in Subparagraph (b)(3) of Rule .1624. The required property line
buffer was not indicated on the drawings.
2. Rule .1619(d)(2)(A) requires landfill construction drawings which delineate the areal limits
of grading, including borrow and stockpile areas. There were no borrow or stockpile areas
indicated on the drawings.
3. Rule .1619(d)(3)(B) requires landfill operation drawings to include the size, location and
general grade for the leachate piping system. The LCS pipe sizes were not indicated on the
drawings.
4. Rule .1619(e)(4)(B)(i)(II) requires the analysis of the leachate management system
incorporate actual leachate generation data from the existing landfill. The analysis presented
appears to use only HELP model derived estimates.
5. Rule .1619(e)(4)(C)(iii) requires the leachate management system description to include final
disposal plans and applicable discharge limits, including documented prior approval of the
waste water treatment plant which may be designated in the plan. Final disposal plans are
not discussed and no approvals from waste water treatment plants were provided.

Mr. Ron Vail 
Engineering Technical Review 
November 18, 2016 
Page 2 of 3 

Engineering Plan
6. Rule .1620(e)(2) requires engineering drawings to illustrate grading plans including
proposed limits of excavation, subgrade elevations, boring locations and intermediate
grading for partial construction. There were no subgrade elevations illustrated on the
drawings.
7. Rule .1620(e)(4) requires engineering drawings to illustrate the leachate collection system
including base elevations, piping system grade and inverts, cleanouts, valves, sumps, top of
protective cover elevations and details. The piping system grades and top of protective cover
elevations were not illustrated on the drawings.
8. Appendix B.1, Section I. calculates flow through a 24” protective cover constructed with
sand. However, Section 1.2 of the report and drawings ED-4 and ED-5 indicate the
protective cover will be constructed with washed #57 stone.
9. Appendix B.1, Section II. calculates flow through a 6 to 8-ounce geotextile at the base of the
protective cover. However, Section 1.2 of the report and drawings ED-4 and ED-5 indicate
a 16-ounce geotextile at the base of the protective cover.
10. Appendix B.1, Section III. calculates flow through a heat-bonded geocomposite layer at the
base of the protective cover. However, Section 1.2 of the report and drawings ED-4 and ED-
5 indicate only a 16-ounce geotextile at the base of the protective cover.
11. Appendix B.2 calculates soil retention of a 6-ounce geotextile at the base of the protective
cover. However, Section 1.2 of the report and drawings ED-4 and ED-5 indicate a 16-ounce
geotextile at the base of the protective cover.
12. Appendix B.3 calculates maximum head of the LCS with a drainage net at the base of the
protective cover. However, Section 1.2 of the report and drawings ED-4 and ED-5 indicate
a 16-ounce geotextile at the base of the protective cover.
Operation Plan
13. Rule .1625(b)(1) requires operation drawings be prepared for each phase of landfill
development. There were no drawings labeled as operation drawings in the application and
the Table of Contents in the Operations Plan Report does not mention operation drawings.
Closure and Post-closure Plan
14. General Statute 130A-295.2(h) requires the owner or operator of a sanitary landfill to
establish financial assurance sufficient to cover a minimum of two million dollars
($2,000,000) in costs for potential assessment and corrective action (PACA) at the facility.
There was no mention of the PACA costs in the financial assurance cost estimates.

If you should have any questions regarding this matter please contact me at [phone], or
by email at [e-mail] .

Sincerely,

Allen Gaither
Environmental Engineer

Mr. Ron Vail 
Engineering Technical Review 
November 18, 2016 
Page 3 of 3 

CC: Mr. Vance Moore – Garrett and Moore, Inc.
Mr. David Francis – Haywood County
Ms. Elizabeth Werner – SWS/RCO