7602_EnergizerBattery_20170404_ApplicationRenewalLetter_DIN27740

ERM NC, Inc.

15720 Brixham Hill Avenue
Suite 120
Charlotte, NC 28277
[phone]
[phone] (fax)

April 4, 2017

NCDEQ– Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Attention: Mr. Edward Mussler

Reference: Application for Permit Renewal
Industrial Landfill Permit No. 7602-INDUS-1983
Energizer Battery Manufacturing, Inc.
Randolph County, North Carolina

Mr. Mussler:

On behalf of Energizer Battery Manufacturing, Inc. (Energizer), ERM NC, Inc. (ERM) is
submitting this application for permit renewal for Industrial Landfill Permit No. 7602-
INDUS-1983 for the Energizer landfill facility located in Randolph County, North
Carolina. The current Permit to Operate, Phase 3A, for the facility is due to expire on
August 23, 2017. In accordance with North Carolina Division of Waste Management
Rules, we are submitting this Permit Renewal Application prior to reaching 6 months
before the permit expiration date.

Technical Industrial Landfill permitting requirements have been submitted to and
approved by the Division of Waste Management through June 26, 2012 up to and
including the Application for Permit to Operate Phase 3A. Approved documents have
included:

 Site Suitability Studies
 Hydrogeologic Investigations
 Facility Plan
 Operations Plan
 Construction Technical Specifications
 Construction Quality Assurance (CQA) Plan
 Design and Construction Plans
 Groundwater Monitoring Plan
 Closure Plan
 Post Closure Care Plan
 Permit Modifications to adjust property boundaries

At this time, Energizer does not intend to modify or alter the approved plans and
documents currently in place.
Mr. Edward Mussler
April 4, 2017
Page 2

To date, the constructed and approved Phase 3A has not received any waste. The interior
and exterior portions of Phase 3A have been stabilized with vegetation since construction
in 2012. Erosion and sedimentation control measures remain in place and are routinely
inspected by Energizer personnel as well as NCDEQ - Division of Land Quality. As
approved by the Division of Waste Management, Manholes 3A & 3B installed for leachate
collection at Phase 3A, were temporarily plumbed to discharge clean storm water collected
within Phase 3A and discharge to the onsite sediment basin. This condition remains to
date since no waste has been placed in Phase 3A. Therefore, leachate sampling for Phase
3A will not occur until Phase 3A becomes active with placement of waste within the
approved 3A limits. Permit required monitoring, sampling and reporting have been an
ongoing activity in accordance with the approved plans and permit conditions.
ERM visited the facility along with Energizer personnel on December 6, 2016 to formally
inspect the existing Phase 3A site conditions. This site visit was performed on a day
during a rain event to adequately observe overall site drainage and flow. A photo record
of the existing conditions follows this letter for reference. In summary, the following was
noted from the site inspection:

 Site Security and Signage are in good condition; no indications of unauthorized
entry or vandalism
 Erosion & Sedimentation Control Measures are in good condition; mowing occurs
routinely and vegetation appears healthy
 Phase 3A Interior and Exterior slopes are stabilized and in good condition
 Manholes 3A & 3B are in good condition and draining rainfall appropriately to the
sediment basin
 The temporary discharge line from Manholes 3A & 3B is in good condition and
functioning appropriately
 Groundwater Monitoring Wells are in good condition and adequately protected
 The Phase 3A leachate collection line and stone column appear to be draining
adequately to Manholes 3A & 3B
 Storm water is diverted around the Phase 3A footprint
 There were no visual indications of eroding or unstable areas within or along the
exterior Phase 3A slopes
 Leachate line cleanout and saddle are in good condition
 The temporary “rain flap” on the north side of Phase 3A is in good condition
 Access roads remain in good condition and are all weather access to serve the
facility
These items as described above are included in the attached photo record from December
6, 2016.

Photo Record
ERM Site Visit and Inspection
December 6, 2016

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