1108_BuncombeCo_TS_WasteRemovePlan_DIN27991_20170516

Environmental Infrastructure Consulting, PLLC
3294 Lantern Coach Lane
Roswell, GA 30075
Tel: [phone]

May 16, 2017

Mr. Allen Gaither, P.E.
Environmental Engineer
North Carolina Department of Environmental Quality
Division of Waste Management
Solid Waste Section, Permitting Branch
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778-8211

Subject: Buncombe County, North Carolina
New Transfer Station
Determination of Completeness Letter April 19, 2017
Permit #1108T-TRANSFER-1996, Document ID 27638

Dear Mr. Gaither:

The intent of this letter report is to respond to item #2 in your letter referenced above. Buncombe County
intends to hire a contractor to excavate a portion of this pre-regulatory landfill in order to construct
(primarily) the foundation of the new transfer station and other project features such as the entrance and
exit roads. It is believed that landfill operations were conducted in the majority of the area proposed to be
disturbed. The County’s plan to excavate, dispose, temporarily cover, and re-establish final cover is
outlined in the following paragraphs.

The County’s Transfer Station Manager, Dane Pedersen, who has successfully completed a 40-hour AHERA
course recommended by the Western North Carolina Regional Air Quality Agency, and is certified to identify
asbestos containing waste, will be on-site during all excavation. Should Mr. Pedersen identify any
potentially asbestos-containing waste, he will halt waste excavation and direct the contractor to another
part of the site to continue work. He will then contact a local industrial hygienist, Ray Woodcock MS, CIH,
who will come to the site and conduct sampling and testing, and make a waste determination. Should the
material indeed be asbestos-containing waste, he will make recommendations for appropriate handling and
disposal. The asbestos disposal area at the Buncombe County Landfill will be made available to the
contractor.

The contractor will excavate the site in a manner that controls dust. Excavated waste will be placed in
suitable hauling vehicles that meet any applicable NC DOT regulations for hauling municipal solid waste and
the hauling bed will be covered prior to leaving the transfer station site. Disposal of the excavated material
will be allowed at the Buncombe County Subtitle D landfill. At the end of each day, the contractor will cover
any exposed waste with a compacted layer of six inches of suitable soil in accordance with 15A NCAC 13B