4406_BlueRidgePaper_RevVertExpOpsManual_DIN27712_20170530

OPERATIONS & MAINTENANCE MANUAL
LANDFILL NO. 6
VERTICAL INCREASE

Prepared for

BLUE RIDGE PAPER PRODUCTS INC.
CANTON MILL
DBA EVERGREEN PACKAGING
CANTON, NORTH CAROLINA

November 2016
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November 30, 2016
TABLE OF CONTENTS

Section No. Title Page No.

1.0 GENERAL ........................................................................................................................... 1-1 
1.1 Purpose .............................................................................................................. 1-1 
1.2 Design Concept .................................................................................................. 1-2 
1.3 Development Concept ........................................................................................ 1-2 
2.0 OPERATIONAL PROCEDURES ........................................................................................ 2-1 
2.1 Commencement of Operations........................................................................... 2-1 
2.2 Site Access ......................................................................................................... 2-1 
2.3 Operating Hours ................................................................................................. 2-2 
2.4 Personnel Responsibilities ................................................................................. 2-2 
2.4.1 Organization. .............................................................................................. 2-2 
2.4.2 Personnel. .................................................................................................. 2-3 
2.5 Health, Safety and Fire Considerations .............................................................. 2-4 
2.6 Equipment Requirements ................................................................................... 2-7 
2.7 Waste Delivery and Acceptance......................................................................... 2-7 
2.8 Waste Inspection Plan ........................................................................................ 2-8 
2.9 Waste Placement and Grading........................................................................... 2-9 
2.9.1 Waste Placement Plan. .............................................................................. 2-9 
2.9.2 Special Handling of Waste. ...................................................................... 2-14 
2.9.3 Asbestos Disposal Procedures. ................................................................ 2-15 
2.9.4 Wet Weather. ............................................................................................ 2-17 
3.0 LANDFILL DEVELOPMENT ............................................................................................... 3-1 
4.0 LEACHATE MANAGEMENT .............................................................................................. 4-1 
4.1 Leachate Generation .......................................................................................... 4-1 
4.2 Leachate Drainage Layers ................................................................................. 4-1 
4.2.1 Tire-Derived Aggregate. ............................................................................. 4-2 
4.2.2 Reclaimed Concrete Aggregate. ................................................................ 4-3 
4.3 Leachate Storage ............................................................................................... 4-3 
4.4 Leachate Flow Control ....................................................................................... 4-3 
4.5 Leachate Disposal .............................................................................................. 4-4 
5.0 LANDFILL INSPECTION AND MAINTENANCE ................................................................ 5-1 
5.1 General ............................................................................................................... 5-1 
5.2 Access Roads .................................................................................................... 5-1 
5.3 Equipment .......................................................................................................... 5-2 
5.4 Erosion Control Facilities .................................................................................... 5-2 
5.5 Leachate Collection Piping ................................................................................. 5-2 
5.6 Leachate Storage Pond ...................................................................................... 5-3 
5.7 Liner Repair ........................................................................................................ 5-3 
5.8 Landfill Underdrain System ................................................................................ 5-3 
5.9 Fugitive Dust Control .......................................................................................... 5-4 

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TABLE OF CONTENTS (cont'd)

Section No. Title Page No.
6.0 WATER QUALITY MONITORING ....................................................................................... 6-1 
6.1 General ............................................................................................................... 6-1 
7.0 LANDFILL GAS MONITORING .......................................................................................... 7-1 
7.1 General ............................................................................................................... 7-1 
8.0 RECORD KEEPING & REPORTING .................................................................................. 8-1 
8.1 General ............................................................................................................... 8-1 
8.2 Operating Records and Annual Reports............................................................. 8-1 
8.3 Waste Description .............................................................................................. 8-1 
9.0 FINAL CLOSURE ................................................................................................................ 9-1 
9.1 General ............................................................................................................... 9-1 
9.2 Closure Procedures ............................................................................................ 9-1 
9.2.1 Grading. ...................................................................................................... 9-2 
9.2.2 Drainage Channels, Pipes, or Drains. ........................................................ 9-2 
9.2.3 Final Cover Systems. ................................................................................. 9-2 
9.2.4 Seeding. ..................................................................................................... 9-6 
9.3 Erosion Control ................................................................................................... 9-7 
9.4 Long-Term (Post-Closure) Maintenance ............................................................ 9-8 
9.4.1 Mowing. ...................................................................................................... 9-8 
9.4.2 Site Inspection. ........................................................................................... 9-8 
9.5 Leachate Collection ............................................................................................ 9-8 
9.6 Water Quality Monitoring .................................................................................... 9-9 
9.7 Gas Monitoring ................................................................................................... 9-9 
9.8 Alternative Uses ................................................................................................. 9-9 
9.8.1 Solar Array. ................................................................................................. 9-9 

LIST OF APPENDICES

APPENDIX A WASTE RECEIPT FORMS
APPENDIX B INSPECTION FORMS
APPENDIX C ENVIRONMENTAL MONITORING PLAN
APPENDIX D FIRE OCCURRENCE NOTIFICATION FORM
APPENDIX E ASTM D6270-08, STANDARD PRACTICE FOR USE OF SCRAP TIRES
IN CIVIL ENGINEERING APPLICATIONS
APPENDIX F GAS MONITORING PLAN
APPENDIX G LANDFILL TRAINING PROGRAM OUTLINE
APPENDIX H STORMWATER MANAGEMENT PLAN

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LIST OF FIGURES

Figure No. Title Page No.

1-1 DEVELOPMENT CONCEPT ............................................................................................. 1-4 
2-1 ORGANIZATION CHART .................................................................................................. 2-2 
2-2 WASTE PLACEMENT ..................................................................................................... 2-10 
2-3 INTERNAL CELL DRAINAGE EAST-WEST .................................................................... 2-12 
2-4 INTERNAL CELL DRAINAGE NORTH-SOUTH .............................................................. 2-13 
3-1 LANDFILL NO. 6 DEVELOPMENT .................................................................................... 3-2 
9-1 FINAL COVER SYSTEM ................................................................................................... 9-3 
9-2 STORMDRAIN INLET/PENETRATION ............................................................................. 9-4 
9-3 SITE PLAN ......................................................................................................................... 9-5 

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November 30, 2016
OPERATIONS & MAINTENANCE MANUAL
LANDFILL NO. 6
VERTICAL INCREASE

1.0 GENERAL

1.1 Purpose

The purpose of this manual is to provide information to the personnel involved in the operation,
maintenance, and closure of the Blue ridge Paper Products Inc., dba Evergreen Products
(Evergreen), Canton Landfill Facility (Landfill). Guidelines and procedures for the development
and operation of the Landfill are provided herein. It is important to recognize that some of the
procedures in this manual may require modification over time in response to new regulations or
as improved methods are developed for carrying out the day to day landfill activities. Changes
in procedures must be verified with the Canton Mill area management, particularly
Environmental, Health and Safety Department (EHS) and Mill Engineering prior to
implementation.

It is equally important for the personnel involved in landfill operations to understand the critical
requirements for successful landfill operation and maintenance. Operation of a landfill is as
much about managing water as it is the solid waste. Approximately one million gallons per acre
of precipitation falls to the ground in the Canton, North Carolina area on a yearly basis.
Management of this and other waters which may be associated with or absorbed by the
incoming waste is a principal task of the landfill operations personnel.

The Landfill has been designed to collect the precipitation and other water which becomes
leachate. It is the operations personnel's goal to insure that maximum leachate collection
efficiency is maintained while simultaneously minimizing leachate generation to the extent
practical. Minimizing leachate generation is accomplished by separating clean surface runoff
from the wastes, encouraging evaporation of leachate, and other procedures which are
discussed herein.

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This manual was prepared with regard to the Solid Waste Rules and Regulations (Regulations)
of the North Carolina Department of Environmental Quality (NCDEQ). It includes descriptions of
development procedures, landfill operations, site maintenance, safety procedures, monitoring
requirements, leachate management, and numerous other important procedures which must be
adhered to. Everyone associated with the management and operation of the Landfill should be
familiar with this manual to ensure a safe and environmentally secure facility.

1.2 Design Concept

It is not the purpose of this document to provide a detailed account of the design of the Landfill;
however, a general discussion of the design of the Landfill is presented herein. The Landfill
operations personnel are encouraged to review the Design Reports and Engineering Drawings
which provide detailed descriptions of the Landfill and its features.

The Landfill incorporates an engineered liner system beneath the waste to minimize the
potential for leachate to impact the groundwater underlying the site. The current landfill design
begins by placing a geosynthetic clay liner (GCL) over the cell base grades followed by a 60-mil
thick high-density polyethylene (HDPE) geomembrane. Over the geomembrane is placed a
non-woven geotextile followed by a 15-inch granular drainage (leachate collection) layer to
collect and transport leachate. Embedded within the drainage layer is a network of perforated
pipes to aid in the transport of leachate by gravity flow to a discharge sump or wet well. From
the sump, the leachate is pumped to the mill's wastewater treatment plant. Leachate storage
ponds are an integral part of the system and provide leachate storage during periods of heavy
rainfall.

Once an area of the Landfill has reached final waste grades, final cover is applied as detailed in
Section 9.0. Final Cover is installed to reduce leachate generation and allow consolidation of
the waste. The residual water within the waste will slowly percolate out via the leachate
collection system as the waste consolidates.

1.3 Development Concept

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The Landfill uses natural geographic features in the area such as depressions to maximize the
space utilized for the waste stream from the Canton Mill. The main waste streams entering the
Landfill are treatment plant sludge, multi-fuel boiler ash and lime from the papermaking process.
The engineering properties of these two materials can vary significantly. Traditionally landfill
construction consists of building a small self-enclosing berm and installing a liner system inside
on which to place waste. To circumvent any issues with the paper mill wastes (i.e., stability)
and traditional landfilling techniques, the Landfill enhances and utilizes the depression walls and
embankments to buttress the waste to allow the same quantity of waste fill in a similar sized
footprint as a typical landfill that would accept municipal solid waste. Development and
operation of the Landfill in this manner allows for separation of clean surface water from the
waste, thus minimizing leachate generation.

The current permit to operate Area D allows placement above the rim (i.e., perimeter dike) of
the landfill depressions. Development above the rim typically begins by filling the space below
the rim of the depression with waste and then filling above the rim after approval is received
from NCDEQ. Figure 1-1 shows the waste grades for Area D South and North, at the end of
filling above the rim. Applications to the NCDEQ for successive permit modifications to increase
the vertical height of the landfill Areas was made based on successful operation below the rim
of each landfill Area.

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2.0 OPERATIONAL PROCEDURES

2.1 Commencement of Operations

(a) At least five business days prior to commencing operation of a new landfill Area,
Evergreen shall notify the NCDEQ of the intent to commence operations.

(b) The notice shall include the following:

(1) Facility identification, including permit number;
(2) Date of intended commencement of operations; and
(3) The name and telephone number of the facility manager or other primary contact
person.

2.2 Site Access

All vehicles and visitors will enter the site via the gated road which accesses the Landfill. The
entrance to the Landfill will have a facility sign which includes the following:

 The facility name and permit number;
 The name, address, and telephone number of Evergreen;
 The type of wastes accepted and not accepted (i.e. "No hazardous or liquid
waste accepted"); and
 The penalty for unlawful dumping.

All visitors will check in at the Mill’s main gate which is located on Main Street in Canton. Only
approved employees will have unrestricted access to the Landfill. All others will proceed only
after receiving clearance from security at the main gate and landfill management. No visitors
will be allowed on-site unaccompanied and the number of visitors will be minimized.

During non-operational hours, the gate at the entrance to the Landfill will be locked.
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2.3 Operating Hours

The Landfill will normally accept mill wastes seven days per week, at up to a 12-hour per day
schedule, depending on daylight hours. It is not uncommon for operations to be expanded to 24
hours per day during mill outages or process upsets.

The normal start of the workday for operators will be 5:30 A.M. The operators will perform daily
maintenance and move the equipment to the operating area within 1/2 hour of commencement
of dumping. An operator shall be present at the operating area at the commencement of
dumping.

2.4 Personnel Responsibilities

The personnel and departments involved in the operation of the Landfill include: 1) EHS
department; 2) Mill Engineering; 3) RURU-Environmental Laboratory Services (ELS); and
4) Landfill Operations. The organization, responsibilities, and tasks conducted by these people
and department are described below.

2.4.1 Organization. An organization chart, Figure 2-1, is presented to outline the chain of
command and support groups which include the EHS Department and Mill Engineering.
FIGURE 2-1

ORGANIZATION CHART

VICE PRESIDENT
OPERATIONS
MANAGER
ENVIRONMENTAL
LABORATORY SERVICES
ENVIRONMENTAL
HEALTH & SAFETY
MILL
ENGINEERING
LANDFILL
OPERATIONS
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2.4.2 Personnel.

2.4.2.1 Environmental, Health and Safety Department

The Environmental Health & Safety Department (EHS) is responsible for securing and
assuring compliance with licenses and permits required for operating the Landfill. This
responsibility includes quantity estimates of all plant waste brought to the site and
environmental monitoring of the Landfill in accordance with the conditions of the landfill
permit. In addition, the department's responsibility includes assuring that the landfill
operation is in compliance with all regulations of the NCDEQ. This responsibility
includes periodic site audits and inspections as well as submission of appropriate data to
the NCDEQ.

EHS personnel are also charged with directing and overseeing the daily operation of the
Landfill to assure that the operating plans are being implemented properly.
Responsibilities of the EHS personnel related to the Landfill include:

a. initiating site development to maintain continuity of operation;
b. directing the overall planning and scheduling of waste placement;
c. maintaining site records and tracking landfill volume consumption;
d. supervising and training personnel; and
e. supervising the site safety program.

In addition, this department is responsible for the maintenance of leachate collection
systems, stormwater runoff facilities, and roads.

2.4.2.2 Mill Engineering

The Mill Engineering group is responsible for overseeing major construction projects at
the Landfill and providing support services for site maintenance. Major construction
projects, such as new landfill Area construction (i.e., cell development and closure),
would be implemented by Mill Engineering.
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2.4.2.3 Landfill Operator

The Landfill Operators are responsible for the daily operation of the landfill’s active face
(current waste placement area). Operators must complete an approved operator
training course. An outline of the course is provided in Appendix G.

The Landfill Operators will:

a. direct placement of the waste by haul vehicle operators,
b. spread and compact wastes,
c. apply cover materials as required,
d. inspect equipment and facilities,
e. abide by established safety rules,
f. maintain site security in conjunction with Canton Mill Security,
g. immediately note and report unusual events or circumstances,
h. maintain such records as may be required (see Section 8.0),
i. immediately report any observed and/or imminent environmental impacts
to EHS department management, and
j. strive to maintain neat and efficient operations.

The mill site operators and haul vehicle operators will be responsible for the proper
loading and handling of their loads. While on the Landfill, they will comply with the
provisions of this manual and directions provided by the Landfill Operator. A certified
Landfill Operator shall be on-site during all operating hours of the Landfill. Problems
encountered at the Landfill should be reported to the Landfill Team and to EHS
management.

2.5 Health, Safety and Fire Considerations

The following health and safety procedures will be adhered to at the Landfill:

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1. Only essential personnel will be involved in activities associated with operation of
the Landfill.

2. Manholes or other similar enclosed facilities at the Landfill are classified as
confined space structures. Entry into these structures will be in accordance with
Mill protocols for confined space entry, the inside air will be tested in accordance
with the Mill’s confined space entry procedures.

3. Dumping areas will be maintained firm and level. After directing trucks to the
dumping area, the operating personnel will stand clear of the truck.

4. The leachate storage pond gate will be locked at all times, except when access is
required.

5. Exit ramps will be provided in the leachate storage pond for exit in the event that
someone falls in.

6. In the event of an accident involving property damage, Mill security personnel will
be notified immediately, to generate necessary reports.

7. In the event of an accident involving personal injury, assess the severity of the
injury and do one of two things. For serious or life threatening injuries call
emergency personnel by dialing 911 outside the Mill, or 2911 in the Mill. If the
resulting injuries are only minor, the injured person must report to the Mill’s
medical section.

8. In the event of an environmental emergency, the Landfill Operator will follow the
spill and release reporting procedure detailed in the Canton Mill Employee Safety
Handbook or call mill extension 6711.

9. Keep gate locked when area not in use.

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10. Follow all safety policies and procedures in accordance with the Canton Mill
Employee Safety Handbook.

In the event of a fire, the following procedures will be implemented:

1. If it is an equipment fire, the fire extinguisher provided with all equipment will be
utilized, if feasible, to extinguish the fire.

2. If the fire does not appear to be controllable with a fire extinguisher, or if the fire
is associated with the landfilled wastes, the emergency dispatcher at Mill
extension 2911 will be contacted immediately. The emergency dispatcher will be
provided with information concerning the location and extent of the fire.

3. The emergency dispatcher will mobilize the appropriate firefighting equipment
and personnel. All fire personnel should be notified in advance to alert them of
the nature of hazards at the Landfill so they may be appropriately prepared and
equipped.

4. All efforts to keep applied water and firefighting chemicals within the landfill limits
will be made.

5. EHS department personnel will be notified as soon as possible so that an
inspection can be made.

6. Hot ashes on the sludge pile will not be considered a fire hazard unless they are
blown by strong winds.

7. EHS department personnel will notify the NCDEQ Division of Solid Waste
Management, Solid Waste Section, verbally within 24 hours and a written
notification must be made within 15 days of the occurrence. A sample fire
occurrence form is shown in Appendix D.
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November 30, 2016
2.6 Equipment Requirements

The following equipment will be available to conduct the daily landfilling activities, place final
cover, minimize erosion, maintain roads, and operate the leachate system:

1. Bulldozer for fine grading;
2. Bulldozer for waste placement and grading;
3. Front-end loader to move cover material and construct temporary berms;
4. Two-way radio communication system.

2.7 Waste Delivery and Acceptance

To assure that all information regarding a waste delivery is accurately recorded, it is necessary
to adhere to a "flow control" system. The details of the "flow control" system are described in
this section and Section 2.8, as well as Section 8.0, which describes in detail the record keeping
and reporting requirements which will be followed by this facility.

Each day, drivers will provide the following information:

1. The types and sources of the waste being delivered; and
2. The number of truckloads of each type of waste delivered.

Each month, drivers will provide the following information:

1. Weights of the trucks according to the established plan.

Sample waste receipt forms are shown in Appendix A.

Landfill personnel will determine if the Landfill is permitted for the type and source of waste
being delivered, see Section 2.8. When the truck arrives at the disposal area, the Landfill
Operator will direct the unloading of the waste. Weigh tickets will be obtained periodically from
the Scale Operator by Landfill personnel for recording onto the monthly accounting forms.
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A sample of trucks will be weighed and the gross weight recorded in accordance with Section
8.3. Tare weight will be determined by deducting the truck empty weight determined at the time
the truck was acquired from the weight of the truck when it enters the site.

2.8 Waste Inspection Plan

The loader operator and truck driver will inspect the waste load and determine if the waste is
accepted at the Landfill according to the list of permitted wastes shown below. If there is any
question as to the waste being accepted at the Landfill, EHS management will be notified to
obtain a decision on whether it is an acceptable waste.

The general categories of accepted waste are:

1. Fly ash from multi-fuel boilers;
2. Lime waste (mud);
3. Wastewater treatment plant sludge;
4. Wood waste debris;
5. Cinders;
6. Asbestos containing material (ACM); and
7. Biosolids

The Landfill is not permitted to accept the following wastes:

1. Municipal wastes;
2. Hazardous wastes;
3. Radioactive waste materials;
4. Liquid wastes;
5. Non-Evergreen waste;
6. Biomedical waste;
7. Sharps not properly packaged;
8. PCB waste as defined in 40CFR76; and,
9. Wastes banned from disposal in North Carolina by G.S.130A-309.10(F).
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The Landfill Operator will also inspect each load. If an unpermitted waste is improperly
accepted for disposal, the Landfill Operator shall notify EHS management.

In the event a special waste is generated, the owner will secure NCDEQ approval prior to
disposal.

2.9 Waste Placement and Grading

2.9.1 Waste Placement Plan. The following is the waste placement plan. This plan is
designed around the nature of the waste disposed at the Landfill and its location below or above
the rim of the active landfill Area. Each lift shall be constructed as detailed herein to achieve the
grades shown on the waste grading plans prepared as part of the engineering drawings for each
phase. Failure to adhere to the procedures in this Manual could have negative results on
overall or local landfill stability.

2.9.1.1 Waste Placement Below the Rim

The sludge, woodwaste, and lime mud will be dumped by the haul truck operator and
spread by an equipment operator. Dumping of waste will start at the lower elevations
within the cell. The Landfill Operator will push and spread the waste over the working
face, in layers no greater than 2 feet thick as shown in Figure 2-2. Spreading the waste
in thin layers, allows the waste to drain, achieves greater in-place compaction (density),
and maintains the stability of the working face. The thin layers of waste will make up
waste in lifts approximately 10 to 15 feet thick. Each lift of waste must achieve positive
drainage either through proper waste grading or through a mechanical means described
in Section 2.9.2 (Special Handling of Waste).

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Papermill sludge as a byproduct of the papermaking process contains varying amounts
of clay that is used as filler. As the sludge is landfilled deeper, the consolidation of the
sludge makes the sludge less permeable; water does not drain through it as easily. In
order to maintain good drainage within the landfill, the top surface of each lift will be
covered with a 12-inch thick drainage layer of granular drainage material, i.e. stone,
gravel, etc. In certain locations within the Landfill, the use of a substitute for the stone
aggregate as the drainage layer is allowed as described under Leachate Drainage
Layers in Section 4.2. The drainage layer will aid in draining the next lift of waste,
making for a more stable landfill operation. In addition to the drainage layers, chimney
drain strips oriented north to south will be extended upward to the top of the waste lifts,
as shown in Figure 2-3. As with the chimney drain strips, the stone drainage layer along
the lined sideslopes will also be extended with each new lift of waste. Above the rim this
sequence is continued and the final waste surface is covered with a one-foot-thick
drainage layer as shown on Figure 2-3. Between Area D South and North; and between
Area D North and Area E (proposed) are containment berms that separates the two
cells. A drainage layer is also present beneath the waste and will be placed over the
final waste surface, prior to filling above the rim or final cover construction, as shown on
Figure 2-4. Figures 2-3 and 2-4 are generalized cross-sections and are oriented east to
west and north to south, respectively.

Special procedures will be implemented during winter operation of the Landfill. Snow
and ice removal from operational areas including roads and the working face in the
active landfill Area must be maintained to allow proper operation of the Landfill. Waste
placement, grading, and site cleanliness become more important during the winter since
ungraded frozen sludge or other wet wastes can become a barrier to traffic movement.
The access road must be plowed and sanded to provide safe travel conditions. Salt
should only be used if necessary, because it may seep into the groundwater and could
affect groundwater quality data. Sanding will be the preferred method of road treatment
in the winter months. Drainage structures such as culverts should be kept free of ice
and snow to assure unrestricted runoff during thawing conditions.

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Any damage to the liner system of the Landfill that occurs as a result of construction or
operational activities will be reported immediately to EHS management for appropriate
action.

2.9.1.2 Waste Placement Above the Rim

Waste placement above the rim in Area D South and North is allowed, according to the
current Permit to Operate. Waste placed above the rim of the landfilled Area does not
have the depression wall/embankment to buttress it against movement. Placement of
waste above the rim is performed similar to waste placement below the rim with some
exceptions. Proper waste placement above the rim is critical to landfill stability. Waste
placed above the rim of the landfilled Area will have outside slopes as determined by a
stability analysis conducted during the design phase for each cell. Typical outside
slopes are likely to range from 3 to 4 feet horizontal to 1 foot vertical. Soft wet wastes
must be placed greater than 100 feet away from any outside slope to maximize slope
stability.

2.9.2 Special Handling of Waste. Other than asbestos disposal, which is described in Section
2.9.3, certain situations require special landfilling procedures to maintain the integrity of the
Landfill and protect the working area and surrounding environment. One special procedure is in
areas of the Landfill that have become too wet to work on and the other special procedure is for
disposal of boiler ash.

Occasionally, wetter than normal waste material will be delivered to the Landfill for disposal.
This saturated waste material will not be placed closer than 100 feet from any outside slope.
When an area is too wet to work, a mechanism is needed to allow the excess water to drain
freely away from the saturated waste area. Drainage and enhanced equipment flotation will be
achieved by using a drainage layer that utilizes either a drainage geocomposite, used paper
machine wires or used paper machine felts placed over the wet area. This will ensure a
channel for excess water to drain from the saturated waste materials while allowing continued
waste placement.

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The safe disposal of boiler ash will protect the working atmosphere and the surrounding
environment. Boiler ash amounts to approximately 1,400 cubic yards per week. Two types of
ash are brought out to the Landfill: cinders and fly ash. The cinders consist of inorganic boiler
residue from the burning of coal and wood fuel. This material is landfilled by spreading it over
the working face or it is used as a gravel substitute within the active area of the Landfill. The fly
ash is a much finer material and can dry out and become dusty. Landfilling the fly ash can be
accomplished by spreading the fly ash and immediately placing a layer of sludge over it or
working it into the sludge, depending on the moisture content of the sludge. This will prevent
blowing of the ash, and water from the sludge will minimize the generation of fly ash dust.

2.9.3 Asbestos Disposal Procedures.

2.9.3.1 Notification and Approval Procedures

A disposal area located between Areas F and H, as shown on Figure 3-1, has been
permitted in accordance with 40 CFR Part 61 and 15 NCAC 2D and 10A NCAC 41C to
accept asbestos containing materials (ACM). Anyone wishing to dispose of ACM at
Landfill No. 6 must contact the EHS Department at 646-2028. The EHS Department will
determine that the material to be disposed of is ACM and will issue and coordinate the
disposal with the contractor. ACM must be hauled and disposed of by a contractor
permitted by the State of North Carolina. The ACM must be removed from the source,
transported to the disposal site, and properly buried in compliance with Toxic Substance
Control Act and North Carolina Rules.

Before approving the ACM disposal, the abatement contractor will assure that any
personnel on the transport crew who may be exposed to asbestos fibers above the
OSHA permissible exposure limit are required to wear a protective respirator during
asbestos unloading and that they have complied the requirements of Evergreen/Blue
Ridge Respiratory Protection Program. Personnel or ambient air monitoring may be
required during the disposal event.

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2.9.3.2 Site Security and Maintenance

During the unloading of asbestos waste at the Landfill, the Landfill Operator will assure
that all personnel and equipment not directly involved with the unloading activity are kept
at least 100 feet back from the disposal area. If the driver of the truck that hauled the
asbestos has not been trained, he/she will remain in the truck with the windows up, or
the driver should remain 100 feet away as per the Rules during a manual unloading
process of friable asbestos or during clean-up of asbestos materials. All friable ACM is
to be wetted and bagged according to the regulations. Within the disposal area, the
bagged ACM is to be placed on an appropriate sized sheet of plastic, and then covered
with plastic. Before the end of the day, at least 18 inches of soil will be placed over the
plastic covered asbestos waste.

The asbestos disposal area at the Landfill shall be permanently identified on a map as
an asbestos waste disposal area in compliance with the Regulations.

2.9.3.3 Disposal Procedures

Vehicles used to transport ACM must be marked during loading and unloading per 40
CFR 61.149(d)(1)(iii). All trucks must be weighed at the landfill scales on their way in
and must reweigh when empty. The weight tickets must be signed by the transporter
before departure. All friable or potentially friable asbestos waste will be transported to
the disposal area in double 6-mil poly bags, labeled in compliance with 29 CFR
1926.58(k). The transport container shall be leak-tight and labeled in compliance with
40 CFR 61.152. Non-friable asbestos may be transported without bagging if the
transport container is poly lined and the material is adequately wetted and covered with
6-mil poly cover and secured to prevent the effects of wind or evaporation on the
material during transport. It is the responsibility of Evergreen and their ACM contractor
to properly package and label the asbestos waste. The Landfill Operator can reject
loads that are not properly packaged and labeled. Non-friable asbestos shall not be
shredded, crushed, or subjected to any other form of volume reduction prior to
placement in the Landfill.
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Trucks approaching the asbestos unloading area shall approach as closely as possible
before unloading waste. The ACM contractor and Landfill Operator will coordinate
asbestos disposal in the designated area shown on Figure 3-1. Waste containers shall
be lowered to the ground at the disposal area and not pushed or dropped from the back
of a truck. All containers shall be inspected during unloading and any damaged
containers shall be immediately wetted sufficiently to prevent dispersal of asbestos fibers
during the burying of the waste. The operators can then cover the asbestos with the
proper amount of cover material.

Damage to containers outside the disposal area may be repaired only by properly
trained and licensed personnel under the supervision of the ACM contractor. The
amount of asbestos material that may be repacked by the contractor crew is limited to
minor asbestos abatement projects in accordance with 10A NCAC 41C.0605. These
Rules allow the abatement of disturbances of less than or equal to 35 cubic feet (1 cubic
meter), 160 square feet (15 square meters) or 260 linear feet (80 linear meters), of
regulated asbestos containing material. If the quantities are greater than the allowed
quantities, an asbestos abatement contractor shall be used to clean-up the asbestos
release. Workers who must handle or repack damaged bags must wear proper
protection equipment, which includes disposable protective clothing, gloves, and
respirators equipped with HEPA filters, and must be properly trained and licensed to
work with asbestos. All protective clothing and poly lining in the container shall be
disposed of in compliance with the asbestos requirements of 29 CFR 1910.1001.

2.9.4 Wet Weather. During very wet weather, access to the working face may become
difficult. Grit or gravel can be used to provide a stable traffic mat to improve movement of
vehicles on the Landfill as needed, but the amount of these materials should be held to a
minimum.

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3.0 LANDFILL DEVELOPMENT

Waste placement within each cell will begin at the lowest elevation and placed as outlined in
Section 2.9 in a uniform layer over the entire open operational area. Subsequent lifts will be
placed on top of the lower lifts in the same manner until the rim elevation is reached. The initial
development of each cell does not permit placement of waste above the rim. Therefore, prior to
achieving waste capacity at any given cell, the following cell will be constructed and tied into the
current cell as necessary to allow for proper leachate containment, transport, and disposal.
Waste placement within that cell will proceed as with the previous cell, beginning at the lowest
elevations and buttressing against waste of the previous cell.

Upon reaching cell capacity beneath the rim, waste placement above the rim may commence
after all necessary permits are acquired. All outer waste sideslopes should be graded as
determined by a stability analysis conducted during the design phase for each cell. Typical
outside slopes are 3 horizontal to 1 vertical (3H:1V) below the rim and for slopes with toes that
are not adjacent to the perimeter dike; and 4H:1V above the rim where the toe is adjacent to the
perimeter dike, as shown on Figure 2-3. Waste placement above the rim will continue as in
previous cells, maintaining uniform layers over the entire open operational area until final waste
grades are achieved, at which point final cover will be placed as outlined in Section 9.0. The
current and future landfill development of Landfill No. 6 is shown on Figure 3-1.

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4.0 LEACHATE MANAGEMENT

4.1 Leachate Generation

Leachate will be generated in the landfilled Areas through two mechanisms. Precipitation
infiltrating into and running off of the active waste face is the major source of leachate
generation at the Landfill. Waste consolidation and subsequent drainage of entrained water is
the secondary mechanism by which leachate it generated at the Landfill. Further discussion
concerning the volumes of leachate may be found in the Design Reports for Areas D South and
North.

Leachate is collected and transported through a gridwork of perforated pipes that underlie the
waste and drainage layers that are placed along the side slopes of the landfill and between
waste lifts. Leachate will flow by gravity to the leachate pump station and storage ponds and is
pumped via a force main to the Canton Mill wastewater treatment plant.

4.2 Leachate Drainage Layers

Leachate drainage is an important element to the landfill operation. The landfill leachate
drainage layers are typically constructed with stone aggregate consistent with gradations of
ASTM #57, #67, and #78 stone size. The stone is placed along the bottom and sideslopes of
each cell prior to landfill operations. Additional stone is used between each waste lift which
drains to the exterior sideslope or to a centrally located chimney drain.

The use of stone aggregate is required for the base layer, along the sideslope, and for the
chimney drain. The use of stone aggregate or recycled products is allowable for the drainage
layers between waste lifts. The recycled products include tire derived aggregate (TDA) and
reclaimed concrete aggregate (RCA). A description and handling procedures for the recycled
products is described below.

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4.2.1 Tire-Derived Aggregate. TDA, also known as tire chips, may be substituted for #67 (¾”)
stone in select locations of the Landfill. The use of TDA, however, carries several operational
and handling changes compared to using stone that are addressed below.

TDA will only be used in the leachate drainage layers between the intermediate waste lifts. TDA
shall not be used in the construction of chimney drains, in the drainage layer at the base of the
landfill Area, or adjacent to any geosynthetic liner or cover material. The drainage
characteristics of the TDA are dependent upon the grain size of the material. The grain size
specification for the TDA will adhere to ASTM C136-05, Type B (See Appendix E) and the
maximum particle size not to exceed three inches.

It is important to maintain safe handling and storage of tire chips at the Landfill to minimize the
potential of fires. The National Fire Protection Association (NFPA) and Rubber Manufacturers
Association recommends tire chip storage piles not exceed 10,000 square feet in area and 10
feet in height. Tire chips will be stored in an area outside of the active cell but within an area
that the stormwater drains through the erosion and sedimentation control structures. During
active operations of Area D South and North, the TDA can be stored in the footprint of Area E
where other landfill materials are stockpiled and stormwater discharges can receive pollutant
treatment in the sedimentation pond. This location is preferred over the active waste cell as
truck maneuverability can become difficult over non-compacted, i.e. loose, TDA layers.

Placement and compaction of TDA requires careful operational practices. Soft sludge areas
require the use of a high strength geotextile separation fabric to prevent the migration of waste
into the TDA void spaces. In addition, TDA may be tracked into soft waste with a crawler tractor
to increase the strength of the waste surface before a geotextile is installed as a new
drainage/travel layer. A two-foot layer of TDA is recommended when substituted for one-foot of
aggregate stone thickness to maintain the hydraulic conductivity properties comparable to stone
after compaction as shown on Figure 2-2. Compaction of TDA should adhere to ASTM
specification D6270-08, Standard Practice for Use of Scrap Tires in Civil Engineering
Applications (See Appendix E).

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Periodic inspections of the tire chip storage pile should be performed to maintain the
recommended pile size and height.

4.2.2 Reclaimed Concrete Aggregate. RCA may be substituted for #67 (¾”) stone in select
locations of the Landfill. Identical to TDA, RCA will only be used in the leachate drainage layer
in the intermediate waste lifts and shall not be used in the construction of chimney drains, in the
drainage layer at the base of the landfill, or adjacent to any geosynthetic liner or cover material.
The grain size specification for the RCA will have a maximum stone size of 6 inches and contain
no more than 10 percent fines (i.e., particles smaller than 0.075 mm, or a No. 200 U.S.
Standard sieve).

Placement and compaction of RCA is similar to stone aggregate. RCA layers shall be placed
one-foot thick (as shown on Figure 2-2) and may be tracked into soft sludge areas for added
strength before a new drainage/travel layer is installed. RCA compaction shall follow the stone
aggregate compaction specifications. RCA storage piles shall be located in the footprint of Area
E, with other material storage piles, and stormwater discharges can receive pollutant treatment
in the sedimentation pond.

4.3 Leachate Storage

The leachate storage ponds utilize a synthetic liner to contain excess leachate. The ponds are
designed to store leachate during extended wet weather periods prior to transportation to the
WWTP. Typically, the ponds will be dry by design. The capacity of the ponds is approximately
1.7 million gallons. The location of the leachate storage ponds is shown on Figure 3-1.

4.4 Leachate Flow Control

The leachate transport piping system between the Landfill and the wastewater treatment plant is
designed with gate valves to control the flow if necessary. The following scenarios are
described with the proper actions to be taken.

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The leachate transport system includes a pump station with the capacity to handle up to 200
gpm of leachate flow. If this capacity is exceeded, the leachate flow in excess of 200 gpm will
be directed to the leachate storage ponds. There are no actions required by the Landfill
Operator for this scenario. Once the flow falls below 200 gpm, the ponds will begin to empty.

In the event the leachate transport pipe from the pump station to the treatment plant develops a
leak, pipe break, blockage, or the pump station needs maintenance, the transport pipeline can
be shut off. A gate valve located on the outlet of the pond can be closed thereby allowing the
ponds to fill. Leachate flow will then be temporarily stored in the leachate storage ponds while
the problem is solved.

4.5 Leachate Disposal

The leachate generated during the operation of the Landfill will be treated by Evergreen's
NPDES permitted wastewater treatment facility.

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5.0 LANDFILL INSPECTION AND MAINTENANCE

5.1 General

Landfill inspection and maintenance will be an ongoing activity. All personnel will be expected
to observe the condition of Landfill facilities throughout their workday and notify the EHS
management of areas and equipment which may need repair and maintenance. Formal landfill
inspections will be conducted in the spring and fall of each year. Additional inspections may be
warranted following unusual climatic or operational events including, but not limited to, major
rain storms, flood, fire, hurricane, or earthquake. These inspections will follow the inspection
forms attached in Appendix B. A description of the inspection items are discussed in the
remainder of this section. EHS management is ultimately responsible to insure that the
inspection and maintenance of all Landfill facilities and equipment occurs.

5.2 Access Roads

The access roads to the Landfill will be maintained by Evergreen. Frequent inspections by the
Landfill Operators, especially during the spring and winter months will be made to insure that
these roads are in safe condition. The summer months are most prone to dry, dusty conditions
that can be a nuisance for operators and neighboring properties. Dust control measures are
described in Section 5.9 for minimizing dust problems.

Internal landfill access roads, including those within the landfill Areas, will be maintained as all-
weather roads. Prompt attention to road repairs is the most cost-effective approach since
deterioration becomes increasingly more rapid once it has begun.

Provisions will be made for snow removal during the winter to maintain relatively normal
operations. Waste placement, grading, and site cleanliness become more important during the
winter since waste such as ungraded frozen sludge can become a barrier to traffic movement.
The access road will be plowed and sanded to provide safe travel conditions. Salt should be
used sparingly. Sanding will be the preferred method of road treatment.
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5.3 Equipment

Maintenance of equipment and landfill operations vehicles is critical in controlling and
maintaining landfill operations. All equipment will be subject to a comprehensive, preventive
maintenance program, as specified in the manufacturer’s specifications. Critical parts or
replacement equipment will be identified and obtainable within a short period of time to maintain
continuity of operations.

5.4 Erosion Control Facilities

Open Areas - Areas outside of the individual landfill Areas, which have been disturbed, will be
seeded to prevent erosion. The seeding will be performed in accordance with the seeding
schedule contained in the closure plan. Prior to any land disturbing activity greater than 1/2
acre, a soil and erosion plan must be secured by the appropriate mill group (EHS or Mill
Engineering).

Ditches - Areas, which are riprapped or otherwise protected, will be repaired as necessary. All
ditches, which are not riprapped or otherwise protected, will be seeded. All debris and other
blockages will be removed from the ditch to allow for unobstructed drainage. Reseeding of the
drainage ditches will be necessary from time to time, as erosion occurs.

Cover System – It is important that the waste containing Areas of the Landfill that have received
final cover remain intact to function to reduce leachate properly. The cover soils will be
replaced and the area re-seeded in places where the final cover system has eroded. Repeated
erosion in a particular area may require a different cover soil such as riprap as opposed to
vegetative soil.

5.5 Leachate Collection Piping

A cleanout is located at the end of the leachate collection mains and laterals that extend to the
perimeter of each landfill Area. These devices provide a means to remove blockages within the
piping system, should they occur.
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5.6 Leachate Storage Pond

To insure the integrity of the leachate storage pond, annual inspections will be made. When the
ponds are empty, visual inspection of the liner will be made. Any tears or punctures will be
noted and repaired.

5.7 Liner Repair

If tears or punctures occur in the liner within the pond or along the sideslopes of the landfill, they
will be repaired as soon as possible. Punctures and tears less than 6 inches in length will be
repaired by Evergreen personnel if trained personnel are available. Repairs will involve
placement of an overlapping patch (6-inch minimum overlap) which will be tack-welded to the
underlying liner. Extra liner will be stored on-site for field repairs. If the liner tear is greater than
6 inches in length, a liner installer will be contacted to make the necessary repairs.

5.8 Landfill Underdrain System

The landfill underdrain system will be inspected on a monthly basis. An inspection form, see
Appendix B, will be filled out to document each inspection. The inspection will consist of the
following list.

1. Pipe outlets shall be checked for blockages and that the discharge is not eroding
the outlet ditch. Any blockages should be removed to provide free flow from the
pipe outlet. If erosion should occur, the ditch outlet should be stabilized,
riprapped, or otherwise reinforced. The end of the pipe also has a rodent guard
to prevent animals from entering the pipe. This should be checked and repaired,
if necessary.

2. Inspect the manholes for blockages or silt build-up. For either case, the EHS
management should have the manhole cleaned and reinspected.

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In addition to a monthly inspection, the underdrains shall be inspected after any major rain
storms, floods, fire, hurricane, and earthquake or facility failure.

5.9 Fugitive Dust Control

Landfill activities can be a potential source of dust. Dust results from trucks driving over the
gravel access roads, blowing of dry waste transported in the trucks, and dust emissions during
the landfilling of dry waste. The special handling of dry waste such as fly ash and prevention of
dust emissions during landfilling activities is described in Section 2.9.2.

The Canton Mill fly ash collection, storage, and loading vessel incorporates a wetting system to
raise the moisture content of the fly ash so that it can be transported without dusting. Transport
truck beds are covered with tarps to prevent escape of dust from dry waste during hauling. The
application of dust control measures on access roads within the Landfill is discussed below.

Dust control measures will be implemented at the facility by utilizing water spray trucks to wet
roads during dry periods. Additional measures such as applying calcium chloride may be
required on an as needed basis. The primary access road to the facility has been paved in
order to reduce dust generation.

In addition to water, several alternative dust control agents exist for suppressing dust with sand
utilized as needed. Some alternatives include natural salt brine solutions as a replacement for
calcium chloride; asphalt emulsions; organic, non-bituminous materials; and polymers.

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6.0 WATER QUALITY MONITORING

6.1 General

To aid in evaluating the performance of the Landfill, a groundwater and surface water
monitoring program will be conducted. The collection, preparation, preservation, and delivery of
the samples to the laboratory shall be the responsibility of the EHS department. A description of
the sampling program and procedures is provided in the Environmental Monitoring Plan in
Appendix C.

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7.0 LANDFILL GAS MONITORING

7.1 General

To aid in evaluating the performance of the Landfill, a landfill gas monitoring program will be
conducted. The collection of landfill gas measurements shall be the responsibility of the EHS
department. A description of the sampling locations, frequency and procedures; landfill gas
safety procedures; equipment specifications and quality control; and reporting are provided in
the Landfill Gas Monitoring Plan in Appendix F.

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8.0 RECORD KEEPING & REPORTING

8.1 General

One of the most important elements of a well-run landfill is an efficient record keeping system.
For a facility of this nature, it requires the timely collection, interpretation, and management of
large volumes of data. Data collected will be presented in an annual report to the NCDEQ. The
annual report will include the source, type, and volume of waste accepted over the course of the
calendar year.

A copy of the permit and operating plan will be maintained at the facility.

8.2 Operating Records and Annual Reports

(a) Evergreen will maintain documentation of all facility operations, including:

(1) Identification of the facility, owner, and operator;
(2) Quantity, type and source(s) of wastes received;
(3) Complete record of inspections, maintenance, repairs, and emergency
event response;
(4) Data on all environmental monitoring required for the current operating
Area(s).

(b) Evergreen will file an annual report of operation with the NCDEQ by July 31 of
each year, for the previous 12 months of operation.

8.3 Waste Description

The Landfill is licensed to dispose of wastes which fall into seven general categories.
Regardless of the type of waste, similar accounting procedures will be used. Accounting will
include logging the number of truckloads with regard to waste type and volume.
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The general categories of accepted waste are:

1. Fly ash from multi-fuel boilers;
2. Lime waste (mud);
3. Wastewater treatment plant sludge;
4. Wood waste debris;
5. Cinders;
6. Asbestos containing material (ACM); and
7. Biosolids.

The scaled amount of each category of acceptable waste will be recorded on a truckload log
sheet. Truck weight samples of each waste category will be logged as needed. A copy of the
log sheet is included in Appendix A.

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9.0 FINAL CLOSURE

9.1 General

Closure of the site is a continuing process which includes the following activities:

1. Final waste grading and shaping;
2. Closure of discontinued channels, pipes, or drains;
3. Placement of cover materials;
4. Seeding and fertilizing.

The principle goals of the closure plan for the Landfill are: 1) to minimize future generation of
leachate; and 2) to provide a cover system suitable for developing a grass crop which will
prevent erosion. The final cover system designed for this site will minimize future generation of
leachate, and provide a suitable stormwater management plan which will minimize the potential
of erosion.

Inspection and monitoring of closed areas are necessary to detect erosion and to initiate repair
for prevention of significant damage to the landfill cover. Uneven settlement may result in
ponding or breaks in the cover system, these areas will be rebuilt and/or regraded to restore
proposed contours. In addition, maintenance and post-closure care will include periodic mowing
to discourage large, deep-rooted vegetation which can damage the cover integrity.

The Owner may permit third-party use of select areas for alternative use; however, State
approval must be obtained. One such use is the FLS Energy Solar array located on Area B-
Lower which was approved in 2009. Further information is provided in Section 9.8, Alternative
Uses.

9.2 Closure Procedures

The subsections which follow describe the various closure procedures and activities which must
be performed.

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9.2.1 Grading. The waste will be placed and graded to design final waste elevations. Prior to
cover installation, a topographic survey will be performed to insure that the proper grades exist
and there are no low areas or depressions within the closure area. The survey will confirm that
the slopes do not exceed the proper grades. The survey will also be used to check surface
water runoff ditches to insure that proper slopes exist. The waste grades should be kept a
minimum of 5 ft (vertical) below the top of the road or 11.5 ft parallel with the slope from the
edge of the road, as shown on Figure 9-1. This will allow for a minimum ditch depth of 2 ft.
Waste limits are shown on a typical cover section in Figure 9-1.

9.2.2 Drainage Channels, Pipes, or Drains. The closure of leachate collection channels,
pipes, or drains will be accomplished in a manner which ensures the integrity of the system for
the system's design life.

The design life of all components within the Landfill is 50 years; typical products which have this
life are stainless steel and high-density polyethylene (HDPE). Design of the closure should also
take into consideration the forces acting on the area of interest.

Stormwater will be discharge out of Area D via a system of culverts and catch basins. Culverts
penetrating the cover system will have concrete headwalls and aprons at the inlet. The
stormwater outlets are shown in Figures 9-2 and 9-3. The stormwater runoff from the closed
Area D will flow to the south and discharge to the Pigeon River. Modifications will be required to
the detention basin at the toe of the South dike of Area D. Stormwater runoff calculations and
drawings showing the stormwater routing are presented in Appendix H, Stormwater
Management Plan.

9.2.3 Final Cover Systems. Two types of final cover systems over the landfilled Areas
have/will be completed; one consists of three layers and the other will consist of five layers. The
two types of final cover systems are described below, from top to bottom are:

Areas A, B, and C have been covered and consist of the following three layers:

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1. Four inches of vegetative cover soil;
2. 36 inches of suitable on-site soils, i.e. residual soils; and
3. 12 inches of granular drainage material.

Area D will be covered and consist of the following five layers:

1. Four inches of vegetative cover soil;
2. 24 inches of suitable on-site soils, (i.e. residual soils);
3. Drainage Geocomposite;
4. Flexible geomembrane liner; and
5. 12 inches of granular drainage/gas collection material.

The 12-inch granular drainage layer will tie into the stone leachate collection and drainage layer
along the perimeter of the landfill Areas and will act as a passive gas collection system. The
gas collection system will consist of a series of pipes with discharge vents that outlet through
the cover system.

Permanent markers consisting of metal or fiberglass placards will be placed at the waste
boundary of landfilled Areas that have been permanently closed. The markers will extend up
approximately 3 to 5 feet above the final cover surface, contain the words “Edge of Waste,” or
“EOW,” and have a spacing not to exceed 250 feet. Caution should be taken when installing
the sign post so as not to penetrate the liner.

9.2.4 Seeding. All areas which have final cover applied will be seeded. Seeding should
normally occur between March 1 and October 15. All surface grading and construction of runoff
control structures such as drainage ditches, berms, and culverts are to be performed prior to
seeding. The top layer of soil shall be loosened by raking, discing, or other acceptable means
before seeding. Lime (2 tons/acre or as needed based on testing) and fertilizer (1,000 lbs/acre
of 10/10/10 or as needed based on testing) will be harrowed or disced into the soil at a minimum
of 3 inches. If the site is hydroseeded, lime, fertilizer and seed can be applied simultaneously.
The seed mixture to be used is as shown below.

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SEEDING MIXTURE (OR EQUAL)

Tall Fescue (KY 31) 80 lb/acre
Sericea lespedeza 20 lb/acre
Kobe lespedeza 10 lb/acre
110 lb/acre

The seed will be applied uniformly with a cyclone seeder, drill, cultipack seeder, or hydroseeder.
Seed should not be planted if there is a danger of frost shortly after seed germination.
Maximum seeding depth is 1/4 inch when using methods other than hydroseeding.

9.3 Erosion Control

The following procedures will be used for erosion control on the seeded areas:

 Slopes less than 4:1 - Apply unrotted, long-fibered hay, straw, or cellulose fiber at
a rate of 2 tons per acre. Mulch material should be relatively free of all kinds of
weeds, and should be anchored with a tractor drawn implement designed to
punch and anchor it into the top 2 inches of soil. Anchoring of the mulch will be
performed immediately after placement to minimize loss by wind or water. This
method of anchoring should be done on the contour wherever possible.

 Slopes steeper than 4:1 - On 4:1 slopes or steeper, the seed will be applied by
hydroseeding with a binder or excelsior matting to control erosion. Siltation
fences will be installed at the bottom of all seeded slopes. Berms will divert
runoff from the top of the slopes to established slopes.

 Drainage ditches - The grass-bottomed drainage ditches will be seeded in the
same manner as the remainder of the site. The same mulch specified above will
be placed in these areas. Staples, lightweight biodegradable paper, plastic, or
cotton nettings will be placed within the ditches to anchor the mulch.

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9.4 Long-Term (Post-Closure) Maintenance

The subsections which follow describe the various activities which must be performed to insure
the long-term integrity of the Landfill subsequent to final closure.

9.4.1 Mowing. To prevent deep-rooted tree growth, the closed portions of the Landfill and
drainage ditches will be mowed at least twice per year. Evergreen permits local farmers to use
several areas that have final cover applied for hay production provided they cut the area at least
2 times per year to prevent tree growth.

9.4.2 Site Inspection. Once an Area of the Landfill is closed, the Area will be inspected by the
EHS in the spring and fall of each year for a period of at least three years to insure the cover
system integrity is maintained against differential settlement, erosion and other problems. The
inspection will include an examination of the following items:

 Surface drainage ways;
 Surface grading; and
 Grass growth.

Each inspection will include notation of any problems and recommended remedial actions.
Following the initial three years, an inspection frequency of once per year will be sufficient
unless major problems develop, whereupon more frequent inspections will be made.

9.5 Leachate Collection

Leachate collection will continue past the closure of the individual Landfill Areas. The primary
source of leachate during this period will be consolidation of waste. The amount of leachate
which must be collected, transported, and treated will be greatly reduced from that generated
during operation of the landfill Area.

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9.6 Water Quality Monitoring

The semi-annual monitoring program described elsewhere in this manual will continue after site
closure. After closure, if the concentrations of parameters analyzed stabilize, the NCDEQ can
be approached to reduce the frequency of sampling and the number of parameters analyzed.

9.7 Gas Monitoring

Landfill gas shall be monitored in accordance with Section 7.0 and Appendix F until the facility
effectively ceases generation of gas.

9.8 Alternative Uses

The owner may permit third-party use of select areas of the Landfill for alternative use; however,
State approval must be obtained. In such cases, the person or company responsible for the
operation and maintenance of the specific site must be made available. Examples of this may
include but are not limited to security, fencing, mowing, and maintaining the integrity of the cap.

9.8.1 Solar Array. In 2009, approval was granted for FLS Energy to install and operate a solar
array located on the closed portion of the Landfill, Area B-Lower. This area is shown on
Figure 3-1. FLS Energy maintains all responsibility for operating equipment associated with the
solar array, and is required to install perimeter fencing and maintain all interior vegetated areas
according to Section 9.4.

FLS Energy Contact information:
FLS Energy Inc.
130 Roberts Street
Asheville, NC 28801
Ph# [phone]

APPENDIX A

WASTE RECEIPT FORMS

APPENDIX B

INSPECTION FORMS

Month:
Year:
Date Inspector Initials / Time Visual Status Rainfall / Findings / Comments
LANDFILL # 6 - ASBESTOS CELL INSPECTION
To be inspected weekly at a minimum
To be inspected following a rainfall > 0.50"

APPENDIX C

ENVIRONMENTAL MONITORING PLAN

ENVIRONMENTAL MONITORING PLAN
LANDFILL NO. 6
CANTON, NORTH CAROLINA

BLUE RIDGE PAPER PRODUCTS INC. –
CANTON MILL
DIVISION OF EVERGREEN PACKAGING
CANTON, NORTH CAROLINA

MAY 2009
(REVISED DECEMBER 2014)

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TABLE OF CONTENTS

Section No. Title Page No.

1.0 INTRODUCTION .............................................................................................................. 1-1

2.0 SAMPLING LOCATIONS AND FREQUENCY ................................................................ 2-1

3.0 WATER QUALITY MONITORING PARAMETERS ......................................................... 3-1

4.0 SAMPLING PROCEDURES ............................................................................................ 4-1
4.1 Groundwater Sample Collection .......................................................................... 4-1
4.1.1 Well Inspection and Water Level Measurement .......................................... 4-1
4.1.2 Monitoring Wells Where a Bladder Pump is Used ...................................... 4-2
4.1.3 Monitoring Wells Where a Submersible Grundfos Pump is Used ............... 4-2
4.1.4 Monitoring Wells Where a Bailer is Used for Sample Collection ................. 4-3
4.2 Surface Water and Underdrain Sampling Procedure ........................................... 4-3
4.3 Leachate Sampling Procedure ............................................................................. 4-4
4.4 Sample Volume, Preservation, and Holding Times .............................................. 4-4
4.5 Field Instrumentation Calibration ......................................................................... 4-5

5.0 EQUIPMENT DECONTAMINATION ............................................................................... 5-1
5.1 Field Instrumentation Decontamination ................................................................ 5-1
5.2 Bladder Pump and Grundfos Pump Decontamination ......................................... 5-1
5.3 Teflon Bailer Decontamination ............................................................................. 5-2

6.0 SAMPLE CUSTODY ........................................................................................................ 6-1
6.1 Sample Monitoring Forms .................................................................................... 6-2
6.1.1 Chain-of-Custody Record ............................................................................ 6-2
6.1.2 Sample Collection Forms ............................................................................ 6-2
6.1.3 Instrument Calibration Form ........................................................................ 6-2
6.2 Packing and Shipping .......................................................................................... 6-3
6.2.1 Packing ........................................................................................................ 6-3
6.2.2 Shipping ...................................................................................................... 6-3

7.0 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) ............................................... 7-1

8.0 REPORTING .................................................................................................................... 8-1

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LIST OF APPENDICES

APPENDIX A STANDARD RECORDKEEPING FORMS AND CHAIN OF CUSTODY
FORM
APPENDIX B MONITORING WELL INSTALLATION DIAGRAMS
APPENDIX C POTENTIOMETRIC MAP

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LIST OF FIGURES

Figure No. Title Page No.

1-1 SITE LOCATION MAP ...................................................................................................... 1-2
2-1 WATER QUALITY MONITORING LOCATIONS ............................................................... 2-2

LIST OF TABLES

Table No. Title Page No.

2-1 ENVIRONMENTAL MONITORING LOCATIONS ............................................................. 2-1
3-1 ANALYTICAL PROGRAM ................................................................................................ 3-2

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1.0 INTRODUCTION

This Environmental Monitoring Plan (EMP) summarizes the sampling procedures and analytical
methods to be used for groundwater, surface water, underdrain, and leachate monitoring at the
Blue Ridge paper Products Inc.’s (BRPP) Landfill No. 6 site in Canton, North Carolina (See
Figure 1-1). The procedures, protocols, methods, and monitoring locations in this EMP shall not
be changed or altered without approval from the North Carolina Department of Environment and
Natural Resources (NCDENR).

The purpose of the EMP is to detect any potential impacts of the landfill on the groundwater and
surface water in the vicinity of the site. The monitoring wells have been located based on the
groundwater flow directions determined from previous hydrogeologic studies at the site. A
potentiometric map of the groundwater surface is provided in Appendix C.
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2.0 SAMPLING LOCATIONS AND FREQUENCY

Samples will be collected from twenty-one (21) groundwater locations, six (6) surface water
locations, one (1) underdrain location, and one (1) leachate location on a semi-annual basis in
March and November. The groundwater, surface water, underdrain, and leachate locations are
listed in Table 2-1 and shown on Figure 2-1.

TABLE 2-1

ENVIRONMENTAL MONITORING LOCATIONS
LANDFILL NO. 6
BLUE RIDGE PAPER INC., CANTON, NORTH CAROLINA
GROUNDWATER LOCATIONS
MW-1A MW-8 MW-16S
MW-2 MW-9 MW-16D
MW-3A MW-10 MW-17
MW-4 MW-11 MW-18
MW-5A MW-12 MW-20
MW-6 MW-13 MW-21
MW-7A MW-14
MW-15

SURFACE WATER LOCATIONS
BB-UP (Bowen Branch Upstream)
BB-DOWN (Bowen Branch Downstream)
BB-3
BB-4
PR-UP
PR-DOWN
UNDERDRAIN LOCATION
Bowen Branch Underdrain Discharge Point

LEACHATE LOCATION
Leachate Collection Point in Area G

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3.0 WATER QUALITY MONITORING PARAMETERS

The field and laboratory monitoring parameters, analytical methods, and reportable detection
limits (RDLs) for the groundwater, surface water, underdrain, and leachate monitoring are
shown in Table 3-1.
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TABLE 3-1 ANALYTICAL PROGRAM LANDFILL NO. 6 BLUE RIDGE PAPER INC., CANTON, NORTH CAROLINA
Water Quality
Parameter Units
Analytical
Method RDLs1
Specific Conductance at 25C (Field) mhos/cm SM 2510B 10
Temperature (Field) degrees C SM 2550B 0.1
pH (Field) pH units SM 4500 HB 0.1
Turbidity (Field) NTU Field Screen 1.0
Nitrate-Nitrite as N mg/l SM 4500 NO3H 0.20
Nitrite as N mg/l SM 4500 NO2B 0.01
Total Dissolved Solids mg/l SM 2540C 25
Total Organic Carbon mg/l SM 5310C 0.5
Total Recoverable Phenols mg/l EPA 420.1 0.005
Chloride mg/l EPA 300.0 1.0
Fluoride mg/l EPA 300.0 0.1
Sulfate mg/l EPA 300.0 1.0
Arsenic ICPMS mg/l EPA 200.8 0.005
Barium mg/l EPA 200.7 0.01
Cadmium ICPMS mg/l EPA 200.8 0.001
Calcium mg/l EPA 200.7 0.01
Chromium ICPMS mg/l EPA 200.8 0.002
Copper ICPMS mg/l EPA 200.8 0.005
Iron mg/l EPA 200.7 0.05
Lead ICPMS mg/l EPA 200.8 0.005
Magnesium mg/l EPA 200.7 0.01
Manganese ICPMS mg/l EPA 200.8 0.005
Mercury mg/l EPA 245.1 0.0002
Nickel ICPMS mg/l EPA 200.8 0.005
Potassium mg/l EPA 200.7 0.5
Selenium ICPMS mg/l EPA 200.8 0.005
Silver ICPMS mg/l EPA 200.8 0.002
Sodium mg/l EPA 200.7 0.05
Zinc mg/l EPA 200.7 0.02
TOX mg/l SW 846 9020B 0.03
BOD2 mg/l SM 5210B 2.0
COD2 mg/l EPA 410.4 20
Total Phosphorous3 mg/l SM 4500 PE 0.02

Notes:
1. RDL = Reportable Detection Limits
2. BOD and COD are done on the leachate and underdrain samples only.
3. Total phosphorous as Phosphate is done on leachate only.

Method Reference: The analytical methods selected are presented in Test Methods for Evaluating Solid Waste,
OSWER, SW-846, Third Edition, as revised; Methods for Chemical analysis of Water and Wastes, EMSL, EPA-
600/4-79-020, revised March 1983; and Standard Methods for the Examination of Water and Wastewater, APHA,
19th Edition, 1995. Equivalent and appropriate analytical methods may be substituted with Juniper Ridge Landfill
approval, e.g., manual for automated and vice versa.

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4.0 SAMPLING PROCEDURES

The following sections describe the procedures to be followed for collecting groundwater,
surface water, underdrain, and leachate samples at the BRPP site. Sample recordkeeping
forms and chain-of-custody forms to be completed for each water quality monitoring location are
presented in Appendix A. Monitoring well installation diagrams for the BRPP monitoring wells
are presented in Appendix B.

4.1 Groundwater Sample Collection

There is typically one of three possible purging and sampling procedures followed for collection
of samples from the monitoring well locations at the BRPP site. The specific sampling methods
are shown in Subsection 4.1.2, 4.1.3, and 4.1.4.

4.1.1 Well Inspection and Water Level Measurement. Upon arrival at each groundwater
sampling location, the sampling personnel will observe the physical condition of the monitoring
well(s). The inspection will include observation of the condition of the ground surface seal and
the well guard pipe to evaluate if any evidence of frost heaving, cracks, or vandalism are
present. The condition of the monitoring well will be recorded on the field data records.
Periodically, the area around the well may have to be cleared of weeds, brush, or other
materials prior to beginning the water sampling activity.

Following inspection of the sampling location, the water level will be measured. The water level
in the well casing will be determined by lowering a clean electronic sounding probe into the well
until contact with the water surface is made. The distance from the monitoring well reference
elevation to the water surface contact will be entered into the field records. Water levels in the
monitoring wells will be measured to the nearest 0.01 foot. In all cases, the depth to water will
be referenced to the top of the PVC well casing (permanently marked measurement reference
point). In instances where water is flowing from the well casing, the water level will be noted as
such. Upon removing the water level probe, it will be decontaminated as described in
Section 5.0.

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4.1.2 Monitoring Wells Where a Bladder Pump is Used. A submersible bladder pump is used
to purge and sample monitoring well locations listed below. The bladder pump is adjusted to
remove water from the monitoring well at a rate of approximately 200 millimeters per minute.
Field measurements for pH, conductivity, temperature, and turbidity are monitored at five-minute
or more intervals until three consecutive field readings are within the field parameter
stabilization listed below for approximately 30 minutes prior to sample collection. The use of a
bladder pump is applicable at the following wells:

MW-13 MW-16S
MW-14 MW-18
MW-15 MW-21
MW-16D

Field parameter stabilization criteria:
pH + 0.1 standard pH unit with respect to previous pH measurement.
Specific conductance + 10% of previous measurement.
Turbidity + 10% or <10 NTU of previous measurement.
Temperature + 1C of previous measurement.

4.1.3 Monitoring Wells Where a Submersible Grundfos Pump is Used. A submersible Grundfos
pump is used to purge and sample the monitoring well locations listed below. The Grundfos
pump is adjusted to remove water from the monitoring well at a flow rate of between 1.0 and 1.5
gpm. Field measurements for pH, conductivity, temperature, and turbidity are taken every six to
ten minutes until three or more well volumes are removed and the field parameters stabilize as
discussed in Section 4.1.2. A sample is collected after completing the above purging process.
If the water column is drawn down to the pump head, the pump will be turned off and a sample
of the recharge water will be collected. The use of a Grundfos pump is applicable at the
following locations:

MW-10
MW-17
MW-20

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4.1.4 Monitoring Wells Where a Bailer is Used for Sample Collection. A Teflon bailer is used to
purge and sample the monitoring locations listed below. In the case where the well has
sufficient recharge, three well volumes of water will be removed from the well prior to sample
collection. In the case where the recharge is insufficient and the well water is drawn down
significantly, the well will be purged close to dry and a sample of the recharge will be collected.
In the case where the monitoring well produces three volumes of water, periodic field
measurements of pH, conductivity, temperature, and turbidity will be monitored, and purging will
continue until these parameters have stabilized as discussed in Section 4.1.2. The following
wells will be sampled using a bailer:

MW-1A MW-7A
MW-2 MW-8
MW-3A MW-9
MW-4 MW-11
MW-5A MW-12
MW-6

4.2 Surface Water and Underdrain Sampling Procedure

Surface water samples from the six surface water locations as well as the one underdrain
location listed in Table 2-1 will be collected in the following manner:

1. Collect the sample by immersing the sample bottle or sampling device not more
than 1 foot below the water surface. If a stream is being sampled, the sample
point will be upstream of the sampler with the opening of the sample bottle or
sampling device oriented upstream, but avoiding floating debris. If a culvert is
being sampled, the sample bottle or sampling device will be placed where the
water flows out of the bottom of the culvert.

2. Directly fill the appropriate sample containers from the sampling device if
needed.

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3. If possible, measure the following parameters in the water body:

 temperature
 pH
 specific conductance
 turbidity

If direct measurement is not possible, these parameters will be measured from
water remaining in the sampling device or a separate plastic bottle. This
information will be recorded in the sample data record, sample labels will be
completed, and the chain-of-custody (COC) procedures will be initiated.

4. Complete the Surface Water or Underdrain Sample Data Record (see
Appendix A).

4.3 Leachate Sampling Procedure

Leachate samples will be collected from the leachate manhole by either using a Teflon bailer or
a glass beaker attached to a pole. After filling sample bottles, pH, conductivity, temperature,
and turbidity readings will be taken.

The information will be recorded on a Leachate Sample Data Record (see Appendix A), sample
labels will be completed, and the COC procedures will be initiated.

4.4 Sample Volume, Preservation, and Holding Times

Obtaining required sample volumes, adhering to specified sample preservation procedures and
complying with allowable sample holding times are necessary to produce analytical testing
results which will be representative of the site water quality conditions. In preparing for each
sampling event, the sampling personnel will prepare schedules which will permit adequate
laboratory notification and sample delivery to allow testing within the allowable holding times.
Preservation of collected samples is accomplished by refrigerating samples at 4 degrees
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Celsius (C) and in some cases by acidification. Physical preservation of the samples will be
accomplished by storing the filled sample bottles in covered insulated coolers constructed of
impact resistant plastic. Efforts will be made to pack the coolers such that the sample bottles
are not subject to movement or breakage.

4.5 Field Instrumentation Calibration

Sampling quality control will include the daily calibration of field equipment used to measure pH,
turbidity, and specific conductance.

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5.0 EQUIPMENT DECONTAMINATION

Decontamination of the sampling equipment and instrumentation is required prior to initiation of
sampling and between each sample location to minimize the potential for cross contamination
between samples. Clean nitrile or PVC gloves will be worn to reduce contamination potential
when performing the decontamination activities, when handling decontaminated sampling
equipment, as well as prior to and during all sampling.

5.1 Field Instrumentation Decontamination

Field instrumentation, i.e., pH, specific conductance, turbidity, and temperature probes and
meters will, under no circumstances, be introduced into a sampling device or sample bottle. To
minimize latent influences between sampling locations, the probes and meters will be rinsed
with distilled water and, when appropriate, wiped dry with clean paper towels. The electronic
water level probe will be introduced into monitoring well(s) prior to the purging process. Upon
extraction from a monitoring well, the probe and associated electric lead wire(s) will be cleaned
with consecutive rinses of distilled water.

5.2 Bladder Pump and Grundfos Pump Decontamination

The Grundfos pumps and bladder pumps used for well purging and sampling, along with the
tubing attached to them, will be decontaminated as follows. The bladder pump is cleaned with a
solution of soapy water, deionized (DI) water rinse, rinsed with alcohol, and followed by a DI
water rinse. Each bladder as well as the pump seals and tubing are replaced between wells.
The outside of the Grundfos pump is cleaned in the same manner as the bladder pump.
Several gallons of DI water is pumped through the Grundfos pump and all tubing is replaced
between samples.

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5.3 Teflon Bailer Decontamination

Each Teflon bailer used to purge and sample at monitoring well locations will be cleaned in the
Rogers and Callcott Laboratory with a soapy hot water scrub, hot water rinse, alcohol rinse, and
DI water rinse. Each bailer will be wrapped with tin foil after decontamination and prior to use.

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6.0 SAMPLE CUSTODY

Chain-of-custody (COC) procedures will be followed during sample collection and handling
activities during both the field and laboratory operations. The COC procedures assure that
each sample is accounted for at all times. To maintain the highest degree of control in sample
handling, preprinted labels will be utilized so that all necessary information is retained with the
sample. COC records will be used to maintain control over sample access during and after
shipment from the sampling location. Additionally, proper completion of field sample logs,
accession books, tracking sheets, and extraction logs by appropriate field and laboratory
personnel will provide for thorough tracking of the samples from collection through analysis and
final reporting.

The objectives of sample identification, custody, and tracking procedures are as follows:

 All samples collected for analysis are uniquely labeled for identification purposes
throughout the analytical process.

 Samples are correctly analyzed and results are traceable to field records.

 Important sample characteristics are preserved.

 Samples are protected from loss, damage, or tampering.

 Any alteration of samples (e.g. preservation or damage due to shipment or other
processes) is documented.

 A record of sample integrity and analytical fate is established.

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6.1 Sample Monitoring Forms

The use of standard forms accomplishes one or more of the specific objectives of sample
identification, custody, and tracking. Standard forms used by the samplers for water quality
monitoring are provided in Appendix A and are discussed below. See attached COC form, field
sampling log, and calibration form.

6.1.1 Chain-of-Custody Record. The COC Record is initiated in the field by the individual
physically in charge of sample collection. The COC must be completed prior to the shipment of
samples to the laboratory. The COC contains information specific to the sample location, date
and time of sample collection, the sampler, the project name and number, laboratory project
number, the number of containers of each sample being shipped, an itemization of the analyses
requested for each sample and any remarks about the sample(s) prior to shipment. The
completed COC is signed by the sampler and enclosed with the samples. The COC is then
signed each time possession of the samples changes, with the signatures of the persons
relinquishing and receiving the samples, as well as the time and date of the sample exchange
being indicated on the COC Record.

6.1.2 Sample Collection Forms. The Monitoring Well, Surface Water, Underdrain, and
Leachate Sampling Forms will be completed in the field by the individual placed in charge of
sample collection. This form correlates the assigned sample bottle designation to a specific
well. The forms also list pertinent sampling information that must be recorded at the time of
sample collection (i.e., date and time of sampling and field parameter test results).

6.1.3 Instrument Calibration Form. Field instrument calibration procedures will be recorded on
the Instrument Calibration Form on a daily basis.

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6.2 Packing and Shipping

Samples will be packed and shipped so as to maintain the sample container integrity as well as
to provide for the health and safety of the sample transporter.

6.2.1 Packing. Sample containers are generally packed in picnic coolers for shipment. Bottles
are to be packed tightly so that no motion is possible. Styrofoam, vermiculite, and bubble-pack
are suitable as bottle packing material for most instances. (High-hazard samples may require
different packing.) Ice is placed in double Ziploc™ bags and added to the coolers in order to
maintain the required 4C preservation requirement. All necessary paperwork will be placed in
a separate Ziploc™ bag and also placed in the cooler. The cooler top will then be closed and
taped shut. Custody sealing and taping of coolers may be required for certain
samples/occasions.

6.2.2 Shipping. The standard procedure followed for shipping environmental samples to the
analytical laboratory is:

1. For projects where the laboratory can be practically accessed:

 Deliver all samples directly to the laboratory.

2. For projects where the laboratory is not practically accessed:

. All shipping of environmental samples must be done through Federal
Express or an equivalent overnight delivery service.

. If prompt shipping and laboratory receipt of the samples cannot be
guaranteed (i.e. Sunday and holidays), the samplers will be responsible
for proper storage of the samples until suitable transportation
arrangements can be made.
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7.0 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)

Quality assurance/quality control (QA/QC) is an integral part of this EMP to provide for
assessment of the adequacy of the analytical results and their intended use. QA/QC activities
associated with sampling include utilization of standardized collection procedures and sample
data records, calibration of field instruments, and adherence to COC procedures. Analytical
QA/QC involves the use of approved analytical protocols by qualified laboratories. Assessment
of analytical data quality is performed through review of method-specified quality control data, to
be reported along with the analytical results. To ascertain that the QA/QC objectives are met,
the following data validation methods will be used to verify the accuracy and precision of the
reported results.

 Chain of Custody for each sample is continuous and included with report.

 Verification that all sample holding times were met.

 Identification of values falling outside of historical (>5 sample rounds) range.

 Identification of wells whose depths have changed since construction.

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8.0 REPORTING

The BRPP program will include semi-annual and annual reporting to the NCDENR in
accordance with current waste management regulations.

APPENDIX A

STANDARD RECORDKEEPING FORMS AND
CHAIN OF CUSTODY FORM

APPENDIX B

MONITORING WELL INSTALLATION DIAGRAMS

APPENDIX D

FIRE OCCURRENCE NOTIFICATION FORM

SOLID WASTE MANAGEMENT FACILITY
FIRE OCCURRENCE NOTIFICATION
NCDEQ Division of Waste Management
Solid Waste Section
Notify the Section verbally within 24 hours and submit written notification within 15 days of the occurrence.
(If additional space is needed, use back of this form.)
NAME OF FACILITY:PERMIT #
DATE AND TIME OF FIRE:@
HOW WAS THE FIRE REPORTED AND BY WHOM:
LIST ACTIONS TAKEN:
WHAT WAS THE CAUSE OF THE FIRE:
DESCRIBE AREA, TYPE, AND AMOUNT OF WASTE INVOLVED:
WHAT COULD HAVE BEEN DONE TO PREVENT THIS FIRE:
DESCRIBE PLAN OF ACTIONS TO PREVENT FUTURE INCIDENTS:
NAME:TITLE:DATE:
***********************************************************************************************************
THIS SECTION TO BE COMPLETED BY SOLID WASTE SECTION REGIONAL STAFF
DATE RECEIVED _________________________________
List any factors not listed that might have contributed to the fire or that might prevent occurrence of future fires:
___________________________________________________________________________________________________________
FOLLOW-UP REQUIRED:
NO PHONE CALL SUBMITTAL MEETING RETURN VISIT BY:____________________ (DATE)
ACTIONS TAKEN OR REQUIRED:
Revised 6/15/2016

APPENDIX E

ASTM D6270-08, STANDARD PRACTICE FOR USE OF SCRAP TIRES
IN CIVIL ENGINEERING APPLICATIONS

APPENDIX F

GAS MONITORING PLAN

LANDFILL GAS MONITORING PLAN
LANDFILL NO. 6
CANTON, NORTH CAROLINA

Prepared for

BLUE RIDGE PAPER PRODUCTS INC. –
CANTON MILL

DIVISION OF EVERGREEN PACKAGING

CANTON, NORTH CAROLINA

November 2013
(Revised December 2014)
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TABLE OF CONTENTS

Section No. Title Page No.

1.0 INTRODUCTION ............................................................................................................. 1-1 
1.1 Landfill Gas Characteristics ................................................................................. 1-1 

2.0 LANDFILL GAS MONITORING LOCATIONS AND FREQUENCY ................................ 2-1 

3.0 SAMPLING PROCEDURES ............................................................................................ 3-1 
3.1 Landfill Gas Measurement Procedure ................................................................. 3-1 

4.0 LANDFILL GAS SAFETY PROCEDURES ..................................................................... 4-1 

5.0 EQUIPMENT SPECIFICATIONS AND QUALITY CONTROL ........................................ 5-1 

6.0 REPORTING.................................................................................................................... 6-1 

7.0 PROFESSIONAL CERTIFICATION ................................................................................ 7-1 

LIST OF APPENDICES

APPENDIX A LANDFILL GAS MONITORING DATA FORMS
APPENDIX B GAS PROBE WELLS
APPENDIX C POTENTIOMETRIC SURFACE PLAN

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LIST OF FIGURES

Figure No. Title Page No.

1 SITE LOCATION MAP ......................................................................................................... 1-2 
2 GAS MONITORING LOCATIONS ....................................................................................... 2-2 

LIST OF TABLES

Table No. Title Page No.

1-1 TYPICAL COMPONENTS OF LANDFILL GAS ................................................................ 1-1 
2-1 LANDFILL GAS MONITORING LOCATIONS .................................................................. 2-1 

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1.0 INTRODUCTION

This Landfill Gas Monitoring Plan (LFGMP) summarizes the landfill gas (LFG) procedures used
for monitoring at the Blue Ridge Paper Products Inc.’s (BRPP) Landfill No. 6 site in Canton,
North Carolina (See Figure 1). Also included in this LFGMP is a discussion of the
characteristics of LFG and general safety considerations associated with LFG monitoring. The
procedures, protocols, methods, and monitoring locations in this LFGMP shall not be changed
or altered without approval from the North Carolina Department of Environment and Natural
Resources (NCDENR).

1.1 Landfill Gas Characteristics

Landfill gas (LFG) is a mixture of several gases that are produced through anaerobic (oxygen
less) decomposition of organic wastes. Typically, LFG is composed of mainly methane and
carbon dioxide with smaller amounts of nitrogen and water vapor. LFG is also composed of
trace amounts of hydrogen sulfide, other sulfur compounds, and volatile organic compounds
(VOCs). Typical components of LFG are shown below in Table 1-1.

TABLE 1-1

TYPICAL COMPONENTS OF LANDFILL GAS

Component Percent
(dry volume basis except moisture)
Methane 45 –60
Carbon Dioxide 40 –60
Nitrogen 2 –5
Oxygen 0.1 –1
Hydrogen sulfides, disulfides and other
sulfur compounds 0 – 1
Ammonia 0.1 –1
Hydrogen 0 –0.2
Carbon Monoxide 0 –0.2
Moisture 2 –12
Volatile Organic Compounds (VOCs)0.01 –0.6

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General LFG characteristics which a field technician should be aware of include:

 LFG production undergoes changes over the life of the waste placed. Initially air
entrained in the waste stimulates aerobic decomposition and produces mainly
carbon dioxide. As the oxygen is depleted, large amounts of carbon dioxide are
produced with some hydrogen. During complete anaerobic conditions, methane
production begins and as the waste ages, the methane, carbon dioxide, and
nitrogen production becomes fairly steady.

 LFG is primarily composed of methane (typically 50%) and carbon dioxide
(typically 45%) both colorless and odorless gases. The odor associated with
LFG is due to the lesser and trace gases, such as hydrogen sulfide, that are part
of the LFG mixture.

 LFG is flammable and potentially explosive. Methane has a flammability range of
5 to 15 percent by volume in air. Five percent being the lower explosive limit
(LEL) and 15 percent being the upper explosive limit (UEL). Between these
limits, the LFG-air mixture is readily flammable. Just because LFG contains
methane above the UEL does not mean that somewhere away from the source
the conditions for flammability are not met.

 Methane and carbon dioxide have specific gravities of 0.55 and 1.52,
respectively. However, the mixture that comprises LFG has a specific gravity
closer to that of air (i.e., 1.0); it should not be assumed that LFG will rise.

 LFG can migrate within open conduits and through trench backfill or through the
vadose zone (unsaturated soil or bedrock above the water table). This migration
can allow it to accumulate to flammable or lethal levels in manholes, buildings
and other structures designed for human occupancy. This migration through the
vadose zone may also cause the LFG to separate into its component gases.
LFG migration below the landfill is limited by the presence of a geosynthetic liner
system. Landfill gas movement in unlined landfills may be influenced by
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groundwater variations. Estimated depths to the potentiometric surface are
shown in Table 2-1. A potentiometric surface plan is provided in Appendix C. .
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2.0 LANDFILL GAS MONITORING LOCATIONS AND FREQUENCY

During the operation of the facility, gas monitoring will be conducted quarterly at six gas probes
and the ambient air of the Landfill House and the Pump Station Motor Control Rooms (see
Figure 2). These gas monitoring locations are listed in Table 2-1. The gas monitoring locations
have been selected between the waste boundary and the landfill property boundary to monitor
the vadose zone for potential LFG intrusion. A typical gas probe diagram and logs of on-site
gas probes are provided in Appendix B.

TABLE 2-1

LANDFILL GAS MONITORING LOCATIONS

Location
Gas Probe
Installation Date
Gas Probe
Bottom Depth
(FBG)
Gas Probe
Screen
Interval
(ft)
Surface
Lithology
Depth to
Groundwater
(ft)
Estimated

GP-3

1/23-24/ 2013 8 3 to 8

Residuum 26
GP-4 1/23-24/ 2013 7 3 to 7 Residuum 36
GP-5 1/23-24/ 2013 8 3 to 8 Residuum 16
GP-6 1/23-24/ 2013 8 3 to 8 Residuum 12
GP-7 1/23-24/ 2013 8 3 to 8 Residuum 46
GP-8 1/23-24/ 2013 8 3 to 8 Residuum 28
P-1
(Landfill House
crawl space)
NA NA NA
P-2 (Landfill House septic line penetration)
NA NA NA
P-9
(Pump Station
Motor
Control Room
East)
NA NA NA
P-10
(Pump Station
Motor
Control Room
West)
NA NA NA

Abbreviations
FBG – feet below ground
NA – Not applicable

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3.0 SAMPLING PROCEDURES

The following section describes the procedures to be followed for collecting LFG measurements
at the BRPP site. LFG measurement recordkeeping forms to be completed for each monitoring
event are presented in Appendix A.

3.1 Landfill Gas Measurement Procedure

Upon arrival at each sampling location, the sampling personnel will observe the physical
condition of the gas probe. The inspection will include observation of the condition of the
ground surface seal and the probe guard pipe to evaluate if any evidence of frost heaving,
cracks, or vandalism are present. The condition of the gas probe will be recorded on the
recordkeeping form. Periodically, the area around the probe may have to be cleared of weeds,
brush, or other materials prior to beginning the water sampling activity.

Following inspection of the sampling location, a background set of gas readings will be
measured and recorded on the recordkeeping form. The gas probe casing will then be
unlocked. The inlet tubing from each meter is attached to the valve on top of the gas probe and
the gas readings are recorded. Each meter is detached from the probe and allowed to continue
operating at a distance away from the gas probe head until background levels are obtained prior
to moving to the next monitoring location.

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4.0 LANDFILL GAS SAFETY PROCEDURES

If landfill gases are detected above 100 percent of the LEL at the property line monitoring
locations or exceed 25 percent of the LEL at the Landfill House or Motor Control Rooms, the
EHS Department will notify NCDENR.

In the event the gas levels rise to the point where there is a hazard to health, safety, or property,
the following steps shall be taken:

 Evacuate all personnel immediately to a safe distance upwind from the landfill;
 Ventilate any structures;
 Notify NCDENR;
 Investigate to determine the source of the gas release; and
 Remediate the problem.

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5.0 EQUIPMENT SPECIFICATIONS AND QUALITY CONTROL

The equipment to monitor the gas concentrations include:

 CES-Lantec GEM 2000 Landfill Gas Monitor or equivalent.

The meter will be calibrated daily and operated according to the equipment manufacturer’s
specifications. Calibration results will be recorded on the instrument calibration log contained in
Appendix A

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6.0 REPORTING

Upon completion of each quarterly monitoring event, a copy of the Landfill Gas Monitoring forms
will be maintained on file with the EHS Department. However, the LFG readings will be
reported to NCDENR if the gas readings:

 Exceed 100 percent of the LEL at the property line; or
 Are above 25 percent of the LEL in any of the enclosed spaces or buildings.

Submittal of the data requires that the first page of the submittal be a standalone completed pdf
of the NC DENR Division of Waste Management-Solid Waste Environmental Monitoring
Reporting form. A copy of the form is provided in Appendix A.

APPENDIX A

LANDFILL GAS MONITORING DATA FORMS

APPENDIX B

GAS PROBE WELLS

APPENDIX C

POTENTIOMETRIC SURFACE PLAN

APPENDIX G

LANDFILL TRAINING PROGRAM OUTLINE

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EVERGREEN PACKAGING LANDFILL FACILITY
OPERATOR TRAINING PROGRAM OUTLINE

SECTION 1 – PROGRAM INTRODUCTION

1.1 Training Course Description and Introduction

A. Training Program Goal
B. Distribution of Course Materials
C. Introduction of Training Staff
D. Description of Course Format
E. Schedule Review

1.2 North Carolina Certification Rules

A. Intent of the Certification Rules
B. Certification Rule Requirements

1.3 Types and Characteristics of Solid Waste

A. Definition of Hazardous and Non-Hazardous Solid Waste Materials
B. Industrial Solid Waste
1. Production (Mill) Waste
2. Industrial Wastewater Treatment Sludge
C. Waste Not Approved for Landfilling

1.4 Environmental Concerns and Regulations

A. Public Concern about Environmental Impact
B. Historic Landfill Issues
C. Solid Waste Landfill Environmental Impacts
1. Groundwater Quality Impact
a. Groundwater Pollutants
2. Air Emissions Impact
3. Surface Water Impact
4. Other Local Site Impacts
a. Odor
b. Dust

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SECTION 2 – LANDFILL DESIGN

2.1 Leachate Collection and Management

A. Leachate Generation
B. Leachate Characteristics
C. Leachate Collection System Design Criteria
1. Types and Purpose
2. Drainage Materials
3. Filtration Materials
4. Design by Function Concept
D. Leachate Collection System Design
1. Granular Stone Drainage
2. Perforated Collector Pipe
E. Leachate Disposal

2.2 Landfill Gas Collection and Management

A. Solid Waste Landfill Gas Generation
1. Biological Decomposition of Wastes
a. Biological Processes
2. Landfill Gas Characteristics
a. Properties of Major Constituents
i. Methane
ii. Carbon Dioxide
iii. Hydrogen Sulfide
iv. Safety Procedures
B. Solid Waste Landfill Gas Collection
1. Passive Collection Systems: Design Considerations
a. Perimeter Systems
b. Interior Systems
2. Gas Monitoring

2.3 Capping and Closure Design

A. Purpose of Landfill Capping
B. Intermediate and Final Cover
C. Cap Design and Construction

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SECTION 3 – LANDFILL OPERATIONS

3.1 Operations Plan – Development and Use

A. Operations Plan Design
B. Typical Operations Plan Components
1. Staffing and Job Descriptions
2. Equipment Operations and Maintenance
3. Definition and Monitoring of Acceptable Waste
4. Operating Procedures
5. Contingency Procedures
6. Monitoring/Reporting Requirements
7. Health and Safety Procedures
C. Operations Plan Modification

3.2 Waste Receipt and Traffic Control

A. Delivery Vehicle Site Access
B. Waste Volumes and Types
1. Records and Recordkeeping
C. Workface Access

3.3 Workface Operations

A. Waste Delivery Coordination
B. Off-load Inspection
C. Adverse Conditions Operations

3.4 Waste Compaction

A. Reasons for Compaction
1. Effective Use of Air Space
2. Surface Control
B. Types of Compaction Equipment
C. Monitoring of Compaction Results

3.6 Surface Water Control

A. Requirements
1. Control run-on and run-off
B. Purpose of Surface Water Control
1. Prevent discharge of pollutants from the landfill into water or wetlands
2. Prevent water from running onto the landfill
a. Erosion problems
b. Infiltration into the wastes and creation of additional leachate
C. Methods of Control
1. Perimeter ditches
2. Berms on landfill surface
3. Siltation fences, hay bales, etc.
4. Sedimentation basins
5. Mulch, jute matting

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3.7 Site Security

A. Operating Schedules
B. Traffic and Access Control
1. Natural barriers
2. Installed barriers
C. Procedures for Controlling Unauthorized Dumping

3.8 Enforcement

A. Environmental Regulations
1. Spills and releases
B. Site Rules and Regulations

3.9 Complying with Design Requirements

A. Types of Landfill Plans
1. Site Plans
2. Contour Maps
a. Preconstruction grading
b. Construction grading
c. Final grading
3. Cross-section
a. Landfill
b. Construction
4. Phasing Plans
B. Surveys
1. Measurement of Field Slopes
2. Measurements of Elevations
3. Location Surveys
C. Capacity Use Monitoring
1. Capacity Survey
2. Calculation of Areas and Volumes
D. Regular Inspections

3.10 Waste Identification and Restriction

A. Definition of Acceptable and Unacceptable Solid Waste
B. Detection and Prevention of Unacceptable Wastes
C. Purpose of Waste Identification and Restriction
1. Protection of Human Health and the Environment
a. Operator and waste hauler safety
b. Compatibility with other wastes and materials of construction
c. Leachate treatability and disposal
d. Groundwater protection
2. Operator Risk Reduction
a. Explosions
b. Health risk associated with exposure to chemicals
3. Prevention of Illegal Dumping
a. Increased risk of detection of illegal dumpers
b. Penalty to non-conforming haulers
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D. Procedures for Inspection and Restriction
1. Waste Receipt Training
a. Recognition and identification of excluded wastes
b. Safe handling of unacceptable materials (hazardous wastes and
PCBs)
c. Health and safety procedures (OSHA)
2. Source Controls
3. Potential Wastes that Require Inspection
a. Wastes in drums or other container not normally used for disposal
b. Wastes in containers with DOT or other descriptive labels
c. Sludges and materials with liquid content
4. Notification of Proper Authorities (if hazardous wastes delivered to site)
a. Environmental Health and Safety Department
b. Waste received and source
c. Steps taken to remove and dispose of wastes
E. Management of Unacceptable Wastes
1. Waste in Possession of Hauler
a. Hauler retains materials (proof is on hauler to show that waste
meets disposal criteria in landfill
2. Waste in Possession of Landfill
a. Waste is responsibility of landfill operator and must be managed
according to regulations
b. Screen, store, and/or test waste as appropriate
c. Treat, store, or dispose of in accordance with RCRA and
applicable state regulations

3.11 Waste Handling

A. Incinerator Ash
1. Placement in Landfill
a. Blowing
b. Compaction
c. Waste lift heights
B. Paper Mill Sludge
1. Placement in Landfill
a. Water content
b. Compaction
c. Waste lift heights
C. Lime Mud
1. Placement in Landfill
a. Water content
b. Compaction
c. Waste lift heights
D. Mixing of Waste
1. Stability considerations

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SECTION 4 – LANDFILL MAINTENANCE

4.1 Maintenance Program Design

A. Types of Maintenance
1. Reactive Maintenance
2. Preventative Maintenance
B. Philosophy of Preventative Maintenance
C. Elements of a Preventative Maintenance Program
1. Monitoring and Inspections
2. Fixed and Variable Period Maintenance
3. Major Preventative Maintenance Tasks and Overhaul
D. General Site Maintenance
1. Erosion Control
2. Drainage Control
E. Leachate Management System Maintenance Program
F. Gas Management System Maintenance Program

4.2 Groundwater Monitoring and Control

A. Monitoring Requirements and Regulations

4.3 Leachate Collection System Maintenance

A. Maintenance and Repair of Structural Systems
1. Manholes
2. Annual Cleaning of Collection Headers
3. Sumps
B. Maintenance and Repair of Mechanical Systems
1. Pumps
2. Sensors

4.4 Surface Water Control

A. Erosion Control
B. Repair of Drainage Swales and Waterways
C. Cleaning and Dredging of Retention and Sedimentation Basins

4.5 Spills and Release Controls

A. Contingency Planning
B. Solid Waste Spills
C. Liquid Spills
D. Reporting Requirements

4.6 Capping and Vegetation

A. Interim and Final Cover Installation
B. Temporary and Permanent Vegetation
1. Installation
2. Maintenance

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4.7 Closure and Post-Closure Care

A. Minimum Final Cover
B. Written Closure Plan
C. Closure Implementation
D. Post-closure Care
1. Post-closure Care Requirements
a. Required post-closure care
b. Post-closure monitor
c. Key monitoring parameters
d. Elements in monitoring program
2. Groundwater Monitoring
3. Leachate Generation
4. Gas Concentration
5. Subsidence Monitoring
a. Measurement
b. Allowable
6. Surface Erosion
7. Air Quality

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SECTION 5 – MONITORING AND REPORTING

5.1 Reporting Requirements

A. Management Requirements
1. Operational
B. Environmental/Permit Requirements
1. Permit Conditions

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SECTION 6 – HEALTH AND SAFETY

6.1 Contingency Planning

A. Environmental
1. Accidental Spills or Releases
2. Leaks and Leak Detection
B. Health and Safety
1. Accidents or Illnesses
C. Operational
1. Fire
2. Equipment or Truck Breakdown
3. Hot Loads

6.2 Health and Safety

A. General Safety Requirements
1. General Safety Rules and Regulations
a. Restrict public access to site and dumping areas
b. Prevent illegal dumping
c. Control exposure of public and landfill operators to hazards
2. Access
a. Install fence or other barriers to control access to site
b. Signs and/or barriers to control public access to working face of
landfill
c. Traffic control
3. Gas Management
a. Monitoring of structures
b. Venting of areas in which gas could accumulate
c. Entry procedures to control access to manholes or other areas in
which gas could accumulate
B. Operator Safety
1. Personnel Protective Equipment
2. Identification of Hazardous Substances
3. Materials Handling Safety
4. Chemical and Hazardous Materials Exposures
5. Major Hazards of Operations Systems and Equipment
a. Noise
b. Mechanical hazards
c. Electrical hazards
6. Trenching Safety
7. Fire and Explosions from Landfill Gas
a. Gas monitoring devices

APPENDIX H

STORMWATER MANAGEMENT PLAN