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HomeMy WebLinkAbout2601_AnnStreetMSWLFPhase 3InterimClosure_DIN26023_20160422.pdf 5400 Glenwood Ave, Suite 400 Raleigh, North Carolina 27612 tel: 919 325-3500 fax: 919 781-5730 April 22, 2016 Mr. Ming-Tai Chao Environmental Engineer North Carolina Department of Environmental Quality Division of Waste Management – Solid Waste Section Raleigh Central Office 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Subject: Cumberland County, North Carolina Subtitle D Landfill – Phase III Interim Closure Modification Permit No. 2601-MSWLF-1997 Dear Mr. Chao: CDM Smith Inc. (CDM Smith), on behalf of Cumberland County (County), is requesting a modification of the Phase III interim closure grades in order to increase the gross airspace of Phase III. Phase III was originally permitted with side slopes of 4:1, but the slopes along the eastern side of the landfill have been filled at an average slope of 3.6:1. A cross-section comparing the permitted grade to the current conditions is provided in Attachment 1. A Civil 3D analysis estimates that approximately 100,000 cubic yards (CY) of additional material was placed along the eastern slope. This represents an increase of approximately 1.5% to the County’s currently permitted gross airspace of 6,582,400 CY. The slightly steeper eastern slope has created a wide plateau area (at elevation 200) that the County would like to fill in with waste to capture the available airspace. CDM Smith is requesting approval to increase the maximum Phase III closure elevation from 205 to 215 in order to capture the available airspace in addition to extending the existing eastern side at a slope of 3.5:1 from the current elevation of 200 to 210 as shown in Attachment 1. This proposed minor grading change will provide a more constant slope for construction of the final cover system. Once an elevation of 210 is reached the slope will transition back to 4:1 consistent with the landfill final cover system presented in the Phase IV Permit to Construct Application. The revised Phase III closure height of 215 is well below the maximum vertical permitted height of 255 and increases the gross airspace of Phases I-III by approximately 100,000 CY. A revised version of Table 1-4 from the Phase IV Permit to Construct Application is presented in Table 1 with a revised Section 1 of the Facility Plan provided in Attachment 2. Mr. Ming-Tai Chao April 22, 2016 Page 2 Table 1. Subtitle D Landfill Phase Capacity and Operational Life Phase Area (acres) Gross Airspace (cy) Total Usable Airspace (cy) Operating Life (years) Remaining I-III (Current) 42.0 4,157,653 4,089,891 2.4 IV (Future) 13.3 928,609 861,979 5.0 V (Future) 01 928,609 861,979 5.0 VI (Future) 01 667,529 600,899 1.8 Total 55.3 6,682,400 6,414,748 14.2 Notes: Gross Airspace – Volume of airspace from the top of the landfill base liner system through the top of the final cover system. Total Usable Airspace – Volume of airspace for MSW and daily cover and/or alternate daily cover material. Does not include intermediate or final cover material. 1 – Vertical expansion Please contact me at (919) 325-3532 should you have any questions or if there is anything I can do to help facilitate the approval of this permit modification. Sincerely, Aaron M. Weispfenning, P.E. CDM Smith Inc. cc: Jeffery Brown, Cumberland County Martin Sanford, CDM Smith Attachment 1 Revised Phase III Interim Closure Grades and Cross-Section Camp Dresser McKee & Smith CUMBERLAND COUNTY NORTH CAROLINA ANN STREET SUBTITLE D AND C&D LANDFILLS FIGURE 2016 SURVEY AND MODIFIED INTERMEDIATE CLOSURE 1-1 PLAN REPRESENTS PERMITTED CONTOURS RAISED TO EL. 215 AND 2016 SURVEY CONTOURS Attachment 2 Revised Section 1 of Facility Plan 1-1 Section 1 Facility Plan 1.1 Introduction The Ann Street (North Carolina Department of Environment and Natural Resources, Division of Waste Management Solid Waste Section (SWS) Permit # 26-01) site is located near the geographic center of Cumberland County (County) at the end of Ann Street and adjoins the Fayetteville city limits. The Subtitle D landfill and Construction and Demolition (C&D) Debris landfill is located within the property and permitted boundary of the Ann Street site. The Subtitle D landfill is located approximately 300 feet east and adjacent to the closed unlined Municipal Solid Waste (MSW) landfill. In addition to these landfill units, the Ann Street Landfill facility also has a white goods area, concrete debris stockpile area, oyster shell recycling area, furniture collection area, and recycling drop off area. The Ann Street site is immediately surrounded by other waste disposal and public works facilities. The Milan Yard Landfill, a possible Superfund site, is located to the north. The city of Fayetteville, Public Works Commission (PWC), Cross Creek Water Reclamation Facility is located to the south. The Ann Street Landfill was originally permitted and began operations in 1980. A transition plan for the Cumberland County Ann Street landfill was prepared in April 1994 in accordance with the North Carolina Solid Waste Management Rules (T15A: 13B.1600-.1680). As defined in the Transition plan, MSW disposal activities were confined to the western half of the site from 1980 through December 31, 1997. The transition plan was amended on November 14, 1997 to address Phase I operation of a C&D landfill above the Category 1 landfill closure area, adjacent to the closed vertical expansion, which was closed out in March 1999 in accordance with North Carolina Solid Waste Management Rules (T15A: 13B .1624). The 22.9-acre Phase I area (Cells 1-5) Permit to Operate was approved on December 29, 1997. On January 1, 1998 MSW was transitioned into the new Subtitle D landfill and C&D debris was placed over the Category 1 closure area. The Permit to Construct the 19.1-acrea Phase II area (Cells 6-8) was received on March 13, 2000 with the Permit to Operate issued on February 12, 2001. A permit renewal to continue operations within Phase II was issued on February 12, 2006. The Permit to Operate for Phase III (vertical expansion within existing Cells 1–8) was issued on June 15, 2012. The approved waste footprint of the entire MSW landfill (Phases I-VI) is 55.3 acres with the proposed Phase IV lateral expansion (13.3 acres) comprised of Cells 9 (6.3 acres) and 10 (7.0 acres). Proposed Phases V and VI are vertical expansions over Phases I–IV. 1.2 Waste Stream In accordance with the approved permit, the landfill accepts only residential, commercial and industrial waste generated within the County and its municipalities. MSW material generated within the County is disposed in the Subtitle D landfill. C&D debris generated within the County is disposed in the C&D landfill located above the closed unlined MSW landfill. Wood and yard waste is disposed at Section 1 • Facility Plan 1-2 the County’s Wilkes Road Yard Waste Facility, which is located within the City limits at 771 Wilkes Road. 1.2.1 Types of Waste The Ann Street Subtitle D Landfill and C&D Debris Landfill will continue to accept appropriate residential, commercial, and industrial waste generated by residents, businesses, and government facilities within the County and its municipalities. The Wilkes Road Yard Waste Facility will continue to handle wood and yard waste generated within the County and its municipalities. The County also operates a separate white goods area and pre-extraction area for items such as tires, metals, furniture, and carpeting at the Ann Street Site. C&D debris is currently disposed above the unlined MSW landfill. 1.2.2 Recent Waste Disposal Rates According to disposal records maintained by the County, the Subtitle D landfill received 117,970 tons in Fiscal Year (FY) 2014 and 140,371 tons in FY 2015. The C&D debris portion of the landfill received 31,596 tons in FY 2014 and 36,239 tons in FY 2015. 1.2.3 Population and Areas Served By Facility The County will continue to accept waste only from generators within the approximate 661 square mile County area. This includes Fort Bragg, a permanent Army Post, which occupies approximately 130,000 acres in the northern parts of the County and extends into Hoke County. Based on U.S. Census Bureau, the County’s population estimate for 2014 was approximately 326,328. The U.S. Census Bureau estimates the County’s population will increase by 8.2 percent from 2010 to 2020. 1.2.4 Waste Segregation Management Procedures The County’s Ann Street landfill staff places a high priority on proper management of incoming waste. The same level of concern and effort will continue to be put forth for future expansion areas. The waste segregation procedures begin at the scale house where wood and yard waste is diverted to the Wilkes Road Yard Waste Facility. C&D debris is directed to the C&D debris disposal area located over the closed unlined MSW landfill. The County also provides a separate white goods area on the landfill property and a pre-extraction area adjacent to the convenience center for tires, metals, carpeting, and furniture. The scalehouse serves as the central location for waste segregation. The scale house operator directs waste haulers to the appropriate waste disposal areas. A field operator is present at the working face area to direct waste haulers and to ensure that prohibited materials are not placed in the landfill. Landfill personnel who have the potential of being exposed to hazardous materials are required to be 40 hour OSHA certified in the identification of household hazardous waste and hazardous waste. The County also has implemented a waste screening program to identify and dispose of unauthorized wastes delivered to the landfill. 1.2.5 Franchise Requirements The Cumberland County Ann Street Landfill facility, which is owned and operated by the County, is located within the city limits of Fayetteville North Carolina. The franchise agreement between Cumberland County and the City of Fayetteville (City) will establish an agreement for the County to continue operating the Ann Street Landfill facility in accordance with the North Carolina Solid Waste Section 1 • Facility Plan 1-3 Management Rules. The landfill accepts for disposal both C&D, MSW, tires, and white goods material. The landfill facility also operates a recycling drop-off location for City and County residents. The City Solid Waste Management Department is responsible for collection and disposal of residential household waste within the City. The City also operates a curbside recycling program. By operating the Ann Street Landfill facility which provides waste disposal capacity and a recycling drop-off area, the County’s operations have been consistent with and supportive of the city’s solid waste management plan since operations began in 1980. The franchise agreement will ensure that the solid waste management partnership between the County and City will continue; thereby, ensuring the City will have access to efficient, cost-effective, and environmentally sound waste disposal capacity. 1.2.6 Governmental Oversight and Regulation of Fees and Rates The City of Fayetteville residents pay a $48 Solid Waste User Fee, through property owners’ tax bill, which pays for the disposal of household MSW at the Ann Street Landfill. The $48 user fee also allows City of Fayetteville residents to use the County's Wilkes Road landfill, container/recycling sites, and the Household Hazardous Waste Facility for disposal of household kitchen and bathroom trash, yard waste and hazardous material such as paint, pesticides, and used motor oil. Oversight and regulation of the user fee is set by the Cumberland County Board of Commissioners. Regarding C&D material disposal, the County has established a negotiated flat rate fee for any waste disposed of by the City of Fayetteville. There is no charge to City of Fayetteville residents for the use of the recycling drop-off location at the Ann Street Landfill. 1.2.7 Equipment Requirements Standard landfill equipment will continue to be used at the Cumberland County Ann Street Landfill facility. This may include, but not be limited to, equipment such as: Front-end loaders Trash Compactors Dozers Foam Sprayer for Alternative Cover Material Trackhoes Track Loaders Tanker Truck Wheel Loader Pick-up Trucks Dump Trucks 1.3 Landfill Capacity The remaining landfill disposal capacity for the Cumberland County Ann Street Landfill facility is based on the Airspace Utilization Factor (AUF), which is the weight (tons) of waste per volume (cubic yards) of airspace occupied by MSW or C&D and cover soil. The latest airspace topographic survey was prepared in June 2015; therefore, data from that survey was utilized in the following airspace calculations. Section 1 • Facility Plan 1-4 1.3.1 Consumed Airspace Volume Calculations 1.3.1.1 Subtitle D Landfill The gross capacity of the entire MSW landfill unit (Phases I–VI) is 6,682,400 cy and is the volume between the top of the landfill base liner system and the top of the final cover system. CDM Smith created two Digital Terrain Model (DTM) surfaces: the existing landfill surface and the base grades for Phases I-III. The existing landfill surface was created from a topographic survey performed by Joyner Keeny, PLLC on June 26, 2015. The base grade layer surface was created using design grades for Phases I-III. Using the TIN Subtraction Method in Civil 3D, the volume between the landfill base grade and existing landfill surface was calculated to be approximately 3,998,079 cubic yards (cy). To account for the 2- foot thick clay liner and 2-foot thick sand drainage layer over the existing 42.0 acre landfill footprint the calculated volume was reduced by 271,040 cy. The resulting volume is 3,727,039 cy and represents the airspace used during the period from January 1, 1998 to April 1, 2015. Subtracting the June 17, 2014 and the June 26, 2015 surfaces results in approximately 161,508 cy of airspace used over the 12-month period. The 2015 total (3,727,039 cy) minus the 2014 total (3,566,162) is 160,877 cy and differs by 0.4% from the yearly surface result of 161,508 cy. The calculations are used to check one another. The total remaining gross airspace for Phases I-III is approximately 613,150 cy. This was determined by subtracting the DTM surfaces for the 2015 survey from the intermediate closure grades for Phases I-III and adding the final cover volume (2-feet over the existing 42.0 acre landfill footprint). The total remaining usable airspace for Phases I-III as of June 26, 2015 was calculated as follows (see Appendix A for calculations): Remaining usable airspace = Remaining Gross Airspace – Final Cover – Intermediate Cover = 613,150 cy – 135,520 cy – 67,760 cy = 409,870 cy 1.3.1.2 C&D Landfill NCDENR did not require landfills to report annual airspace based on certifying surveys until 2008. According to the operating permit, the volume within Phases I-III is 447,284 cy and the volume within Phase IV is 605,000 cy. Using Civil 3D, CDM Smith compared the surfaces from the annual aerial surveys to calculate the volume of airspace used. The results of these comparisons are provided in Table 1-1. Section 1 • Facility Plan 1-5 Table 1-1. C&D Landfill Volumes Period Airspace Used (cy) Cumulative Airspace (cy) Start End January 1, 1998 August 1, 2008 454,718 454,718 August 1, 2008 June 11, 2009 32,656 487,374 June 11, 2009 July 3, 2010 70,452 557,826 July 3, 2010 June 17, 2011 54,700 612,526 June 17, 2011 June 8, 2012 61,885 674,411 June 8, 2012 July 9, 2013 58,100 732,511 July 9, 2013 June 17, 2014 57,078 789,589 June 17, 2014 June 26, 2015 68,245 857,834 As shown in Table 1-1, approximately 857,834 cy of airspace were used from January 1, 1998 until June 26, 2015 and approximately 68,245 cy of airspace were used from June 17, 2014 through June 26, 2015. Based on the survey conducted on June 26, 2015, the airspace remaining within Phases I-IV is 194,450 cy. Volume calculations for the C&D landfill are provided in Appendix B. 1.3.2 Scale House Data Historical scale house data provided to CDM Smith by Cumberland County is included in Tables 1-2 and 1-3. Table 1-2 provides monthly tonnage data for FY 2015. Table 1-2 provides annual tonnages from 1998 through FY 2015.The tonnage analysis is provided in Appendix C. Table 1-2. Monthly Ann Street Landfill Scale House Records Fiscal Year 2015 Month Tons MSW C&D July 2014 11,769 3,557 August 2014 11,040 2,782 September 2014 11,427 3,138 October 2014 10,918 3,570 November 2014 9,267 2,178 December 2014 13,402 3,511 January 2015 13,363 2,524 February 2015 9,278 2,100 March 2015 12,010 2,930 April 2015 11,657 3,085 May 2015 11,542 3,491 June 2015 14,697 3,374 TOTAL 140,371 36,239 AVERAGE 11,698 3,020 Section 1 • Facility Plan 1-6 Table 1-3. Yearly Ann Street Landfill Scale House Records Fiscal Year MSW C&D Tons Monthly Avg Tons Monthly Avg 01/01/98 - 06/30/98 96,272 16,045 -1 -1 1999 138,041 11,503 -1 -1 2000 131,813 10,984 -1 -1 2001 134,366 11,197 -1 -1 2002 129,418 10,785 -1 -1 2003 138,336 11,528 -1 -1 2004 123,416 10,285 -1 -1 2005 173,798 14,483 -1 -1 2006 171,964 14,330 -1 -1 2007 178,020 14,835 -1 -1 2008 164,222 13,685 296,4412 -1 2009 170,156 14,180 16,228 1,352 2010 140,178 11,682 27,831 2,319 2011 151,134 12,594 29,428 2,452 2012 139,675 11,640 26,979 2,248 2013 114,619 9,552 32,431 2,703 2014 117,970 9,831 31,596 2,633 2015 140,371 11,698 36,239 3,020 Total 2,553,768 - 497,173 - Average - 12,047 - 2,390 1 – data not available 2 – Estimated tons from January 1, 1998 through June 30, 2008 1.3.3 Current Landfill Disposal Efficiency Calculations The AUF is a method that compares the amount of MSW disposed to the concurrent amount of airspace occupied. Since this method does not require estimations of in-place MSW density or volume of cover material, the calculations are more accurate when sufficient scale house and survey data are available. The facility AUF is preferable for remaining landfill life calculations since it is less influenced by yearly variances in operations or waste stream. Based on the July 2015 Cumberland County Ann Street Landfill Airspace Analysis Report, the current facility AUF for the Subtitle D landfill is 0.68 tons per cubic yard (tons/cy) or 1,360 pounds per cubic yard. Through the use of alternative daily cover and compaction efforts yearly AUF values have increased since 2005. The facility AUF over the last 9 years is 0.77 tons/cy and 0.83 tons/cy over the past 5 years. 1.3.4 Landfill Operating Life 1.3.4.1 Subtitle D Landfill The actual remaining life or constructed landfill airspace may vary from the estimates provided depending on the actual AUF values and tonnages of material disposed at the Subtitle D landfill. The following data was used to determine operating life as presented in Table 1-4: Section 1 • Facility Plan 1-7 Annual AUF = 0.83 for Phases I – III Annual AUF = 0.77 for Phases IV-VI Average monthly disposal rate for FY 2015 = 11,698 tons Table 1-4. Subtitle D Landfill Phase Capacity and Operational Life Phase Area (acres) Gross Airspace (cy) Total Usable Airspace (cy) Operating Life (years) Remaining I-III (Current) 42.0 4,157,653 4,089,891 2.4 IV (Future) 13.3 928,609 861,979 5.0 V (Future) 01 928,609 861,979 5.0 VI (Future) 01 667,529 600,899 1.8 Total 55.3 6,682,400 6,414,748 14.2 Notes: Gross Airspace – Volume of airspace from the top of the landfill base liner system through the top of the final cover system. Total Usable Airspace – Volume of airspace for MSW and daily cover and/or alternate daily cover material. Does not include intermediate or final cover material. 1 – Vertical expansion 1.3.4.2 C&D Landfill The following information was provided in the C&D landfill Permit Renewal Application originally submitted in January 2015 and revised in May 2015. Actual remaining life or constructed landfill airspace as presented in Table 1-5 may vary from the estimates provided depending on the actual AUF values and tonnages of material disposed at the C&D landfill. Table 1-5. C&D Landfill Phase Capacity and Operational Life Phase Area (acres) Waste Volume (cy) Operating Life (years) I-III (completed) 12.6 447,2842 -- IV (Current) 8.2 605,0002 4.5 V (Future) 01 87,6702 1.5 VI (Future) 3.0 292,2402 5.0 VII (Future) 01 292,2402 5.0 VIII (Future) 3.7 249,1503 2.0 Total 27.5 1,973,584 18.0 1 – Vertical expansion 2 – Volume in cubic yards for Waste and Daily Cover Material. 3 – Volume in cubic yards for Waste, Daily, Intermediate, and Final Cover. Section 1 • Facility Plan 1-8 1.3.5 On-Site Soils The Volume Analysis Tool of AutoCAD Civil 3D 2014 software was utilized to determine earthwork cut and fill volumes associated with constructing the perimeter access road, base grades, and Sediment Pond #5 for the remaining landfill cells (Cells 9-10). The TIN Subtraction Method was used to compare the volumetric difference between the proposed and existing grades within the landfill. The estimated cut and fill volumes (in-place) are as follows: Cut soil volume = 111,070 yd3 Fill soil volume = 107,158 yd3 The surplus soil will be cut soil minus fill soil: 111,070 yd3 – 107,158 yd3 = 3,912 yd3 (Soil Surplus) Net Soil Balance: 3,912 yd3 Soil Surplus - 43,204 yd3 Clay Liner Soil Required (2-foot thickness) - 543,958 yd3 Daily and Intermediate Cover Soil Required for Subtitle D landfill (5:1 Waste to Cover Ratio) - 178,435 yd3 Final Cover Soil Required for Subtitle D landfill (2.0-foot thickness for 55.3 acres, excludes intermediate cover. Intermediate cover is accounted for above) - 235,194 yd3 Daily and Intermediate Cover Soil Required for C&D landfill (8:1 Waste to Cover Ratio) - 88,734 yd3 Final Cover Soil Required for C&D landfill (2.0-foot thickness for 27.5 acres, excludes intermediate cover. Intermediate cover is accounted for above) __________________________ Equals -1,085,613 yd3 Therefore, 1,085,613 yd3 of soil is required from on-site and off-site borrow sources to construct Phase IV base grades and clay liner; provide daily and intermediate cover; and construct the final cover cap system for the Subtitle D and C&D landfills. (Note: this estimate does not include the sand needed (43,204 yd3) to construct the protective cover layer for Cells 9 and 10.) 1.3.6 Borrow Material Source Several borrow sources have been identified on the County landfill property. The sources have been identified within upland areas located on the Cape Fear River side of the property. A specific grading plan for this area will be developed to provide excavation limits to the County. 1.4 Containment and Environmental Control Systems The landfill will utilize the existing containment systems installed, which were approved and constructed as part of previous construction phases. Section 1 • Facility Plan 1-9 1.4.1 Erosion & Sedimentation Control – Subtitle D Landfill During construction of Phase II of the Subtitle D landfill disposal area, the County submitted and obtained approval of an amendment to an existing Erosion & Sedimentation Control Permit issued by the Land Quality Division for construction of Phase I. These sediment and erosion control measures were implemented during Phase II construction and remain in place. During landfill operations, stormwater from the western half of the site is routed by berms and swales away from the landfilling operations and deposited MSW into a sedimentation pond (Sediment Pond #2) located west of the landfill. Stormwater from the northern portion of the site is routed to a sedimentation pond located on the north side of the landfill (Sediment Pond #3). Stormwater flow originating from the operations on the eastern and southeastern portions of the site is directed to Sediment Pond #5 located in the southeastern corner of the facility. The County will apply for an amendment to the existing Erosion & Sedimentation Control Permit for construction of Phase IV. Once each portion of the landfill has reached approved final grades and received the closure (final cover) system, the stormwater runoff will be directed to the same sedimentation ponds as described above. Temporary erosion control measures, such as silt fences, fast germinating vegetation, rock check dams, etc. will be installed as necessary to reduce the amount of sedimentation and erosion. 1.4.2 Erosion & Sedimentation Control – C&D Landfill The C&D landfill utilizes the existing landfill sedimentation and erosion control measures such as sediment ponds, sediment traps, and drainage ditches, to handle stormwater runoff. The current sedimentation and erosion control permit was revised prior to Phase 2 operations and includes the operation of a C&D landfill on the landfill property. A revised permit was submitted to the Solid Waste Section and included in the Transition Plan amendment dated November 14, 1997. The remaining C&D landfill phases will utilize the same sedimentation and erosion control structures as provided and approved for previous phases of the C&D Landfill. 1.4.3 Methane Control The County, through Fayetteville Gas Producers, LLC (FGP) operates an active landfill gas collection and control system at the closed unlined landfill and the current Subtitle D and C&D disposal areas. The collection system meets the specifications of 40 CFR 60.759 and is consistent with the collection and control system design plan which was approved by NCDENR/DAQ on May 2008. The landfill gas collection system eliminates or reduces the landfill gas at the facility boundary to below the lower explosive limit (LEL) for methane and minimizes landfill gas in on-site structures. The landfill gas is treated and transported to Cargill, Inc. in Fayetteville via underground pipeline where it is used as a fuel. Any landfill gas not sent offsite to Cargill, Inc. is flared at a flare station located on the northeast side of the Ann Street property. Upon closure of the Subtitle D and C&D landfills, the existing active gas collection system will be expanded to include additional collection wells in both landfills. Additional information is provided in the Landfill Gas Monitoring Plan (Operation Plan - Appendix E). 1.5 Leachate Management 1.5.1 Introduction The Phase IV expansion of the Subtitle D landfill will utilize portions of the existing leachate collection system (LCS), which was permitted and constructed as part of Phases I and II. Leachate will be collected within the Phase IV disposal area and conveyed through the existing gravity collection Section 1 • Facility Plan 1-10 system to existing pump station #1 and pumped to the onsite leachate storage pond. The stored leachate is discharged to an existing sanitary sewer and is treated at the City of Fayetteville Cross Creek Water Reclamation Facility. 1.5.2 Contingency Plan Leachate generated by the Subtitle D landfill is currently discharged directly to the Cross Creek Water Reclamation Facility. The long-term plan for leachate disposal is to continue the current plan. Should leachate quality exceed the permitted limits, as determined by the City of Fayetteville Cross Creek Water Reclamation Facility the County will construct a pretreatment facility at the outlet from the leachate storage pond, prior to discharge to the PWC sanitary sewer system. By monitoring leachate quantity and quality, the County will be able to identify potential quality issues in advance and implement a plan to pretreat prior to the realization of any impact on the City’s Cross Creek Water Reclamation Facility performance. This will allow the design and construction of the pretreatment facilities to be based on actual data obtained from the operation of the Subtitle D landfill facility. 1.6 Floodplain Development The Federal Emergency Management Agency (FEMA) 100-year floodplain landfill map that encompasses Phase IV (Map ID: 3720044800J) was revised on January 5, 2007 after the original facility design and permitting was completed. The updated FEMA floodplain map shows a portion of the 100-year floodplain extending into Phase IV. CDM Smith performed storage calculations that confirm the storage volume displaced during the construction of Phase IV is mitigated by the additional volume excavated during the construction of Sediment Pond #3. The updated floodplain map is provided in Appendix E. The floodplain map is in the process of being revised with the 100-year floodplain no longer extending into Phase IV. The revised map is scheduled to be issued in late 2016 followed by a six month review period before prior to being adopted in 2017. It is likely that the revised floodplain map will be adopted prior to placement of waste in Phase IV. In the event that the floodplain map revision is delayed the City of Fayetteville granted Cumberland County a Floodplain Development Permit on January 29, 2016 to allow construction of Phase IV. A copy of the permit is provided in Appendix E. Protective measures along with how operations would be adjusted in the event of a flood are included in the Operation Plan.