7904_Rockingham_MSWLF_ACMApproval_DIN27510_20170313

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Frost, Larry
From:Frost, Larry
Sent:Monday, March 13, 2017 2:00 PM
To:'Marty Nugent'; Kathryn Jolly
Cc:Heim, Susan A
Subject:RE: Alternative Cover Materials Policy
Martie, 
You have elected to use an approved ACM in the manner prescribed in the APPROVED ALTERNATIVE DAILY COVER 
MATERIALS 
FOR USE AT SANITARY LANDFILLS, Date of Issue: January 7, 2014, Document Number 20365.  
To implement the use of the ACM, you should place a notice in the facility daily operating record with the procedure for 
using the ACM according to the information in the document.  
The next time you either amend or modify your permit the ADC must be incorporated into the facility operation plan 
and it will be listed in the permit at the next permit action. 
The Section hereby approves the implementation of automotive shredder Residuals as an alternate cover material at the 
Rockingham County landfill. 
Larry Frost 

From: Marty Nugent [mailto:[e-mail]]  
Sent: Monday, March 13, 2017 1:10 PM 
To: Frost, Larry <[e-mail]>; Kathryn Jolly <[e-mail]> 
Subject: Re: Alternative Cover Materials Policy 

Larry,

I am requesting the use of Automotive Sherrder Residuals for alternative daily cover along with our tarps and
dirt at the Rockingham County Landfill per NCDENR regulations.

Thanks

Martie Neugent
Landfill Manager
Rockingham County Landfill
Office [phone]
Cell [phone]
Fax [phone]

On Fri, Mar 10, 2017 at 7:03 AM, Frost, Larry <[e-mail]> wrote:
See attached

Larry Frost
Engineering Project Manager
2
Division of Waste Management, Solid Waste Section
North Carolina Department of Environmental Quality

[phone] office
[phone] mobile
[e-mail]

Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

1646 Mail Service Center, Raleigh, NC 27699-1676
Telephone: [phone] Internet: http://portal.ncdenr.org/web/wm/sw
An Equal Opportunity/Affirmative Action Employer – Printed on Dual Purpose Paper

North Carolina Department Of Environment And Natural Resources
Division of Waste Management
Solid Waste Section

APPROVED ALTERNATIVE DAILY COVER MATERIALS
FOR USE AT SANITARY LANDFILLS

Date of Issue: January 7, 2014
Document Number 20365

NOTICE
This is a guidance document developed to assist landfills in the selection and use of alternative daily cover
materials. It should not be interpreted as a replacement to North Carolina General Statutes or Administrative
Code. DENR officials may determine that the guidance is not applicable based on site specific conditions.
DENR reserves the right to change this guidance at any time without public notice.

Guidance Document History
Date Document Number Revision
January 7, 2014 20365 Original Issue

TABLE OF CONTENTS
Introduction .......................................................................................................................... 1
Regulatory Authority and Interpretation ............................................................................. 1
Implementation .................................................................................................................... 2
Compliance ........................................................................................................................... 3
Approved Alternative Daily Cover Material Detail Sheets
Automotive Shredder Residuals ................................................................................ 4
Combustion Residuals ............................................................................................... 5
Construction & Demolition Debris Fines .................................................................. 6
Petroleum Contaminated Soils ................................................................................. 7
Spray-applied Mortar Coating ................................................................................... 8
Foam Coating ............................................................................................................. 9
Foundry Sand ............................................................................................................ 10
Soil/Mulch Mixture .................................................................................................... 11
Synthetic Tarps ......................................................................................................... 12

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INTRODUCTION
During the 2013 session of the North Carolina General Assembly, Session Law 2013-413 was passed
which amended North Carolina General Statute (NCGS) 130A-295.6 concerning the use of alternative
cover materials (ACM) as daily cover at sanitary landfills. The statute states that once an ACM has
been approved for use by the Department of Environment and Natural Resources (NCDENR) at any
sanitary landfill in North Carolina, it may be used at all sanitary landfills within the state.
The Solid Waste Section (Section) of the NCDENR Division of Waste Management prepared this
guidance document to assist the regulated community in the implementation of the statue. Section
staff developed an inventory of ACM approved for use in North Carolina and the summarized the
approved operational conditions and application processes for use of the ACM. This information,
along with instructions on how to add the use of previously approved ACM to a sanitary landfill
operation and permit, is provided.

REGULATORY AUTHORITY AND INTERPRETATION
Industrial waste landfills (IndLF), construction and demolition solid waste landfills (C&DLF), and
municipal solid waste landfills (MSWLF) are all considered sanitary landfills by North Carolina statutes
and rules.
Previously there was no statutory language regarding daily cover, alternative daily cover or
alternative cover materials. However, cover requirements and alternatives based on specific types of
sanitary landfills were addressed in the Solid Waste Management Rules - Title 15A Chapter 13, Sub-
chapter B of the North Carolina Administrative Code (15A NCAC 13B). The following rule references
provide the current requirements which can affect the use of an ACM at a specific type of sanitary
landfill.
Industrial waste landfills are permitted and operated under Sections .0503, .0504, .0505 and .0510 of
the NCAC.
 Part .0505(3)(a) specifically states: Solid waste shall be covered after each day of operation,
with a compacted layer of at least six inches of suitable cover or as specified by the Division.
C&D waste landfills are currently permitted and operated under Sections .0531 through .0547 of the
NCAC.
 Part .0542(f)(1) states: Except as provided in Subparagraph (3) of this Paragraph, the owners
and operators of all C&DLF units must cover the solid waste with six inches of earthen material
when the waste disposal area exceeds one-half acre and at least once weekly. Cover must be
placed at more frequent intervals if necessary to control disease vectors, fires, odors, blowing

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litter, and scavenging. A notation of the date and time of the cover placement must be
recorded in the operating record as specified in Paragraph (n) of this Rule.
 Part .0542(f)(3) states: Alternative materials or an alternative thickness of cover may be
approved by the Division if the owner or operator demonstrates that the alternative material
or thickness controls disease vectors, fires, odors, blowing litter, and scavenging without
presenting a threat to human health and the environment. A C&DLF owner or operator may
apply for approval of an alternative cover material. If approval is given by the Division,
approval would extend to all C&DLF units at one specific facility.
MSW landfills are currently permitted and operated under Sections .1601 through .1680 of the NCAC.
 Part .1626(2)(a) states: Except as provided in Sub-Item (b) of this Item, the owners or
operators of all MSWLF units must cover disposed solid waste with six inches of earthen
material at the end of each operating day, or at more frequent intervals if necessary, to
control disease vectors, fires, odors, blowing litter, and scavenging.
 Part .1626(2)(b) states: Alternative materials of an alternative thickness (other than at least
six inches of earthen material) may be approved by the Division if the owner or operator
demonstrates that the alternative material and thickness control disease vectors , fires , odors
, blowing litter, and scavenging without presenting a threat to human health and the
environment, in accordance with 40 CFR Part 258.21. A MSWLF owner or operator may apply
for a generic approval of an alternative cover material, which would extend to all MSWLF
units.

IMPLEMENTATION
The use of an ACM must be documented in the approved operation plan for the facility. If a facility
intends to utilize an ACM that is currently not in their approved operation plan but is included in the
ACM summary, they may do so by following one of the following procedures:
1. The facility may elect to use an approved ACM in the manner prescribed in this document. To
implement the use of the ACM, the facility owner or operator should place a notice in the facility
operating record with the procedure for using the ACM according to the information in this
document and send a copy of the notice and procedure to the Permitting Branch Supervisor of the
Section and the facilities Environmental Senior Specialist (ESS). The ADC must be incorporated into
the facility operation plan and will be listed in the permit at the next permit action.
2. The facility may choose to implement an ACM that has been approved in a manner not
prescribed in this document by performing an abbreviated demonstration period. This will allow the
operator to tailor the ACM to their specific use, staff, and facility operation. The Section will provide
oversight and concurrence to the process. The owner or operator should contact their (ESS) to discuss

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the specifications for the testing. At the conclusion of the process, a notice should be placed in the
facility operating record with the procedure for using the ACM and a copy of the notice and
procedure sent to the Permitting Branch Supervisor of the Section. At the next permit action, the
ACM must be incorporated into the facility operation plan and will be listed in the permit.
If a facility wishes to use an ACM that has not previously been approved by the Section, the operator
must complete a demonstration process. Contact your ESS for assistance.
COMPLIANCE
Regardless of the method chosen, the Section will enforce compliance with the proper use of the
ACM in accordance with the rules, statutes, site specific conditions, and historical precedent. An
operator who chooses to implement an ACM as described in choice 1 above will be immediately
responsible for compliance and subject to the NCDENR tiered-enforcement process. An operator who
chooses option 2 will be subject to enforcement that considers the demonstration nature of the
action, with the understanding that changes to the process or ACM will be instituted immediately to
correct any issues.
ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Automotive Shredder Residuals (ASR)
APPROVED LANDFILL USE: MSWLF, C&DLF (lined)*
MATERIAL CHARACTERISTICS: Automotive Shredder Residuals are the fines remaining after scrap cars
have passed through a shredder and all recoverable materials have been removed. ASR can consist
of glass, synthetic fibers, rubber, plastics, automobile liquids residue, metal fines and dirt. It is
possible for the ASR to contain substances considered hazardous such as lead, cadmium and PCB.
USAGE CRITERIA:
1. ASR can be applied, in lieu of soil, to a full depth of six inches given calm site (weather)
conditions.
2. If site (weather) conditions are, or are forecast to be, windy the ASR must either be:
a. Mixed with soil at a ratio of 50% soil with 50% ASR prior to application on the working
face, or
b. Placed on the working face to a minimum depth of 3” and then covered with soil a
minimum depth of 3”.
3. During the use of ASR as an ACM, soil cover to a full depth of six inches shall be applied once
per week.
4. ASR shall not be used on any exterior/outside slopes and may not be used for intermediate
cover.
5. The ASR must be sourced from within the approved service area of the landfill facility.

* A CDLF equipped with a liner system may use the ASR as alternate daily cover only. Use of more
than six inches equates to disposal. ASR is not a C&D waste. To dispose of ASP in a lined CDLF,
contact the Permitting Branch of the Solid Waste Section for further clarification.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Combustion Residuals (CR)/Ash
APPROVED LANDFILL USE: : MSWLF, C&DLF (lined)*, IndLF (lined)*
MATERIAL CHARACTERISTICS: Combustion Residuals or Ash are, generally, the residuals remaining
from the combustion of coal or the incineration of waste materials. The CR/Ash generally consists of
fine particles such as fly-ash as well as larger particles similar to sand, gravel or stone.
USAGE CRITERIA:
1. CR/Ash can be applied, in lieu of soil, to a full depth of six inches given calm site (weather)
conditions.
2. If site (weather) conditions are, or are forecast to be, windy the CR/Ash must either be:
a. Mixed with soil at a ratio of 50% soil with 50% CR/Ash prior to application on the
working face if it can become airborne or exhibits dust like properties, or
b. Placed on the working face to a minimum depth of 3” and then covered with soil a
minimum depth of 3” if it can become airborne or exhibits dust like properties.
3. During the use of CR/Ash as an ACM, soil cover to a full depth of six inches shall be applied
once per week, unless otherwise approved by the Section*.
4. CR/Ash may not be used for intermediate cover, if it can become airborne or exhibits dust like
properties.
5. The CR/Ash must be sourced from within the approved service area of the landfill facility.
Warning: Some materials such, as flue gas desulfurization residue, are destined for recycle and
cannot be contaminated with soil. Site specific handling practices should be discussed with the
Solid Waste Section prior to implementation.

* A CDLF or IndLF equipped with a liner system may use the CR as alternate daily cover only. Use of
more than six inches equates to disposal. CR is not a C&D waste. To dispose of CR in a lined CDLF,
or a non-CCB industrial landfill, contact the Permitting Branch of the Solid Waste Section for
further clarification.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Construction and Demolition Debris (C&D) Fines
APPROVED LANDFILL USE: : MSWLF, C&DLF
MATERIAL CHARACTERISTICS: Construction and Demolition Debris Fines are, generally, the residuals
and fine particles remaining in the bottom of dumpsters, roll-off containers and trucks used in the
transportation or processing of C&D debris.
USAGE CRITERIA:
1. C&D Fines can be applied, in lieu of soil, to a full depth of six inches given calm site (weather)
conditions.
2. If site (weather) conditions are, or are forecast to be, windy the C&D Fines must either be:
a. Mixed with soil at a ratio of 50% soil with 50% C&D Fines prior to application on the
working face, or
b. Placed on the working face to a minimum depth of 3” and then covered with soil a
minimum depth of 3”.
3. During the use of C&D Fines as an ACM, soil cover to a full depth of six inches shall be applied
once per week.
4. C&D Fines shall not be used on any exterior/outside slopes and may not be used for
intermediate cover.
5. The C&D Fines must be sourced from within the approved service area of the landfill facility.
Warning: C&D fines can contain large percentages of drywall dust or gypsum. These materials
may produce significant amounts of hydrogen sulfide, an obnoxious smelling compound. If odor
problems develop, the use of the fines should be suspended immediately and the offending area
covered with soil.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Petroleum Contaminated Soils (PCS)
APPROVED LANDFILL USE: : MSWLF, C&DLF (lined)*, IndLF (lined)*
MATERIAL CHATRACTERISTICS: Petroleum Contaminated Soils are, generally, native soils
contaminated with some petroleum liquid. Generally, these soils are be sourced from environmental
cleanup sites, spill sites or sites associated with above ground or underground storage tank (AST or
UST) removal. In the case of ACM usage, petroleum is narrowly defined as the low to medium boiling
point petroleum derived fuels such as gasoline, kerosene, diesel, motor oil, mineral spirits and fuel
oils #11 through #6. All other petroleum derived liquids such as solvents, acids, tars and asphalts are
excluded. In all cases, the concentration of Total Petroleum Hydrocarbons (TPH) in the PCS cannot
exceed 3,000 parts per million (PPM) regardless of type or test method. The material may not contain
chlorinated solvents or other hazardous materials or exhibit the hazardous characteristic of
flammable.
USAGE CRITERIA:
1. PCS can be applied, in lieu of soil, to a full depth of six inches.
2. The PCS must be stockpiled within a disposal area and shall be managed and applied in such a
way that runoff cannot leave the lined landfill area.
3. The PCS shall be managed in such a way to prevent run-off and fugitive emissions (i.e. use of
tarps, berms and/or wetting to prevent blowing).
4. PCS is prohibited from disposal. Therefore, the facility may not accept more PCS than can be
used in a 45 day period. The amount of PCS accepted should not exceed 20% of the
permitted facility average monthly waste stream.
5. PCS shall not be used on any exterior/outside slopes and may not be used for intermediate
cover.
6. The PCS must be sourced from within the approved service area of the landfill facility.
7. PCS can only be used at lined landfill facilities.
8. Records must be maintained in the facility operating record indicating the volume of PCS
accepted and applied at the facility on a daily basis.
* A CDLF or IndLF equipped with a liner system may use the PCS as alternate daily cover only. Use
of more than six inches equates to disposal. PCS is neither a C&D nor an Industrial waste. To
dispose of PCS in a lined CDLF, or a non-CCB industrial landfill, contact the Permitting Branch of
the Solid Waste Section for further clarification.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Spray-applied Mortar Coating (SMC)
APPROVED LANDFILL USE: : MSWLF, C&DLF, IndLF
MATERIAL CHARACTERISTIC: SMC is, generally, a commercially sourced non-flammable, non-toxic
product containing proprietary components including mix setting agents, reinforcing materials and
cement. Other components, such as latex paint, may also be added to the mixture. All of the
components are generally mixed on site with water and/or leachate to produce slurry that is then
spray-applied to the working face.
USAGE CRITERIA:
1. SMC can be applied, in lieu of soil, given appropriate site (weather) conditions.
2. SMC must be applied in accordance with the manufacturers’ application guidelines.
3. SMC must be applied in two directions to ensure adequate coverage.
4. During the use of SMC as an ACM, soil cover to a full depth of six inches shall be applied once
per week unless otherwise approved by the Section.
5. The use of non-hazardous latex or water based paint in the mixture is approved provided that
the paint has been collected for recycling.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Foam Coating (Foam)
APPROVED LANDFILL USE: MSWLF, C&DLF, IndLF
MATERIAL CHARACTERISTICS: Foam Coating is, generally, a commercially sourced non-flammable,
non-toxic, non-hardening water based product. The proprietary liquid concentrate is delivered to the
site and diluted with water prior to application with proprietary equipment.
USAGE CRITERIA:
1. Foam can be applied, in lieu of soil, given appropriate site (weather) conditions.
2. Foam must be applied in accordance with the manufacturers’ application guidelines.
3. During the use of Foam as an ACM, soil cover to a full depth of six inches shall be applied once
per week.
4. Foam shall not be used on any exterior/outside slopes and may not be used for intermediate
cover.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Foundry Sand (Sand)
APPROVED LANDFILL USE: MSWLF, C&DLF (lined)*, IndLF (lined)*
MATERIAL CHARACTERISTICS: Foundry Sand is, generally, a by-product of the smelting and forging
processes for metals fabrication. Metal pieces and particulate may also be found in the sand. Prior
to use, a Toxicity Characteristic Leaching Procedure (TCLP) analysis must be performed to ensure no
hazardous constituents are found in the sand at the source. The TCLP analysis results must be
submitted with the Operation Plan revision.
USAGE CRITERIA:
1. Sand can be applied, in lieu of soil, to a full depth of six inches.
2. The Sand must be stockpiled within a disposal area and shall be managed and applied in such
a way that runoff cannot leave the lined landfill area.
3. The Sand shall be managed in such a way to prevent run-off and fugitive emissions (i.e. use of
tarps, berms and/or wetting to prevent blowing).
4. Sand is prohibited from disposal. Therefore, the facility may not accept more Sand than can
be used in a 45 day period. The amount of Sand accepted should not exceed 20% of the
permitted facility average monthly waste stream.
5. Sand shall not be used on any exterior/outside slopes and may not be used for intermediate
cover.
6. The Sand must be sourced from within the approved service area of the landfill facility.
7. Sand can only be used at lined landfill facilities.
8. Records must be maintained in the facility operating record indicating the volume of Sand
accepted and applied at the facility on a daily basis.

* A CDLF or IndLF equipped with a liner system may use the sand as alternate daily cover only. Use
of more than six inches equates to disposal. Sand is not a C&D waste. To dispose of sand in a lined
CDLF, a lined landfill not previously permitted to accept it or a non-CCB industrial landfill, contact
the Permitting Branch of the Solid Waste Section for further clarification.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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ACM: Soil/Mulch Mixture (S&M)
APPROVED LANDFILL USE: MSWLF, C&DLF, IndLF
MATERIAL CHARACTERISTICS: Soil/Mulch Mixture is, generally, a mixture of native soils and wood
mulch generated from the grinding of yard trash, land clearing debris and pallets constructed of
unpainted and untreated natural wood. Additionally, shredded tire chips may be used in addition to,
or in lieu of, wood mulch.
USAGE CRITERIA:
1. S&M can be applied, in lieu of soil, to a full depth of six inches.
2. S&M can be mixed at a ratio from 80% soil to 20% mulch up to 50% soil to 50% mulch by
volume.
3. During the use of S&M as an ACM, soil cover to a full depth of six inches shall be applied once
per week.
4. S&M may not be used for intermediate cover.

ALTERNATIVE DAILY COVER MATERIAL DETAIL SHEET
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January dd, 2014 – DIN nnnnn
ACM: Synthetic Tarps (Tarps)
APPROVED LANDFILL USE: MSWLF, C&DLF, IndLF
MATERIAL CHARACTERISTICS: Synthetic Tarps are, generally, a commercially sourced non-flammable,
non-toxic, sheet product constructed of an impermeable synthetic polymer typically reinforced with
fibers. Acceptable sheet products include, but are not limited to, geotextiles, polyethylene
membranes, plastic film, tarps and composite geotextile/plastic membranes. Tarps may be applied
by hand, using landfill equipment and/or an Automatic Tarping Machine (ATM).
USAGE CRITERIA:
1. Tarps can be applied, in lieu of soil, given appropriate site (weather) conditions.
2. Tarps must cover the entire working face. Any waste not covered by tarps must be covered
by soil.
3. Tarps must be secured in place with the use of soils or other ballast system such as tires or
sand bags.
4. During the use of Tarps as an ACM, soil cover to a full depth of six inches shall be applied once
per week.
5. Tarps shall not be used on any exterior/outside slopes and may not be used for intermediate
cover.