8103_Rutherford_CDLF_ACMDemoApproval_DIN28012_20170623

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, North Carolina 27699-1646
919 707 8200
June 23, 2017

Mr. Steve Garrison, County Manager
Rutherford County
289 North Main Street
Rutherford, North Carolina 28139

Subject: Alternative Cover Material Demonstration, Approval
Permit No. 8103-CDLF-2002, Rutherford County C&D
Rutherford County, DIN 28012

Dear Mr. Garrison;
On June 20, 2017, the Division of Waste Management, Solid Waste Section (Section) received
an application for an Alternative Cover Material (ACM) demonstration entitled;
MVS, Bulk Transportation, Spindale, NC, & Cellulose Residue. Prepared for Rutherford County.
Prepared by MVS Bulk Transportation. June 2017. DIN 28011.
The application presents information regarding the use of cellulose residue as an ACM at the
Rutherford County C&D Landfill, Permit No. 8103-CDLF-2002. The Section has reviewed the
information presented in the application and conditionally approves the demonstration project for
the use of cellulose residue solely as alternative weekly cover as described in the application
under the following conditions;
1. Prior to initiating the demonstration, a description and schematic of storage location and
method of handling the stockpiled cellulose residue must be submitted to the Section for
review and approval. Unless otherwise approved, the ACM must be stockpiled within the
permitted disposal area of the C&D Landfill. Runoff from the storage area must not
leave the permitted landfill disposal area;
2. Prior to commencing the demonstration; a pre-operations meeting will be held with the
Section Regional Permitting Engineer and Field Operations Branch compliance staff to
review the operations to manage and spread the cellulose residue;
3. The cellulose residue may not be disposed of in the C&D landfill;
4. Staged ACM must be maintained at a moisture level sufficient to prevent blowing dust;
5. The use of 100 percent cellulose residue will be evaluated by the Section after thirty days
to determine if adjustments such as, but not limited to, mixing the material with earthen
material at approved rates prior to application as cover will be required;
6. The facility will monitor and document the effectiveness of the demonstration through
recordkeeping to include photographs and a daily log of application dates, and the
performance of the ACM to protect public health and safety and the environment, and
control vectors, fires, odors, and nuisances. The performance of the ACM must also be
documented during wet weather events. The records must be kept and made available in
accordance with Solid Waste Rule.0542(f)(1);
7. Contingency plans must be maintained at the facility to address operations during any
staffing shortages, emergency weather or disaster conditions, equipment failure, etc.;
8. The cellulose residue may not be used for other purposes than demonstrating ACM at the
facility without prior review and approval. The use of cellulose residue for intermediate
or final cover is not approved, however, may be considered at the end of the
demonstration period;
9. The demonstration will expire on December 23, 2017;
10. Prior to the expiration of the approved demonstration period a demonstration report will
be developed and submitted to the Section for review, to certify the effectiveness of the
cellulose residue as an ACM.
The ACM must comply with 15 NCAC 13B .0542(f)(3) which requires the Owner or Operator to
demonstrate that the ACM will control disease vectors, fires, odor, blowing litter, and
scavenging without presenting a threat to human health and the environment.
The demonstration period does not allow for or give exemption to the requirements for cover. If
the use of the product is not sufficient for weekly cover, it should not be used. It is the owner and
operator’s responsibility to ensure an adequate cover is being provided. The use of the ACM
must be discontinued if it does not perform as well as soil in the areas of fire prevention, vector
control, blowing waste prevention, odors, and scavenging.
After six (6) months of using the conditionally approved ACM, the facility owner or operator
may then either:
1. within sixty (60) days provide a certified Demonstration Report demonstrating the
feasibility to request approval for the use of the ACM on a full-time basis, or
2. cease use of the ACM, properly dispose of any remaining ACM, and provide a Closure
Letter detailing the findings of the use of the material during the approval period and
what actions were taken to dispose of the material.
The certified demonstration report must be signed by the owner or operator and certified by a
professional engineer licensed in North Carolina. The report shall include documentation
addressing the performance and effectiveness of the material, the number of times the ACM was
used, the quantities of the ACM, and other supportive information, including photographs.
Following satisfactory demonstration of the ACM and application, the Solid Waste Section may
issue a Permit Modification or other permit revision approval for the facility that includes the
ACM operation.
Please note that the continuation of the use of this ACM is performance based. Should the
application of the ACM become impracticable or contribute to conditions hazardous to public
health, safety or the environment, the operator is responsible for immediately terminating the
ACM use and applying compacted earthen material cover in accordance with the Solid Waste
Rules. Impracticable conditions are conditions that make the placement of ACM difficult due to
adverse climate such as rain, wind, or frozen precipitation, or other conditions that adversely
 Rutherford County
June 23, 2017
Page 3 of 3 

affects the ability of the ACM to meet the Performance Standards. The operator must maintain a
ready stockpile of earthen material cover material and the equipment necessary to apply the
earthen material cover to respond to an adverse situation. Therefore, approval of the continued
use of the ACM may be revoked at any point in time by the Section.
All documents referenced including this letter may be accessed at; 
http://edocs.deq.nc.gov/WasteManagement/0/fol/420/Row1.aspx. Should you have any questions
you may contact Kris Riddle at [phone] [e-mail] or Larry Frost at (828)
296-4704 [e-mail].

Sincerely,

Ellen Lorscheider, Solid Waste Section Chief
Division of Waste Management, NCDEQ

ec: Ed Mussler, Permitting Branch Head
Jason Watkins, Field Operations Branch Head
Deborah Aja, Western District Supervisor
Kris Riddle, Environmental Senior Specialist
Larry Frost, Engineering Project Manager