4117_A1SandRockCDLF_Comment_PTCPhase3App_DIN28822_20180716

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, July 16, 2018 10:18 AM
To:'[e-mail]'
Cc:Ritter, Christine; Patrone, John; Stanley, Sherri; '[e-mail]'
Subject:Comments (DIN28822) on Engineering Portions, PTC-Phase 3,A-1Sandrock CDLF, 41-17
Hi David:

DIN 28822

I completed a review of the PTC Application (DIN 28812) for Phase 3 Construction of A-1 Sandrock C&DLF,
Permit # 4117-CDLF-2008 and have some comments on the application document which are stated
below. Christine will send out her comments on hydro portions of the application, if any, in a separate
document.

1. Throughout the entire Permit Application please change the acronym of the Department from NCDENR
to NCDEQ.

2. Forward
i. (page viii) There is no 2017 PTC application but the modification (DIN 28454) of the approved
2015 PTC application for Phase 2 including Facility Plan (page 5 only) and Closure and Post-
Closure Cost Estimates (pages 77, 78, 81, & 82) and Financial Assurance (pages 87 & 88).

ii. (page viii) The references to the NC Solid Waste Management Rules are incorrect.

3. CDLF Facility Plan
i. (Section 1.1, page 10) The referenced Section 3.3.2 is not available in the Permit Application.

ii. (Section 1.1, page 10) The described drawing set titled “A-1 Sandrock South Mine Facility Plan”
is not included in the Permit Application.

iii. (Section 1.3.1, page 11) The 2013 update franchise information shall be described in this sub-
section & Appendix 1.

iv. (Section 1.3.2 Landfill Capacity) The approved capacity for Phase 3 & Phase 4, which are
described in the latest modification [dated September 5, 2017 (DIN 28454)] to the 2013 Facility
Plan (DIN 20125) are 647,787 CY (at interim elevation of 854 feet amsl) and 505,536 CY (at
final elevation 904 feet amsl), respectively. The approved gross capacity for the CDLF (Phases
1 through 4) is 2,240,000 CY. Please explain why and how the new gross capacity increase to
2,391,654 CY without changing the final cover elevations (including exterior side slopes) and
waste footprint?

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4. Engineering Plan
i. (Section 2.1.2, Bullet item 6, page 16) The referenced Section 7 describing borrow site selection
and a field evaluation of the soils during construction is likely Section 4.

ii. (Section 2.1.2, Bullet item 7, page 16) The referenced Section 5.2 does not specify the soil
compaction requirements.

iii. (Section 2.2) Should this Section incorporate the findings concluded in 2015 Design Hydrologic
Report, which is a supplemental document to the 2002 Design Hydrologic (the actual title of the
document is "Site Application Report – Part 1 of 2, Hydrogeologic Investigation and Conceptual
Plan", dated June 2002 and revised through November 6, 2003).

iv. (Section 2.4.4) The referenced drawings are likely incorrect. Drawings EC1 & EC2 are E&S
details, and the drawing EC3 shows final contours of the final cover system and layout of E&S
BMPs.

v. (Section 2.4.5) Should both drawings EC1 & EC2 show the permanent measures pertaining to
the final cover?

vi. (Section 2.4.6) Should the rule-required vertical separation underneath the CDLF base be
established by the 2002, 2013, and 2018 PTC submittal? The related info collected through the
years investigations must be presented in the subsection.

vii. (Sections 2.5 & 3.2.1 & Appendix 2) The average waste density of 0.68 Ton/CY is obtained
from the waste operations as stated in Section 1.3.2. Why use the assumed density 0.5 Ton/CY
for the calculations/estimates of Landfill Capacity and Service Life, Slope Stability Analysis,
Settlement Calculations?

viii. (Sections 2.5 & 3.2.1 & Appendix 2) According to Appendix 7 and Drawing S2, there are five
borings being installed in new Phase 3 area recently, why the laboratory testing data and SPT
values of the representative soil samples (more site specific than those data (Table 2, Appendix
2) collected from 2002 Site Study Report) are not used in the engineering calculations in
Appendix 2?

5. Construction Plan Requirement
i. (Section 3.1) Please show the described horizontal separations on Drawings E1 through E6.

ii. (Section 3.5.1) The Rule 15A NCAC 13B .0540(5) requires the permittee to hire a licensed
Geologist/Engineer, accompanying with a SWS Hydrologist, conducting inspection of the
finished landfill subgrade. Please add the requirement to this Section.

iii. (Section 3.7) The referenced drawing should be Drawings E1 - E6 & EC1 – EC4.

6. Construction Quality Assurance
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i. (Section 4.2.3.1, Item D) The Table 4C does not include QA/QC requirements - testing item,
method, & frequency regarding vegetative soli layer/drainage layer or seeding schedule.

ii. (Tables 4A &4D) ASTM D 422 is officially withdrawn by ASTM committee in 2016. Please use
the new method.

7. General Facility Operations Plan
i. (Section 5.1) The Rule is not allowed any waste operation deviates from the approved operation
plan without the SWS approval. Please remove the phrase in the last sentence or define the
“significant changes” in this Section.

ii. (Sections 5.1.1, 5.4.2 & 5.5) Please provide a hard copy of the described mining permit which
must be the current and valid one.

iii. (Section 5.3) The waste activities inside the facility are shown on Drawings E1 – E6.

iv. (Section 5.3) Please define “products” in the last bullet item. There are many recovered and
recyclable material (such as concrete, wooden pallet, etc.) being considered as “products” and
stockpiled on the ground; to avoid confusion please specify or define what kind products may be
placed in the roll-off boxes.

v. (Section 5.4, Third Paragraph) Please define “Materials” in the first sentence. To avoid any
confusion, using, may be appropriate, “raw” or “non-processed” material instead.

vi. (Section 5.7) Please use “Shall” instead of “Should” in the last sentence of the first paragraph.

vii. (Section 5.9.1) The Section needs to provide follow-up actions / countermeasures to
manage/handle the situation when an elevated temperature (exceeding 120 degree of Fahrenheit)
inside the pile(s) of combustible wastes/products is detected.

viii. (Sections 5.14.3.4 & 5.14.3.5) To be consistent with descriptions of “Periodic Cover” in Section
7.4, please use remove “daily cover” and use periodic cover instead.

8. Processing Facility Operations Plan
i. (Section 6.4.5, Bullet Item 2) Please make sure that the description of material storage (inside the
over-the-road shipping containers) is matching or reflecting the real field operations (material
may be stored on the grade).

ii. (Section 6.4.5, Bullet Item 3) The beneficial fill material must be defined according to Rule 15A
NCAC 13B. .0562.

iii. (Section 6.4.7) The facility is storing various unprocessed & processed material – combustible
woody material (boil fuel & mulch), inert material (concrete, rock, etc.). To avoid any
confusion, please defined unprocessed wastes of 3,000 CY. Does this raw material of 3,000 CY
include earthen inert debris which can be processed to beneficial fill as stated in Section 6.4.5?

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iv. (Table 6.1) Demolition Wastes are listed as prohibited wastes in Table 6.1, but the Section 6.2
states Demolition Wastes are acceptable wastes at the processing unit/facility. Please clarify.

9. Closure & Post-Closure Plan
i. (Section 8.1.1) The Drawing E6 shows the final contours of the CDLF.

ii. (Section 8.2) There is no Phase 32, please correct the typo. Additionally, should this Closure
Plan include Phases 1 through 4 of the CDLF because the Permit Application intends to include
Phase 4 (vertical expansion) construction (refer to the last sentence of the fourth paragraph of
“Forward”)?

iii. (Section 8.2.1.1) The Drawing E5 shows the Phase 3 intermediate cover contours and Drawing
E6 shows the final cover system of the CDLFG, not Drawing E2.

iv. (Section 8.2.1.5) The Construction Plan (Section 4) and Drawing EC3 do not contain the
described specifications of seeding (including seed types and seeding schedules) or mulch.

v. (Section 8.2.2) The sum of the approved capacity for Phases 1 through 3 is approximately
1,726,311 CY according to the approved Facility Plan (DIN 20125) and the existing permit dated
October 2, 2017 (DIN 28455). Please explain why the capacity increases without increasing
intermediate cover elevations and the waste footprint for each phases development (refer to
Comment No 3.iv.)?

vi. (Section 8.2.4) Are there reasons to reduce the unit cost for each listed item in the closure cost
estimate? What about the inflation factors over the years?
Item Unit Price in 2013 (DIN 20125) Unit Price in 2018
CSB $10/CY $8/CY
Establish Vegetation $1,800/acre $1,500/acre

vii. (Section 8.2.4) According to Section 8.1.3 the on-site borrow will not provide adequate amount
of soil for compacted soil liner, a component of the final cover system. The unit price of the
CSB in the cost estimate must be based on the quote(s) from off-site borrow, and the potential
locations of the off-site borrow should be documented in the Closure Plan.
viii. (Section 8.2.4) The footnote indicates the quantity (CY) for each VSL and CSB incorporate 15%
shrinkage factor. The correct quantity shall be 60,920 CY.

ix. (Section 8.3.1.3) Please add the hydrogen sulfide requirements.

x. (Section 8.3.1.3) The gas monitoring locations are shown on Drawing M1, not MP-1.

xi. (Section 8.3.4) There are six (6), not 5, monitoring wells subjecting to semi-annual detection
monitoring program.

10. Financial Assurance
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i. The cost for closure and post closure must be revised accordingly. Additionally, the amount of
one million dollar for PACA is subject to annual inflation adjustment since the FY 2011 to
present. Please contact Sarah Rice at 919-707-8287, if you have any question of this matter.

11. Drawings
i. (Drawings S1, E2 through E6) What are the “Temporary Storage Areas A through E?” What are
wastes or products being stored in these areas?

ii. (Drawing E6) please add the proposed gas vent locations (approximately 66 vents – 3 vents per
acre according to the criterium specified in Section 8.1.2) to the drawing.

12. Appendix 1
i. The 2009 Franchise Agreement in the Appendix 1 expired; please provide the amended
Franchise Agreement dated in 2013, which expires on October 03, 2023.

13. Appendix 2
i. Refer to Comment No. 4.vii & viii.
Please contact me if you any questions of the comments.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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