6301_MooreCo_CDLF_Cell6_Comment_PTCAppl_FID1387698-20200116

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Chao, Ming-tai
To:[e-mail]
Cc:Taylor, Mark; Stanley, Sherri; Powell, David C; Drummond, Jaclynne
Subject:Comments on the engineering portion of Moore County CDLF, Cell 6 PTC Application, 63-01
Dear Mr. Lambert:

The Solid Waste Section (SWS) completes a review of the engineering portions of the PTC Application (FID
1386972) for the Moore County C&DLF unit – Cell 6. Blow please find the comments on the permit
application:

1. Throughout the entire application, the professional seal & date must be provided in the Signature Page
in the final permit application.

Facility Plan
2. (Section 4.2) According to local government approval documents (transcript of 11/19/2019 public
meeting and PowerPoint presentation), the gross capacity of the C&DLF will be 2.5 million cubic yards
(MCY). Rule 15A NCAC 13B .0537(e)(2)(B) defines gross capacity of a C&DLF as “the volume of the
landfill calculated from the elevation of the initial waste placement through the top of the final cover,
including any periodic cover.” Therefore, the gross capacity of 2.63 MCY shown on Table 1 is incorrect.
Please revised the landfill capacity.

3. (Section 4.3.2) The Section states that the C&DLF will monitor hydrogen sulfide concentrations, a
constituent of explosive gases, in addition to methane gas monitoring. The action level of the hydrogen
sulfide concentration should be specified in this Section and Landfill Gas Monitoring Plan. 

Operations Plan
4. (Section 2.0, the first paragraph) The typical waste inspection/screening forms should be appended to
the Operation Plan.

5. (Section 4.0) Please describe operator training program and current training status.
i. The Operation Plan must describe the landfill operator training program according to NCGS
130A-309.25.
ii. The training program and certificate of each operating personnel should be placed in the operating record.

6. (Section 5.0) Pursuant to NCGS 130A-295.6(h1), the SWS prepares a guidance -“Approved Alternative
Daily Cover Materials (ADCM) for Use at Sanitary Landfill” dated July 21, 2017, which can be found in the
following link:
https://edocs.deq.nc.gov/WasteManagement/0/edoc/723214/ApprovedACM_Rev1_GDE_20170721.pdf?searchid
=f7d5b34c-664b-4338-930a-d1db93f0272f. If the County  
The C&DLF may apply the ADCM stated in the guidance as weekly cover over wastes at working face.  

7. (Section 8.2) Please describe the measures/approaches to manage a vehicle containing a “hot load” at each of the
likely scenarios: the vehicle approaches the scale house, the vehicle inside the landfill facility prior to reaching
landfill working face, and the vehicle at the landfill working face.

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8. (Section 8.2.1) The Solid Waste Section has prepared a standardize form to report a fire incidence which
can be downloaded from the link
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf
If the County wants to use the standardize form, please download a copy of the form and appended it to
the Operation Plan.

9. (Section 11.0 & Post-closure Plan) Leachate outbreaks at the landfill were observed and documented in
the facility audit/inspection reports. This section should describe the routine and non-schedule (such as
after a major storm event or hurricane) inspections for leachate outbreak, reporting requirement if
leachate breakout is observed, and the remedial measures including sampling and investigation
requirements. The guidance document for a leachate release sampling and investigation can be found in
the link:
https://edocs.deq.nc.gov/WasteManagement/0/edoc/1319075/MSW%20Leachate_Release_Sampling_G
uide.pdf?searchid=22b91c58-be48-4f48-97ec-ae3766e88565.

10. (Section 12.0) The following record or report should be placed in the operating record:
i. Historical asbestos waste buried locations – sketch, drawing or GPS coordinates.
ii. Open burning permit or approval documents and fire incurrence reports (Section 8.0)
iii. Leachate outbreak and follow-up investigation plan/report or correction plan/report.

11. (Section 14.2) The Section describes operation of yard waste collection units at the landfill facility
should be revised and modified coordinating with the proposed Cell 6 development and operation.
i. There are likely two (2) yard waste collection sites being operational in the future – one (11
acres) located on the northwest corner of the landfill facility and the other (2.8 acres) located on
the northeast side of MSW transfer station. The existing one (8.1 acres) abut to the Cell 5 of the
C&DLF will be not available if the Cell 6 is approved for construction and operational.
ii. The Drawing 02 may be revised (by deleting the 8.1-acre unit from drawing) accordingly.
iii. The mentioned Operation Plan (DIN 18523) approved February 27, 2013 may be out-of-date
because the Rule Section 1400 is readopted effective November 1, 2019. Please revise the yard
collection operation plan according to the new rule.

12. (Section 14.3) For operating a Temporary Storm Debris Site (TDDSS), please provide the requested
information below:
i. Please provide the Permit No. of this TDDSS. 
ii. Describe the size (in acreage) of the TDDSS.  
iii. The TDDSS shall not be activated and receive disaster debris without the approval from the Solid Waste
Section.  
iv. When the site is activated following an emergency event:  
(a) Only PERMITTED wastes for the C&DLF may be accepted in the TDDSS. If the County
intends to collect MSW disaster debris as well (the permitted MSW transfer station is on-
site), the separate TDDSS unit for MSW streams must be established and obtained an
approval from the SWS. Through the waste screening processes, all non-conformance or
prohibited wastes shall not be accepted at this unit; any inadvertently accepted non-
conformance or prohibited wastes shall be properly handled, managed, and disposal off
according to the approved Operation Plan.
(b) Activation must be requested and received from the Regional Environmental
Senior Specialist for the facility.
(c) All permitted debris must be removed from the TDDSS within six (6) months from the
activation date.
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(d) Storm debris must be placed in rows with a maximum of 12 feet high and 25 feet wide. A
minimum of 15 feet row aisles must be maintained to separate piles.
(e) Adequate isle lines shall be established and maintained for each waste stockpile for
firefighting.

Closure and Post-Closure Plan
13. (Section 2.2) Please address the following concerns;
i. The closure cover of the C&DLF shows on Drawing 07 should be the final grades, including the
3-feet final cover system, not the top of the intermediate cover layer. (ref Comment No. 1)
ii. The approved gross capacity, not the net capacity, of the C&DLF – Phases 1 through 8 should be
2.5MCY. The soil volume amount (approximately 236,800 CY) & net waste capacity
(approximately 2,131,200 CY= gross capacity – final cover soil amount – weekly covers) stated
in this section should be revised accordingly.

14. (Section 2.6) The drawing that shows the gas vent layout/locations over the closed landfill cover is not
available. Please provide the gas vent layout drawing. 

15. What is the benchmark associated with the landfill? Is it the waste edge marker? The County should
maintain permanent physical markers that accurately identify the edge of the approved waste footprint for all
disposal units inside the landfill facility. 

Engineering Plan
16. (Table 1) The safety factor of 2.34 for Analysis Condition 2 – Rotational is likely a typo.
Appendix B Technical Specifications
17. (Earthwork 310000)
i. Part 1.03A. What is the relationship of the borrow sources specification and the geotechnical
evaluation/investigation study mentioned in Section 4.2 of the Facility Plan?
ii. Part 1.03D.
a. The surveyor for the project shall be licensed in the State of North Carolina.
b. For a sloped surface, the required thickness of each layer shall be measured perpendicularly
to the surface of the slope.
iii. Part 2.03 is not relevant to the Moore County C&DLF project. The material specification shall
meet the requirements for the proposed landfill base grade [per Rules 15A NCAC 13B .0540(2)
& (5)] & the final cover systems [per Rule 15A NCAC 13B .0543] including a test pad (Section
4.3.3 of the Facility Plan) and soil shear strength requirements (for the compact clay liner and the
vegetative soil layer) concluded from the slope stability analysis in the Engineering Plan and
minimum thickness of each components of the final cover system according to the Closure Plan.
iv. The section should provide construction specifications for each component of the landfill base
system and final cover system – intermediate soil cover layer (6 to 12 inches), 18-inch-thick
compacted clay liner (permeability, in-place density, soil shear strength), and 18-inch-thick
vegetative support layer (soil shear strength).

18. Appendix B should include technical specification for landfill gas venting system.

Appendix E – CQA Plan
19. This CQA Plan is too genetic, not the project specific one. All components associated with geosynthetic
liner material – geomembrane (HDPE or LLDPE) and geosynthetic clay liner, geocomposite drainage
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material, and components associated with leachate collection and removal system should be removed
from the CQA Plan.

20. (Section 3.2.1) For each borrow the following requirements should be considered:
i. Soil shear strength testing requirement and passing criteria (concluded from the slope stability
analysis) for the earthen material used for final cover system.
ii. The soil types (per Rule 15A NCAC 13B .0540(2)(b) for the earthen material used for landfill
base grade.
iii. Should a borrow have contamination concerns, the earthen material must free from any land-use
restriction by passing the criteria established in the NC Preliminary Soil Remediation Goals
(PSRG) dated December 2019.

21. (Section 3.2.2) The Plan should describe the test pad including testing (methods and frequencies) on
material and construction approaches for the final soil cover system.

Drawings
22. The final elevation of the landfill cover is at 475 feet above mean sea level (amsl) as noted in the
previous permits (FID 1236050 & DIN 24740) and approved permit applications (FID 1236052 & DIN
24737 & 11236) and is not the elevation of the intermediate cover. Please revised the notes of Drawings
07 & 08. 

23. (Drawing 09) The haul road associated with landfill operation sequence Phase 6 -Years 1 through 5 is
likely not operational. The haul road directly leads to the working face inside the Cell 6 for waste
disposal is a must. The initial working face at the Cell 6 should be added to the drawing.

Regarding if NCGS 153A-160 is applicable to the Cell 6 expansion, the legal councilor for the SWS is working
on the case right now. Upon receiving the final decision, the SWS will inform you. Please contact me if you
have any question on the above-mentioned comments. Thank you and have a wonderful evening.

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From: Chao, Ming‐tai  
Sent: Friday, January 03, 2020 10:24 AM 
To: Taylor, Mark <[e-mail]> 
Cc: Drummond, Jaclynne <[e-mail]> 
Subject: Moore County CDLF, Cell 6 PTC Application, 63‐01 

Hi Mark:

Happy New Year.

On 12/23/19 the Solid Waste Section (SWS) received a hard copy of the PTC Application for Cell 6 of the
Moore County C&DLF, 6301-CDLF-1992. You left a note inside the submittal and stated that an electronic
copy of the PTC application will be sent to the SWS later. After talking with Jackie Drummond today, I found
out that she has not received any hard copy of the PTC application at all.

According to public meeting minutes, the SWS understood that that C&DLF has a tight schedule for this new
PTC & PTO. Since Jackie and I work at two different offices, we can not review the permit with a single copy
of the application. Please send a hard copy of the PTC application ASAP to Jackie ( she will review the design
hydro and all monitoring plans) at the following address:

Ms. Jaclynne Drummond
Solid Waste Section
2090 U.S. 70 Highway
Swannanoa, NC 28778-8211

Please place an electronic copy of the PTC application in a drop-off box so I can retrieve from there and then
upload the document to DWM Laserfiche. Thank you for your corporation on this matter.

 Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]