5103_JohnstonLF_response_20200122

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
SMITH GARDNER
ADDRESS TEL WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 [e-mail]
January 22, 2020
Ms. Donna Wilson
Engineering Project Manager
don na.wilson(ancdenr.gov
Ms. Christine Ritter
Hydrogeologist
christine.ritter(ancdenr.gov
NC DEQ - Division of Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699
RE: Johnston County MSW Landfill - Phase 6 (Permit No. 51-03)
Permit to Construct Application
Response to Review Comments
Dear Ms. Wilson and Ms. Ritter:
On behalf of Johnston County, Smith Gardner, Inc. (S+G) would like to respond to the
comments in your emails dated and received by S+G via email on January 8 and 9, 2020 (see
attached). All comments are repeated below in italicsfollowed by our response in bold.
D. Wilson 1/8/2020 Email
I. For clarification, what was the reason for the decrease in footprint of Phases 6
through 10 in the northeast corner?
The change in size of the footprint of Phases 6-10 was due to the design of a future
sediment basin adjacent to future MSW Phase 9. In prior versions of the Facility and
Engineering Plan for the site, this basin was only shown conceptually.
2. In Phases Sand 6, please provide a description of which leachate line clean -out
points will be covered over and not accessible in the future, and whether those
leachate lines will be accessible for cleaning from the sump end. Will the leachate
lines in either Phases 5 or 5 be extended to the adjacent future phases?
Phase 5 Cleanouts: Development of Phase 6 will cause three cleanouts along the
west side of Phase 5 to be covered over. Upon future development of Phase 10, two
cleanouts on the south end of Phase 5 will be covered over. Three cleanouts along
the east side of Phase 5 will remain long-term and these cleanouts will allow the
flushing of the majority of the leachate collection system piping within Phase 5. The
northernmost cleanout along the east side of Phase 5 leads directly to the gravity
sump near the northwest corner of Phase 5.

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Ms. Donna Wilson and Ms. Christine Ritter
January 22, 2020
Page 2 of 4
Phase 6 Cleanouts: Future development of Phase 7 will cause the westernmost
cleanout at the south end of Phase 6 to be covered over. The central cleanout on the
south end of Phase 6 can be extended during construction of Phase 7. This extended
cleanout and the easternmost cleanout at the south end of Phase 6 will remain
accessible until future development of Phase 10. All leachate collection pipes in
Phase 6 will remain accessible long-term from the north end of Phase 6.
3. How will methane wells and vents be prevented from being located in areas of
asbestos disposal?
Although facility staff will record the approximate location and elevation of asbestos
waste once placed and covered and maintain in the facility operating record, given
the random nature of when asbestos may arrive for disposal at the site and where it
may be placed, it is virtually impossible to avoid asbestos when drilling landfill gas
(LFG) extraction wells or vents and associated piping. Therefore, waste disturbing
activities in areas with known or suspected asbestos -contaminated waste must be in
compliance with National Emission Standards for Hazardous Air Pollutants
(NESHAP) regulations as administered by the NC Department of Health and Human
Services (DHHS) Division of Public Health. As is S+G's normal practice, an Asbestos
Work Plan is prepared and submitted to the NC DHHS Division of Public Health ahead
of planned waste disturbing activities (such as drilling LFG extraction wells) for
review and approval. This plan includes procedures to be used to control emissions
during the excavation, storage, transport, and ultimate disposal of the excavated
potential asbestos -containing material.
4. Operations Manual -Section 3.2.1.2 -When is the leachate production numbers
compared to historic numbers to determine if there has been a reduction, and has
this, up to now, led to any flushing of lines and camera inspection, other than
construction ?
The County has not observed obvious drops in leachate generation from the leachate
collection systems at the site which were not believed to be otherwise associated
with changes in rainfall, changes in temperatures, or operations (filling, covering,
flow meter issue, etc.). Flushing of all accessible leachate collection piping at the
site occurs routinely on a periodic basis.
5. Section 3.2.2 -Has flow in the leak detection layer reached the action leakage rate?
How many times, and what were the response actions?
No. Based on 2014-2019 records, a maximum of 10,626 gallons was collected from
the Phase 4A leak detection system in any one month (November 2015). This equates
to approximately 12 gallons/acre/day (gpad) based on the area of Phase 4A (29.4
acres) and is well below the 100 gpad action leakage rate. Typical observed flow
rates in the Phase 4A leak detection system are approximately 3 gpad.

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Ms. Donna Wilson and Ms. Christine Ritter
January 22, 2020
Page 3 of 4
6. Please provide an update to the Corps of Engineers wetlands permit.
Johnston County anticipates issuance of 401 and 404 water quality certifications from
the NC DEQ Division of Water Resources and the US Army Corps of Engineers,
respectively, for stream and wetland impacts related to development of Phase b in
the very near future (January or February 2020).
C. Ritter 1/9/2020 Email
The NC Solid Waste Section is requiring additional information regarding the
Leachate Lagoon Monitoring Points LL-1, LL-2, LL-3, and LL-4. No construction data
was provided for these four monitoring points in Table I Well Construction
Information located in the Water Quality Monitoring Plan. Are these piezometers or
monitoring wells? To accurately monitor potential releases from the Leachate
lagoon, it is necessary for the monitoring points to have a well screen positioned to
capture shallow groundwater flow. Please provide information to demonstrate that
the monitoring points are designed and constructed to monitor shallow groundwater
in the vicinity of the lagoon. If this data is unavailable, the Section may require new
monitoring wells to be installed and positioned downgradient of the leachate lagoon
between the lagoon and the two creeks on the northern and western sides of the
lagoon.
Monitoring wells 1-1-1 through LL-4 were installed in 1997 and have been monitored
semi-annually since. Well construction records indicate the wells extend to depths
ranging from approximately 15 feet to 28 feet below grade and are screened across
the uppermost water table. Copies of the well logs are included in the revised Water
Quality Monitoring Plan (See Comment #2 below) for your review.
2. Additionally, within the Water Quality Monitoring Plan, Section 2.2.1 Existing Network
states that " Leachate will be monitoring in accordance with the guidance detailed in
Section 1.4. Section 1.4 of the Water Quality Monitoring Plan does not contain
guidance for leachate monitoring. Please clarify and revise appropriately.
The sentence has been revised to say "Leachate will be monitored for the parameters
detailed in Section 2.2.3." Additionally, the Water Quality Monitoring Plan has been
revised to include the available boring logs for the monitoring network.

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Ms. Donna Wilson and Ms. Christine Ritter
January 22, 2020
Page 4 of 4
Please contact us at your earliest convenience if you should have any questions or comments
on this submittal.
Sincerely,
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SMITH GARDNER, INC.
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DocuSigned by:
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Pieter K. Scheer, P.E.
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DocuSigned by: SEAL069
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Joan A. Smyth, P.G. - A_
Vice President, Senior Hydrogeologis 2/2020
6oan(asmithgardnerinc.com
Attachments: DWM Comments (January 8 & 9, 2020 Emails)
Enclosure: Revised Water Quality Monitoring Plan
CC: Sherri Stanley, NC DEQ
Rick Proctor, Johnston County

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Pieter Scheer
From: Wilson, Donna J <[e-mail]> on behalf of Wilson, Donna J
Sent: Wednesday, January 8, 2020 6:27 PM
To: Pieter Scheer ([e-mail])
Cc: Proctor, Rick; Ritter, Christine; Hammonds, Andrew
Subject: Johnston County Landfill, review comments
Flag Status: Flagged
Hello Pieter,
I've reviewed the application for the Phase 4A vertical expansion, and the PTC for Phase 6 and I have the following
questions and comments:
1. For clarification, what was the reason for the decrease in footprint of Phases 6 through 10 in the northeast
corner?
2. In Phases 5 and 6, please provide a description of which leachate line clean -out points will be covered over and
not accessible in the future, and whether those leachate lines will be accessible for cleaning from the sump
end. Will the leachate lines in either Phases 5 or 6 be extended to the adjacent future phases?
3. How will methane wells and vents be prevented from being located in areas of asbestos disposal?
4. Section 3.2.1.2 — When is the leachate production numbers compared to historic numbers to determine if there
has been a reduction, and has this, up to now, led to any flushing of lines and camera inspection, other than
construction?
5. Section 3.2.2 - Has flow in the leak detection layer reached the action leakage rate? How many times, and what
were the response actions?
6. Please provide an update to the Corps of Engineers wetlands permit.
I had some questions about groundwater monitoring for the area downgradient of the leachate lagoon, and Christine
Ritter may be contacting you to discuss.
It is noted that the overall landfill footprint of Phases 6 through 10 has changed with this submittal, and that a portion of
the northeast corner has been reduced. The acreage has decreased by 2.1 acres. The Phase 4A expansion is an increase
of 126,693 cubic yards. The decrease of capacity in Phases 6 through 10 is 549,933 cubic yards, resulting in an overall
decrease of 423,240 cubic yards.
The official approved capacity of the lined landfill units, including both MSW and C&D units, is 19,900,000 cubic
yards. This includes MSW Phases 4A and 5 through 10, and C&D Areas 1 and 2. An increase of 10% or more of this
volume would be a substantial amendment.
Responses to comments should be incorporated into the text of the application. Only the pages or parts of the
application that have changes should be resubmitted.
If you have any questions please let me know.
Thanks, Donna

DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Donna J_ Wilson
Engineering Project Manager, Solid Waste Section
DiviEion of 9asre Managernent
North Carolina Department ofEniironmental Quality
919.707.8255 (Office)
Donna_ ilson [ denr_go -
Physical Address: 217 Nest Jones Street, Raleigh SIC 27603
Mailing address: 1646 Mail Service Center, Raleigh SIC 27699
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DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
Pieter Scheer
From: Pieter Scheer <[e-mail]> on behalf of Pieter Scheer
Sent: Monday, January 13, 2020 2:52 PM
To: Scheer, Pieter
Subject: FW: Johnston County Landfill, review comments
From: Ritter, Christine [maiIto: [e-mail]]
Sent: Thursday, January 9, 2020 9:40 AM
To: Pieter Scheer ([e-mail]); Rick Proctor; Joan Smyth ([e-mail])
Cc: Wilson, Donna J; Ulishney, Adam
Subject: RE: Johnston County Landfill, review comments
Good morning -
The NC Solid Waste Section is requiring additional information regarding the Leachate Lagoon Monitoring Points LL-1,
LL-2, LL-3, and LL-4. No construction data was provided for these four monitoring points in Table 1 Well Construction
Information located in the Water Quality Monitoring Plan. Are these piezometers or monitoring wells? To accurately
monitor potential releases from the leachate lagoon, it is necessary for the monitoring points to have a well screen
positioned to capture shallow groundwater flow. Please provide information to demonstrate that the monitoring points
are designed and constructed to monitor shallow groundwater in the vicinity of the lagoon. If this data is unavailable,
the Section may require new monitoring wells to be installed and positioned downgradient of the leachate lagoon
between the lagoon and the two creeks on the northern and western sides of the lagoon.
Additionally, within the Water Quality Monitoring Plan, Section 2.2.1 Existing Network states that "Leachate will be
monitoring in accordance with the guidance detailed in Section 1.4. Section 1.4 of the Water Quality Monitoring Plan
does not contain guidance for leachate monitoring. Please clarify and revise appropriately.
Thank you.
Christine Ritter
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DocuSign Envelope ID: 3089CC5D-2DE3-4DA7-A6D9-B5C00607E1B9
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