6301_MooreCo_CDLF_Cell6_2ndComment_PTCAppl_FID1401154_20200420

From:Chao, Ming-tai
To:Taylor, Mark
Cc:Stanley, Sherri; David Lambert; Randy Gould, PE (Moore Co Public Works); Kirkman, Rachel; DiFrancesco, Ron; Powell, David C; Drummond,Jaclynne
Subject:Comments on the revised Moore County CDLF, Cell 6 PTC Application, 63-01, FID
Date:Monday, April 20, 2020 2:38:00 PM
Attachments:image003.emzimage006.pngimage014.pngimage016.wmzimage005.png
image009.pngimage013.pngimage022.pngimage023.png
Hi Mark:

The Solid Waste Section completes a review of the revised PTC-Cell 6 Application and has few comments below:

1. (Operation Plan - Section 9.2.1) The Bullet Item 3 describes the approach of dealing with a hot load by water.This approach is applicable, only if the County can demonstrate how to manage the following aftermath:i. Since the water or liquid contacting any waste is considered as leachate, per Rule 15A NCAC 13B.0101(24); in this Section the County must describe how to manage the leachate generated from thisevent which includes collection, removal and final treatment or disposal. ii. The hot load may result from illegal or incidental disposal of an oxidizing waste which may undergodangerous reaction with water, such as explosion which is used to put off a fire.
The SWS strongly recommend the County to select other approaches to manage an observed hot load such asusing soil/ earthen material. 2. (CQA Plan – Section 3.2.2 & Technical Section 310000) The requirements stated in Rule 15A NCAC 13B.0540(5) shall be incorporated into the plan or technical specification because the major soil excavationactivities are expected for Cell 6 construction according to the cross-sections on Drawing DH-5. 3. (Drawing 09, Phase 5 Build Out (0 year)) The base grades inside the constructed Cell 6 are different fromthose on Drawings 05 & DH-4.
The County stated the Operation Plan for on-site Yard Waste Facility is not a compost facility and Section Rule 1400is not applicable to this facility. Based on the narratives stated in the Operation Plan, the SWS determines that thefacility is a treatment and process facility being operated under a new permit No. 6301-TP-2013 with a 5-year permitcycle. The facility is not a sanitary landfill; therefore, the life-of-site permit as defined in NCGS 13A-294(a2) is notapplicable. The facility is not a compost facility, the 10-year permit cycle, per Rule 15A NCAC 13B .1401(c) is notapplicable, either. Other recycle or waste recovery units will be incorporated into the life-of-site permit at this time. When the C&DLF unit is closed in the near future, the recycling or waste recovery units and the yard waste T&Punits, under the assumption that the County intends to continue operating the units at the landfill property, will beincorporated into a single 5-year permit (maybe call as a post-closure land use permit) for operation. Please contact me if you have any questions on the above-mentioned comments or permit decision.
From: Chao, Ming-tai
Sent: Wednesday, April 08, 2020 9:49 AM
To: 'Taylor, Mark' <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; 'David Lambert' <[e-mail]>; 'Randy Gould, PE
(Moore Co Public Works)' <[e-mail]>; 'Kirkman, Rachel' <[e-mail]>; 'DiFrancesco,
Ron' <[e-mail]>
Subject: RE: [External] RE: Comments on the engineering portion of Moore County CDLF, Cell 6 PTC Application, 63-01

Dear all: The received document is uploaded to Laserfiche with a FID 1395527.

From: Chao, Ming-tai
Sent: Wednesday, April 08, 2020 9:28 AM
To: Taylor, Mark <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; David Lambert <[e-mail]>; Randy Gould, PE (Moore
Co Public Works) <[e-mail]>; Kirkman, Rachel <[e-mail]>; DiFrancesco, Ron
<[e-mail]>
Subject: RE: [External] RE: Comments on the engineering portion of Moore County CDLF, Cell 6 PTC Application, 63-01

Hi Mark: I hope you and your family stay safe and healthy too. This COVID19 messes up the entire world and may create anuncertainty for this permit process down the road. I have a plan but can not share with you all until I get my bossesapproval. I will start review the submittal today, and the document will be uploaded to Laserfiche after I receive the reviseddrawings. Take care.

From: Taylor, Mark <[e-mail]>
Sent: Wednesday, April 08, 2020 9:03 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; David Lambert <[e-mail]>; Randy Gould, PE (Moore
Co Public Works) <[e-mail]>; Kirkman, Rachel <[e-mail]>; DiFrancesco, Ron
<[e-mail]>
Subject: [External] RE: Comments on the engineering portion of Moore County CDLF, Cell 6 PTC Application, 63-01

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]

Hello Ming,

I hope you and your associates are staying safe and secure during this challenging time. Please find attached our Response to
Comments letter addressing your comments on the subject application transmitted by email on January 16, 2020 (follows
below).

Also attached are the revised plans and new appendices referenced in the letter. You will receive a separate email providing
access to a ftp server to download the revised drawings (7 total), also referenced in the letter. Once you are satisfied with the
revised documents, we will transmit hard copies for insertion into the ring binders previously submitted.

We believe we have addressed all of your comments sufficiently to satisfy your expectations as you and I and Mr. Lambert
discussed in recent weeks.

We look forward to hearing from you and to the expeditious approval of the permit.

Thank you and best regards,

Mark

Mark A. Taylor, PE, MSc
Senior Consultant
Golder Associates NC, Inc.
5B Oak Branch Drive, Greensboro, North Carolina, USA 27407
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From: Chao, Ming-tai <[e-mail]>
Sent: Thursday, January 16, 2020 3:24 PM
To: David Lambert <[e-mail]>
Cc: Taylor, Mark <[e-mail]>; Stanley, Sherri <[e-mail]>; Powell, David C
<[e-mail]>; Drummond, Jaclynne <[e-mail]>
Subject: Comments on the engineering portion of Moore County CDLF, Cell 6 PTC Application, 63-01

Dear Mr. Lambert: FID 1387698The 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 thefinal permit application. Facility Plan
2. (Section 4.2) According to local government approval documents (transcript of 11/19/2019 public meeting andPowerPoint presentation), the gross capacity of the C&DLF will be 2.5 million cubic yards (MCY). Rule 15ANCAC 13B .0537(e)(2)(B) defines gross capacity of a C&DLF as “the volume of the landfill calculated fromthe 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 constituentof explosive gases, in addition to methane gas monitoring. The action level of the hydrogen sulfideconcentration 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 theOperation 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 DailyCover 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 CountyThe 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 thelikely scenarios: the vehicle approaches the scale house, the vehicle inside the landfill facility prior to reaching landfillworking face, and the vehicle at the landfill working face. 8. (Section 8.2.1) The Solid Waste Section has prepared a standardize form to report a fire incidence which can bedownloaded from the linkhttps://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdfIf the County wants to use the standardize form, please download a copy of the form and appended it to theOperation Plan. 9. (Section 11.0 & Post-closure Plan) Leachate outbreaks at the landfill were observed and documented in thefacility audit/inspection reports. This section should describe the routine and non-schedule (such as after amajor storm event or hurricane) inspections for leachate outbreak, reporting requirement if leachate breakout isobserved, and the remedial measures including sampling and investigation requirements. The guidancedocument 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_Guide.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 berevised 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 northeastside of MSW transfer station. The existing one (8.1 acres) abut to the Cell 5 of the C&DLF will be notavailable 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 becausethe Rule Section 1400 is readopted effective November 1, 2019. Please revise the yard collectionoperation plan according to the new rule. 12. (Section 14.3) For operating a Temporary Storm Debris Site (TDDSS), please provide the requestedinformation 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 WasteSection. 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 intendsto collect MSW disaster debris as well (the permitted MSW transfer station is on-site), the separateTDDSS 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 beaccepted at this unit; any inadvertently accepted non-conformance or prohibited wastes shall beproperly handled, managed, and disposal off according to the approved Operation Plan.
(b) Activation must be requested and received from the Regional Environmental Senior Specialist forthe facility.
(c) All permitted debris must be removed from the TDDSS within six (6) months from the activationdate.
(d) Storm debris must be placed in rows with a maximum of 12 feet high and 25 feet wide. Aminimum 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 Plan13. (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-feetfinal 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 be2.5MCY. The soil volume amount (approximately 236,800 CY) & net waste capacity (approximately2,131,200 CY= gross capacity – final cover soil amount – weekly covers) stated in this section shouldbe revised accordingly.
14. (Section 2.6) The drawing that shows the gas vent layout/locations over the closed landfill cover is notavailable. 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 maintainpermanent physical markers that accurately identify the edge of the approved waste footprint for all disposal unitsinside 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 Specifications17. (Earthwork 310000)i. Part 1.03A. What is the relationship of the borrow sources specification and the geotechnicalevaluation/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 thesurface of the slope.iii. Part 2.03 is not relevant to the Moore County C&DLF project. The material specification shall meetthe requirements for the proposed landfill base grade [per Rules 15A NCAC 13B .0540(2) & (5)] & thefinal cover systems [per Rule 15A NCAC 13B .0543] including a test pad (Section 4.3.3 of the FacilityPlan) 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 eachcomponents of the final cover system according to the Closure Plan.iv. The section should provide construction specifications for each component of the landfill base systemand final cover system – intermediate soil cover layer (6 to 12 inches), 18-inch-thick compacted clayliner (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 Plan19. This CQA Plan is too genetic, not the project specific one. All components associated with geosynthetic linermaterial – geomembrane (HDPE or LLDPE) and geosynthetic clay liner, geocomposite drainage material, andcomponents 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 basegrade.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 materialand 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 previouspermits (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 notoperational. The haul road directly leads to the working face inside the Cell 6 for waste disposal is a must. Theinitial 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 thecase right now. Upon receiving the final decision, the SWS will inform you. Please contact me if you have anyquestion on the above-mentioned comments. Thank you and have a wonderful evening.

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 MooreCounty 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 notreceived 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 theapplication. Please send a hard copy of the PTC application ASAP to Jackie ( she will review the design hydro andall monitoring plans) at the following address: Ms. Jaclynne DrummondSolid Waste Section2090 U.S. 70 HighwaySwannanoa, 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 uploadthe document to DWM Laserfiche. Thank you for your corporation on this matter.