9809_WilsonLF_Response_20210709

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SMITH{ GARDNER
ENGINEERS
July 9, 2021
Christine Ritter
Hydrogeologist
NCDEQ - Division of Waste Management
217 West Jones Street
Raleigh, NC 27603
RE: Westside CRD Landfill — Area 2
ABBRESS TEL WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 www.smithgardnerinc.com
Site Study and Design Hydrogeologic Report
Response to Comments
Dear Christine:
On behalf of Wilson County (County), Smith Gardner, Inc. (S+G) is pleased to provide a
response to comments received from you and Ms. Donna Wilson, via email correspondence
from May 3, 2021 through May 13, 2021 (attached), which are repeated below in italics
followed by S+G's response in bold.
Response to Comments (May 3, 2021, Christine Ritter)
Attachment A - Site Studv and Desian Hvdroaeoloaic Report
3.2 Wetlands and Streams
Please provide the USArmy Corps of Engineers confirmation letter of the wetland delineation
performed by Soil and Environmental Consultants, P.A.
Email correspondence from Samantha Dailey, US Army Corps of Engineers confirming
the wetland delineation is provided in Appendix A.1 of Attachment A.
2. 3.5 State Nature and Historic Preserves and 3.7 Threatened and Endangered Species
Please clarify the information presented in the February 73, 2020 letter found in Appendix A.4
which shows an amphibian: Anaxyrus quercicus /oak toad/ with a State status of significantly
rare'and federal status unclear in the table provided. This species was identified within a
one -mile radius of the project area by the NC Department of Natural and Cultural Resources.
The NC Natural Heritage Program letter states that if a federally -listed species is found
within the project area or is indicated within a one -mile radius of the project area, the NC
NHP recommends contacting the US Fish and Wildlife Service for guidance.
Section 3.7references the Threatened & Endangered Species Report prepared by Soil &
Environmental Consultants and was subsequently reviewed by the US Fish and Wildlife
Service (Appendix A.6/. In this report, a species list was generated to include 4 total

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Christine Ritter
July 9, 2021
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threatened, endangered, or candidate species and the US Fish and Wildlife Service review of
this report confirmed the conclusion of "no effect " or "may affect, likely no adversely affect "
for the 4 identified species.
Please clarify whether the Oak toad species is a federally -listed species and if so why it was
not identified in the S&EC Threatened & Endangered Species Report and provide the
supporting US Fish and Wildlife documentation recommended by the NC Natural Heritage
Program that the project area will not adversely affect this species.
Anaxyrus quercicus (oak toad) is not a federally -listed species. The table referenced in
the DEQ comment is located within the N.C. Natural Heritage Program (NHP) report and
uses the NHP standard reporting notations. The "---" notation under the "Federal
Status" column refers to no Federal Status. As such it is not a "federally -listed
species". All federally -listed species potentially affected by the project are included
within the Official Species List provided in the U.S. Fish & Wildlife Service (FWS) report
that was attached to the S&EC report in Appendix A.6 of Attachment A. Additionally, it
should be noted that the S&EC report was submitted to the FWS and they concurred
with the findings in emails dated May 13 and May 19, 2020, which were included in
Appendix A.6 of Attachment A of the August 2020 submittal.
3. 6.3.1 Soil Borinq Locations
Soil boring locations are not shown in Figure 2 as stated. Please provide a drawing with
locations of soil borings, piezometers, and monitoring wells referenced in Section 6.3. 1,
including the soil borings and piezometers identified in Table7. Soil borings SB-7, SB-2, SB-3,
SB-4, B-17, and B- l9 were not identified or illustrated on any figure in this report. An average
of one boring per acre is required in accordance 15A NCAC 13B. 1623 W Design
Hydrogeologic Report. Area 2 is 33 acres and clarification of the number and location of
borings is necessary to ensure the requirements of the Rule are met.
The Area 2 footprint has been revised to eliminate potential impacts to Areas of
Archaeological Significance (See Response to Comment 16 below). The revised Area 2
footprint is approximately 19 acres; therefore, the borings established meet the
requirements of the Rule.
4. 6.5.2 Long Term Water Levels (Mislabeled as 4.5.2)
A review of annual precipitation data from 2000 through 2079 indicated highest annual rainfall
amounts in 2015, 2016, and 2018. Given that piezometers PZ- 7, PZ-2, PZ-3, and PZ-4 were
installed in 2006, can you provide additional water level data from 2006 to the present for
these four piezometers to support long-term water table assumptions? 2020 was also one of
the wettest years on record in North Carolina. Can you provide additional water level data

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Christine Ritter
July 9, 2021
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from the four piezometers for 20201n addition to the May and June 2020 data provided in the
report?
6.7 Groundwater Contour Mapping,
6.9 Summary,
8.0 Landfill Gas Monitoring Plan
These 3 sections all make reference to Buck Branch on the west side of Area 2. Please revise
to reflect that Buck Branch is located on the east side of Area 2.
Subsection "Long Term Water Levels" has been revised to be labeled as 6.5.2 with all
consecutive subsections adjusted accordingly.
Additional water level data has been provided for PZ-1 - 4, as well as the recently
installed MW-1 - 6D from May 2020 to April 2021. Updated long term water level data
appears in Table 3 and Figures 3, 5, 6 and 7.
All references in sections 6.7, 6.9, and 8.0 to the location of Buck Branch have been
revised to reflect Buck Branch lying to the east of the proposed Area 2.
Attachment K - Water Quality Monitoring Plan
5. 2.1 Monitoring Frequency
Monitoring frequency will be conducted annually until which time a constituent is
detected in exceedance of the NC 2L/IMAC groundwater standard and the facility will
be required to conduct semi-annual water quality monitoring. In the event elevated
metals are detected, the facility may prepare an Alternate Source Demonstration or
calculate new site -specific background standards.
Additionally, a minimum of one sample from each well, background and down
gradient, must be collected and analyzed for the constituents before waste placement
in each cell or phase.
Please include this language in the Water Quality Monitoring Plan.
The monitoring frequency and minimum sampling requirement language has
been included in section 2.1 of Water Quality Monitoring Plan as described.

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6. 2.2 Proposed Monitoring Network and Analytical Parameters
The Table l referenced in this section is titled Monitoring Network and Well
Construction Details for Dunn Erwin Landfill - Harnett County. Please replace with
correct information and water quality monitoring network.
Please discuss the absence of proposed surface water sampling locations. Can
surface water samples be collected from Buck Branch Creek, located on the east side
of Area 2?
Table 1's title has been revised to "Soil Boring and Piezometer Construction
Westside C and D Landfill - Area 2 Expansion".
Surface water samples are not proposed in Toisnot Swamp due to the lack of
surface water in the swamp area. Two (2) surface water sample locations have
been added for Buck Branch Creek, which can be monitored if sufficient water is
available to sample.
7. 2.2.3 Analytical Parameters
This paragraph states that groundwater and surface watersamples will be collected
semi-annually for Appendix l VOCs and metals. Does the facility intend to collect
water quality samples on an annual or semi-annual basis?
Please state the 1,4-dioxane will be collected in addition to Appendix l parameters,
field parameters, and CDLFparameters.
For field measurement and sampling procedures, please reference the following EPA
guidance document in your Water Quality Monitoring Plan:
https://www. epa. got/quality/quality-system-and-technical-procedures-lsasd-field-
branches
The paragraph in section 2.2.3 has been revised to state groundwater and
surface water samples will be analyzed annually until a constituent is detected
in exceedance of its respective standard. This mirrors the same language as
described in comment 2a regarding monitoring frequency.
1,4-dioxane is included as an additional parameter to be analyzed for.
Made reference to the EPA guidance document for field measurement and
sampling procedures in section 2.2.3.

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July 9, 2021
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Attachment L - Landfill Gas Monitoring Plan
8. Please state that all landfill gas monitoring wells and facility structures will be
monitored for both methane and hydrogen sulfide.
Please replace the Landfill Gas Monitoring Data Form with the current form which
includes hydrogen sulfide and may be found on the last page of the NC Solid Waste
Section Landfill Gas Monitoring Guidance document:
https://files. nc.gov/ncdeq/Waste %20Managemen6DWM/SW/Field %200pera tions/Envi
ronmental%2OMonitoring/LandfillGasMonitoringGuidanceDocument. pdf
Section 2.1 states that all landfill gas monitoring wells and facility structures
will be monitored for both methane and hydrogen sulfide.
Appendix A of Attachment L has been revised to include the most current Landfill
Gas Monitoring Form which includes hydrogen sulfide.
Response to Comments (May 13, 2021, Donna Wilson)
Characterization Maps
9. Addzoning, residential structures, land use, and commercial and industrial buildings.
Provide a drawing that shows discernable topography elevation lines and surface
water drainage patterns of the disposal area footprint, including drainage ditches.
Remove the green hatch shading from the landfill footprint, so that the interior
features can be more easily viewed.
Figure 1A, 1 B and 1 C have been developed to include the additional requested
information. See Attachment A for the updated figures.
10. It should be noted that adjacent parcel No. 3732-5I -33I5, owned by Perry Dubose
Bullard, contains a closed LCID landfill, less than 2 acres. It was operated in the
1980s-1990s, ID number N0080. Latitude/longitude location is 35.726819,-77..870230.
Figure 1A has been updated to include this information.
17. Provide the recombination map, and property deed information for the landfill
property.
Attachment C provides the Overall Map and recombination deed identifying all
the parcels for the property.

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Christine Ritter
July 9, 2021
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12. County Approval
a. For the notification letters sent to the adjacent property owners, provide the
attachment that was sent with the letters.
b. For the certified letters that were not received or claimed, was there any other
communication provided regarding the County approval.
C. Were the residents living near the proposed landfill on Buck Branch Road and
Heather Court notified of the proposed meeting for County approval.
d. Provide the adjacent landowners identified on a map.
Attachment D.2 has been updated to include the letter notification attachment
that was sent to all property owners. For the certified letters not received or
claimed no additional communication was provided, nor was any additional
notification given to residents near the proposed landfill on Buck Branch Road or
Heather Court. However; as required by Rule the notification of public meeting
was advertised in the Wilson Times and a public meeting was held thirty (30)
days following notification.
13. Please provide the Countyzoning letter for the area.
County Zoning approval is included in Attachment C.2.
14. Section 2. 7.5should state the distance to the nearest private potable well (at the
mobile home residential areal, with description of where it 1s located.
Section 2.1.5 now states the location of the nearest private potable well and
distance from landfill footprint.
l5. Section 3.6 - Water Supply Watersheds - Provide the stream classification for Toisnot
Swamp for the area downgradient of the landfill.
The stream classification for Toisnot Swamp has been included in Section 3.6.
16. Cultural resources
Provide text discussion of each of the investigations, with summary of findings.
Provide the final report for the Phase 2 study. Provide Cultural Resources response to
Phase 2, and discuss their response.
Provide the cultural resource study and Cultural Resources response for the western
area of the landfill, including supporting infrastructure area.
Section 3.4 has been revised to include a summary of the investigations and
findings, and a complete copy of the reports is provided in Appendix A.3 of
Attachment A. Additionally, a copy of the September 11, 2017 SHPO
correspondence is included in Appendix A.3 requesting further surveys of
archaeological sites 31WL2 and 31WL178.

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July 9, 2021
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I7. On the wetlands sketch map and soil survey map, add the disposal area outline, not
hatched.
The Wetland Sketch Map is an original document and was conducted prior to
developing the disposal outline and does not include the disposal area outline.
Figure 2 of Attachment A includes the Wetland Survey and Stream Delineation
performed by S&EC. For reference, the disposal area outline has been included
on the soil map in Appendix A.2 of Attachment A.
19. Wetlands
a. Provide delineation correspondence/submittals and documentation,
confirming that the delineation covers the landfill disposal footprint and the
surrounding infrastructure area.
b. On some drawings, a blue line/perennial stream is shown on the center south
part of the disposal area, with reference to a report by Carolina Ecosystems.
On other drawings, this was shown as intermittent. Please clarify. Does this
area contain wetlands?
The waste footprint and surrounding infrastructure area are within the
evaluation limits shown on the Wetland Sketch Map in Appendix A.1 of
Attachment A, and do not contain wetlands. Also, as noted in the Response to
Comment 1 above, email correspondence from Samantha Dailey, US Army Corps
of Engineers confirming the wetland delineation is provided in Appendix A.1 of
Attachment A.
Please note that the Wetland Sketch Map is the formal delineation. The features
noted on the map have been surveyed and are included in the Existing Conditions
Mapping (Figure 2 of Attachment A). Other drawings and documentation
presented, specifically those presented by Carolina Ecosystems, have been
developed using online databases, and do not reflect the level of accuracy of the
field work conducted by S&EC.
19. Environmental Assessment Report
It is not correct to say that the landfill would have a compacted soil Liner. Layer,
subgrade, or similar term would be more appropriate.
The Environmental Assessment Report has been modified to read "compacted
subgrade".

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Christine Ritter
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20. The Socio-Economic Report
a. Section 2.0 should state that north of the landfill is the closest residential area,
containing 28 rental homes, at a distance ranging from 650 feet to 1300 feet.
b. The maps, calculations, and data should show/represent 1 mile from the
landfill boundary, instead of 1 mile from the center of the landfill.
C. There is a middle school located approximately 1 mile southwest from the
landfill, Darden Middle. The building itself is just over 1 mile, and the athletic
fields are within 1 mile of the landfill.
d. There is an elementary school about 7.1 miles southwest of the landfill,
Barnes Elementary.
e. There is a daycare facility 1 mile southwest of the landfill, Hattie Daniels Day
Care Center.
f There are apartment buildings less than 1 mile southwest of the landfill,
Beacon Pointe.
g. Churches within 1 mile should be included.
h. Describe communication regarding the proposed landfill with the nearby
community.
The Socio-Economic Report has been revised to evaluate the one -mile radius
from the property boundary and to address the items noted. The report has also
been revised to include sensitive receptors shown on the NCDEQ Community
Mapping Tool.

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Christine Ritter
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S+G trusts that the above responses and accompanying attachments adequately address
your comments. Should you have any additional questions, comments, or require further
clarification, please do not hesitate to contact me at your earliest convenience.
Sincerely, }�*#►������ ���i•j�#� 2021
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W. Michael Brinchek, P.E. '''+.�,l,g„SIS**`*
Senior Project Manager (ext. 128)
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Joan A. Smyth, P.G.
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