9809_WilsonCDLF_reviewcomments_20220628

Wilson, Donna J
From: Wilson, Donna J
Sent: Tuesday, June 28, 2022 9:10 AM
To: Michael Brinchek ([e-mail])
Cc: Stanley, Sherri; Ritter, Christine; College, John H
Subject: Wilson County C&D Landfill, Area 2 PTC comments, 9809-CDLF-2004
I've completed review of the PTC application for the Wilson County C&D Landfill. Below are the complete comments,
including my earlier preliminary comments. Some of the comments have been already addressed.
1. Provide a cover sheet for the Permit to Construct application, table of contents, and executive summary.
2. All portions of the application, other than the Siting location restrictions for Area 2, should apply to and include
both Area 1 and Area 2 (e.g., Facility Plan, Operating Plan, Closure plan, etc.). The cover sheets of these
different sections should state "Areas 1 and 2." This includes tables and volumes.
3. Asbestos waste disposal must be within the permitted C&D landfill footprint. Provide information on the history
of operation of the separate asbestos disposal area.
4. The onsite LCID landfill will need to meet the new LCID rules. Existing LCIDs are required to meet the new rules
or close by Jan. 1, 2026.
5. Facility Plan:
a. Table 1, Capacity — The table should confirm that the gross capacity represents the volume from the
bottom of waste to the top of the final cover. Same comment for the Closure Plan.
b. Provide a drawing that incorporates the buffer distances to the property line, residences, surface, water,
and wells. Show the closest residences and well on the drawing.
c. Section 7 — Settlement. Is the required 4 foot separation distance, post -settlement, to the seasonal high
groundwater table met, considering the maximum 1.5 foot calculated settlement? Add specific
information for this in the text.
d. The traffic study and environmental impact study should be discussed in this section, per the new rules
changes, and a reference to their location in the application.
e. Tear -off shingle recycling is mentioned. If this is still in operation, it should be marked on a map, the
approved plan and letter from Dec. 2012 should be included in an appendix, or it should be updated as
necessary.
6. Technical specs - Site preparation - Specify the maximum storage time of concrete, pipes, etc. that will be
removed during land clearing. Or address this in another section of the report.
7. Technical specs and CQA — The standards and requirements of the top 2 feet of the subgrade are not adequately
covered. This should be addressed for both in -place and constructed subgrade. It appears that the discussion of
the constructed subgrade is included in the Embankment sections, and these sections allow soil types not
approved for the landfill subgrade (for example, SP). The standards for the landfill subgrade are specific to the
rules, whereas other embankment construction does not have these standards.
8. Appendix A of the Facility Plan —The Final Cover Infiltration Analysis summary does not show that infiltration of
the alternate final cover is less than the regulatory final cover.
9. CQA — Section 2.6 —The Final CQA report must contain the statement by the project engineer that construction
was completed in accordance with the CQA plan, the conditions of the permit to construct, and the
requirements of NC Solid Waste Rule 15A NCAC 13B .0541.
10. Final cover — The text description (Facility Plan and elsewhere) should include the side slope final cover with the
12-inch intermediate cover below.
11. Drawings:
a. Final cover side slope detail should include both the 24 inch soil layer and the 12 inch intermediate
layer.
b. Provide a detail drawing of the alternative gas vent that is not drilled.

c. As noted in the Facility Plan, the existing borrow area is shown on figure S1. The borrow area location
should be clarified on the drawing.
d. Show the locations of the waste tire, scrap metal, white goods, and shingle recycling areas on Drawing
S1.
12. Provide status of the Stormwater and Erosion & Sedimentation Control permits.
13. Operating Plan:
a. Section 3.1.2 - Describe methods to prevent leachate from the active face from entering the stormwater
features, for example, the placement of a soil berm at the base of the active slope.
b. Describe methods for compliance with windblown litter/waste, Rule .0542 (g). At the conclusion of each
operating day, all windblown material resulting from the operation shall be collected and disposed of by
the owner or operator.
14. Water quality monitoring plan — Why are wells 2 and 5 proposed within the landfill footprint, requiring future
abandonment, instead of outside the landfill footprint? It appears that areas downgradient of Phase 2 are not
represented in monitoring, based on the potentiometric surface maps. Please clarify.
15. Landfill gas monitoring plan —The closest residences should be added to this map, on Heather Ct. and Buck
Branch Cr. Monitoring points are needed in direct line with the closest residences, unless otherwise dictated by
geologic materials for probable gas migration.
16. Closure costs — It should be stated that it is based on the largest area requiring closure at any given time. This
would be the area requested to be approved for the next PTO (or all future areas), and all areas containing
waste that are not closed. Provide a note indicating what the 8.1 acres listed consists of. If it is intended to be
Phases 1 and 2, it would be 9.1 acres.
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DonnaJ" Wilson
Engineering Project Vfanager' .Solid Pv'aste .Section
Division of MasteManagement
North Caroli_ua Department of Environmental Quality,
919-707-8255 (Office)
D0nna.1Vi1SGn,dAcdenr_ goy"
Physical Address: 217 West Jones Street, Raleigh SIC 27603
_flailing address: 1646 Dail Service Center, Raleigh NC 27699
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