79J_SamSmithLCIDcomment_DIN25750_20160314.pdf

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Acting Director
Solid Waste Section

March 14, 2016

Mrs. Ella Mae Richardson &
Mr. Sam W. Smith, Jr.
Sam W. Smith, Jr. Inc. LCID Landfill
P.O. Box 428
Eden, NC 27288

Subject: Comments on the Permit Amendment Application for a Five-Year Permit Review
Sam W. Smith, Jr. Inc. Land Clearing and Inert Debris (LCID) Landfill
Rockingham County, North Carolina
Permit No. 79J-LCID, Document Identification Number (DIN) 25750

Dear Mrs. Richardson & Mr. Smith:

On February 22, 2016 the Division of Waste Management (DWM), the Solid Waste Section
(SWS) received the electronic copy of the permit amendment application for a five-year permit
review of the above-referenced landfill facility. This permit application that is prepared by
William E. Mitchell Associates was logged and scanned to the document tracking system with a
document identification number (DIN 25659). Via the February 22, 2016 e-mail messages to
Mrs. Richardson, the SWS acknowledged of receipt the permit application document and
requested of paying the permit fee in the amount of $500.00 dollars (Invoice No. SW016-0016).

On February 26, 2016 the SWS informed Mrs. Richardson via the email message of the
completion of reviewing the submitted permit application document (DIN 25659) and the
initiation of the Compliance History Review (CHR) Processes according to the North Carolina
General Statues § 130A-295.3. On March 03, 2016 the SWS sent Mrs. Richardson a letter
containing the CHR forms and information to complete the required forms.

On March 09, 2016, Susan Heim, Deb Aja, and Ming-Tai Chao representing the Solid Waste
Section visited the Sam W. Smith, Jr. Inc. LCID Landfill and conducted the facility audit. Ming-
Tai Chao delivered Mrs. Richardson in person the paper copies of the above-mentioned fee
invoice and CHR forms. The SWS appreciates of Mr. Sam W. Smith, Jr. (the Permittee) in
participation of the entire site visit and audit. Based on the information provided by the
Permittee and the observation from this site visit/audit, the SWS officially requests Mrs.
Richardson and Mr. Smith to provide the update information and/or document which are not
available in the submitted permit amendment application (DIN 25659) and to complete the
described action items below:

Mrs. Ella Mae Richardson &
Mr. Sam W. Smith, Jr.
March 14, 2016
DIN 25750
Page 2 of 4

1. CONDUCT AS-BUILT SURVEY AND INSTALL THE PERMANENT AND
PHYSICAL MARKERS TO DELINEAT THE LANDFILL WASTE DISPOSAL
BOUNDARY/WASTE FOOTPRINT FOR BOTH PAHSES 1 AND 2

According to the PERMIT CONDITION No. 7, Attachment 2 of the Permit to Operate for
the referenced LCID Landfill (DIN 12400) dated December 13, 2010, the permanent
markers that accurately delineate the waste disposal boundary must be established and
maintained. No edge marker is observed at the landfill in this site visit/audit. Therefore, the
Permittee must implement and complete the following tasks on and before April 1, 2016.
a. Conduct an as-built survey by a surveyor, who is registered in the State of North
Carolina to delineate the landfill waste boundaries.

b. Submit the SWS the as-built survey map which must present the applicable information
required by the North Carolina Solid Waste Management Rules (Rule) 15A NCAC 13B
.0564(9) and .0565(2) & (3). The map must be signed, sealed, and dated by the
surveyor.

c. Install permanent markers to physically delineate the landfill waste boundaries according
to the as-built survey map. The locations of each installed edge markers must be shown
and noted on the as-built drawing.

2. PROVIDE THE UPDATE LANDFILL CAPACITY AND RELATED DRAWING(S)
ACCORDING TO THE APPLICABLE NORTH CAROLINA SOLID WASTE
MANAGEMENT RULES 15A NCAC 13B .0565 & .0566.

According to the existing Permit to Operate for the referenced LCID Landfill (DIN 12400)
dated December 13, 2010, the landfill has the approved gross capacity of 143,000 cubic
yards (CY) – consisting of 65,000 CY for the 4-acre Phase 1 area and 78,000 CY for the 4-
acre Phase 2 area. Gross capacity is the measured volume between the bottomof waste and
the top of final cover. During the site audit, the SWS concluded, also confirmed by the
Permittee, that the entire 143,000-CY landfill capacity had been consumed by waste disposal
activities, and the intermediate cover material was placed over the top of wastes in the
landfill disposal area. Instead of permanently closing the site, the Permittee verbally
proposed and requested an approval of a continued operation of the landfill by constructing
vertical expansion of the landfill. Therefore, the Permittee should promptly provide the
SWS the supplemental documents to the permit application document (DIN 25659) in detail
of the construction and operation of the vertical expansion of the landfill. The minimum
description, information, data, and drawing(s) should be provided in the supplemental
documents, which must be prepared by a professional engineer registered in the State of
North Carolina, are described below.
a. The proposed waste footprint in acreage; if the proposed one is different from the
approved waste boundaries of eight (8) acres.
Mrs. Ella Mae Richardson &
Mr. Sam W. Smith, Jr.
March 14, 2016
DIN 25750
Page 3 of 4

b. The proposed landfill gross capacity includes:
i. The in-placed waste volume (in cubic yards) of landfill Phases 1 & 2 based on the
as-built survey.
ii. The additional capacity (in cubic yards) resulting in the landfill vertical
expansion. This capacity shall include the volumes of LCID wastes and volumes
of the final cover system and the volumes of periodic soil cover according to
Rules 15A NCAC 13B .0566(4) &(5), respectively. The estimate capacity of
waste, periodic cover, and final cover must be calculated based on sound
assumptions or acceptable knowledge from the waste industries.
iii. The description of systematic usage of the proposed vertical expansion area
including the fill/disposal operation sequence, the orderly phased development
(acreage and operating capacity of the each described phase), the closure of the
landfill, and the projected land use of the landfill after closure.

c. The drawing shows the contours of the existing fill (based on the requested as-built
survey mentioned in Action Item No. 1) and the contours of the proposed final cover of
the landfill.

d. From the drawing (Action Item No. 2 c) and drawing titled as “Site Grading Plan,
Borrow Pit /LCID Debris Landfill (DIN 25665), the Permittee must provide a minimum
of two cross-sections, one each along each major axis, per proposed operational area of
the landfill show:
i. The original elevation of the ground surface/grade.
ii. The landfill bottom elevation.
iii. The waste fill (intermediate cover) elevation as of March or April 2016.
iv. The proposed final elevation (v) the proposed slopes of the landfill final cover
including the deck portion and side slopes.

e. According to the Rules 15A NCAC 13B .0566(6) &(10) and the approved Erosion and
Sediment Control Plan, the approved best management practices (BMPs) and measures
to prevent soil erosion and run-on or run-off occurring at the proposed waste disposal
areas must be described in the revised Operations Plan and shown on the drawing(s).

3. IMPLEMENT THE POST-CLOSURE CARES AT THE CLOSED PORTIONS OF
THE LANDFILL

The Permittee indicated that the approximately 3 (horizontal) to 1 (vertical) side-slopes on
the east side of the landfill (Phases 1 & 2) are permanently closed. In this site audit, the
SWS observed that the saplings are growing in the sloped areas. Since the saplings or trees
in the sloped areas are highly vulnerable to a hurricane or a strong wind; a falling tree will
damage the landfill cover system resulting in exposure of wastes to the sensitive
Mrs. Ella Mae Richardson &
Mr. Sam W. Smith, Jr.
March 14, 2016
DIN 25750
Page 4 of 4

environment – downslope drainage features of the landfill are tributaries of the Dan River.
The Permittee must remove or cut down the trees or saplings in the landfill sloped area on or
before April 1, 2016.

The sole purpose of this letter is to assist you in obtaining a current and valid permit because the
existing Permit to Operate for Sam W. Smith, Jr. Inc. LCID Landfill, Permit No. 79J-LCID-
expired on December 13, 2015. Please implement and complete the requested action items
stated in the letter, pay the permit fee in the amount of $500.00 dollars, and send the SWS the
completed CHR forms. If you have any questions or concerns of the above-mentioned requests,
please contact myself at 919-707-8251 or [e-mail].

Shortly, the SWS will issue you a separate Facility Compliance Inspection Report which will
document this site audit at your facility from the regulatory perspective in the landfill operations
and provide you the areas that shall pay special attention or be subjected to corrective action(s).

Sincerely,
Ming-Tai Chao, P.E.
Environmental Engineer
Division of Waste Management, NCDEQ

cc: Ed Mussler, Permitting Branch Supervisor Susan Heim, DWM
Deb Aja, DWM Central Files