0403_AnsonLF_respnstocomments_20230707

Civil & Environmental Consultants, Inc.
July 7, 2023
ELECTRONIC SUBMITTAL
donna.wilson&ncdenr. gov
Donna Wilson
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
Dear Donna:
Subject: Response to Comments Email dated June 16, 2023
Environmental Assessment — Anson Landfill Phase 5 Expansion
DWM-SW Permit 0403-MSWLF-2010
CEC Project 165-276
Comment #1—Leachate recirculation plan — The Section staff has concerns and comments
regarding the recirculation/spraying of landfill leachate on to the working face. Newer concerns
are the potential for aeration of PFAS constituents by spraying. Other concerns are odor and runoff
from the spraying. This plan, and any text referencing it, should be removed from the current
application, so that it doesn't hold up the permit approval. A revised application for leachate
recirculation can be submitted at a later date as a permit modification.
Response: Any references to leachate recirculation have been removed from this Permit
Application in its entirety.
Comment #2 - Permit to Construct Application and Vertical Expansion:
a. The application cover page should state - Permit to Construct Application, Phases 4 and 5,
Horizontal and Vertical Expansion.
Response: The application Cover Page has been updated to State "PERMIT TO
CONSTRUCT APPLICATION ANSON COUNTY LANDFILL PHASES 4 & 5
HORIZONTAL AND VERTICAL EXPANSION"
b. Introduction page — Section 1.1 Project Description. The text should state that this is a
Permit to Construct Application for an expansion to the landfill of 68 acres, to be added to
the existing 133.10 acres, for a total of 201.1 acres (or as correction needed, the size should
be accurate to the drawings). It should also state that the application is for a re -design of
the configuration and labeling of the remaining areas in Phase 4 with the Phase 5 addition,
and that this application is for a vertical expansion over the Phase 1 through 5 area from a
previous maximum height of elevation 490 to a new maximum height of elevation 560,
3701 Arco Corporate Drive, Suite 400 1 Charlotte, NC 28273 1 p: 980-237-0373 f: 980-237-0372 1 www.cecinc.com

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 2
July 7, 2023
which is a 70 feet vertical expansion. It should also state the increase in capacity of the
landfill from the previous approved capacity, with both numbers provided.
Response: Section L I has been updated with the following language: "This Permit to
Construct Application is an expansion of 65.34 acres to the previously permitted 133.10
acre facility, resulting in a total acreage of 198.44 acres for the facility. In addition to the
horizontal and vertical expansion, the previously permitted Phase 4 area has been
reconfigured and re -labeled with the Phase 5 area expansion. The vertical expansion will
overlay on top of the existing Phases 1-3 of the currently permitted landfill and will
increase the maximum height from elevation 490 feet to elevation 560 feet. The previous
permitted capacity for the facility was 21, 640, 632 cubic yards. This vertical expansion
results in a difference of 70 vertical feet and an increase in capacity of 19,857,735 cubic
yards and results in 41,498,367 cubic yards of total capacity for the facility. "
c. Facility Report Section 2.1.1 should repeat the information in comment b. above.
Response: Section 2. L I has been updated with the above mentioned information.
Comment #3 - Leachate line drawing Phase 4, Cell 3/4:
a. There's a hump that the leachate line (and leachate flow) would have to go over, how
is it held on the slope? The pipe has a steeper slope down to a cross, and sloped upward
again to the back part of the cell. The back part of the leachate line needs access to
clean -out, camera, and jet clean.
Response: An image below has been added to demonstrate flow lines of the leachate
collection in Phase 4 Cell 4(formerly referred to as Phase 4 Cell 3). A note was added to
ensure that appropriate fittings are installed especially in this area to allow for video
inspection and jet -cleaning these lines. The middle pipe shown at the 310-312 elevation
noted in the comment is to provide cleanout access of the main collection line of the cell,
and is not necessary for part of the collection system. It is shown as perforated and part
of the collection system for redundancy and enhanced collection in this area. The leachate
line at the 310-312 elevation is anchored in the gravel column of the leachate collection
system as per detail 35IC700 and this portion of the line utilizes similar slopes as other
areas of the cell.
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 3
July 7, 2023
SWEEPING BEND ELBOW
TO ALLOW FOR
LEACHATE CLEANING/
CMERA INSPECTION
Tuic A17FA
Leachate Lines
Flow Arrow
{Typical
i Leachate
b. Provide the detail drawing for the leachate pipe cross. Show how leachate is collected
from the back part of the cell to the middle pipe or trench.
Response: Detail 35AIC700 has been added to demonstrate the leachate pipe cross design.
An additional 45 degree wye has been added to the back leachate collection line to
facilitate leachate flow to the cross section of the pipe. See revised Drawing C304 for
additional detail.
c. The leachate collection system will need to collect the leachate to meet the maximum
head on the liner requirements (provide info)
Response: HELP model calculations found in Appendix C apply to these areas, as the
maximum distance of flow until leachate hits a collection system trench and the minimum
slope are the same as other areas of the cell design. The drainage geocomposite is
designed for a maximum pipe spacing of 1195 feet and the leachate collection pipe is
design to collect leachate from a maximum of 16 acres at 2% slope without ponding
leachate. As shown in the HELP model calculation, in the worst case conditions (open
area with only 10' waste, maximum peak daily value), the maximum head on the liner is
calculated to be 9.9 inches.
Civil & Environmental Consultants, Inr.

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
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July 7, 2023
d. In phase 4 Cell 3 north most line, what is the radius of the leachate pipe 90 degree turn
so that the line can be camera inspected and cleaned? Or otherwise describe how this
will work.
Response: This area has been revised to show two 45 degree sweeping bend elbows and
natural pipe deflection shall be used to facilitate camera inspection and jetting of the
northmost line and accessing the cross line. See revised Drawing C304 for additional
detail.
Comment #4 - Drawings 1-1, 1-2, and 1-3:
a. Drawing 1-1 — Clarify that the 100-year FEMA is the 100-year floodplain. Remove or
label the floodway.
Response: Figure 1-1 has been updated to clarify that the 100 year FEMA line is shown
and the FEMA Floodway is labeled as well.
b. Drawing 1-2 — The map is blurry and can't be read. Label the 100-year floodplain
boundaries (AE).
Response: Figure 1-2 has been updated with a clearer map of the FEMA Panel for the
site. The 100 year FEMA floodplain line has been labeled.
c. Drawing 1-3 — Label the 100-year floodplain.
Response: Figure 1-3 - 100 year FEMA floodplain line has been labeled.
d. Update the phase locations.
Response: Phase Locations for the Landfill have been updated on each Figure.
Comment #5 — Drawings and tables should be updated for Phase 4, Cells 1 and 2.
Response: The drawings have been revised to depict Phase 4 Cell I and Cell boundaries/acreage
updates per the Permit Modification submitted in April by Weaver Consultant's.
Comment #6 - The capacity tables in Section 2.3:
a. Text should state that the volume includes a vertical expansion over Phases 1 to 5, where
the previous maximum height was 490 and the new final height is 560.
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 5
July 7, 2023
Response: Text has been updated to reflect vertical and horizontal expansion in Sections
1.1, Section 2. L I and Section 2.3.2.
b. The total capacity with Phase 5 expansion as calculated appears to be 201 acres. Also
correct this in other places in the application, such as the closure plan and cost calculations.
Response: The total capacity with the Phase 4 / 5 Expansion is 198.44 acres. Total acreage
has been updated throughout the Permit Application.
Gross capacity, defined as the volume of the landfill from the bottom of waste to the top
of final cover, is needed in the application for each phase. Another column can be added
for gross capacity excluding final cover, if desired.
Response: Gross Capacity for each Phase of the Landfill is shown on Table 2-4 in Section
2.3.2 of the Engineering Report. See footnote 8 stating that gross capacity is defined as
the volume from the bottom of waste to the top of final cover.
Comment #7 - Operations Plan:
a. Alternate daily cover — Provide information in the Ops Plan of each of the alternate daily
covers, including specific details. See files dated 2003 (for petroleum contaminated soils),
dated 2005 (for seaboard solids - used sawdust absorbent), and 2006 (for auto shredder
residue). Update and/or shorten the description of its use as applicable. Primarily, it should
list the details and conditions/limitations of its use.
Response: Site specific details and descriptions of their use have been provided in Section
5.17.7 (page 31) of the revised Ops Plan. Seaboard solids have not been used at the site
recently and have been removed from the Ops plan. WCN will reapply for the use of
Seaboard Solids in the future if needed.
b. For the solidification tank, list all the liquid wastes accepted that are or could be odorous
(be specific as to type). Describe odor control measures for this operation. Odorous waste
should be solidified as soon as possible and disposed in the landfill working face. All waste
should be stored no more than 24 hours from acceptance. Describe recordkeeping of the
waste types, volumes, and dates of solidification. It should be stated that landfill leachate
and condensate will not be solidified in the tank for disposal in the landfill without approval
of the Section. Also address site safety, to prevent persons falling in.
Response: Section 5.5.1 of the Ops Plan and Section 2.2.4.1 of the Facility Report have
been updated to add the information listed above. Waste types accepted are listed in
Section 2.2.
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 6
July 7, 2023
c. For the landfill gas collection wells to be extended, add the last response to previous
comment #12, to the text of the Operating Plan and Engineering Plan.
Response: Previous submittal Comment #12 response of "When landfill filling is
occurring in areas where landfill gas extraction wells are in place, the procedure for the
existing well is to vertically extend the pipe with solid piping through fusion welding and
installing a temporary cap. Once filling operations have been completed in areas, landfill
gas extraction wells may be re -drilled. Alternatively, the wells may be extended by
providing protective encasement piping (concrete riser pipe) or other protective structures
to enable waste placement and cautious compaction around the well casement. The well
pipe is typically extended vertically through fusion welding and temporarily capped. When
the waste mass is at the extension elevation, the annular space between the gas well pipe
and encasement pipe is filled with aggregate and the encasement pipe is removed. Finally,
the wellhead is installed and lateral piping is connected to the gas collection system. If gas
wells are abandoned, a gas collection system modification/expansion would be filed with
DEQ for approval. " Has been added to Section 5.19.4 of the Operations Plan
d. For the operational berms, or inter -cell berms, describe the design and method, so that there
is not a backup of leachate. Describe how the flap will be removed and the valve opened.
Confirm that a written certification for the proper connection (flap removed, valve opened)
will be placed in the operating record, each time a cell is connected.
Response: Valve operation at operational berm locations will be a cell construction
specific item. The valve will be opened and the operational berm with associated flap will
be removed prior to waste placement in the upper portion of the cell area. Language
referring to a written certification for proper connection etc. to be placed in the operating
record for the facility for documentation purposes has been added to the Phase 5 PTC
Operations Plan Report Table 8-1 and will be performed prior to accepting waste each
time a new cell is connected.
Comment #8 - Construction and CQA plan:
a. For the non-destructive leak testing over the entire liner as required by G.S. 130A-
295.6(h)(1) using technology such as electronic leak detection, provide information on the
method, or where it can be found in the project specs.
Response: Specification Section 02076 has been revised to include requirements for
electronic leak location surveys for the geosynthetic liner.
b. For previous comment 17f, concerning the geotextile removal over the leachate trench, and
the record notation, the response should be added to the text of the application, or provide
the location it is in.
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 7
July 7, 2023
Response: Previous submittal Comment response of: "The geotextile surrounding the
leachate collection pipe aggregate is removed and/or folded back from the top of the
leachate trench prior to waste placement to enable direct contact between the leachate
collection trench aggregate and waste per.1624 (b)(11)(B)(iii) and (b)(13)(B). Prior to
opening a new cell area, a note will be added to the operating record describing the
geotextile removal. " has been added to Section 2.5.1.3 in the Engineering Report.
c. Page 3 is an extra blank page.
Response: The blank page 3 has been removed from the CQA Plan.
d. In Section 1.2.3 — Add the following (or similar) to the text to provide more clarity of the
rule requirements: The CQA report will include the information required by Rule .1621
(Construction Quality Assurance Plan) and Rule .1624 (Construction Requirements for
MSWLF Facilities) including (1) results of all construction quality assurance and
construction quality control testing, (2) documentation of any failed test results, (3)
descriptions of procedures used to correct the improperly installed material and results of
all retesting performed, (4) procedures to ensure that the integrity of the landfill systems
will be maintained prior to waste placement, (5) as -built drawings noting any deviation
from the approved engineering plans, (6) a comprehensive narrative including daily reports
from the project engineer, (7) a series of color photographs of major project features, (8)
documentation of proceedings of all progress and troubleshooting meetings, and (9) a
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 Rule 15A
NCAC 13B .1624.
Response: The above language has been added to Section 1.2.3 of the CQA plan.
Comment #9 — Section 3.4 — The rule references to .1619 should be corrected, two locations.
Response: References to .1619 have been updated to reference Rule .1626(1) in Section 3.4.
Comment #10 — Landfill Gas Master Plan should be updated for cells that are built/operating.
Response: Section 2.1 of the Landfill Gas Master Plan has been updated to state: " The current
landfill footprint is approximately 133.1 acres. Currently Phases 1-3 and Phase 4 Cell I and Cell
2 are currently operating. Upon completion of Phase 5 expansion, the landfill footprint will be
approximately 198.44 acres. "
Comment #11 — Final Cover:
a. Section 3.6.5 — Please clarify the sentence, "The permitted final cover system will remain
an option for the final cover of the landfill."
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 8
July 7, 2023
Response: Text has been updated state: "The permitted final cover system includes a
standard Final Cover cap system detail and an alternate final cover cap system detail an
option for the final cover of the landfill. "
b. The description of the final cover in the text doesn't match the Figure 3-3 illustration.
Response: The alternative final cover system language has been added in section 3.6.5
along with the correct Alternative Cover Cap Detail Figure 3-4.
Provide infiltration calculations and comparison to show that the alternate final cover
allows equivalent or less infiltration than the regulatory standard final cover.
Response: Infiltration Calculations for both the standard and alternative covers are
located within the HELP Model Calculations in Appendix C.
d. For the design, Rule .1627 requires the final cover to have a permeability less than or equal
to the permeability of any base liner system or the in -situ subsoils underlying the landfill,
or the permeability specified for the final cover in the effective permit, or a permeability
no greater than 1 x 10-5 less, whichever is less. For this landfill, the final cover must have
a permeability less than or equal to the base liner. In the application text, the rule
requirement has been written incorrectly.
Response: The text has been revised in Section 3.6.5 to state: "The final cover must have
a permeability less than or equal to the permeability of any base liner system or the in -situ
subsoils underlying the landfill, or the permeability specified for the final cover in the
effective permit, or a permeability no greater than I x 10-5 less, whichever is less. "
Comment #12 — Groundwater - Section 5.1 — There are errors about the history of the landfill. It
was not permitted as 9230.
Response: Section 5.1 has been revised to remove the language referring to Permit #9230
Comment #13 —Closure, post -closure, and cost estimates:
a. It should be stated that landfill gas monitoring around the landfill perimeter and in
buildings during post -closure will be monitored at least quarterly.
Response: In the Operations Plan Section 5.19.1 Inspection table -Landfill Gas Monitoring
has been added to the Quarterly schedule. Section 7.2 of the engineering report has been
updated to state `Landfill gas monitoring around the perimeter of the landfill and inside
of buildings and occurs on a quarterly year. "
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 9
July 7, 2023
b. Section 6.5 — Closure costs are to be calculated in accordance with Rules .1800 et seq.
Response: Closure Costs have been updated per .1800 rules.
From the closure costs, describe in text what the 82 acres for the landfill gas collection
system represents.
Response: Section 6.2 of the engineering report has added language: "As shown in Table
6-1, the closure cost estimate includes 100.12 acres of landfill gas system construction as
part of closure. Currently, Phases 1-3 have landfill gas collection systems installed and
total approximately 98.48 acres. The landfill gas extraction well layout can be found in
Appendix F. "
d. In a few places the Rules for C&D landfills are referenced, .0543, .0546. These should be
changed to the appropriate MSW Rules.
Response: References to the C&D Rules have been revised per comment in section 6.5 and
Section 7.5. in the engineering report.
Comment #14 —Several maps are listed incorrectly in the Permit to Construct table of contents
(groundwater contour and bedrock contour map numbers do not match titles).
Response: Engineering Report Drawings Table of Contents has been revised.
Comment #15 — Attachment C, Document Page 1312: The NCDEQ Solid Waste Section Landfill
Gas Monitoring Form title page should be located before the example form page (document page
1311).
Response: An example Landfill Gas Monitoring Form is included as the last page of the
NCDEQ Solid Waste Section Landfall Gas Monitoring Guidance Document, which is
included in the LFG Monitoring Plan as Attachment B. An example Landfall Gas
Monitoring Form is also included in the LFG Monitoring Plan as Attachment C.
Comment #16 —Landfill Gas Master Plan
a. Page 5: This is an extra page. Text should be condensed to eliminate this page.
Response: Text has been reduced to eliminate blank page.
b. Section 2.1: Correct inconsistencies in the number of phases specified on the property (i.e.,
there are five total phases not four).
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 10
July 7, 2023
C.
Response: Section 2.1 of the text has added language about the current Phases.
d. Section 2.2.3: The current plan indicates that flare capacity will need to be updated in 2023.
Include a brief description of flare capacity expansion plans to accommodate the new cells
in Phase 4 and 5.
Section 2.2.3 has been updated to include language about increasing the flare capacity.
Comment #17 — Landfill Gas Monitoring Plan, Section 1.1, and Water Quality Monitoring Plan,
Section 2.0: Provide an updated timeline of facility activities in the background summary.
Background information does not provide the most up to date details on the progression of site
construction.
Response: The Background sections of both plans have been updated to reflect
construction activities through the date of this response.
Comment #18 —Water Quality Monitoring Plan
a. Maps need to be updated.
a. Maps 3a and 3b need to include the recently installed and abandoned wells as
reported to DEQ on 02/03/2023.
b. Ensure all map legends correctly identify the features listed on the maps.
Response: Maps 3A and 3B are based on seasonal high water table measurements from
the hydrogeologic report for Phase 5; as such, it would not be appropriate to change
well locations on these maps. However, well locations have been adjusted on Figure
I and the Water Quality Monitoring Location Map in Appendix A to reflect the recent
well relocations.
b. Section 2.2: Specify which wells have been recently replaced, and which ones will remain
in the monitoring network.
Response: Updates to the groundwater monitoring network have been incorporated into
the text and figures.
c. Sections 5.0 & 6.0: Specify that 1,4-Dioxane will be monitored in leachate and Enhanced
Liner System samples.
Response: These sections now include 1,4-dioxane as a monitored constituent. In addition,
Sections 3.0, 4.0, 5.0, and 6.0 have been further updated to include PFAS monitoring per
the March 2023 memo.
Civil & Environmental Consultants, Inr,

Anson County Landfill Phases 4 & 5 Permit To Construct Application NCDEQ Comments
CEC Project 165-276
Page 11
July 7, 2023
d. Section 7.1: The link to the SWS Environmental Monitoring Branch is broken and should
be replaced with the proper link.
Response: Text revised to remove link to website; this will avoid broken links in the event
of future website updates. All memos provided on the SWS's Environmental Monitoring
page (as of the date of this response) are included in Appendix C of the WQMP.
e. Section 7.2: Several Rules are cited incorrectly throughout this section and need to be
corrected.
a. Additionally, the timeframe to submit an assessment monitoring program report
should be included in this plan (as detailed in .1633(d)(2)).
b. The full requirements for a return to detection monitoring from assessment
monitoring must be detailed in this plan.
Response: Rules citations have been corrected. The timeframe within which to submit an
assessment monitoring report and the full requirements for a return to detection
monitoring have been added to the WQMP.
Please let us know if you need any additional information in support of this review.
Sincerely,
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
;W
Chris Haggard, E.I.
Assistant Project Manager
Nathan Bivins, P.E.
Project Manager
Civil & Environmental Consultants, Inr.