3301_EdgecombeCDLF_20160617_Comment_DIN26274

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
Solid Waste Section

June 17, 2016

Mr. Eric Evans, Manager
Edgecombe County
P.O. Box 10
Tarboro, NC 27886

Re: Comment on the Revised Permit Amendment Application
Edgecombe County Construction and Demolition Debris (C&D) Landfill
Edgecombe County, North Carolina
Permit No.3301-CDLF-1997, Document ID No. (DIN) 26274

Dear Mr. Evans:

The Solid Waste Section (the SWS) has completed a review of the revised permit amendment
application (DIN 26114) for the above-referenced C&D Landfill, dated August 2014 and revised
May 2016. Few comments that stated below are required your prompt responses.

Facility Plan
1. The Section A- Facility Plan of the permit application (Page # 2) requests the SWS for an
approval of issuing a 10-year permit to continue operating the Edgecombe County C&D
Landfill, Permit No. 33-01-CDLF-1997. The SWS denies this request but may issue
Edgecombe County (the County) a 5-year Permit To Operate for a continued
operating the Edgecombe County C&DLF – Phases 1, 2, 3, & 4. This permit decision
is made based on the following considerations:
a. The Corrective Action Plan (CAP) is not completed and the CAP effectiveness is
subjected to revaluation. The CAP (DIN 9206) and the amendment (DIN 11254) that
were originally approved in January 2009 and August 2010, respectively. The
proposed hydraulic barrier wall (a major component of the CAP has not been
constructed) is scheduled to construct in December 2017 according to the approved
Interim Corrective Action Evaluation Report dated May 24, 2016 (DIN 26122). The
issuance of a 5-year permit will allow the SWS to assist the County in
implementation and completion of the hydraulic barrier wall.

b. The permit fee associated with a 10-year permit of a C&D landfill shall be
$18,000.00 dollars. The County has paid the 5-year permit fee of $9,000 on
September 29, 2014. The current permit of the landfill has expired on March 31,
2015. The new 5-year permit, if approved and issued, will (i) allow the County
Mr. Eric Evans
June 17, 2016
DIN 26274
Page 2 of 3

regain the valid current permit status which makes the County is legible to obtain a
Life-Of-Site Permit when the new permit expires on March 31, 2020 and (ii) save the
County not to pay for additional fee.

c. According to the Facility Plan the 5-year permit for the C&D Landfill – Phases 1, 2,
3, & 4 will have available waste capacity of 182,867 cubic yards which has the
service life more than 5 years.
Please revise the Section A- Facility Plan (page #2) accordingly.

Water Quality Monitoring Plan (Appendix II-C)
2. The following monitoring wells should also be functioned as Corrective Measures: MW-
5 and MW-12. Please revised the summary table in Section 2.2.1.3 on Page 11 of the
Water Quality Monitoring Plan.
Financial Assurance
3. The revised financial assurance (FA) document are provided in the Section D-8 &
Appendix XI-E, and the revised cost estimates of the closure and post-closure activities
are stated in Section E of the permit application. It is evident that the April 29, 2016 FA
provided by the County is not sufficient. The side-by-side cost comparison is
summarized in the following table:
County FA Letter 04/29/2016 Permit Application (DIN 26114)
Item Amount Item Amount Reference
Closure Cost 870,806 Closure Cost

1,290,727 Appendix III-E
Post-Closure Cost 2,044,626 Post-Closure Cost

2,245,294 Appendix V-E
Corrective Measures 2,342,000
Corrective
Measures

1,782,737.5 Section D-5
PACA - PACA

2,000,000
NCGS 130A-
295.2(h)
Total 5,257,432

7,318,758
Please revised the FA document accordingly. Please also submit the copy of the FA letter
to Ms. Sarah Rice who can be reached at 919-707-8287 or [e-mail], and
1646 Mail Service Center, Raleigh, NC 27699-1646.
Drawings
4. Phase 9 of the C&D Landfill is proposed in the Facility Plan and showed on the cross-
section drawing, Drawing 7 of 13, in Section C – Operation and Waste Acceptance Plan.
However, the Phase 9 waste footprint is not available on any other plan drawings. Please
add the Phase 9 to the applicable drawings throughout the permit application document.
Mr. Eric Evans
June 17, 2016
DIN 26274
Page 3 of 3

The County should submit the SWS a hard copy of the revised portions of the application
document including the responses to the above-mentioned comment and drawings and one
electronic copy of the entire revised permit application. If you have any questions please contact
me at 919-707-8251 [e-mail].

Sincerely,

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

cc:
Samuel P. Watts P.G., S&ME Ed Mussler, P.E, Permitting Branch Supervisor
Ervin Lane DWM John College, DWM
Sarah Rice, DWM Drew Hammonds, DWM
Central Files