3301_EdgecombeCDLF_20160718_Responseto2ndComment_DIN26577

July 18, 2016
North Carolina Department of Environmental Quality
Division of Waste Management -Solid Waste Section
217 West Jones Street
Raleigh, North Carolina 27603
Attention: Mr. Ming-Tai Chao, P.E.
Reference:
Dear Mr. Chao:
S&ME, Inc. (S&ME), on behalf of Edgecombe County, is submitting the following responses to the
comments made in the June 17, 2016 letter from the North Carolina Department of Environmental Quality
(NCDEQ), Division of Waste Management (DWM), Solid Waste Section (SWS). In the June 17, 2016 letter,
the SWS commented on the issuance of a 5-year permit rather than a 10-year permit; the Water Quality
Monitoring Plan and the Financial Assurance documentation portions of the permit application for
continuing operation of the C&D Landfill. The SWS comments are stated in italics below. S&ME's response
to the SWS comments are provided in bold.
Facility Plan
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 operation of the Edgecombe County C&DLF Phases 1, 2, 3 4. This permit decision is made of
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) 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 schedule 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 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 the C&DLF shall be $18,000. The County has paid
the 5-year permit fee of $9,000 on September 29, 2014. The current permit of the landfill expired on
March 31, 2015. The new 5-year permit, if approved and issued, will (i) allow the County to regain the
valid current permit status which makes the County eligible to obtain a Life-Of-Site Permit when the
new permit expires on March 31, 2020 and (ii) save the County in not paying for the additional fee.
According to the Facility Plan, the 5-year permit for the C&D LF Phases 1, 2, 3 4 will have
available waste capacity of 182,867 cubic yards which has the service life of more than 5 years.
Please revise the Section A -Facility Plan (page #2) accordingly.
S&ME, Inc. I 3201 Spring Forest Road I Raleigh, NC 27616 I p 919.872.2660 I f 919.876.3958 I www.smeinc.com