P1303_EverettLCIDLF_responseto3rdComment_DIN26789_20160926

1
Chao, Ming-tai
From:Branch Smith <[e-mail]>
Sent:Monday, September 26, 2016 10:24 AM
To:Chao, Ming-tai
Subject:RE: Everett's LCIDLF, P1303, DIN 26720
Attachments:160926 LCID-2.pdf
Follow Up Flag:Flag for follow up
Flag Status:Flagged
Mr. Chao:

Please review the map and see if this approach will meet the concerns of leachate draining into potentially damaged
pipe. I propose concrete pipe sealed watertight. The other option is digging a ditch but any leachate will get in this ditch
as well. This pipe is not directly under the landfill as it is in clean fill. Runoff and leachate will always be of concern, but
this should minimize your concerns as stated below.

Kind Regards;
Branch

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Friday, September 09, 2016 2:07 PM
To: Branch Smith <[e-mail]>
Cc: Hare, Wes <[e-mail]>; [e-mail]
Subject: Everett's LCIDLF, P1303, DIN 26720

Dear Mr. Smith:

The Solid Waste Section (SWS) completed a review of the revised Permit Application (DIN 26704) and has
two comments stated below:

1. (Operations Plan, Waste Disposal Plan, on Page 2 of 6) Pursuant to the Solid Waste Management Rules
(Rule) 15A NCAC 13B .0566(5) & (7), the soil cap, at minimum of one foot thickness, shall be installed
over the disposal area at the landfill no later than 120 calendar days [not one year, proposed in Item (t)]
after completion of any phase of disposal operations. The soil cap must be revegetated at the specified
time frame as well. The Item (t) must be revised accordingly.
Response: O&M text changed.

2. (Drawing Nos. LCID-2 & LCID-3) A 24-inch-diameter aluminum pipe is added to the revised plan
drawings to drain the surface runoff in the ditch along the east side of the landfill into the stormwater
holding area, which is located on the west side of the landfill. And this transverse aluminum pipe is to
be installed underneath the landfill. The SWS has strong concerns of this design because the buried
pipe, if it is damaged or leaks for any reason, will potentially provide a least-resistant path for leachate
migration to the on-site surface-water body (stormwater holding area) and consequently to the
groundwater underneath the landfill. (Don’t forget what causes the coal ash spill into the Dan
River.) Leachate is defined as any liquid, including any suspended components in liquid, that has
percolated through or drained from solid waste according to Rule 15A NCAC 13B .0101(24). Please
noted that the landfill will be perpetually located at the property, but the pipe has a limited service
2
life. Mr. Everett who owns and operates this landfill will be legally and financially responsible for any
environment damages to surface water and groundwater resulting from leachate migration via the
damaged pipe. Consequently, this design has a potential violation of the Rule 15A NCAC 13B.
.0566(14) - leachate shall be properly managed on site through the use of current best management
practices.
Response: Pipes have been removed – see revised maps.

Additionally, the Permit Application must properly address the following concerns, if Mr. Everett insists
to use this approach to manage the on-site stormwater/drainage system:
i. According to the “LCID Full-Build Out Cross-Section” on Drawing No. LCID-3, the pipe intake
(daylight) is placed on the grade without any backfill cover, and approximately 50% of the pipe
is covered by less than 1-foot thick cover.
a. Will this pipe be able to resist waste loads (static) and live loads, generated from the
movements of dump truck and earth-moving equipment with an acceptable factor of
safety? Please provide the detailed calculation to demonstrate the selected pipe has adequate
strength to support the maximum static and live loads in construction and operation of the
landfill.
Response: Pipes have been removed – see revised maps.

b. Provide a typical detail and cross section of the pipe trench which must meet the
assumptions/concepts of pipe-soil system used in the calculations mentioned in the above-
mentioned item (a) including, but not limit to, trench width & depth, specifications for
backfill materials and compaction efforts, thickness of cover and bedding, etc.
Response: Pipes have been removed – see revised maps.

ii. If the pipe trench and installation will be constructed after the minimum 4-feet-thick landfill base
is completely constructed, the trench safety requirements must be clearly specified on the
drawing.
Response: Pipes have been removed – see revised maps.

iii. Will the aluminum pipe have chemical compatibility and corrosion resistance to the potentially
exposed environmental media such as leachate, waste, standing water, or backfill
material? Shall the pipe be protected by a suitable coating or applying cathodic
protection? Please clarify.
iv. What is the service life of the pipe? Please provide detailed references and calculations.
v. Response: Pipes have been removed – see revised maps.

vi. Is there an inspection and maintenance plan for the drainage pipe to be conducted during the
landfill operation period? Should the pipe be damaged for any reason, how you plan to repair the
pipe? Please clarify.
vii. Response: Pipes have been removed – see revised maps.

Please contact myself if you have any questions to the above-mentioned comments. Thanks and have a
wonderful weekend.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
3
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Chao, Ming-tai
Sent: Tuesday, September 06, 2016 11:33 AM
To: '[e-mail]' <[e-mail]>
Cc: Rice, Sarah M <[e-mail]>; Hare, Wes <[e-mail]>; Hammonds, Andrew
<[e-mail]>
Subject: Everett's LCIDLF, P1303

Dear Mr. Smith: Good morning. On August 29, 2016 the Solid Waste Section (the SWS) received the hard
copy of the responses to the July 11, 2016 comments (DIN 26446) and the revised Operations Plan and
supporting documents associated to the proposed new landfill. The above-mentioned documents are scanned,
logged and uploaded to the document tracking system with a DIN 26704. The SWS will review the revised
operations plan and responses shortly.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

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