6403_Nash_responseletter_20161024

1100 Crescent Green Drive, Suite 208, Cary, North Carolina 27518 • O: 919-792-1900 • F: 866-311-7206
October 19, 2016

Ms. Donna Wilson Department of Environmental Quality Waste Management
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
RE: Response to Comments Nash County C&D Landfill - Horizontal Expansion Application
Permit 6403-CDLF-2000

Ms. Wilson: Please find our responses to your comments from for your January 29, 2016 letter for
the above referenced project.
FACILITY PLAN
Comment 1. The landfill expansion crosses over 2 property parcels. The two parcels
should be combined.
Response 1. The “Closed MSWLF Facility Boundary” (permit 6401) is comprised of
three parcels on the east side of Pig Basket Creek totaling 188.34
acres. The “C&DLF Facility Boundary” (permit 6403) is comprised of
two parcels on the west side of Pig Basket Creek totaling 186.76 acres.
Comment 2. Discuss and identify the land deed and parcel ID for the landfill and
expansion, and provide a copy of the land deed in an appendix.
Response 2. A copy of the land deed for each of the two parcels are attached.
Comment 3. A traffic study is required for an expansion to an existing landfill, in
accordance with 130A-295.5, to include a letter from the Division
Engineer of the Department of Transportation.
Response 3. Please find a letter from the NCDOT District 4 Division Engineer,
attached.
Comment 4. Each section of the application (Closure and Post-Closure Plan,
Operations Manual, etc.) should be labeled on the cover sheet and
heading to indicate the plan covers the original landfill and the
expansion. An example could be - Facility Plan, Nash County C&D
Landfill and Horizontal Expansion. As it is worded now, it appears to
only apply to the expansion.
Ms. Donna Wilson
October 19, 2016
Page 2
Response 4. The cover sheet and headings for each section have been modified to
“Nash County C&D Landfill and Horizontal Expansion”.
Comment 5a. The pages of the Facility Plan are labeled “Engineering Plan” in the
header. Please change to “Facility Plan.”
Response 5a. The header section of the Facility Plan are now labeled “Facility Plan.”
Comment 5b. Discuss site suitability approval, and include the site suitability letter in
the appendix.
Response 5b. The attached letter from Christine Ritter dated October 1, 2012
regarding Nash County C&D Landfill Site Suitability states “the Site
Application document is considered valid for the area of the proposed
landfill expansion”. A copy of this letter is attached.
Comment 5c. Section 1.0 – According to file records, the closed MSW landfill property
is approximately 185 acres (instead of 188.34 acres). Please clarify. It
should be noted in text that the closed MSW and C&D on top landfill is
a different permit, permit 6401, from the current C&D Landfill, permit
6403.
Response 5c. The “Closed MSWLF Facility Boundary” (permit 6401) is comprised of
three parcels on the east side of Pig Basket Creek totaling 188.34
acres. The “C&DLF Facility Boundary” (permit 6403) is comprised of
two parcels on the west side of Pig Basket Creek totaling 186.76 acres.
Comment 5d. For the landfill phase volumes, acreage, and life discussion, table, and
calculations, please combine the discussion of the Facility Plan, Section
3.0, with the facility design description in the Engineering Plan, Section
2.0. The combined discussion and table should be in the Facility Plan.
Response 5d. Section 3.0 of the Facility Plan has been modified accordingly.
Comment 5e. Capacity Table – Footnote (or other method) should note that the
volumes are gross capacity and include the bottom of waste to the top
of final cover. For permitting, gross capacity is needed. If desired, net
capacity (without final cover) can also be listed.
Response 5e. Section 3.0 of the Facility Plan has been modified to include gross
capacity.
Comment 5f. Provide discussion of soil quantities required and available onsite.
Response 5f. Section 3.3 discussing soil quantities has been added to the Facility
Plan.

Ms. Donna Wilson
October 19, 2016
Page 3
ENGINEERING PLAN
Comment 6a. In several places in the application it is stated that the expansion is 16.8
acres. Shouldn’t this be 15.8 acres? Phases 1-3 are 11.2 acres, and the
total is 27 acres.
Response 6a. The proposed Horizontal Expansion is 15.8-acres.
Comment 6b. Typo – Section 2.5, “Requirements.”
Response 6b. Typo has been corrected.
Comment 6c. Please provide a copy of the sedimentation and erosion control permit
application (information and summary pages, but not calculation
pages).
Response 6c. A sedimentation and erosion control permit application has NOT been
prepared for the Horizontal Expansion Area. A sedimentation and
erosion control permit application for the limits of disturbance required
for Phase 4 (Cells 4a and 4b, roads, and associated Sediment Pond
No. 3) will be prepared and approved prior to initiating construction on
any portion of the proposed Horizontal Expansion Area. A
sedimentation and erosion control permit application will also be
prepared for all other future phases of the proposed Horizontal
Expansion Area.
Comment 6d. How will leachate or runoff from the working face be managed to keep it
flowing to the sediment ponds? If leachate is mixed with surface water
in the sediment ponds then an NPDES permit is likely required. Include
documentation from DWQ that an NPDES permit is not required.
Response 6d. Soil berms will be constructed around the working face to contain
stormwater that has come into contact with uncovered waste materials.
Leachate should not be mixed with surface water in the sediment
ponds.
Comment 6e. What is the distance to the nearest home(s) and well? What is the
distance to the nearest surface water from the expansion?
Response 6e. See the revised Engineering Report - Section 3.1.2 - OFFSITE
RESIDENTIAL STRUCTURES AND WELLS.
See the revised Engineering Report Section 3.1.3 – SURFACE
WATERS.
CQA PLAN
Comment 7a. Typo in page header “Expantion”.
Ms. Donna Wilson
October 19, 2016
Page 4
Response 7a. The page header has been corrected.
Comment 7b. Section 5.0 – It should be stated that the CQA report will contain the
items as listed in Rule .0541 (c) and (d)(4).”
Response 7b. The statement “the CQA report will contain the items as listed in Rule
.0541 (c) and (d)(4)” has been added to section 5.5 – CQA REPORT.
Comment 7c. Specification 02200-5, Section 2.02 – Shouldn’t the list include visual
classification to confirm proper soil classification?
Response 7c. Specification 02200-5, Section 2.02 has been modified to include visual
classification to confirm proper soil classification.
OPERATING PLAN
Comment 8a. If yard waste is accepted, and the product is distributed to the public,
then it has to be composted to address pathogens, pesticides, and
herbicides. This would require taking temperature of the piles, and
keeping records, to show that at least 131oF has been reached for 3
consecutive days, and modifying the operations plan to discuss the
requirements that apply to a Type 1 compost facility. If the yard waste is
sold for boiler fuel, or used for mulch onsite in areas not accessible to
the public, it would not have to be composted.
Response 8a. Section 11.5 has been revised to state “Ground yard waste materials
are not offered to the public”.
Comment 8b. Section 5.3 – Medical waste is defined in 130A-290 (a)(17a).
Response 8b. The General Statute reference has been corrected.
Comment 8c. The plan should include discussion of other solid waste management
onsite, including the convenience center, waste tires, scrap metal,
pallets, etc.
Response 8c. See Engineering Report – Section 11.6 and Section 11.7.
Comment 8d. Section 8.0 – Please reword this sentence, “Specifically to control such
"disease vectors" as rodents, flies, mosquitoes, or other animals or
insects, depressions or low areas susceptible to ponding of water will
be prevented; scrap tires are stored directly in trailers; provide
adequate cover to the disposal unit to limit attraction and otherwise
manage the Facility to prevent to not attract and prevent the presence
of disease vectors and address promptly any issues when identified.”
Response 8d. Section 8 has been reworded.
Ms. Donna Wilson
October 19, 2016
Page 5
Comment 8e. Section 9.3 – Please clarify if the facility is located in the Eastern Wake
Fire/Rescue District.
Response 8e. Any reference to “Eastern Wake Fire/Rescue District” has been
removed.
Comment 8f. Section 11.2 – In addition to the general public, address whether landfill
staff will remove waste (for recycling or recovery) at the working face.
Response 8f. A sentence has been added to clarify landfill staff will not remove waste
(for recycling or recovery) at the working face.
Comment 8g. Section 11.7 – For the alternate daily cover of soil/mulch mixture,
address compliance with the stated guidance document, i.e., placing a
notice in the facility operating record, and notifying the persons listed in
the document. Also, include the details of the allowed use, from the
guidance memo, in this application (or include the page as an
appendix).
Response 8g. Details of the allowed use of Alternative Daily Cover (ADC) consisting
of Soil/Mulch Mixture (S&M) mixed at a ratio 50% soil to 50% mulch by
volume has been added. Refer to “APPROVED ALTERNATIVE DAILY
COVER MATERIALS FOR USE AT SANITARY LANDFILL” Document
number 20365, dated January 7, 2014 for further procedures on
compliance with alternative daily cover.
Comment 8h. Section 11.8 – Typo - Please reword, “. . . additional waste of cover
soil.”
Response 8h. The “COVER MATERIAL REQUIREMENTS” section has been revised.
Comment 8i. Describe the overall surface water features, including the onsite ponds.
Response 8i. The “DRAINAGE CONTROL AND WATER PROTECTION
REQUIREMENTS” section has been revised.
Comment 8j. Include a discussion of operation during extreme conditions, such as
ice storms, heavy rains, and windy conditions.
Response 8j. A new “SEVERE WEATHER CONDITIONS” section has been added.
CLOSURE PLAN
Comment 9a. Section 2.0 – Include the minimum slope of the top of the landfill.
Response 9a. A sentence has been added to Section 2.0 as follows: “The minimum
slope of the top of the landfill shall be a minimum of 5%”.
Comment 9b. Section 3.0 – The wording is confusing.
Ms. Donna Wilson
October 19, 2016
Page 6
Response 9b. Section 3.0 has been modified as follows: “The largest area of the
C&DLF unit requiring the specified cap system at any time during the
active life of the proposed 15.8-acre Horizontal Expansion of the
existing 11.3-acre Nash County C&DLF is estimated to be
approximately 27-acres”.
Comment 9c. Provide design description and installation details for the gas vents on
the final cover.
Response 9c. Detail 2 on Sheet 8 of the Engineering Drawings provide design
description and installation of the gas vents on the final cover.
Comment 9d. Describe the design of the surface water control features and
installation, including the terrace berms and down drain pipes.
Response 9d. The location of terrace berms and down drain pipes are shown on
Sheet 5 of the Engineering Drawings. The Details of terrace berms and
down drain pipes are shown on Sheet 8 of the Engineering Drawings.
Comment 9e. Capacity Table – Footnote (or other method) should note that the
volumes are gross capacity and include the bottom of waste to the top
of final cover.
Response 9e. Section 4.0 MAXIMUM INVENTORY OF WASTE ON-SITE has been
modified as follow: “The maximum inventory of wastes on-site over the
active life of the existing 11.3-acre Nash County C&DLF and proposed
15.8-acre Horizontal Expansion is estimated to be a gross capacity
(bottom of waste to top of final cover) of approximately 2,406,234 cubic
yards, which equate to approximately 847,400 tons waste.”
Comment 9f. Describe the establishment of vegetation.
Response 9f. A Seeding Schedule, including a schedule and reference to relevant
erosion and sedimentation control requirements is included in Detail 5,
Sheet 9 of the Drawings.
Comment 9g. Section 5.3 – It should be stated that a Closure CQA report will be
submitted to the Department, and should list the items to be included in
the report.
Response 9g. Section 5.2 of the Closure Plan has been revised as follows: “Within 30
days of completion of Closure Cap Construction, a Closure Cap CQA
report prepared in accordance with of the CQA Plan, Section 3.2 FINAL
COVER CAP CONSTRUCTION, and submitted to the Department”.
POST-CLOSURE PLAN
Ms. Donna Wilson
October 19, 2016
Page 7
Comment 10a. Groundwater monitoring, surface water monitoring, and landfill gas
monitoring should be discussed.
Response 10a. Section 2.0 - MONITORING AND MAINTENANCE ACTIVITIES has
been modified to include: “Groundwater Monitoring and Surface Water
Monitoring will conducted at the closed unit two times per year by the
responsible party for a minimum of a 30 year post-closure period.
Gas Monitoring will conducted at the closed unit four times per year by
the responsible party for a minimum of a 30 year post-closure period.”
Comment 10b. Frequencies of all maintenance and monitoring should be included.
Response 10b. Frequencies of all maintenance and monitoring activities are included in
the revised Section 2.0 - MONITORING AND MAINTENANCE
ACTIVITIES as well as the Post-Closure cost estimate.
Comment 10c. Costs should include maintenance of the gas vents.
Response 10c. Costs for maintenance of the shallow passive gas vents are included in
the Final Cover System Repair line item of the Post-closure cost
estimate.
Comment 10d. Final cover maintenance cost appears low for 27 acres.
Response 10d. Post-closure estimates are comparable to similar C&DLF facilities.
Comment 10e. Post-closure costs should also include the 30 year cost calculation.
Response 10e. The post-closure estimate has been revised to include the 30 year cost
calculation.
Comment 10f. A summary financial assurance page should be included that shows the
addition of the closure costs, post-closure costs, and required potential
assessment and corrective action costs.
Response 10f. DEQ policies have removed the requirement for the potential
assessment and corrective action costs (PACA) estimates.
DRAWINGS
Comment 11a. Sheet 1 – Please provide a legend.
Response 11a. Sheet 1 has been revised.
Comment 11b. Illustrate that the setbacks to the property line, residences, wells, and
surface water have been met.
Response 11b. Setbacks to the property line have been added to Sheet 1.
Ms. Donna Wilson
October 19, 2016
Page 8
Comment 11c. Provide directional flow arrows for surface water to the labeled
sedimentation ponds.
Response 11c. The drawings have been revised to provide directional flow arrows for
surface water to the labeled sedimentation ponds.
Comment 11d. Final cover drawing – Please label the side slope and top slope, with
the ratio or % slope.
Response 11d. The cross-section sheet has been modified to indicate side-slopes are
4Hor:1Vert and a 5% minimum slope of the top of final cover.
MONITORING PLAN
Comment 12a. Plan should discuss the installation of groundwater wells MW-6R, MW-
7, and MW-8, including details of construction. It should be noted that
the wells will be installed and the sampled prior to disposal of waste in
the expansion footprint.
Response 12a. The Monitoring Plan includes a discussion about the timing and
installation of groundwater wells MW-6R, MW-7, and MW-8 in Section
7.3. This section includes a statement that new wells will be installed
and the sampled prior to disposal of waste in the expansion footprint.
Details of construction are described in Section 8.
Comment 12b. Plan should discuss the proper abandonment of well MW-6, and when it
will be abandoned.
Response 12b. Section 7.3 and Section 8 of the Monitoring Plan discuss the proper
abandonment of well MW-6, and when it will be abandoned.
Thank you for your consideration.
Sincerely,
GARRETT & MOORE, INC.

Vance F. Moore, P.E.
President
Attachments: Permit Renewal Response to Comments Nash County C&D Landfill Permit to Construct Application

1100 Crescent Green Drive, Suite 208, Cary, North Carolina 27518 • O: 919-792-1900 • F: 866-311-7206
October 12, 2016

Mr. Tim Little, PE Division Engineer NCDOT, Highway Division 4
509 Ward Blvd.
PO Box 3165
Wilson, N.C. 27895 RE: Nash County C&D Landfill - Horizontal Expansion Application
Permit 6403-CDLF-2000

Mr. Little:
Nash County is in the process of permitting a horizontal expansion to the existing Nash
County Construction and Demolition Landfill (C&DLF) Permit 6403-CDLF-2000. In
accordance with G.S. 130A-295.5, a traffic study is required for certain solid waste
management facilities. However, an applicant for a permit for a sanitary landfill or for a
transfer station may satisfy the requirements of this section by obtaining a certification
from the Division Engineer of the Department of Transportation that the proposed facility
will not have a substantial impact on highway traffic. (2007-550,s.8(a).)
To that end, we are providing the following information for your consideration.
The Nash County C&DLF entrance is located at:
3057 Duke Road
Nashville, N.C. 27856
This same entrance was utilized for the Nash County Municipal Solid Waste (MSW)
Landfill over an approximately 30-year period until 1999. The Nash County C&DLF
initiated operation in January 2000. Annual tonnages and associated vehicle traffic
decreased significantly in 2000 due to Nash County no longer accepting MSW at the
facility.
The proposed horizontal expansion of the Nash County C&DLF is being permitted in order
to provide the same level of service to the citizens of Nash County as the original C&DLF.
The proposed expansion does not increase the Facility’s service area and/or the
anticipated annual tonnage. Annual tonnages at the Nash County C&DLF less than
10,000 tons, and no significant increase or decrease in landfill highway traffic is
anticipated with the proposed C&DLF expansion.
For these reasons, the proposed facility will not have a substantial impact on highway
traffic.
Mr. Tim Little, PE
October 12, 2016
Page 2
We are seeking your concurrence on behalf of Nash County, and we would appreciate
obtaining a certification from you stating the proposed facility will not have a substantial
impact on highway traffic.
Thank you for your consideration.
Sincerely, GARRETT & MOORE, INC.

Vance F. Moore, P.E.
President