6403_NashLF_responsetocomments_20170127

1100 Crescent Green Drive, Suite 208, Cary, North Carolina 27518 • O: 919-792-1900 • F: 866-311-7206
January 23, 2017

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 11, 2017 email and
Christine Ritter’s January 12, 2017 email for the above referenced project.
FACILITY PLAN
Comment 1. Please provide a drawing or sketch that illustrates the change in
property, and recombination. Also discuss the property recombination
in the Facility Plan Intro.
Response 1. Section 2 has been added to the Facility Report to specifically discuss
the property recombination. A drawing that illustrates the change in
property, and recombination is included in Appendix A of the Facility
Plan Report.
Comment 2. Copies of the land deeds for the landfill parcel have not been provided
with the application.
Response 2. Appendix 1 has been added to the Facility Report to include Deeds and
the Instrument of Combination.
Comment 3. The previous response to comments concerning the traffic study should
be discussed in the text of the application, and supporting
documentation referenced in text and included in the application
appendices.
Response 3. Section 7 has been added to the Facility Report to specifically discuss
the traffic study.
OPERATIONS PLAN
Comment 4. The following previous response to comments should be discussed in
the text of the application ‐ Soil berms will be constructed around the
working face to contain stormwater that has come into contact with

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January 23, 2017 Page 2

uncovered waste materials. Leachate will not be mixed with surface
water in the sediment ponds.
Response 4. The Operations Plan, Section 11.9 has been modified to include the
previous response to comments.
FACILITY PLAN
Comment 5. Site suitability should be discussed in the text of the application,
including a description of the area approved, and a copy of the Site
Suitability approval letter included as an appendix in the application. A
copy of this letter can be provided upon request.
Response 5. Section 3 has been added to the Facility Report to specifically discuss
the Site suitability. Appendix B has been added to the Facility Report to
include the Site Suitability approval letter.
Comment 6. Section 2.5 of the Facility Plan – Typo in the Title, and Table of
Contents.
Response 6. Section 2.5 of the Facility Plan has been revised to correct the Typo in
the Title and Table of Contents.
ENGINEERING PLAN
Comment 7. Section 3.1.2 of the Engineering Plan – Provide a sentence describing
the distance to the nearest homes and possibly wells that are south and
southwest of the expansion, not far from the 500 foot buffer.
Response 7. Section 3.1.2 of the Engineering Plan has been revised to state, “The
nearest residential structure or well is greater than 500 feet from the
disposal boundary.”
OPERATION PLAN
Comment 8. Section 11.5 of the Operation Plan – Typo – “Ground yard waste
materials are offered not offered to the public.” Ground yard
waste/mulch that has not been composted can also be used as
landscape mulch on the landfill property in areas that are not accessible
to the public (for example, it can’t be used around the site entrance,
office buildings, or scale house).
Response 8. Section 11.5 of the Operation Plan has been revised to correct the Typo
and to add the statement “Ground yard waste/mulch that has not been
composted can also be used as landscape mulch on the landfill
property in areas that are not accessible to the public (for example, it

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January 23, 2017 Page 3

can’t be used around the site entrance, office buildings, or scale
house)”.
Comment 9. Operation Plan – Section 11.8 – About the alternate daily cover, there
are implementation details that are not addressed. It should be stated
that a notice will be/has been placed in the operating record that states
that the soil/mulch mixture for alternate cover will be used and the
procedure for use; and that a copy of that notice has been/will be sent
to the Permitting Branch Supervisor of the Section and the facility’s
Environmental Senior Specialist (ESS). See page 2 of the guidance
document, “Implementation,” for the alternate cover.
Response 9. Operation Plan – Section 11.8 has been revised to add “that a notice
will be been placed in the operating record that states that the
soil/mulch mixture for alternate cover will be used and the procedure for
use; and that a copy of that notice will be sent to the Permitting Branch
Supervisor of the Section and the facility’s Environmental Senior
Specialist (ESS).”
FACILITY PLAN
Comment 10. Yard waste area – Section 2.4 of the Facility Plan states that the
existing yard waste area is shown on Sheet 1 of the drawings, and the
relocated future area is shown on Sheet 2 of the drawings. Drawings
should be updated to show these areas. Since both Sheet 1 and 2 are
labeled as existing conditions, it would be better to include the future
area on Sheet 3, 4, and/or 5.
Response 10. The Facility Plan has been revised to add Facility Plan Drawing FD-1 at
the end of the Facility Plan Report.
ENGINEERING PLAN
Comment 11. Engineering Plan – Section 3.6 – Provide a narrative description of the
design of the final cover vents and the final cover surface water control
features, including the terrace berms and down drain pipes.
Response 11. The Closure Plan has been revised to include a narrative description of
the design of the final cover vents and the final cover surface water
control features, including the terrace berms and down drain pipes.

Ms. Donna Wilson
January 23, 2017 Page 4

CQA PLAN
Comment 12. CQA Plan –
a. Provide a narrative description of how the final cover vents will be
installed, including placement within the low permeability layer and
excavation and disposal of waste.
b. Provide a narrative description of how the final cover surface water
control features will be installed within the final cover layers, including
the terrace berms and down drain pipes.
Response 12. The Closure Plan has been revised to include a narrative description of
how the final cover vents will be installed, including placement within
the low permeability layer and excavation and disposal of waste.
The Closure Plan has been revised to include a narrative description
how the final cover surface water control features will be installed within
the final cover layers, including the terrace berms and down drain
pipes.
POST-CLOSURE PLAN
Comment 13. Post‐closure plan ‐ 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
($1 million). See NCGS 130A‐ 295.2 (h1).
Response 13. The Post‐closure plan has been revised to add a summary financial
assurance page that include closure costs, post‐closure costs, and
PACA costs.
ENGINEERING DRAWINGS
Comment 14. Drawings ‐ Sheet 1 (Overall Facility Existing Conditions) – Please label
wetlands and power line easement, and add the description of the
convenience center back in.
Response 14. The Facility Plan has been revised to add Facility Plan Drawing FD-1 at
the end of the Facility Plan Report. Facility Plan Drawing FD-1
identifies wetlands, power line easement, and the convenience center.
Comment 15. Drawings ‐ Sheet 3, 4, and 7 – Please show existing contour lines
lighter than proposed base grade lines, as in the last submittal.

Ms. Donna Wilson
January 23, 2017 Page 5

Response 15. Drawings ‐ Sheet 3, 4, and 7 have been revised and re-plotted.
GROUNDWATER AND SURFACE WATER MONITORING PLAN
Comment 16a. In Section 5.6 Groundwater Sample Collection Please insert language
which states (in accordance with 15A NCAC 13B .0544 (b) (1) (D)) that
the detection monitoring program will include monitoring for the
constituents listed in Appendix I of 40 CFR Part 258, Mercury, Chloride,
Manganese, Sulfate, Iron, specific conductance, pH, temperature,
Alkalinity, and Total Dissolved Solids. Additionally, the NC Solid Waste
Section requires that all groundwater and surface water monitoring
locations at C&D landfills be analyzed for tetrahydrofuran.
Response 16a. The requirements are included in Section 9 which describes laboratory
testing.
Comment 16b. Please include a figure depicting potentiometric surface superimposed
on a topographic map, as the colored lines are difficult to discern on
the aerial photograph. Clearly indicate on the topographic map the
groundwater and surface water monitoring locations as the colored
dots representing the monitoring locations are difficult to distinguish
from surroundings on the aerial photograph.
Response 16b. Figure 1 “GROUND-WATER, SURFACE-WATER, AND EXPLOSIVE
GAS MONITORING LOCATIONS” has been revised to remove the
aerial photograph. The potentiometric surface is superimposed on a
topographic map.
LANDFILL GAS MONITORING PLAN
Comment 17. Please provide a figure with the locations of the landfill gas monitoring
wells on a topographic or scaled site map of the facility. It is difficult to
see the colors depicting the landfill gas monitoring locations on the
aerial photograph provided. Are landfill gas monitoring wells MM‐11
and MM‐12 new locations for the expansion? In Table 1, please
specify which landfill gas wells are existing and which are proposed to
be installed.
Response 17. Figure 1 “GROUND-WATER, SURFACE-WATER, AND EXPLOSIVE
GAS MONITORING LOCATIONS” has been revised to remove the

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aerial photograph. Table 1 has been modified to please specify which
landfill gas wells are existing and which are proposed to be installed.

Thank you for your consideration.
Sincerely,
GARRETT & MOORE, INC.

Vance F. Moore, P.E.
President
Attachments: Permit Renewal Response to Comments
Nash County C&DLF and Horizontal Expansion
Permit to Construct Application