7606_GoldHillRdCDLF_comment_Phase 2AFinal CoverEvaulation_DIN28345_20170728

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Friday, July 28, 2017 11:13 AM
To:'Raup, Michael'; Garrett, David; Al Morton
Cc:Mussler, Ed; Patrone, John; Rice, Sarah M; Aja, Deborah
Subject: Gold Hill Road C&DLF Certification Closure Report _Phase 2A, 76-06, DIN 28345
Gentlemen: DIN 28345

Thank you for submitting the certified CQA Report (DIN 28336) for Phase 2A of Gold Hill C&DLF, Permit
No. 7606-CDLF-2001. The Report was dated November 24, 2014 and prepared by SCS Engineers, PC and
certified/signed/sealed by NC Professional Engineers – Adam Smith and David Garret. This CQA Report states
the 2014 activities of evaluating the thickness of cover soil of the final cover system over Phase 2 of the
C&DLF, approximately 9 acres.

After a review, the Solid Waste Section DOES NOT think that the constructed final cover system over Phase
2A area meet the requirements stated in
i. North Carolina Solid Waste Management Rule (Rule) 15A NCAC 13B .0543 and
ii. The Closure Plans [included inside the Financial Assurance Calculation – Second Revision dated
September 29, 2010 (DIN 11912) and Financial Assurance Calculation Update dated October 10,
2013 (DIN 19992)] prepared by David Garret & Associates.

Below are the insufficiencies identified in the CQA Report:
i. The required laboratory and field testing results are not available in the CQA Report. The test
results will include, but not limited to, earthen material soil classification data (Atterberg Limits/PI),
in-place soil density data (standard Proctor and nuclear gauge data), hydraulic conductivity data (less
than or equal to 1*10-5cm/sec), etc. According to the Closure Plan dated October 10, 2013 (DIN
19992) the testing frequency for each required test item summarized below:
Testing Item Testing Frequency
Permeability Test One test per lift per acre
In-Place Soil Density Four nuclear density gauge tests per lift per acre

a. Without the in-place soil density or soil shear strength results, please explain why the assumed
engineering parameters used in the slope stability analysis are valid and how the factor of safety
for the 3 to 1 landfill side slope are confirmed.

b. The hydraulic conductivity data is not available in the CQA Report; this violates the Rule 15A
NCAC 13B .0543(c)(1)(A).

ii. The minimum thickness of each component of the prescribed final cover system is eighteen (18)
inches was not achieved. The final cover system over the Phase 2A has been constructed (likely
according to the Rule 15A NCAC 13B .0505) by installing non-engineering control earthen material
with the thickness ranging from 16 to 36.5 inches. This violates the Rules 15A NCAC 13B
.0543(c)(1)(B) & (C).

iii. There is no landfill gas vent or well installed at the closed cover system. This violates the Rule
15A NCAC 13B .0543(c)(2)(B). The gas vents should be installed at the final cover at a rate of
three vents per acre according to the Closure Plan dated October 10, 2013 (DIN 19992).
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iv. The acreage of the closure area is not measured by the licensed surveyor registered in the State of
North Carolina. The as-built survey of the closed area is not available in the certified CQA
Report. Without the acreage of the closed area shown on the as-built drawing, the Solid Waste
Section can not confirm if Morton and Sewell Land Company, LLC fulfills the requirement stated in
Administrative Order On Consent Amendment # 1 (DIN 28246) –

“During operation of the Gold Hill Road Construction and Demolition Debris Landfill, the
facility shall close and open sub-phases as needed that will be no larger than 6.1 acres at any
given time.”

Within 30 calendar days after receiving this e-mail message, Morton and Sewell Land Company, LLC must
complete the following tasks:

1. Should the Solid Waste Section have previously given Morton and Sewell Land Company, LLC an
approval of installing the cap system as described in the certified CQA Report as an alternative cap
system, please provide the Solid Waste Section a copy of the approval document.
2. Otherwise, please provide the measures to resolve the above-referenced violations.

Until the resolutions are achieved the Solid Waste Section (1) shall not issue Morton and Sewell Land
Company, LLC a new Permit Approval To Operate for the constructed Gold Hill Road C&DLF – Phase 1A and
(2) will engage the processes to rescind the exiting permit issued to Gold Hill Road C&DLF.

Please contact myself if you have any question of the decision on the certified CQA Report or you want to meet
and discuss the resolution(s). Thank you and have a wonderful weekend.

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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From: Raup, Michael [mailto:[e-mail]]
Sent: Thursday, July 27, 2017 11:11 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Garrett, David <[e-mail]>
Subject: Gold Hill Road Certification Report

Per your request, the Gold Hill Certification Report.

We will also send the updated facility plan topography report in the next two days.

Michael C. Raup, P.E.
Geotechnical Engineer
Amec Foster Wheeler Environment & Infrastructure, Inc.
4021 Stirrup Creek Drive - Suite 100
Durham, North Carolina 27703

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