HomeMy WebLinkAbout0403_AnsonLF_reviewcomments_201708041
Wilson, Donna
From:Wilson, Donna
Sent:Friday, August 04, 2017 11:48 AM
To:'Bivins, Nathan'
Cc:Nelson Breeden (NelsonB@WasteConnections.com); Teresa Bradford (teresa.bradford@ncdenr.gov);
Sugg, William P
Subject:Anson Landfill Phase 3 and 4 comments
Hello Nathan – I’ve completed my review of the Anson Landfill Phase 3 and 4 PTC application and I have the following
questions and comments:
1. Section 2.2.1, Section 4.2, and Operations Plan – Types of Wastes
a. Ash is mentioned as being accepted. It should be stated that coal ash may be accepted for disposal after
approval of Anson County and the Solid Waste Section.
b. It should be noted that certain wastes can not be accepted due to landfill ban. See
https://deq.nc.gov/conservation/recycling/banned‐materials.
2. Section 2.3.2 – Life expectancy
a. The gross capacity number doesn’t correspond with the last permit issued. The original volume
approved, as noted in the public notice for gross capacity, is 19,310,000 cy. Variance of this number is
allowed if less than 10% (without a substantial amendment, public notice). The change in volume
should be explained in text, with the percent increase from the original approved noted.
b. The capacity table needs to also state that the gross capacity is from the bottom of waste to the top of
the final cover
3. Section 2.4.1 – The protective cover permeability minimum is different between the standard and alternate liner
(1.9 x 10‐4 vs. 1.9 x 10‐3).
4. Section 2.5.1.3 and 3.6.1 – Post‐settlement slope of the base liner and leachate collection system piping should
be addressed, and a reference provided to the post‐settlement slope calculations.
5. Section 2.5.1.4 and Operations Plan ‐ Leachate tanks should be replaced with the leachate basin.
6. Section 3.6.5 – The final cover side slope is described as 3:1, inconsistent with other sections. Top slope should
be minimum 5% post‐settlement, instead of 3%.
7. Closure and Post‐Closure Plans:
a. Gas extraction well installation should be described. Reference should be made to the plans and
drawings in the appendix. When are extraction wells to be installed (incrementally)?
b. Plans should include items listed in Rule .1629 (b)(1), (b)(3), and (c). Post‐closure plan should include
monitoring frequencies for maintenance of the cap, leachate collection system (including camera
inspection), and the monitoring and gas collection systems.
c. Cost estimates provided are for Phase 3 and 4 only. The costs should be for largest area requiring
closure or post‐closure. Financial assurance can either be based on (1) the entire landfill, including areas
not yet built, or (2) the landfill area consisting of areas built and approved for use, incrementally
increased as new areas are built. Provide calculations for either the entire landfill or Phases 1, 2, and
the first area of Phase 3 to be constructed. Provide a summary financial assurance sheet that totals the
closure cost, post‐closure costs, and potential assessment and corrective action costs.
8. Gas collection plan – Text should be updated concerning filling, dates, construction, and design of system for the
entire landfill.
9. Appendix A ‐ Operations Plan –
a. Describe access control – gates, fences, etc. to prevent unauthorized entry.
b. Sections 5.13 and 5.17.7 ‐ Alternate daily cover – Past permits have listed the approval of three
alternate daily cover materials: petroleum contaminated soils, auto shredder fluff, and seaboard solids.
For other alternate cover mentioned, foundry sand, foam, and fabric blanket, clarify in text that the
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notice and notification requirements have been met, as described in the guidance document “Approved
Alternative Daily Cover Materials for Use at Sanitary Landfills,” Implementation section on page 2 (pdf
page 5). The guidance document can be viewed at ‐ https://deq.nc.gov/about/divisions/waste‐
management/waste‐management‐permit‐guidance/solid‐waste‐section.
c. Section 5.19.13 – The leachate collection system must be camera inspected and jet cleaned regardless
of the permeability of the protective cover. Leachate lines should be camera inspected at the end of
construction. The text states it will be 6 months following construction, please address.
d. Section 7.2 – Landfill Gas monitoring – Provide the number of gas monitoring wells and building
monitoring points. Provide a reference to a map showing the location of the wells and a cross‐section of
a landfill gas monitoring well.
e. Section 9.0 – DEQ phone number should be 919‐707‐8200.
f. Describe surface water control measures at the active working face, including run‐off and run‐on.
g. Compost Operations Plan – Temperatures should be taken at least every other day for the time period
to verify time and temperature requirements (3 consecutive days at 131 degrees).
h. Leachate Recirculation Plan – Table 1 referenced in the text is missing. It is supposed to show volume of
leachate to varying daily waste tonnage.
i. Is leachate recirculation being actively practiced? How is the spraying managed in conjunction with
unloading of waste and equipment spreading and compacting?
10. Leachate collection design:
a. The design and placement of the leachate lines and clean outs for the new phases must allow for
permanent remote camera inspection and jet cleaning. Provide a letter from a camera and clean out
company stating that they will be able to camera and jet clean the leachate design layout as shown for
Phases 3 and 4, with the leachate line sketches/drawings attached. In particular, the concerns are the
lengths of the lines and the curve in Phase 3, cell 1B. The length of the leachate lines for the current
planned cells as they affect future Phases should be considered.
b. The drawings list 8 inch and the specs state 6 inch for the leachate pipes.
11. Drawings:
a. The cell layout engineering drawings do not match the cell layout drawings in the approved hydro plan.
Drawings, including the cross‐sections should be updated. Show base liner elevations on the plan
drawings for seasonal high groundwater and bedrock.
b. The minimum 2% base liner slope is not met in Phase 3 cell 1B in two locations, and in Phase 3 cell 2A
near the sump. The minimum slope of 2% is post‐settlement.
c. Base liner contours should be added to drawings C301 through C304 and final cover contours for
drawings C500 through C502.
d. The progression of fill diagrams don’t show appropriate contours.
12. The CQA plan and/or specifications should address the minimum required interface friction angles for materials
provided, liner and final cover.
13. Appendix C – Engineering Calculations ‐ Settlement:
a. For the calculation of the CCL settlement, it shows that Sc is 0.49 feet. I believe this should be 0.49
inches.
b. Please add units to the settlement results small summary table.
c. Calculations and demonstration should include whether minimum 2% slope of the base liner is
maintained post settlement.
Please provide a response to comments letter with the revised application. Electronic (pdf) copy of the application is
fine, but a paper copy of the engineering drawings is also requested.
If you have any questions or comments please let me know.
Thanks, Donna
Donna J. Wilson
Environmental Engineer
Solid Waste Section, Division of Waste Management
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Department of Environmental Quality
Phone 919-707-8255
Email donna.wilson@ncdenr.gov
Section website http://deq.nc.gov/about/divisions/waste‐management/solid‐waste‐section
Office address – 217 W. Jones St., Raleigh, NC 27603
Mailing and delivery address – 1646 Mail Service Center, Raleigh, NC 27699-1646
Email correspondence to and from this address is subject to the
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