7407_Pitt_CandDLandfillInc_20190307_CARequest_FID1285974

C&D Landfill, Inc.
Corrective Action Permit Modification
March 7, 2019
Ms. Jaclynne Drummond
Compliance Hydrogeologist
Solid Waste Section, Division of Waste Management
North Carolina Department of Environmental Quality
2090 U.S. 70 Highway Swannanoa
Asheville, NC 27887-8211
RE: CORRECTIVE ACTION PERMIT MODIFICATION
C&D LANDFILL
PITT COUNTY, NORTH CAROLINA
PERMITS 7407-CDLF-2001, -2009
Dear Ms. Drummond:
wood.
Wood Environment & Infrastructure Solutions Inc. (Wood) is providing this corrective action
schedule update for the C&D Landfill at 802 Recycling Lane, Greenville, North Carolina (Site) on
behalf of C&D Landfill Inc. As we discussed during our telephone call on February 19, 2019, an
Assessment of Corrective Measures Report was submitted for the Site on October 30, 2017, and
a public meeting was held to discuss the potential corrective measures on December 14, 2018.
We are continuing to evaluate groundwater monitoring data from the Site as we work to select a
corrective measure and submit a Corrective Action Permit Modification Application. To conduct
statistical trend analysis on concentration data four sampling results are required, and the Spring
2019 semi-annual groundwater monitoring event will be the fourth event to include parameters
for evaluating natural attenuation of contaminants. Therefore, we would like to opportunity to
obtain and analyse the data from the Spring 2019 groundwater monitoring event prior to selecting
a groundwater remedy. Based on the schedule for obtaining and analysing the Spring 2019 data,
we expect to submit the permit modification application November 30, 2019.
In addition, Dave Garrett will be submitting information regarding the expansion for Phase 3 under
a separate cover. Based on current information, Wood anticipates that conditions are such that
Phase 3 can be monitored independently, and that groundwater remediation activities in Phases 1
and 2 can be implemented with minimal, if any, influence from activities in Phase 3. The letter is
attached for your reference.

If you have any questions concerning this schedule, please contact Sheri Knox at [phone] or
Damian Hriciga at [phone].
Sincerely,
Wood Environment & Infrastructure, Inc.
Damian Hriciga, PG
Senior Geologist
Sheri L. Knox, PE
Associate Engineer
Attached: Response to Regulatory Comments; C&D Landfill, In. Phase 3 Expansion
cc: Wayne Bell, C&D Landfill, Inc.

wood.
February 27, 2019
Mr. Ethan Caldwell, PE, Permitting Engineer
NCDEQ Division of Waste Management
Solid Waste Section, Permitting Branch
1646 Mail Service Center
Raleigh, NC 27699-1646
Subject: RESPONSE TO REGULATORY COMMENTS
C&D LANDFILL, INC. PHASE 3 EXPANSION
PERMIT NO. 7407-CDLF-2001 (PITT COUNTY)
WOOD PROJECT No. 6468-18-8038
Dear Mr. Caldwell:
Wood Environment & Infrastructure, Inc. (Wood) responds your comments of February 19, 2019
presented in an email message. This response is made on behalf of the Owner/Operator who, per
encouraging earlier comments from SWS officials, is pursuing an expansion into a new footprint
located within the Facility Boundary, west of existing Phase 2. Phases 1 and 2 are discontinuous
and opened in 2002 and 2009, respectively. These phases are soon nearing full capacity and the
Facility needs to expand. Phase 3 is projected to provide 20+ years of capacity, on which the local
government depends for meeting Pitt County's solid waste disposal requirements.
Your comments are presented below, along with responses the Owner supports:
7. Can you provide some clarification on the proposed engineering and construction?
First, a comment on subsurface conditions as identified in the Site Suitability study. The
upper 12 to 15 feet are sandy; below those depths exists a silty to clayey fossil -bearing
layer that is tens of feet thick beneath Phases 1 and 2, but the layer thins and becomes
discontinuous to the north. The water table is typically 5 feet or less beneath the surface.
The upper sandy aquifer is hydraulically connected to on -site streams and ditches.
Beneath the silt -clay is another sand layer represented as a regional aquifer; earlier
observations indicate an upward gradient between the aquifers.
Wood Environment & Infrastructure Solutions, Inc.
4021 Stirrup Creek Drive, Suite 100
Durham, North Carolina 27703
Licensure: NC Engineering F-1253; NC Geology C-247
Tel — [phone]
Fax — [phone]
www.woodpic.com

Review of Preliminary Hydrogeologic Study
C&D Landfill, Inc. Phase 3
Permit 7407-CDLF-2009 (Pitt County)
Greenville, North Carolina
The base grade will be set typically 4 feet above existing grades because of the shallow
water table. While it may be feasible to perform shallow cuts within some portions of
the site, the resulting base grades might be flatter than desired for proper drainage. As
such, a significant volume of structural fill will be required. The Owner has several
hundred acres adjacent to the site for borrow. The borrow soils have not been fully
explored, but the soils in the east side are typically sandy. If fine grain soils that meet the
regulatory grain -size distribution requirements in the upper 24 inches are not present
within the adjacent property, consideration may be given to importing suitable soils or
blending the soils with an admixture to lower the permeability. The construction will be
staged in cells that will facilitate water management to prevent leachate generation.
2. If I am reading the map correct the proposed Phase 3 area is in the location of the borrow
area and is part of the facility from the Phase 2 expansion but has not had site suitability
performed on that specific area.
Phase 3 is located within the Phase 2 facility expansion area, all of which was included in
the 2002 Site Suitability study. The Phase 3 area was originally planned for CDLF
development. The current franchise included the subject property within the facility
boundary when it was approved. Our client will be applying for a new franchise and a
substantial permit amendment due to the volume increase. At some point the Owner
had tentatively decided to use the Phase 3 area as a borrow site, but this did not occur
because the availability of a closer borrow was more cost effective.
3. Additionally, the Phase 3 area will not require rerouting of any creeks, as was previously
discussed.
The current configuration of Phase 3 will not involve the rerouting of streams or creeks.
4. In my brief review of the franchise agreement for Phase 2 it appears that this area was not
included and the franchise agreement.
Regarding the franchise, the Owner understands the volume increase associated with
Phase 3 will require an amendment of both the franchise and the facility permit.
5. I'm assuming you are proposing to construct the Phase 3 area without a liner. This may be
a stumbling block for Phase 3 as applied to General Statues, Rules and past operations.
The Owners of C&D Landfill, Inc. take note of recent permitting for a new CDLF in Harnett
County, which is of similar size and within a somewhat similar topographic and hydraulic
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Review of Preliminary Hydrogeologic Study
C&D Landfill, Inc. Phase 3
Permit 7407-CDLF-2009 (Pitt County)
Greenville, North Carolina
setting, including a prior assessment of groundwater impacts. That application shows a
conventional soil subgrade with certain required soil types within the upper 24 inches.
Based on the groundwater data, it is not clear that the source of groundwater impacts
identified at the site is related directly to waste acceptance criteria or practices. We
understand the site was used for agricultural purposes and that soil was used from an
offsite source for some site grading in Phase 2. It should be noted that the groundwater
impacts were noticed near the end of construction, before Phase 2 was operational.
For C&D Landfill, an Assessment of Corrective Measures has been completed. Subsequent
baseline sampling results are encouraging that natural attenuation may be appropriate.
Based on site geometry, Wood maintains our belief that conditions are such that Phase 3
can be monitored independently, and that groundwater remedial activities below Phases
1 and 2 can be implemented with minimal, if any, influence from activities in Phase 3.
There are no known downgradient groundwater users and the site is relatively well isolated
from all known water supplies.
On behalf of C&D Landfill, Inc. We appreciate the opportunity to provide this information for the
Section's consideration. We look forward to a productive dialog moving forward.
Sincerely,
Wood Environment & Infrastructure, Inc.
CARp
G. David Garrett, PG, PE
Senior Engineer — Geotechnical :•`�
cc: Wayne Bell, C&D Landfill, Inc. 3-7-2019
Ed Mussler, PE, Solid Waste Section
Sherri Stanley, Solid Waste Section
Sheri L. Knox, YP
Associate Engineer -Environmental
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