0403_AnsonLF_reviewcomments_20230202

From: Wilson, Donna J
Sent: Thursday, February 2, 2023 5:01 PM
To: Bivins, Nathan; Tyler Fitzgerald; Susan Reid
Cc: Bradford, Teresa; Stanley, Sherri
Subject: Anson Landfill PTC Application for Phases 4 and 5, Staff Review Comments
Attachments: 0403 Anson Comments PTC Ph 4-5 Feb 2023.pdf, seismic veneer slope stability from 1119
_DukeAsheville.pdf, Seismicl-eachate calcs from 1119_DukeAsheville2.pdf, SeismicUnstable from 1119
_DukeAsheville.pdf
Hello Nathan,
Attached are the complete staff review comments for the Anson Landfill Permit to Construction Application, Phases 4
and 5. All previous preliminary comments have been compiled into one. The seismic documents attached are
referenced in comment 6.
If you have any questions please let me know.
Donna
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Donna J. Wilson
Ena ineering Project Vfanager, Solid haste Section
Division of Maste Management
North CarolinaDepartment ofEnviromnental Quality.
919"707"8255 (Office)
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Physical Address: 217 West Jones Street, Raleigh NC 27603
Mailing address: 1646 Mail Service Center, Raleigh SIC 27699
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Anson Landfill — Permit to Construct Application for Phases 4 and 5
Staff Review Comments - February 2, 2023
1. The Phase 5 expansion and the Phase 5 landfill redesign are different things, and this leads to
confusion with describing and illustrating areas and volumes. Provide a brief discussion and
illustration of the progression of these changes.
a. First show the landfill volume table with the landfill configuration before the Phase 5
expansion. The volumes below are from the 11-3-2022 permit table and the example
drawing is from File ID 1732876.
j
W'V 3 I
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Phase/Cell'
Acres
Gross Capacity,
cubic yards
Status
Phase 1
40.38
3,060,690
Active
Phase 2
33.70
4,672,949
Active
Phase 3
24.4
6,087,435
Active
Phase 4, Cell 1
8.9
1,200,000
Avoroved to o erate
Phase 4, Cell 2
11.46
2,314,080
Future
Phase 4, Cell 3
14.26
4,305,478
Future
Total
133.10
21,640,632
Next, show the landfill with the Phase 5 expansion area and provide the acres of the
expansion, and the volume of the
expansion, noting that the expansion is
also fill over the existing phases. The
a r,
Apr. _ ''� ,� ~~yti example drawing below is from the site
suitability figures.
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3
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Y
1
J,
1
Phase 5 expansion area:
Size of additional area — 66.9 acres
Additional volume — gross capacity of
19,857,735 cy, which is the new area and
a vertical expansion over the existing
area.

c. Last, show the landfill phase redesign with the new phase layout for Phases 4 and 5 (as
updated). Provide a capacity table that represents the acreages and volumes of the new
layout. The Phase 4 volume is the volume within the Phase 4 footprint plus the vertical fill
over the other areas before Phase 5 is used, represented/calculated by the difference
between the two drawings on Sheet C502 (as revised). The Phase 5 volume is the volume
within the Phase 5 footprint plus the area filled vertically on top to final closure,
represented/calculated by the difference between the second drawing on Sheet C502 and
the drawing on Sheet C503.
a
Phase/Cell
Phase/Cell
Acres
Gross
Capacity,
cubic yards
Remaining
Life
Expectancy,
ears*
Phase 1
40.38
3,060,690
-
Phase 2
33.70
4,672,949
-
Phase 3
24.4
6,087,435?
-
Phase 4
?
?
?
Phase 5
?
?
?
Total
201.0
41,498,367
?
*Calculated as of <date>
`,
2. The cover of the application should state Permit to Construct application for Phases 4 and 5. In
several places within the text and appendices, it should be stated that the construction and
operation descriptions are for Phases 4 and 5, not just Phase 5. This includes the CQA Plan and
Specs.
3. General text throughout report and the drawings should be updated for current conditions, such as
cells that are built/operating and tons per day.
4. In the application beginning text and figures, Figures 1-1 and 1-3 show the property boundary and
the 300-foot buffer in purple lines. On the north end, the buffer line crosses within the waste
boundary.
5. Provide an update to the Stream Impact Individual permit.
6. Seismic impact zones — Provide demonstration that all containment structures, including liners,
leachate collection systems, surface water control systems, and final cover are designed to resist the
maximum horizontal acceleration in lithified earth material for the site. Attached are example
seismic calculation pages from another permit, Duke Asheville landfill, permit 1119. The complete
document can be viewed here, Doc ID 1360676, dated 11-1-2019 -
httas://edocs.dea.nc.Rov/WasteManaizement/Browse.asDx?id=732019&dbid=0&reao=WasteManaR
ement.
7. Settlement and pipe loading:
a. The application is also a vertical expansion application over the previous Phases. An
additional 70 feet is added to the overall height of the landfill, from the previous maximum
height. The additional weight affects the older filled cells, for example, settlement and
leachate pipe loading. Address the additional weight/volume to the older cells with specific
information of those cells.

b. Provide settlement calculation for the center of the landfill and other areas not yet
represented, to show that the 4-foot separation distance is met to SHGT and bedrock, and
to demonstrate that the subgrade will continue to have a minimum 2% slope. A drawing
showing all the calculated points is needed. The waste density used was 60 Ib/CF (1620
Ib/CY).
c. App. C — Engineering calculations - For the pipe loading calculations, the waste density used
is 41.44 Ib/CF (1119 Ib/CY). From the annual reports, the density would be about 1700
Ib/CY. PDF page 452.
8. Explain the leachate pipe design for phase 4, cell 3, with the ability to collect leachate to meet the
rules, and the ability to clean out, camera, and jet clean. Of concern are the two lines with unusual
changes in elevation, one along the north edge and one just below that on the north flat part of
elevation 310-312. Also, there are multiple leachate lines longer than 1000 feet. The slope of the
landfill base is required minimum 2% after settlement.
9. Engineering plan and calculations:
a. If cells will be built incrementally for approval, instead of a whole phase, provide the acres
and volumes for each cell or cells to be built at a time (as it is expected).
b. App. C — Update the lifespan study for remaining life (years) of the landfill, Phases 4 and
5. The in -place density used was 1120 Ib/CY which seems low. From the annual report
numbers, it would be about 1700 Ib/CY. PDF page 237.
10. Facility plan — Provide a list of the equipment used to operate the landfill.
11. Facility drawings should include the following. See Rule .1619 (b) and (d) (1).
a. Other solid waste management areas on site, including the convenience center for
residential waste, residential recycling area, white goods recycling, scrap metal area, yard
waste T&P, and tire collection area. Include the parcel and ownership info for this area.
b. The landfill facility property boundaries. This can be the survey drawing that's on Laserfiche,
date 1-20-22.
c. The physical features related to the siting location restrictions within and near the property
boundary, such as floodplains, wetlands, cultural resources, etc.
d. Locations of the gas collection system, including the flare/blower, condensate sumps, and
collection piping.
e. Stockpile and borrow areas.
12. Engineering Plan and/or Operating Plan — When landfill filling is occurring in areas where landfill gas
extraction wells are in place, what is the procedure for the existing well? Will the gas well be
abandoned? If not describe how the fill would occur around a well. The closure plan and gas
collection plan indicate that the wells may be extended.
13. Operations plan:
a. Discuss each of the alternate daily covers used. For the ones that are approved in the
Section guidance document "Approved Alternative Daily Cover Material For use at Sanitary
Landfills," confirm implementation according to the guidance (page 2) that includes a notice
in the operating record with the procedure and the notice and procedure sent to the
Section. The guidance document is here -
https://edocs.deg.nc.gov/WasteManagement/0/edoc/723214/ApprovedACM Rev1 GDE 2
0170721.pdf?search id=f7d5b34c-664b-4338-930a-d1db93f0272f. If the seaboard solids
(used sawdust absorbent) are still being used for alternate daily cover, provide details and
procedure in the text, and follow with the notice in the operating record and to the Section,
as described in the guidance document. Details should include specifics such as the usage
criteria listed in the guidance document.

b. For the operational berms, or inter -cell berms, describe the design and method. Describe
how the flap will be removed and the valve opened. Confirm that a written certification for
the proper connection (flap removed, valve opened) will be placed in the operating record,
each time a cell is connected.
c. Storm Water Conveyance — Include a description of surface water control berms or swales
used to prevent contact water from the active working face (above natural grade), or that
has come into contact with waste, from entering the stormwater collection system.
d. The operating plan and App. G indicate that leachate may be recirculated within in the
landfill by spraying onto the active working face. If this is a currently active practice, provide
information on volumes and dates for the amounts being recirculated, within the last 2 or 3
years. If this is not occurring, update or remove the text.
e. Describe leachate system maintenance in accordance with Rule .1626 (12).
f. Leachate storage basin — The text states that the current basin is designed to meet the
volumes of Phases 1-3 and Phase 4, cells 1 and 2. What are the plans for the next leachate
basin?
g. The asbestos disposal plan should be reviewed and updated as needed. There is a typo
("SO") for the distance to a property boundary or occupied building or structure.
h. Liquids solidification — Describe the maximum time that a liquid waste will be within a
solidification tank before it is solidified and removal for disposal.
i. Section 5.13 - Areas that will not receive waste for 12 months or more, but will receive
additional waste, must be covered with a minimum of 12 inches of soil intermediate cover.
j. Records — Closure and post -closure cost estimates and financial assurance documents
should be added to the list of records to be kept.
14. LFG monitoring plan and collection plan:
a. Show building monitoring points on the map.
b. It appears that LFG monitoring point 4 should be added to the map.
c. LFG monitoring guidance was updated 2021.
d. LFG collection plan — Section 2.2.3 — The text indicates that it is expected to increase the
flaring capacity by 2023, please provide an update.
15. The water quality monitoring plan should include maps showing the shallow and deep
potentiometric water contours.
16. Drawings:
a. Provide detail drawing of the landfill gas collection well on the final cover.
b. For G100 through G204, provide the top of SHGT and bedrock data points for each boring
(on the drawing) that the contours are based on, see .1620 (e) (8).
c. Final cover — Change the contour interval of final cover to 5-foot contours for the side slopes
or for both side and top to allow more readability.
d. Label the leachate pipe sizes for each pipe on a drawing.
e. Show the location of stormwater intercell berms, used to separate clean stormwater from
landfill leachate within a cell.
17. CQA plan and construction:
a. For the Pre -construction meeting held onsite, the Solid Waste Section should be notified so
that a representative may choose to attend.
b. Include - The owner or operator of the MSWLF units shall notify the Division via e-mail no
less than 24 hours before conducting the subgrade inspection required by Part (C), Rule
.1624 (b)(7).
c. Tests for the soil test pad should include a composite sample for recompacted lab
permeability, for each lift.

d. Section 4.2.4.4 — Geomembrane test seams should be made for every 4 hours of continuous
welding, instead of 4 to 6.
e. Geomembrane liner installation testing should include an evaluation of the entire liner for
leaks as required by G.S. 130A-295.6(h)(1) using technology such as electronic leak
detection.
f. Section 2.5.1.3 — Describe how the geotextile surrounding the leachate collection pipe
aggregate Is removed and/or folded back from the leachate trench before waste is placed in
a particular area. See Rule .1624 (b)(11)(B)(iii) and (b)(13)(B). The bedding material for
main collector lines shall be extended to and in direct contact with the waste layer or a
graded soil or granular filter.
g. The last page, page 68, is missing from the application submitted.
h. Section 1.2.3 — For the CQA certification document, the report should also include the
information listed in Rule .1624 (b)(16). The last part of the certification statement "and the
requirements of the rules of this Section" should be worded as "and the requirements of
Rule 15A NCAC 13B .1624."
i. Granular soil material used as filter can have no more than 5% by weight passing the No.
200 sieve, see Rule .1624 (b)(13)(A)(i).
j. Describe the procedures to ensure that the integrity of the landfill systems will be
maintained prior to waste placement.
18. The Composting plan in the Operations Plan appendix should be updated. The rules were changed
in 2019 and are available - https://deg.nc.gov/about/divisions/waste-management/solid-waste-
section/special-wastes-and-alternative-handling/composting.
a. The contact information should be updated. Figure 1 is missing from the plan.
b. The text should be updated to reflect actual yard waste management activities onsite. It is
acceptable to list different options, and how those would operate. For example, the site
may be used to make mulch for onsite use only and would be operated as <Section x>, and
the facility may choose to begin composting of the material, and public distribution, and in
such case, it would be operated in accordance with <Section y>. The boundaries need to be
defined.
19. Closure Plan, Post -closure Plan, and cost estimates:
a. It should be stated that the largest area requiring closure would be X acres for when Phase 4
is open and operating and would be 201 acres when Phase 5 is open and operating. Or
similar, if the cells will be built incrementally instead of a complete Phase.
b. Describe recordation of a notice to the Register of Deeds in accordance with Rule .1627
(c)(8).
c. Section 7.3 should state that landfill gas monitoring around the landfill perimeter and in
buildings, surface water, and groundwater will be monitored during the post -closure period.
d. Provide frequency of the post -closure activities.
e. Describe the five-year certification, in accordance with Rule .1627 (d)(3).
f. Cost estimates for closure and post -closure should be updated as needed, and should be
provided for the next area of landfill to be constructed and permitted for use, whether it is a
Phase or certain cells. Or, the costs may be based on the entire landfill.