HomeMy WebLinkAbout9231_BrownfieldRdCDLF_ApplRev_DIN25973_20160419.pdf1
Backus, Pat
From:Backus, Pat
Sent:Tuesday, April 19, 2016 9:26 AM
To:Don Misenheimer (don@smithgardnerinc.com)
Cc:Stacey Smith, (Smith Gardner); Donald Plessinger (Waste Industries); Werner, Elizabeth
(elizabeth.werner@ncdenr.gov)
Subject:Permit No. 9231-CDLF-2012 Material Recovery C&D Landfill (Brownfield Road)
Don,
I finished reviewing my parts of the application. Elizabeth is reviewing the water monitoring plan, gas monitoring plan,
and hydro sections. Since there were only a few minor comments, I decided to send an email rather than a formal
letter.
These are comments other than were previously discussed about drainage.
Attachment G – Technical Specifications
1. Rock Removal – Section 02229 is reference in Section 02223 Embankment but is not include in the Technical
Specifications attachment.
2. Landfill Gas Wells/Vents – Section 13252 is referenced in Section 02614 High Density Polyethylene (HDPE) Pipe
but is not included in the Technical Specification attachment.
Attachment I – Operation Plan
Section 1.2.3 – Contact Information – North Carolina Department of Environmental Quality
Liz Patterson is in the Raleigh Central Office.
Dennis Shackelford has retired and Drew Hammonds has been appointed as his replacement. His email is
andrew.hammonds@ncdenr.gov .
Section 2.2 Acceptable Waste
The definition listed in the operation plan for “Land Clearing and Inert Debris Waste” is incorrect. The referenced
statute, G.S. 130A‐290(a)(15), states "Land‐clearing debris" means solid waste which is generated solely from land‐
clearing activities. 15A NCAC 13B .0101 (23) states “Land clearing waste” means solid waste with is generated from
land‐clearing activities such as stumps, trees, limbs, brush, grass, and other naturally occurring vegetative
material. Please note that “yard trash”, which was listed in the definition provided, is specifically excluded from
disposal in a C&DLF unit by 15A NCAC 13B .0542(e)(14).
It is stated that “special wastes” described in Section 2.5.3 may also be accepted at the facility. Section 2.5.3
describes special handling procedures for asbestos. There is a statutory definition for “special wastes” in G.S. 130A‐
290(a)(40). It does not include asbestos waste. “Special wastes” are one of the waste excluded for disposal in a
C&DLF unit by15A NCAC 13B .0542(e)(12). Asbestos waste can be accepted and disposed based on 15A NCAC 13B
.0542(c)(2). It might be better to use terminology that doesn’t conflict with a regulatory definition.
Section 2.3 Prohibited Wastes
Scanned By Date DOC ID Permit
Backus
04/19/2016 25973 9231-CDLF-2012
2
There are more wastes that can’t be disposed of in a C&DLF unit than are listed in the operation plan. These are
listed in 15A NCAC 13B .0542(e). This rule will be referenced in the permit and it might be beneficial to reference
this rule in this section so that your screening will exclude these wastes.
Attachment H – Financial Assurance
The estimate you have provided includes Phase 2B and is reasonable and acceptable. However, because it may be a
few years before Phase 2B is constructed and because you may be closing Phase 1 in the interim, I don’t plan to
issue a letter approving the financial assurance at this time. The facility already has financial assurance in place for
the area in the permit to operate.
If you have questions, please contact me.
Thanks,
Pat
Patricia M. (Pat) Backus, P.E.
Environmental Engineer
Division of Waste Management – Solid Waste Section
North Carolina Department of Environmental Quality
(919) 707-8257 office
pat.backus@ncdenr.gov
Office Location: 217 West Jones Street
Mail & Delivery: 1646 Mail Service Center
Raleigh, NC 27699-1646
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.