1302_CabarrusCo_CDLF_PH3PTCAppReview_DIN27206_20170104

ROY COOPER
Governor
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

January 4, 2017

Sent Via Email – [e-mail]
Mr. Kevin Grant
Sustainability Manager
242 General Services Drive
Concord, North Carolina 28025

Subject: Engineering Technical Review
Cabarrus County C&D Landfill
Cabarrus County, Permit # 1302-CDLF-2006, Document ID 27206

Mr. Grant,

The Division of Waste Management, Solid Waste Section (Section) has completed the technical
review of your application submittal titled Substantial Amendment and Phase 3 Permit to
Construct (DIN 26872). The application was submitted on your behalf by CDM-Smith and was
received in the Asheville Regional Office on October 18, 2016.

Based on this review, the Section requires clarification or additional information in order to
complete the permitting activity. Please provide a response to each of the items listed below:
Engineering Plan
1. Rule .0539(e)(4) requires engineering drawings to illustrate the cap system including base
and top elevations, landfill gas devices, infiltration barrier, surface water removal, protective
and vegetative cover, and details. Base elevations and landfill gas devices were not apparent
in the engineering drawings provided.
2. Rule .0539(e)(6)(A) requires engineering drawings to illustrate cross-sections, showing
borings, which indicate existing ground surface elevations, base grades, seasonal high
ground-water level and estimated long-term seasonal high ground-water level. Boring
locations and estimated long-term seasonal high ground-water levels were not apparent in
the engineering drawings provided.
3. Rule .0539(e)(6)(B) requires engineering drawings to include a map showing the existing
ground surface elevation and base grades and must include labeled boring locations which
indicate seasonal high ground-water level and estimated long-term seasonal high ground-
water level. No ground-water contour map was included in the engineering drawings
provided.

Construction Quality Assurance Plan
4. Rule .0541(b)(5) requires a plan for holding daily and monthly troubleshooting meetings.
Section 3.3, Progress Meetings, states progress meetings will be held at a frequency specific
to the needs of the project, typically on a biweekly basis.

Mr. Kevin Grant 
Engineering Technical Review 
January 4, 2017 
Page 2 of 2 

Operations Plan
5. Rule .0542(b)(D) requires operation drawings to illustrate special waste handling areas, such
as asbestos disposal area, within the C&DLF unit. No special waste handling areas were
noted on the operation drawings. Please verify there are no special waste handling areas
planned for CDLF Phase 3.
6. Rule .0542(c)(2) requires asbestos waste to be managed in accordance with 40 CFR 61.
Asbestos waste is defined in Section 2.1, Waste Definitions, however, there is no mention of
asbestos waste management in Section 2.2, Acceptable Waste, Section 2.3, Acceptable
Waste Requiring Special Handling, or Section 2.4, Prohibited Wastes.

Closure and Post-closure Plan
7. General Statute 130A-295.2(h1) requires the owner or operator of a sanitary landfill for the
disposal of construction and demolition debris waste to establish financial assurance
sufficient to cover a minimum of one million dollars ($1,000,000) in costs for potential
assessment and corrective action (PACA) at the facility. There was no mention of the
PACA costs in the financial assurance cost estimates

If you should have any questions regarding this matter please contact me at [phone], or
by email at [e-mail] .

Sincerely,
Allen Gaither
Environmental Engineer

CC: Mr. Martin Sanford – CDM-Smith
Mr. Perry Sugg – SWS/RCO