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Home My WebLink About20191369 Ver 1_Pre App Meeting Notes_20190311CE SAW -RG -C (File Number, SAW 2018-00053) 3.0 Purpose and Need 3.1 Purpose and need for the project as provided by the applicant and reviewed by the Corps- � f fl The Solid Waste 1 Management Act of 1989, North Carolina General Statut 9 §130A -309.09A2 requires Gaston County to provide waste disposal services to Its citizens. Gaston County began siting studies to open a landfill for its citizens as early as the 1980s in anticipation of the pending Act and required need for waste disposal in the county. In 1986 the North Carolina Department of Environmental, Health and Natural Resources (NCDEHNR) Division of Waste Management issued Solid Waste Permit 36-06 authorizing the construction of the Gaston County Landfill. Currently, it is the only municipal solid waste (MSW) landfill in Gaston County and consists of three landfill areas, which include a closed construction and demolition (C&D) landfill (Permit 3606-CDLF-1995), a closed unlined MSW unit with an active C&D landfill on top (Permit 3606-MSWLF-1986), and an active lined MSW landfill (Permit 3606-MSWLF-1997) (Figure 1). FLEGND - �y.� x - itted Landfill PrSilD ,y `' x x x Sq ,dary (321 ac.) z zxx xxxx x x x x n County Landfill x x x x 'qx x x x x xx x x x x x x xrty (424 ac.)xx x x x x x x ty Structures xx x x x x x x x x x x x x xential Structures.' x z- I�Rx x x x x �. zffers I Setbacks xxx ix xxxxxx xtraints' ex x x �I �� Ix onal RPW x Perennial RPW Non -JD Pond %xxX xX _ Pond x x x x x xxxp • x x i' • �� \x x x x x _ wetlands x A1�� I x x x x ,x xx .��I� �♦ �� 1 x x x x 1987 LANDFILL PERMIT Tr Culvert `x x x x x :�� j j I� �� J` x x x APPROVAL x x x •Il ��401� x x x x - ® Closed - Construction & FEMA Floodway x x x x - ��---/// x x Demolition Waste Limits FEMA 100 -Yr Floodplain x x x x x x x x x x i x Closed -Municipal Solid FEMA 500 -Yr Floodplain - x x x x xx v. x Waste Limits x x x x xx/ x 1997 LANDFILL PERMIT I � h= i.CaC reet x x x x x x - Em '� x EXPANSION APPROVAL �— — --- x x x x x x x - 0 Feet 1.000 x x x x x Active Construction 8 K x x x f x x' Demolition Waste Limits x z x x Proposed Final Municipal -'xxx x x x x< x X x j..♦J Solid Waste Limits X% Active Municipal Solid Mste Limits At Capacity Municipal etr Solid Waste Limits Not Yet Constructed r e Figure 1. Gaston County Landfill 1 httos://www.ncleg.net/Enacted Leaislation/SessionLaws/HTMU1989-1990/SL1989-784.html 2 httos://www.nclea.net/enactedleaislation/statutes/html/bvchaoter/chanter 130a.html Page 1 of 3 �; -,d _ � J� ,fir• 1�css �f-f'�^�-��' �� 5 . �ace> 1�� bl� aS �Q CDC c� c sCtz�� n hoc c� rLS t�� J LD1 0l1�x�,evv�- S�r cerci �•A� 4�� A-+� CE SAW -RG -C (File Number, SAW 2018-00053) The closed C&D landfill and the closed unlined MSW landfill (beneath the active C&D landfill) were permitted to operate prior to the implementation of 40 CFR Part 258 (referred to as Subtitle D), which required the installation of impermeable geosynthetic underliners for all new and lateral landfill expansions after October 1993. The promulgation of 40 CFR Part 258 promoted the design of Units I, II, and III in accordance with Subtitle D regulations; thus, increasing capacity and lifespan of the landfill by approximately 30 years at the time. Unit I, Phase 1 and Unit II were opened in 1998 and 2009, respectively. Unit I, Phase I reached capacity in 11 years and Unit II began accepting waste. Unit II currently has remaining capacity for approximately 2.5 more years of waste disposal. The original C&D landfill is now closed and is built out to final contour design. The C&D landfill on top of the closed MSW landfill has approximately 4 months until reaching its permitted volume and final contour design. The Unit I, Phase 1 landfill is at capacity and is no longer accepting waste. As such, the only active landfill area accepting waste beyond a few months is Unit II, which only has a lifespan of approximately 2.5 years remaining. The opening of Unit III will allow for the opening of Unit I, Phase 2, and combined will increase the landfill capacity by 20 years or more, which is enough time for Gaston County to site and study a new landfill location. Table 1 summarizes the remaining capacity and lifespan of the Gaston County Landfill. Table 1. Landfill caoacitv I he original MSW landtlll underneath the GULF began operation in 1986 and ceased accepting MSW waste with the promulgation of 40 CFR Part 258; however, the regulations allowed for a construction & demolition landfill to operate on top of the MSW landfill to build out to the originally permitted volume to final contours. According to the 2010 United States Census Bureau (USCB) census3, approximately 206,086 people were living in Gaston County in fiscal year 3 United States Census Bureau (USCB). 2010. 2010 Population Finder. Accessed on January 21, 2019 at https://www.census.gov/popfinder/?fl=37071. Page 2 of 3 Total Remaining Landfill Areas Permit # Operations Status Permitted Volume Remaining Area Volume (CY) Life Span (ac.) CY 3606- 01 /1996 - CDLF CDLF- 12/1999 Closed -- -- 0 5.5 1995 CDLF Over 3606- 01/2000 - Closed MSW" MSWLF- Present Active 1,482,196 89,100 4 months 37 1986 Unit I, Phase 1 01/1998— Active, but 1,973,000 0 0 yrs 29 3606- MSWLF- 09/2009 At Capacity Unit I, Phase 2 ProposedConNoucted 568,872 568,872 2 yrs 10 07/2009— Unit II 1997 Present Active 3,060,0000 718,900 2.5 yrs 37 Unit III Pr2019 d 4,870,000 4,807,000 18 yrs 11.5 ConNoucted I he original MSW landtlll underneath the GULF began operation in 1986 and ceased accepting MSW waste with the promulgation of 40 CFR Part 258; however, the regulations allowed for a construction & demolition landfill to operate on top of the MSW landfill to build out to the originally permitted volume to final contours. According to the 2010 United States Census Bureau (USCB) census3, approximately 206,086 people were living in Gaston County in fiscal year 3 United States Census Bureau (USCB). 2010. 2010 Population Finder. Accessed on January 21, 2019 at https://www.census.gov/popfinder/?fl=37071. Page 2 of 3 CE SAW -RG -C (File Number, SAW 2018-00053) 2010/2011 and the per capita waste generation rate was estimated to be 1.2 tons per year (NC Solid Waste and Materials Management Annual Report).4 The USCB population estimate for 20175 estimates the Gaston County population at 220,182 citizens with a per capita waste generation rate for fiscal year 2016/2017 at 1.34 tons per year. The USCB and NC Solid Waste Annual Report statistics suggest a continued trend of population growth in Gaston County and potentially increasing per capita waste generation rates. There is an imminent need for waste disposal capacity in Gaston County in the next 2.5 years as summarized in Table 1. And, with the current population growth of Gaston County, the remaining landfill capacity may be consumed at a greater rate, thus shortening the estimated lifespan remaining to less than 2.5 years. To construct a landfill on a new site would take a greater amount of time to do than the 2.5 years of remaining lifespan at the existing landfill. To do so would include a siting study, potential land acquisition, potential rezoning for appropriate landfill land uses, new engineering, landfill infrastructure design, permitting, and the construction of the landfill itself prior to accepting waste from citizens. Therefore, the purpose of the project is to expand the Gaston County Landfill into Unit III and into Unit I, Phase 2 to connect Units I, II, and III for an estimated capacity of 20 or more years. 4 North Carolina Department of Environmental Quality (NCDEQ) Division of Waste Management. 2012. FFY11-12 NC Solid Waste and Materials Management Annual Report. Accessed January 21, 2019 at https://deg.nc.gov/about/divisions/waste- management/waste-management-rules-data/solid-waste-management-annual-reports/fv11-12. 5 United States Census Bureau (USCB) American Fact Finder. 2017. 2017 Population Estimate (as of July 1, 2017). Accessed on January 21, 2019 at hftps://factfinder.census.gov/faces/nav/isf/pages/community facts.xhtml. Page 3 of 3 CE SAW -RG -C (File Number, SAW 2018-00053) 5.0 Alternatives Analysis (33 CFR Part 325 Appendix B(7), 40 CFR 230.5(c) and 40 CFR 1502.14). An evaluation of alternatives is required under NEPA for all jurisdictional activities. An evaluation of alternatives is required under the Section 404(b) (1) Guidelines for projects that include the discharge of dredged or fill material. NEPA requires discussion of a reasonable range of alternatives, including the no action alternative, and the effects of those alternatives; under the Guidelines, practicability of alternatives is taken into consideration and no alternative may be permitted if there is a less environmentally damaging practicable alternative. 5.1 Site selection/screening criteria: In order to be practicable, an alternative must be available, achieve the overall project purpose (as defined by the Corps), and be feasible when considering cost, logistics and existing technology. Criteria for evaluating alternatives as evaluated and determined by the Corps: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The alternative would only be considered practicable and achieve the overall project purpose if the disposal unit needed to expand the landfill adheres to regulatory constraints. Local zoning or land use ordinances, state, or federal rules and/or laws set forth buffers and setbacks, which are regulatory controls that limit the locality of landfill disposal units within a landfill boundary. NC General Statute § 130A-295.61 prohibits a waste disposal unit within FEMA floodplains. North Carolina Administrative Code 15A NCAC 13B .16002 requires a minimum 300 -foot buffer between a disposal unit and all property lines and roads, and a minimum 500 -foot buffer between a disposal unit and all residences and drinking wells. These regulations are more restrictive or equal to those listed for landfills in Gaston County's Unified Development Ordinance 3. Table 2 (below), summarizes the regulatory buffers and setbacks required in determining placement of a disposal unit within a landfill. The 100 - foot buffer around the existing on-site cemetery was a voluntary setback put in place by the landfill during original development to preserve the feature. 1 https://www.ncleg.net/enactedlegislation/statutes/htmI/bychapter/chapter 130a.html 2 North Carolina Administrative Code. http://reports. oah.state. nc. us/ncac/title%2015a%20%20environmental%20guality/chapter%2013%20- %20solid%20waste%20management/subchapter°/o20b/subchapter°/o20b°/o20rules.pdf 3 Gaston County Board of Commission. April 2008. Gaston County Unified Development Ordinance. https://Iibrary.municode.com/nc/gaston county/codes/unified development ordinance Page 1 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) 2. Re u latory constraints a Property Boundary Setback 300 ft Permitted Landfill Boundary Setback 300 ft Residential Structures Buffer 500 ft Road Buffer 300 ft Cemetery Buffer 100 ft FEMA Features Avoid B. Must Allow Landfill to Continue Operation for the Foreseeable Future: The alternative would only be considered practicable and achieve the project purpose if it allows the existing landfill to continue operation for the foreseeable future of approximately 20 years. Approximately 6 to 10 years minimum are needed in order to perform siting studies, potential property acquisition, potential rezoning, engineering design, appropriate permitting, and construction of a new landfill site. The additional 20 years of capacity due to the expansion of the existing landfill would grant the time needed to develop a new landfill site for operation. C. Minimization of Environmental Impacts: The alternative would only be considered practicable and achieve the overall project purpose if only a minimum of environmental impacts are required. The delineated and verified streams and wetlands located on the landfill will be used to approximate impact amounts to determine the minimum amount of impacts needed while still achieving the project purpose and need. 5.2 Description of alternatives 5.2.1 No action alternative: Under the no action alternative, the existing landfill would be at capacity in approximately 2.5 years (year 2020 or 2021) and would have to cease accepting waste. There would be no other available landfill for waste disposal services in Gaston County. And, per North Carolina General Statute §130A -309.09A, waste disposal services are required to be offered by the local jurisdiction to meet local needs and protect human health and environment. Therefore, the no action alternative is not considered a practicable alternative. This alternative would not satisfy the following screening criteria: B. Must Allow Landfill to Continue Operation for the Foreseeable Future: The no action alternative would result in the landfill being at capacity in 2.5 years and would not allow the existing landfill to continue operation for the foreseeable future of 20 years or more. Page 2 of 11 A CE SAW -RG -C (File Number, SAW 2018-00053) C. Minimization of Environmental Impacts: While the no action alternative would not impact streams and wetlands existing on the landfill, it can be assumed that under the no action alternative, there would be environmental impacts associated with unregulated waste disposal as citizens would still need to dispose of waste, although the amount and type of impacts is unknown. This alternative would satisfy the following screening criteria: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The no action alternative would preclude the need to locate additional disposal units on the landfill; thus adhering to regulatory constraints is unnecessary. 5.2.2 Off-site alternatives The proposed project is an expansion of an existing landfill within the permitted landfill boundary. Therefore, offsite alternatives were not considered for this project. Given the remaining 2.5 years of capacity at the landfill, the development of an off-site alternative could not be achieved within the available timeframe nor would it be practicable to develop a new landfill when an expansion is feasible. Off -Site Alternative 1: Off-site alternative 2: 5.2.3 On-site alternatives Three on-site alternatives were examined to determine which on-site layout can be practicably achieved within the project's scope, while also balancing the mandate of avoidance and minimization to the highest degree. These include the Applicant's Preferred Site Layout (On -Site Alternative 1), a More Impact Site Layout (On -Site Alternative 2), and a No Impact Site Layout (On -Site Alternative 3). For all on-site alternatives, existing infrastructure within the landfill includes internal access roads, facility structures such as the scale house, citizen parking, stormwater controls, machinery storage and maintenance areas, groundwater monitoring wells, and a leachate collection system. This infrastructure will not necessitate any impacts for any of the on-site alternatives as they are existing features of the landfill. No development in the FEMA floodplain will occur. On -Site Alternative 1 (applicant's preferred alternative): The applicant's preferred site layout is designed based on the history of the landfill dating back to the 1980s (Figure 9). The proposed final municipal solid waste limits depicted on Figure were originally approved in 1986 and encompass approximately 88 acres. Page 3 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) Unit 1, Phase I consists of 29 acres and is at capacity and Unit II consists of 37 acres and will be at capacity in 2.5 years. Unit 1, Phase 2 and Unit III consist of a combined 21.5 acres and would provide an additional 20 years of combined capacity if constructed concurrently. Figure 9. Preferred Alternative (On -Site Alternative 1) layout The connection of Unit 1 to Unit II will result in impacts to jurisdictional features located in Unit III. The construction of Unit III will permanently impact jurisdictional waters that include approximately 280 linear feet of low quality perennial stream channel and 865 linear feet of low quality intermittent stream channel for a total of 1,145 linear feet of permanent impacts (Table 3, Figure and Figure 10). No wetlands will be impacted by the proposed activity. Construction of Unit I, Phase 2 will be constructed entirely in uplands and will not result in any impacts to waters of the US. A non -jurisdictional pond will also be impacted but is not included in impact or mitigation calculations. See Section 8.0 for additional information about compensatory mitigation associated with this project. Page 4 of 11 4 CE SAW -RG -C (File Number, SAW 2018-00053) Table 3. Proposed impacts associated with On -Site Alternative 1 IIFJD Feature Type Seas onai RPW 2 LANDFILL AREAS Approved JD Area Seasonal RPW (lf) 865 Perennial RPW (If) 280 etlands (ac.) 0 Total Stream Impacts (if): 9,14'J If Total Wetland W;I `, pacts ac.: _ 0 LEGEND Seas onai RPW 2 LANDFILL AREAS -All Buffers / Setbacks Constraints 17 IfOf IRIpaCt {fill) Preferred Alt - Proposed - Stream Impacts �Ijj�,I�►>�I��,I. - - - Seasonal RPW �;�j♦�I��I��II - Perennial RPW ��I��IIj��I✓� �I Pond Demolition Waste Limits Wetlands ►II Ifrf - Non -JD Pond Demolition Waste Limits a Culvert Perennial RPWI 0� 280 if of impact (fi Preliminary 0 0 0 0 0 tlNt f Phase 2 9aawnal RPW {dry..* W-5 ,. c. pe(BRe7al RPMs tlp aCk 0 -a WettaRM(ac.l Tota, Se'sam 1. WS if 0 . Maar i t{pgt lYeVaW Seasonal RPW 1 848 If of impact (611)MM - ✓ j Non JD Pond 1 -� Active Municipal Solid %�- 0.39 ac. (fill) waste Limas ;. (motive Municipal Solid Waste Limits r Not Yet Constructed Figure 10. Preferred on-site alternative impacts All of the proposed channel impacts will consist of gravel fill material to the top of bank, which would then be overlain by a 4 -foot clay layer that will extend to the limits of the disposal unit. Finally, a geosynthetic liner will be laid on top of the clay layer. The gravel fill material will allow infiltration of groundwater flows to continue downstream underneath the disposal unit. The clay and geosynthetic underliner are required per Subtitle D of 40 CFR Part 258 to provide a barrier between the leachate collection system and direct connection to ground and surface waters. This will provide the foundation for the disposal unit. According to the applicant, utilizing Unit III to connect Units I and II to build out the final limits Page 5 of 11 Seas onai RPW 2 LANDFILL AREAS 17 IfOf IRIpaCt {fill) Preferred Alt - Proposed ¢ Final Muriapal Solid Waste Limits ®Closed - Construciron & Demolition Waste Limits -^ Active Construction & Demolition Waste Limits ®Closed - Municipal Solid Waste Limits ✓ j Non JD Pond 1 -� Active Municipal Solid %�- 0.39 ac. (fill) waste Limas ;. (motive Municipal Solid Waste Limits r Not Yet Constructed Figure 10. Preferred on-site alternative impacts All of the proposed channel impacts will consist of gravel fill material to the top of bank, which would then be overlain by a 4 -foot clay layer that will extend to the limits of the disposal unit. Finally, a geosynthetic liner will be laid on top of the clay layer. The gravel fill material will allow infiltration of groundwater flows to continue downstream underneath the disposal unit. The clay and geosynthetic underliner are required per Subtitle D of 40 CFR Part 258 to provide a barrier between the leachate collection system and direct connection to ground and surface waters. This will provide the foundation for the disposal unit. According to the applicant, utilizing Unit III to connect Units I and II to build out the final limits Page 5 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) of the disposal area will provide disposal capacity for 20 or more years versus 2.5 years of remaining capacity if not utilized. This on-site alternative will allow the existing landfill to operate into the foreseeable future. At the end of this section, Table 6 summarizes impacts and Table 7 summarizes the siting criteria associated with the on-site alternatives analysis. This alternative would satisfy the following screening criteria: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The locations of Unit I, Phase 2 and Unit III adhere to the regulatory constraints of the landfill. B. Must Allow Landfill to Continue Operation for the Foreseeable Future: The preferred alternative would allow for additional capacity for landfill to continue operation for the foreseeable future of 20 or more years. This alternative not would satisfy the following screening criteria: C. Minimization of Environmental Impacts: This preferred alternative has the second amount of impacts to aquatic features, but also meets the project's purpose and need. At the end of this section, Table 6 summarizes impacts and Table 7 summarizes the siting criteria associated with the on-site alternatives analysis. Page 6 of 11 ' CE SAW -RG -C (File Number, SAW 2018-00053) On -Site Alternative 2 — More Impact Site Layout: This alternative consists of an additional landfill area other than those proposed in On -Site Alternative 1. This is the only other available area within the constrained permitted landfill boundary for a landfill area. The alternative is depicted on Figure 11. Figure 11. On -Site Alternative 2 layout This alternative consists of final landfill areas that include Unit I and Unit Il, which will be at capacity in 2.5 years, and of a newly proposed landfill area that would utilize the topographic valleys for capacity on the northeast part of the landfill. It is important to note that the northeastern landfill area cannot overlap the adjacent closed landfill areas as they are already built out to their final contours. The construction of On -Site Alternative 2 would impact approximately 1,490 linear feet of perennial stream channel, 1,205.5 linear feet of seasonal stream channel for a total of 2,695.5 linear feet of permanent impacts, and 0.5 acres of permanent wetland impacts. (Table 4, Figure 11, and Figure 12). Page 7 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) Table 4. Proposed im JD Feature Type Seasonal RPW (If) Perennial RPW (1f).4 " Wetlands (ac.) Total Stream Impacts (if): Total Wetland s associated with On -Site Alternative 2 Approved JD Preliminary JD !, 0 1,205.5 0 1,490 0 0.5 0 2,696.6 If 0 0.5 ac. Figure 12. On -Site Alternative 2 impacts On -Site Alternative 2 proposed to use the topographic valleys for disposal capacity into the foreseeable future. This option satisfies all the siting criteria except that it is the most environmentally damaging on-site alternative, including proposing impacts to wetlands (Table 6). Additionally, the alternative encroaches upon a known location of an on-site cemetery and would necessitate the clearing of large forested areas. While the cemetery and forested areas are not included in the siting criteria used for determining disposal area locations within the landfill, they are resources that are taken into account when considering the landfill expansion. It may be viewed as inappropriate to expand the landfill into an Page 8 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) area in close proximity to the cemetery and to clear a large amount of trees when other options are available that do neither. This alternative would satisfy the following screening criteria: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The locations of Unit I, Phase 2 and On -Site Alternative 2 adhere to the regulatory constraints of the landfill. B. Must Allow Landfill to Continue Operation for the Foreseeable Future: The alternative would allow for additional capacity for landfill to continue operation for the foreseeable future of 20 or more years. This alternative not would satisfy the following screening criteria: C. Minimization of Environmental Impacts: The alternative has the most amount of impacts to aquatic features (Table 6). At the end of this section, Table 6 summarizes impacts and Table 7 summarizes the siting criteria associated with the on-site alternatives analysis. On -Site Alternative 3 — No Impact Site Layout: This alternative consists of constructing only Unit I, Phase 2 (Figure 13). There are no impacts associated with this alternative; however, constructing only this disposal unit would merely increase capacity by 2.5 years, which is not an adequate timeframe to site a new landfill location, nor would it allow continued operation of the landfill in the foreseeable future. Page 9 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) Figure 13. On -Site Alternative 3 layout Table 5. Proposed impacts associated with On -Site Alternative 3 JD Feature Type' Approved JD Preliminary JD This alternative would satisfy the following screening criteria: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The location of Unit I, Phase 2 adheres to the regulatory constraints of the landfill. C. Minimization of Environmental Impacts: This alternative has no impacts to aquatic features and is therefore the least environmentally damaging. Page 10 of 11 Area A Area Seasonal RPW (10 0 0 0 U 0 0 0 0 Perennial RPW (10 Wetlands (ac.) Total Stream Impacts (Ifl: Total Wetland U This alternative would satisfy the following screening criteria: A. Disposal Unit Locality Adhering to Regulatory Constraints (logistics): The location of Unit I, Phase 2 adheres to the regulatory constraints of the landfill. C. Minimization of Environmental Impacts: This alternative has no impacts to aquatic features and is therefore the least environmentally damaging. Page 10 of 11 CE SAW -RG -C (File Number, SAW 2018-00053) This alternative not would satisfy the following screening criteria: B. Must Allow Landfill to Continue Operation for the Foreseeable Future: The alternative would only provide additional capacity for 2.5 years and would not allow the landfill to continue operation for the foreseeable future of 20 or more years. Furthermore, the 2.5 years of capacity associated with this alternative does not provide sufficient time to site and construct a new operational landfill. Table 6 summarizes impacts and Table 7 summarizes the siting criteria associated with the on-site alternatives analysis. Table 6. Summary of impacts associated with the on-site alternatives 71".11) Feature Type Proposed Impacts On -Site Alternative 1 On -Site Alternative 2 (Preferred Alternative) ore Impact La out On -Si a Alternative 3 No Impact La out Seasonal RPW (If) 865 280 0 1,205.5 0 Perennial RPW (If) 1,490 0 Wetlands (ac.) 0.5 0 Total Stream Impacts (if): 1,145 If 2,695.5 If 0 Total Wetland Impacts 0 0.5 ac. 0 Table 7. Summary of alternatives analvsis sitina criteria. Page 11 of 11 Adhering to Landfill Envir mer ft'Alternatives Regulatory Future I Con ✓ On -Site Alt 1 i ✓ X (Preferred Alt) I (2nd) X On -Site Alt 2 ✓ ✓ (More Impact Layout) (1st/most) On -Site Alt 3 ✓ X ✓ (No Impact Layout) (3�d/least) Page 11 of 11