20060645 Ver 2_Staff Comments_20110804

Mcmillan, Ian
From: Homewood, Sue
Sent: Thursday, August 04, 2011 5:06 PM
To: Mcmillan, Ian
Subject: duke landfill
Ian,
Here are some notes from the conf. call I had with S&ME and Duke today regarding this project. They completely
understand that nothing we discussed today guarantees that when we see items in writing there won't be more or new
questions. I did indicate that they are headed in the proper direction with their responses.
• They are still in final design stages but will submit full scale drawings that show current and future topo lines,
impact areas, temporary impact areas, any impacts from stabilization etc. These drawings will also show
underdrain network and outlets to the stream channels.
o As an aside, we discussed that should the landfill change the hydrology significantly, they may be
required to mitigate for any loss of water below the impact area that may result from "drying up the
stream". I would suggest a permit condition with visual monitoring of the channels and reporting to
DWQ and then addressing the details when/if the time comes.
• They will submit a new Alternative that will show the estimated life of the landfill if they avoid the large stream
(5C) in the middle of the property. They may submit this analysis asap, as a partial response, so that we may
review it and respond since it is a "project stopper" if we consider it a viable alternative and they'd have to
redesign everything. I indicated that would be acceptable.
9 They will submit to us the regulations that they follow under Solid Waste that requires them to monitor
groundwater below the liner. S&ME indicated that there is a very specific protocol in those regulations that
indicate that if anything shows up in that monitoring, the next step is increased and more widespread
monitoring, then potential remediation etc. Basically it will show to us that another agency/set of regulations,
will ensure that the liner is functioning and take appropriate action if there is indication that it is not. I
o I suggest a permit condition that should that happen in the future, that DWQ be notified so that we can
become involved and make any requirements at that time to ensure surface water protection.
P They said that the solid waste regulations include stormwater coming from the access road that will be the only
new impervious surface on the site (other than the landfill). They also said that for the most part this road will
always be considered part of the long term erosion control plan and covered under that. I have dealt with this
before on mining sites that are 20+ year sites and I've been told by management that we will not require "post
construction" measures if the site is still considered under an erosion control plan (because that is contradictory,
its either one or the other) so we may have to condition the permit that if at any time the stormwater from the
road is not controlled under either erosion control or solid waste. That's just a thought, I told them we'd review
what they send to us and see if it satisfies our requirement to protect downstream waters. May be something
we all have to discuss when we get it.
Let me know if anything here sends up any red flags for you and I will call them back asap and point them in a different
direction. Otherwise they expect to send us at least a partial response sometime this month. I didn't think to ask them
who the reviewer is for their solid waste permitting, but we could always get that info and talk directly to them to make
sure we aren't contradicting but rather covering all angles of this project.
Sue Homewood
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
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