RATIONALE FOR PROPOSED MODIFICATION AND ISSUANCE
Quad County Environmental Solutions, LLC 
Quad County Landfill
Marshall County
Solid Waste Permit No. SW0470010580
Date or Application: November 1, 2019

I.	FACILITY INFORMATION

Facility Name:  	Quad County Landfill
Facility Owner: 	Quad County Environmental Solutions, LLC,
Facility Address:	850 Wingo Road
Byhalia, MS 38611    
Permit No.:		SW0470010580
SIC Code:		4953
Permit Writer:		Trent Jones	
Waste Division:	Solid Waste Permitting Branch

II.	NATURE OF BUSINESS AND CURRENT CONDITIONS

The applicant, Quad County Environmental Solutions, LLC, is currently permitted to operate two solid waste management facilities at the referenced location.  The applicant is in the process of constructing a commercial landfill facility at the site known as the Quad County Landfill (Permit No. SW0470010580). The landfill was previously permitted in July 2018 to accept and dispose of nonhazardous solid wastes from commercial and industrial sources. The permitted landfill disposal area consists of approximately 110.1 acres.  

The applicant also currently operates a class I rubbish disposal site at this location known as the Quad County Rubbish Landfill (Certificate of Coverage No. R1-112). The rubbish site was originally permitted in September 2013. The rubbish site is currently active and operating for the disposal of class I rubbish wastes which include construction and demolition debris, vegetative debris, and other similar non-putrescible wastes. The available class I rubbish disposal area consists of approximately 16.3 acres. No changes are currently proposed for the rubbish disposal operations.  

III.	PROPOSED SOLID WASTE PERMITTING ACTION

Quad County Environmental Solutions, LLC, has submitted a solid waste permit application to modify the types and sources of solid wastes that can be accepted for disposal at the landfill.  The Quad County Landfill described above is currently not permitted to accept residential garbage for disposal.  The proposed modification would allow the landfill to accept waste from residential sources (such as households and apartment complexes) in addition to the commercial and industrial sources already approved.  No other modifications to the landfill size, design, or operations are proposed.  

IV.	LOCATION INFORMATION AND ACCESS ROUTES

The Quad County Landfill is located in northern Marshall County near the Mississippi/Tennessee state line at 850 Wingo Road, Byhalia, MS 38611. The permitted landfill disposal area consists of approximately 110.1 acres within a property area of approximately 212 acres located in Sections 17, 18, 19, and 20, Township 1 South, Range 4 West of Marshall County. 

Access to the Quad County Landfill site is provided by an entrance on Wingo Road (Mississippi) from the south and by Quad County Lane (Tennessee) from the north. The applicant has indicated that the primary access for large commercial waste trucks will be from Quad County Lane and individual and light commercial traffic will typically enter from Wingo Road.

V.	LOCAL SOLID WASTE PLANNING AND ZONING INFORMATION

The proposed permit action is consistent with the Marshall County Solid Waste Management Plan (Plan). The Plan was originally amended by a resolution of the Solid Waste Authority of Marshall County (Authority) on October 9, 2014 (and clarified on February 16, 2016), recognizing up to 120 acres of landfill disposal area at the proposed location for the disposal of nonhazardous solid wastes from commercial and noncommercial sources.  The revised Plan was approved by MDEQ under Administrative Order No. 6708 16 on November 23, 2016. On December 13, 2018, the Authority adopted a resolution to modify the Plan again to allow the Quad County Landfill to also accept nonhazardous solid wastes from residential sources. The revision to the County Plan was approved by MDEQ under Administrative Order No. 6968 19 on August 5, 2019.

In addition, a letter dated September 27, 2018 from the Marshall County Planning Commission confirmed that the facility is in compliance with local zoning, land use and other laws’ regulations, and ordinances. 

VI.	APPROVED SERVICE AREA

The Marshall County Solid Waste Management Plan also includes a service area for the landfill as approved by the Solid Waste Authority of Marshall County. The landfill will only be allowed to accept solid wastes that originate in this approved service area. This approved service area includes Marshall County and those counties which intersect a 50-mile radius from the facility, excluding Lafayette, Pontotoc, and Union counties in Mississippi. The approved service area includes the Mississippi counties of Alcorn, Benton, DeSoto, Marshall, Panola, Quitman, Tate, Tippah, and Tunica; the Tennessee counties of Fayette, Hardeman, Haywood, Lauderdale, Madison, McNairy, Shelby, and Tipton; and the Arkansas counties of Crittenden, Cross, Lee, Mississippi, Poinsett, and St. Francis. 

VII.	GEOLOGIC INFORMATION AND SITING CRITERIA

Geologic information was submitted by the applicant with the previous permit application that demonstrates the site complies with the State’s geologic siting criteria for landfills.  No changes to the previously approved siting criteria are proposed with this modification to the permit. 

As allowed by state regulations (11 Miss. Admin. Code Pt. 4.R.1.3.T), the existing landfill permit (#SW0470010580) allows a reduction in the property line setback distance because suitable natural visual screening is present to support the setback reduction.  The approved setback distances from the property line to the disposal area are as follows: North - 300 feet; South - 250 feet; East - 250  feet; West - 250 feet.

VIII.	CONSTRUCTED COMPOSITE LINER SYSTEM:
The design for the liner system at the Quad County Landfill is consistent with the Mississippi Nonhazardous Solid Waste Management Regulations standards for municipal solid waste landfills. No changes to the previously approved liner system are included in the proposed modification to the permit.  

IX.	HOURS OF OPERATION AND SITE SECURITY

The standard operating hours approved in the current plan of operations for the landfill are Monday through Friday from 7:00 AM to 5:00 PM, Saturday from 7:00 AM to 1:00 PM, and closed on Sunday. However, the plans currently allows for the Quad County Landfill to be opened up to 24 hours a day, seven days a week when an extraordinary need arises to serve landfill customers. Situations requiring the landfill to operate beyond normal hours include but are not limited to the following: an influx of waste received due to natural disasters and emergency circumstances, short duration surges or increases in waste volumes which cannot be accommodated during normal operating hours, and delays in the receipt of wastes receiving due to the inclement weather and on-site complications. 

X.	WASTE ACCEPTANCE 

As stated, the existing landfill permit allows the landfill to be constructed and operated to accept and dispose of various nonhazardous solid wastes from commercial, industrial, institutional and other approved sources from within the approved service area. The facility may also accept regulated asbestos containing materials (ACM) and bulk liquid wastes for solidification and disposal in accordance with the approved plan of operations.  The proposed modification to the permit, if approved, will allow the landfill to also accept and dispose of nonhazardous solid waste from residential sources.  

The applicant estimates an average incoming waste volume over the life of the facility to be approximately 1,200 tons per day. This volume could vary based on the new service areas and increases in volume of solid wastes generated by the growth in existing areas. 

XI.	WASTE COVER SCHEDULE

Six inches of earthen material (or an alternative, approved cover material) will be placed on the active disposal area of the landfill at the end of each operating day. Daily cover material will consist of soils which have been excavated from an on-site borrow area or imported from offsite sources if needed. At the beginning of each day, portions of the daily cover may be removed to promote leachate migration to the leachate collection and removal system. 

XII.	MONITORING SYSTEMS

Groundwater Monitoring
The current landfill permit requires that a groundwater monitoring system be installed and monitored. The approved monitoring system includes groundwater monitoring wells, groundwater sampling protocols, and a data quality assurance plan. A system of 10 groundwater wells has been installed and background data will be collected and provided to MDEQ prior to wastes being received at the landfill.  No changes are requested to the groundwater monitoring system or plans in the proposed modification to the permit

	Methane Monitoring
The current landfill permit requires that a methane monitoring system be installed to monitor for any potential migration of methane gas from the site. Methane monitoring probes will be located on the site with monitoring conducted on a quarterly basis. No changes are being proposed to the methane monitoring plans in the modification to the permit.  

XIII.	FINAL COVER SYSTEM:
Upon closure, a final cover system must be constructed in accordance with State and Federal Regulations and the approved closure plan. An updated closure plan describing the final cover system must be submitted and approved by MDEQ prior to beginning final closure activities. 
The final cover system will be developed with no more than 25% side slopes (with storm water benches) and a top cap with minimum of 4% slopes.  The highest elevation of the landfill is proposed to be no more than 594 feet (including final cover system).
XIV.	APPLICANT DISCLOSURE STATEMENT

In accordance with State Law, the applicant filed a disclosure statement describing the company’s structure, key officers and members, other affiliated businesses and any civil or criminal violations.  An updated disclosure statement for Quad County Environmental Services, LLC was reviewed by the MDEQ Legal Division and determined to be complete on March 4, 2020. 

XV.	FINANCIAL ASSURANCE  

Prior to waste acceptance, Quad County Environmental Solutions is required to establish adequate financial assurance for the estimated closure and post-closure costs of the landfill as required by the draft permit and Rule 1.4 of the Mississippi Nonhazardous Solid Waste Management Regulations.  The financial assurance must be based on third party cost estimates for the closure and post closure care of the landfill and must be approved by MDEQ. The approved financial assurance mechanism must be maintained and updated annually for the life of the facility and through the 30-year post-closure period. 

XVI.	APPLICANT CONTACT INFORMATION

Mr. Andrew Densing, President
Quad County Environmental Solutions, LLC
14339 Hudson Krohn Road
Biloxi, MS 39532
	(228) 328-1820 ext. 118
	adensing@teamwasteusa.com

XVII.	OPERATOR CERTIFICATION

Quad County Environmental Solutions, LLC, is required to employ a person to manage site operations who possesses a Certificate of Competency as a Commercial Solid Waste Landfill Operator in accordance with Rule 1.4.B.(20) of the Mississippi Nonhazardous Solid Waste Management Regulations. In order to obtain a certificate of competency as a landfill operator, a person must demonstrate a level of proficiency and must meet minimum state requirements for experience, education, and training. The company must maintain a properly certified and trained person to manage operations throughout the life of the landfill. 

XVIII.	OTHER ENVIRONMENTAL PERMITS

No modifications to the existing air and water pollution control permits associated with the landfill operations are being requested at this time in conjunction with the proposed modification to the solid waste permit. The currently active permits for the landfill are: National Pollutant Discharge Elimination System (NPDES) permit MSS062383 for storm water management and discharge; Air Permit to Construct and Title V Air Operating Permit 1780-00053 for air emissions controls from the landfill; and Water Quality Certification WQC2017077 for impacts to wetlands and the rerouting of streams on the landfill property.  

Leachate (liquids that passes through or emerges from the waste) generated at the landfill will be collected and temporarily stored in on-site storage tanks prior to being transported to a permitted, out-of-state waste water treatment facilities. Therefore, no permit has been issued for this activity from the Mississippi Environmental Quality Permit Board.

The existing class I rubbish site disposal operations are authorized by Certificate of Coverage R1-112 and storm water management from that disposal area is covered under Baseline Storm Water Permit Certificate of Coverage MSR002140.  No changes are being proposed to the rubbish site operations as part of the proposed modification to the landfill permit.