RATIONALE FOR ISSUANCE
Quad County Environmental Solutions, LLC 
Quad County Landfill
Marshall County
Solid Waste Ref. No.: SW0470010580
April 2018

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:		Charity Rockingham 
WD Branch:		Solid Waste Permitting Branch

II.	NATURE OF BUSINESS AND CURRENT CONDITIONS

The applicant currently operates a class I rubbish disposal site known as the Quad County Rubbish Landfill under Certificate of Coverage No. R1-112. Class I rubbish disposal sites are permitted to accept construction and demolition debris, vegetative debris and other similar non-putrescible wastes. The current area permitted for class I rubbish disposal consists of approximately 37.8 acres.  

III.	PROPOSED SOLID WASTE PERMITTING ACTION

Quad County Environmental Solutions, LLC, has submitted a solid waste permit application to upgrade undeveloped areas of the currently approved rubbish disposal site and to expand the total waste disposal area to allow the facility to accept and dispose of nonhazardous solid wastes from commercial, industrial and other sources. The landfill will not be permitted to accept household garbage and other similar wastes from residences or apartment complexes but will regulatorily be classified by MDEQ as a municipal solid waste landfill.

The draft Solid Waste Management Permit No. SW0470010580 authorizes the development of a disposal area of approximately 110.1 acres for the proposed municipal solid waste landfill.  If this draft permit is issued, the permitted rubbish disposal area authorized under Certificate of Coverage No. R1-112 will be reduced to 16.3 acres. A portion of the new landfill disposal area will be constructed adjacent to and partially over closed portions of the rubbish disposal area. The total waste disposal area for the facility (municipal + rubbish) will be approximately 119 acres. The anticipated life of the landfill at the projected waste acceptance rates is 22 years. 

The siting and operation of this municipal solid waste landfill also requires the applicant to submit permit applications for the associated storm water management, air pollution control and water management activities. Separate rationale documents are available for each of the proposed air and water pollution control permits and summary information on those actions can be also found in Section XIX below.

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 proposed landfill will consist of approximately 110 acres of disposal area 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 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 (MCSWMP). The MCSWMP was formally approved by the Solid Waste Authority of Marshall County on October 9, 2014 and clarified on February 16, 2016 to recognize this proposed landfill facility. The MCSWMP was approved by MDEQ under Administrative Order No. 6708 16 on November 23, 2016. The local Solid Waste Authority as a condition of their approval agreed that the facility could accept nonhazardous solid wastes from industrial and commercial sources in addition to the rubbish wastes that the site currently accepts. The Authority’s action does not allow the site to be permitted to accept residential garbage for disposal. 

In addition, a letter dated December 18, 2017 from the Marshall County Planning Commission confirmed that the proposed facility is in compliance with Marshall County Zoning Ordinances. 

VI.	APPROVED SERVICE AREA

The Marshall County Solid Waste Management Plan also includes a service area for the proposed landfill as approved by the local Solid Waste Authority. This approved service area is Marshall County and those counties which intersect a 50-mile radius from the facility. The approved service area includes the Mississippi counties of Alcorn, Benton, DeSoto, Lafayette, Marshall, Panola, Pontotoc, Quitman, Tate, Tippah, Tunica, and Union; 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.	GEOLOGICAL INFORMATION

State regulations require that sites selected for the development of a municipal solid waste landfill must have a minimum of 5 feet buffer of soil of a low permeability (1.0 x 10-6 cm/s or less) below the bottom of the composite liner system.  For the Quad County Landfill site, 115 sub-surface soil borings were made and evaluated. Acceptable soil buffer materials were generally present near the surface and ranging from 8 feet to 40 feet or more beneath the surface of the site. Generally, the proposed design elevations maintain a minimum of 5 feet of naturally occurring materials across the site.  Areas of the site that may not have suitable low permeability soil materials for the buffer will be excavated and re-constructed to meet the regulatory standards prior to liner construction. Similarly, additional soil buffer may be constructed in areas of the site that do not naturally meet design grade elevations in accordance with regulatory standards. The highest level of groundwater encountered in the borings was approximately 60 feet below ground surface. The composite liner system described in Section VIII will be constructed directly above the soil buffer.

VIII.	CONSTRUCTED COMPOSITE LINER SYSTEM:
The proposed design for the liner system at the Quad County Landfill is in accordance with the Mississippi Nonhazardous Solid Waste Management Regulations. The composite liner system will be constructed above the 5’ natural/constructed clay buffer. The liner system will consist of 24” of compacted clay that must be constructed to a the federal and state permeability standard (k ≤ 1 x 10-7 cm/sec). The permeability of a soil layer is the rate at which liquids move through the soil. A 60 mil HDPE geomembrane liner will be placed over the constructed clay liner material, followed by 18” of a granular collection media.  

The draft permit requires that a quality assurance construction report developed by a third-party engineer be provided to MDEQ demonstrating that the liner system has been constructed in accordance with the approved design plans prior to waste acceptance. MDEQ will also monitor the liner construction activity.

IX.	BUFFER DISTANCE FROM DISPOSAL AREA

As allowed by state regulations (11 Miss. Admin. Code Pt. 4.R.1.3.T), the applicant has requested a reduction in property line setback distance under the assertion that there is suitable natural visual screening present to support the reduction.   The applicant has proposed buffer distances from the property line to the disposal area as follows:

	North:  300 feet 			South:	250 feet 				East:	250 feet 			West:	250 feet

X.	OPERATOR CERTIFICATION

Prior to waste acceptance, Quad County Environmental Solutions will be required by State Regulations to employ a person to manage site operations who will possess and maintain a Certificate of Competency as a Commercial Solid Waste Landfill Operator in accordance with 11 Miss. Admin. Code Pt. 4, R.1.4.B(20). 

XI.	HOURS OF OPERATION AND SITE SECURITY

The standard operating hours proposed 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 draft permit 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. 

At no time will the Quad County Landfill be open for business without a Quad County Landfill employee in attendance and directly supervising landfill activities. In addition, site access will be restricted by a perimeter fence with lockable gates. During hours of operation, access will be controlled by the landfill personnel who will identify all loads and log all loads into the landfill recordkeeping system. After hours of operation, the access control point will be closed and secured with a lockable gate. 

XII.	WASTE ACCEPTANCE 

A.	VOLUME

The applicant has estimated the average 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. 

B.	NONHAZARDOUS SOLID WASTES

The draft permit allows the facility to accept and dispose of nonhazardous solid wastes from commercial, industrial and other sources. The landfill will not be permitted to accept household garbage and other similar wastes from residences or apartment complexes. 

The permittee must implement a screening system to prevent unauthorized waste disposal. Industrial process wastes must be profiled prior to waste acceptance and those profiles are subject to MDEQ review.

C.	ASBESTOS CONTAINING MATERIALS (ACM)

Disposal of ACM may occur in accordance with the approved ACM plan on file with MDEQ. ACM will be prohibited from disposal at the landfill unless the materials are properly bagged or containerized and documented according to all State and Federal Regulations. Asbestos material will be disposed at the toe of the slope of the current work face or in special cells located away from the immediate work area. These locations will be identified, and care will be taken not to excavate in areas where asbestos was previously disposed. 

D.	LIQUID WASTE AND SLUDGES

Bulk and non-containerized liquids are prohibited from disposal in the landfill unless the liquid waste is adequately solidified prior to placement in the disposal cell. The draft permit will authorize the Quad County Landfill to operate a mixing area at the facility to accept liquid wastes for solidification using fly ash or other agents prior to disposal. Liquid wastes are any material determined to contain “free liquids” as defined by EPA test methods. The applicant proposes that solidification of liquid wastes will be conducted inside the constructed disposal cell. The solidification basin will be a mobile containment structure placed near the working face of the landfill.

The draft permit allows the Quad County Landfill to also accept certain sludges for disposal where such sludge materials do not contain free liquids. Sludge shall be defined as is any solid, semi-solid, or liquid waste generated from a commercial, industrial wastewater treatment plant, water supply treatment plant, or an air pollution control facility exclusive of the treated effluent from a wastewater treatment plant. Industrial sludges are subject to the conditions of Part XI.B above.

XIII.	WASTE COVER SCHEDULE

As required by State and Federal Regulations, the landfill’s operating plans propose that at least six inches of earthen material (or an alternative, approved cover material) will be placed on the active working face 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 as available. 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. 

XIV.	MONITORING SYSTEMS

A.	GROUNDWATER MONITORING

The draft permit requires that a groundwater monitoring plan approved by MDEQ be implemented prior to wastes being disposed in the proposed new landfill facility.  The monitoring plan must include a groundwater monitoring system, groundwater sampling protocols, and a data quality assurance plan.

B.	METHANE MONITORING

The draft permit also requires that an MDEQ-approved 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. 

XV.	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). The applicant conducted a slope stability analyses using standard computer models to evaluate the stability of the landfill at final grades. The model generated a factor of safety of 3.25 for the slope under static conditions. A factor of safety of 1.5 for static conditions is considered acceptable.
XVI.	APPLICANT DISCLOSURE STATEMENT

In accordance with State Law, the applicants filed a disclosure statement describing the company’s structure, key officers and members, other affiliated businesses and any civil or criminal violations.  The disclosure statement for Quad County Environmental Services, LLC was reviewed by the MDEQ Legal Division and determined to be complete on December 5, 2016. 

XVII.	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 maintained and updated annually for the life of the facility and through the 30-year post-closure period.
XVIII.	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

XIX.	OTHER ENVIRONMENTAL ISSUES AND PERMIT APPLICATIONS

Quad County Environmental Solutions, LLC, has also submitted permit applications for the following:

A.	STORM WATER MANAGEMENT PERMIT: 

All storm water at the site (water that has not contacted the waste) must be managed to prevent offsite impacts. The landfill disposal area is divided into 4 different watersheds ranging in size from 26 to 49 acres. For each watershed sedimentation basins will be installed and sized based on a 24-hour, 25-year storm intensity. The landfill will eventually have 2 storm water outfalls with discharges into unnamed tributaries of Nonconnah Creek and 2 storm water outfalls with discharges into the Nonconnah Creek. The applicant has submitted an application for a proposed National Pollutant Discharge Elimination System (NPDES) permit to address the storm water management under a draft permit numbered, MSS062383. The draft NPDES permit is accompanied by a permit rationale with additional information. 

B.	AIR PERMIT TO CONSTRUCT:  

To address air emissions from the landfill, the applicant has applied for an air permit to construct as per state regulation 11 Miss. Admin. Code Pt. 2. The proposed landfill will be subject to New Source Performance Standard (NSPS), 40 CFR Part 60, Subpart XXX – Standards of Performance for Municipal Solid Waste Landfills due to the landfill’s design capacity. The estimated gross available air space of the landfill is approximately 15,100,000 cubic yards. This NSPS requires the subject landfill to hold a Title V Air Operating Permit. MDEQ’s Environmental Permits Division has developed a draft permit that is available for review and comment under permit number, 1780-00053. The draft air permit is accompanied by a permit review summary and an information relative document with additional information. 

C.	WATER QUALITY CERTIFICATION:  

The applicant is also requesting water quality certification, WQC2017077, from the MDEQ that the activity will comply with the applicable requirements set forth in 33 U.S.C. and 1341 (a)(l) of the Clean Water Act and all State laws and regulations promulgated pursuant thereto. This request is to address the potential impacts to delineated wetland areas on the site.  The deposition of fill material into waters of the United States, including streams and wetlands, requires authorization from the Corps of Engineers. At this time, MDEQ has reached a preliminary jurisdictional determination (PJD) that there is approximately 1,912 linear feet of stream on the project site that may be considered other waters of the United States. There are two sections of channel on the property that would be considered non-jurisdictional based on our PJD. The applicant is proposing to mitigate the loss of 850 linear feet of stream with the restoration of 900 linear feet of stream channel on the project site. The applicant submitted a detailed mitigation plan which includes goals and objectives, site selection rationale, baseline information including existing plant communities, soils and hydrology, and a mitigation work plan for the 900 linear feet of relocated stream channel.  The proposed mitigation work plan includes a maintenance plan, stream performance standards, long-term and adaptive management plan.