April 7, 2021
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20210407 Nashua Phase III Stage 2 Proposal-Rev1.docx
3. Instrumentation monitoring requirements to monitor strain and settlement of
the zigzag liner relative to its design tolerance;
4, Monitoring parameter action levels; and
5. Procedures for investigating and providing a response action plan for
approval if monitoring parameter action levels are reached.
(19) Prior to filing the notice of intent to operate for Phase III Stage 2, the permittee shall obtain
approval from NHDES for the following plans submitted in accordance with Env-Sw 315:
(a) An updated operating plan, including the following changes:
1. Add information to reflect approval of Phase III Stage 2;
2. Add the zigzag liner inspection, monitoring and maintenance plan prepared
in accordance with Condition (10)(c); and
3. Add fill sequencing plans for Phase Ill Stage 2, as required by Env-Sw
805.11(e), prepared pursuant to Env-Sw 805.11(f), to address provisions of Env-
Sw 806.02(a) and (d).
(b) An updated closure plan, including the following changes:
1. Revise Section 2 closure dates to reflect approval of Phase III Stage 2;
2. Add the zigzag liner inspection, monitoring and maintenance plan prepared
in accordance with Condition (10)(c); and
3. Revise the closure cost estimate, including the cost of post-closure activities, to
reflect approval of Phase III Stage 2.
(c) An updated financial assurance plan that includes Phase III Stage 2, prepared in
accordance with Env-Sw 1400. The financial assurance plan shall:
1. Identify the financial assurance mechanism(s) by stating each type of
mechanism, the institution or entity holding each mechanism, the account or
policy number of each mechanism, the obligation for which each mechanism
shall be used {i.e closure, post closure), and the current balance of each
mechanism; and
2. The closure cost estimate, including the cost of post-closure activities,
prepared pursuant to Condition (19)(b)3.
Please note that there are other conditions of the Phase III permit that do apply to Stage 2
that are not specific to design and permitting. These conditions are, but not limited to, related
to construction, operations, closure, financial assurance records, etc. The two (2) conditions
provided above are the focus of the following scope of services and must be satisfied to
receive construction approval from the NHDES.
In addition, we note that this project still qualifies for coverage under the Alteration of
Terrain (AoT) Permit issued April 24, 2018. As such, no additional AoT permitting is
required, but, depending on when Stage 2 goes to construction, a permit extension may be
required. Costs to renew the AoT permit are not included in this proposal
SANBORN HEAD
