3402_HanesMillRdMSWLF_Decision_WastePaintPilo Project_DIN28813_20180525

May 25, 2018

Sent via email: [e-mail]

Micah Johnson
Sr. Civil Engineer
Hanes Mill Road Landfill
325 W. Hanes Mill Road
Winston-Salem, NC 27105

RE: Hanes Mill Road Landfill Waste Paint Pilot Project Request
Hanes Mill Road Landfill
Permit No. 3402-MSWLF-1997
Forsyth County, North Carolina
Document Identification Number (DIN 28813)

Dear Mr. Johnson:

On May 07, 2018, the Solid Waste Section (Section) received your e-mail message requesting the
Division of Waste Management grant a 6-month period to conduct an in-situ pilot study project to
co-dispose waste paint into the landfill via a waste bulking material.

According to the submittal, Hanes Mill Road Landfill proposes to bulk waste paint from 3RC in-
situ at the landfill working face to sufficiently pass the paint filter test as defined by EPA Method
9095B – Paint Filter Liquids Test. If the representative sample fails the Paint Filter Test, the load
of waste paint will be added to a bulking material mixture as follows: According to bench tests
performed by 3RC, a ratio of 4 parts (by volume) of discarded fine tobacco dust (fines) was found
to quickly and fully absorb 1 part (by volume) of waste paint without mixing adequately enough
to pass the Paint Filter Test. To simulate this successful bench test as part of a pilot study project
at the landfill, this same ratio of 4:1 at a minimum, will be used utilized at the landfill working
face. Separate bench tests will be conducted for each type of bulking material to determine the
optimal ratio of bulking material to waste paint. First, waste paint deliveries and their associated
quantities will be pre-scheduled to ensure sufficient bulking material is available at the landfill.
Prior to waste paint arriving, a pit will be excavated off to the side at the landfill working face.
The pit’s volume will be sufficient to accommodate a minimum 4:1 ratio of waste tobacco bulking
material (i.e. discarded tobacco fines, cigarette filters, cartons and boxes) to waste paint. Next, the
waste paint will be added to the bulking material at a minimum conservative ratio of 4:1 of bulking
material to waste paint (by volume). The pit and bulked material will be properly covered with a
minimum of 12 inches of MSW.

Mr. Micah Johnson
May 25, 2018
DIN 28813 Page 2 of 3

Based on our review of your submittal, the Section cannot approve of the proposed study as it
lacks critical information to ensure compliance with all applicable laws and rules to the operations
of this facility, specifically:

1. It is the Section’s understanding that the receipt of the waste paint at the landfill from
3RC is generally dependent upon the volumes received and operational processing times
at that facility, whereas the proposal details an ability to “pre-schedule” loads to ensure
adequate amounts are on-site. Historical knowledge of how both facilities operate creates
operational concerns surrounding this proposal, as it’s unclear how this process will be
controlled and whether it presents a scenario of bulking material being stored at the landfill
and/or placed in the pits pending arrival of paint material. The bulking material is known
to be a potential dust problem and can easily be moved about the site by wind if not
immediately covered or containerized.

2. The proposal indicates that waste paint will simply be poured into an open pit containing
bulking material at approximately a 4:1 ratio with a desired result of full absorption of the
free liquids. Without any form or type of mechanical mixing, shaking, or vibrating
procedures, there is not viable method to determine if the final waste mixture at the
different depths/profiles inside the pit will pass the paint filter test. Further, there is no
information provided as to how and who will conduct oversight of the dumping of the
material to ensure the desired result is being met, likely resulting in free liquids going into
the larger waste mass in an uncontrolled manner.

3. The proposal does not detail the location of the proposed pit in relation to the working
face, and what if any impact, this will have on daily waste disposal operations at the landfill.
Its states off to the side, which could be trucks and equipment re-entering previously
covered areas creating additional cost, cover materials and manpower to maintain
compliance. Having excavated pits within the waste mass raises concerns about increased
stormwater infiltration and compaction voids which could lead to leachate and landfill gas
generation and migration issues. Further, the placement of 12 inches of MSW waste over
the mixture does not adequately address daily cover requirements.

4. The proposal does not address contingency planning and operational controls for
weather factors such as wind and rain.

5. The proposal does not detail the data collection/recordation methods and how/when
those would be presented in a Pilot Study Report.

In addition to the above items, the submittal does not provide ample reasoning for consideration
of the project to dispose of a waste material that has previously been recycled and reused by this
facility.

Mr. Micah Johnson
May 25, 2018
DIN 28813 Page 3 of 3

The landfill has a long-standing relationship and contract with 3RC to adequately accept, screen,
process, and make available waste latex paint to the landfill for reuse in its posi-shell alterative
daily cover process. This process is detailed in the “10-year Solid Waste Management Plan (Plan)
for the Planning Period Beginning July 1, 2012 and ending June 30, 2020” dated 2012 and prepared
by the Winston-Salem/Forsyth County Utility Commission (CCUC), and is allowed by the existing
life-of-site Solid Waste Management Permit Approval to Operate dated July 25, 2017 (DIN 27884).
In accordance with 130A-309.04(a), the recycling and reuse of waste materials is a priority of the
Solid Waste program. Even in the absence of this reuse method, the Section believes that markets
exist to recycle this material, therefore the Section encourages the CCUC to continue to pursue
recycling and reuse of waste paint materials with your current vendor and/or through another
vendor. The Section has interest in understanding what has changed in CCUC’s current practices
noted above as well as any alternative recycling/reuse options that have been explored prior to
consideration of shifting to disposal as the sole management option.

It should be noted that if the CCUC wants to continue pursuit of the management of the material
inhouse for disposal versus through a recycling vendor moving forward, there are several approved
waste solidification/ stabilization units co-located at disposal facilities statewide, including a unit
specifically to solidify used paint for landfilling in a neighboring county. All approved
solidification units are either above-ground or underground (pit or vault) units and separated from
the waste disposal units at the landfill facility. The SWS would highly recommend the CCUC
pursue this option, at a location away from the active landfill unit inside the Hanes Mill Road
landfill facility.

If you have any questions, please contact me directly at [phone] or [e-mail] .

Sincerely,

Ming-Tai Chao, P.E.
Environmental Engineer
Division of Waste Management, NCDEQ

Copies (via email): Ed Mussler, P.E. Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Susan Heim, Environmental Sr. Specialist
Ed Gibson, P.E., Solid Waste Engineer – CCUC
Jan McHargue, P.E., Solid Waste Administrator - CCUC

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, May 07, 2018 11:11 AM
To:'Micah Johnson'
Cc:Edward Gibson; Jan McHargue
Subject:RE: [External] Hanes Mill Rd Landfill waste paint bulking pilot project request
Hi Micah:

The Solid Waste Section received the pilot study proposal today. I have forwarded the proposal to all related
parties for review and solicit inputs/comments. I expect to gather all inputs/comments by the end of this Month
and properly respond your request. Have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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From: Micah Johnson [mailto:[e-mail]]
Sent: Monday, May 07, 2018 8:01 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Edward Gibson <[e-mail]>; Jan McHargue <[e-mail]>
Subject: [External] Hanes Mill Rd Landfill waste paint bulking pilot project request

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Dear Mr. Chao,
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We, the staff at Hanes Mill Road Landfill, interpret that the intent of prohibiting liquid waste in landfills (15A NCAC 13B
.1626) is to reduce leachate generation and the affiliated risk of leakage through the landfill liner system and into
groundwater. Our proposal below is to be allowed to successfully demonstrate the addition of liquid waste paint into an
absorbent bulking material resulting in a solidified waste mixture that will successfully pass the Paint Filter Liquids Test.
REQUEST: Hanes Mill Road Landfill respectfully requests that the NCDEQ Division of Waste Management grant a 6-month
time period to conduct this in-situ pilot study project to co-dispose waste paint into the landfill via a waste bulking
material. The landfill administrative staff will provide the Solid Waste Division a report of this pilot project’s findings within
30 days of the conclusion of the 6-month pilot project. The Division will then be able to make a directive at its discretion
to approve this method of disposing of waste paint long-term.
PURPOSE: The City of Winston-Salem Utilities – Solid Waste Division currently contracts 3RC to accept and dispose of
paints from residents and commercial customers within its service area. The Hanes Mill Road Landfill proposes to bulk
waste paint from 3RC in-situ at the landfill working face to sufficiently pass the paint filter test as defined by EPA Method
9095B – Paint Filter Liquids Test.
METHOD: The waste paint will be tested for free liquids using EPA Method 9095B – Paint Filter Liquids Test. If the
representative sample fails the Paint Filter Test, the load of waste paint will be added to a bulking material mixture as
follows: According to bench tests performed by 3RC, a ratio of 4 parts (by volume) of discarded fine tobacco dust (fines)
was found to quickly and fully absorb 1 part (by volume) of waste paint without mixing adequately enough to pass the
Paint Filter Test. To simulate this successful bench test as part of a pilot study project at the landfill, this same ratio of 4:1
at a minimum, will be used utilized at the landfill working face. Separate bench tests will be conducted for each type of
bulking material to determine the optimal ratio of bulking material to waste paint. First, waste paint deliveries and their
associated quantities will be pre-scheduled in order to ensure sufficient bulking material is available at the landfill. Prior
to waste paint arriving, a pit will be excavated off to the side at the landfill working face. The pit’s volume will be sufficient
to accommodate a minimum 4:1 ratio of waste tobacco bulking material (i.e. discarded tobacco fines, cigarette filters,
cartons and boxes) to waste paint. Next, the waste paint will be added to the bulking material at a minimum conservative
ratio of 4:1 of bulking material to waste paint (by volume). The pit and bulked material will be properly covered with a
minimum of 12 inches of MSW.
See attached pictures for typical loads of tobacco waste to be used as bulking material.

Sincerely,

Micah Johnson
Sr. Civil Engineer
Hanes Mill Road Landfill
325 W. Hanes Mill Road
Winston-Salem, NC 27105

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